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Universal Recycling Technologies Environmental, Quality,
Health & Safety Management System Manual

6.10 Materials Recovery and Final Disposition

URT shall ensure that Hazardous e-Wastes and Problematic Components and Materials
are processed in licensed and permitted facilities that minimize releases and ina
manner protective of worker health and safety, public health, and the environment.

URT has developed a Hazardous e-WVaste Management Plan that states how the
Hazardous e-Wastes and Problematic Components and Materials are managed both on-
site (if applicable) and materiais destined for material recovery or final disposition.

Related and Supporting Documents
AO6C01P01 Hazardous e-Waste Material Management

6.11 Exportation of Hazardous Electronic Waste

URT shall only permit (both on-site and throughout the entire recycling chain) exports of
hazardous e-waste materials according to the decisions and agreements of the OECD,
the Basel Convention, the Basel Ban Amendment and all other applicable national and
international laws regarding the trade of hazardous electronic waste. URT shail assure
that

a. Hazardous e-waste materials shall only be exported from OECD/EU countries
and Liechtenstein to and through other countries in that same group;

b. Hazardous e-waste materials shail not be traded between any Basel Party and
the US (or any other non-party to the Basel Convention) unless all countries are
Member states of the OECD or have concluded a special bilateral or mutti-lateral
agreement as allowed under Article 11 of the Basel Convention; and

c. Hazardous e-waste materials which are not prohibited in a or b above shall be
approved by the “competent authority” of the importing and transit countries in full
conformity with OECD and Basel Convention decisions or other international
agreement.

Related and Supporting Documents
A06C01P01 Hazardous e-Waste Material Management

6.12 Site Closure Plans

URT has created and maintains a written closure plan and a sufficient financial
instrument that assures proper closure of the facilities in the event of a planned or
unplanned closure of the operation, including sale, closure, and abandonment of
materials or facilities, bankruptcy or any other form of dissolution of the company.

Related and Supporting Documents
e-Stewards Standards

A03C03P01 Clesure Plan

6.13 Insurance Requirements

URT shail maintain insurance adequate to cover the potential risks and liabilities
associated with the nature and size of the company’s operations;

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a. URT is accepting data liability, communicates this te customers, and holds
Professional Liability insurance to cover data liability,

b. URT possesses adequate Commercial General Liability Insurance, Commercial
Auto Insurance, Workers Comp Insurance and Pollution Liability Insurance.

Related and Supporting Documents
Certificate of Insurance on File

e-Stewards Standards
7 Emergency Response Plan

URT has established, implemented and maintains a procedure to identify potential
emergency situations and potential accidents that can have an impact(s) on the
environment and how it will respond to them and how to respond to actual emergency
situations and accidents and prevent or mitigate associated adverse environmental
impacts.

URT will review this procedure at every year and, in particular, after the occurrence of
accidents or emergency situations.

URT will periodically test one emergency response procedure every year and
documentation of debriefing notes will be in the monthly Safety Committee meeting
minutes.

URT has documented emergency procedures, including Fire / Explosion, Spills ar
Material Release, Natural Disasters, Civil Unrest and Theft of hazardous materials /
suspicious persons in the URT Emergency Action Plan.

Related and Supporting Documents

A07C01P01 Corporate Contingency and Emergency Action Plan

8 Checking

8.1 Monitoring and Measurement (ISO 14061 4.5.1)

URT has established, implemented and maintains a procedure to monitor and measure,

the key characteristics of its operations that can have a significant environmental and or
health and safety impact as defined on the Significant Aspect Worksheet.

The procedure shall include the documenting of information to monitor performance,
applicable operational controls and conformity with the URT’s environmental, quality,
health and safety objectives and targets,

URT shall ensure that calibrated or verified monitoring and measurement equipment is
used and maintained and shall retain associated records.

Related and Supporting Documents

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AQ8CO3P01 Monitoring and Measurement
AQ3COTPO1 Objectives & Targets

Ad4C02P61 Evaluation of Compliance
A0BCO3W01 Scale Calibration Work Instruction
e-Stewards Standards

8.2 Validation of processes for production and service provision

URT validates any process for production and service provision where the resulting
output cannot be verified by subsequent monitoring or measurement. This includes any
processes where deficiencies become apparent only after the product is in use or the
service has been delivered. The validation demonstrates the ability of these processes
to achieve planned results.

