Compliance Check Process January 2015
AGENDA C OMPLIANCE C HECKS : � Introduction � Framework � Benefits and Conclusion � Tools 2
COMPLIANCE CHECKS - INTRODUCTION W HAT ARE COMPLIANCE CHECKS ? � Process to obtain and evaluate evidence of legislative compliance � Documented evidence gathering process to prove due diligence W HY DOES K IRKLAND L AKE G OLD WANT TO COMPLETE COMPLIANCE CHECKS ? � To verify that what we do is compliant to regulations. � To reduce the risk of receiving MOL orders. � To improve employee awareness of acceptable conditions at the site H OW TO CONDUCT A SUCCESSFUL COMPLIANCE CHECK ? � Visual inspections � Document review � Interviews � Reporting non-compliance issues. 3
COMPLIANCE CHECKS - INTRODUCTION P URPOSE OF A COMPLIANCE CHECKS The overall purpose of the compliance check is to ensure that the Company and the employee is operating within the letter of the law. Although it is not intended to verify conformance to the company’s various facets of the site management system, it does provide an opportunity to increase awareness and identify improvements. 4
COMPLIANCE CHECKS - FRAMEWORK C ONCEPT / F RAMEWORK Compliance Checks are done monthly and review the following key item: � Legal Compliance to Regulatory Requirements � Workplace documents related to specific activities The “Checker” must review at minimum, the following items to better evaluate compliance: � Management System documentation � Standard operating procedures and other relevant documentation � Employee knowledge of induction training, specific training and the roles and responsibilities of their position at Kirkland Lake Gold. 5
COMPLIANCE CHECKS - FRAMEWORK C ONCEPT / F RAMEWORK � Annual schedule is developed � Items required to check are based on regulation and is refined as risks/hazards are identified � Required documentation is forwarded to the “checkers” monthly � Paper work is completed by “checkers”: � Confirm applicability � Confirm compliance � Ensure sample size is adequate during the interview process � Look at everything (u/g, mill, shops…) � Confirm findings with correct individual before raising the issue � Input results into the non-compliance database � Once all paperwork is complete, actionable items are entered into site database and circulated to the appropriate person for follow-up and closure. 6
COMPLIANCE CHECKS – CONCLUSION & BENEFITS B ENEFITS � Increased knowledge of regulatory requirements for team members � Improved regulatory compliance for operation � Increased awareness of the workforce being checked � Improved ability to highlight “at risk” conditions in the workplace � Support JHSC � Ability to target operational issues based on incidents (fire extinguishers…) C ONCLUSION Compliance Checks are an important link between site compliance and providing a safe working environment for employees. Successful implementation will dictate our performance. If checks are done correctly, including site observations, we can correct and prevent problems. 7
COMPLIANCE CHECKS- TOOLS 1. Schedule 2. Reports 3. Checklist ����������� ����� ��!"���� ���������������� �������������� ������������� #$���%���% 4. Database 8
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