Related and Supporting Documents
A04C05P01 Process Planning and Control

8.3 Identification and traceability

URT identifies the product throughout the realization process. Where traceability is a
requirement, URT controls and records the unique identification of the product.

Related and Supporting Documenis
A04CO5P01 Process Planning and Control

8.4 Verlfication of purchased product

URT verifies its purchased product to ensure it meets specified purchase requirement
and takes appropriate action in the event of product non-conformance.

Related and Supporting Documents
A04C06P01 Purchasing Process

AO8CO4P01 Nonconformance, Corrective and Preventive Action

8.5 Control of monitoring and measuring devices

Measuring and monitoring requirements are determined and appropriate equipment
selected to provide evidence of conformity to requirements. Measurements and
monitoring are carried out in a manner that Is consistent with the measuring and
monitoring requirements.

Where necessary, measuring and monitoring equipment and software are calibrated or
verified at specified intervals defined standards, adjusted as necessary, identified to
show calibration status, safeguarded from unauthorized adjustments and protected from
damage and deterioration.

URT assesses and records the validity of previous measurements when the measuring
and monitoring equipment is found not to conform to requirements. Appropriate action is
taken on any equipment and product affected.

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Records of calibration and verification are maintained.

Related and Supporting Documents
AO08CO3P01 Monitoring and Measurement

8.6 Measurement, Analysis and Improvement - General

URT has planned and implemented the requirements for measuring, monitoring and
improving processes needed to demonstrate;

a) conformity to product requirements,

b) the effectiveness of the EQH&S Management System, and

c) the continual improvement of the EQH&S Management System.

Related and Supporting Documents
AQ8C03P01 Monitoring and Measurement

A09C02P01 Analysis of Data and Continual Improvement
8.7 Customer satisfaction

URT shall determine the methads to evaluate customer satisfaction.
URT shall monitor customer satisfaction as to whether URT has met customer
requirements.

Related and Supporting Documents
A08CO3P61 Monitoring and Measurement

A08CO3WO03 Customer Survey Procedure

8.8 Monitoring and measurement of processes
Processes affecting product conformity are monitored and periodically reviewed to
ensure they achieve planned resulis. When planned results are not achieved, corrective

action shail be taken.

Related and Supporting Documents
A08C03P01 Monitoring and Measurement

8.9 Monitoring and measurement of product

URT shall monitor and measure the characteristics of the product throughout the product
realization process to ensure that product requirements have been meet.

Evidence of conformity with the acceptance criteria shall be maintained. Records
indicating the person authorizing the release of the product for delivery to the customer
shall be maintained. Release of the product shall not proceed until all planned
arrangements have been completed or authorization is received from a relavant
authority or the customer.

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Related and Supporting Documents
A08CO3PQ1 Monitoring and Measurement

8.10 Mass Balance Accounting

URT shail implement and maintain a tracking system for controlling, weighing and
documenting all incoming and outgoing materials throughout the recycling chain.

a. URT utilizes inventory software to calculate a mass balance accounting of all
materials received, processed, currently in inventory and shipped. URT shall
calculate a mass balance report on a six-monthly basis at a minimum.

b. URT monitors and controls the destination of outgoing materials through the

Downstream Vendor Qualification Program.

c. URT provides customers, if requested, a list of End Processors which includes
contact information, as well as any relevant certifications. Additional shipping
records are made available to customers at their request.

d. URT maintains an up-to-date material fiow chart including the listing of
downstream vendor by commodity type, including reuse, to the end processor.
URT also maintains a list of approved vendors and current status (active/inactive}

Related and Supporting Documents
AOQ8C05P01 Inventory and Mass Balance Reporting Procedure

AQ6CO3P01 Downstream Vendor Qualification Program
8.11 Central Database reporting

URT shall report, on an annual basis, to the e-Stewards central database all data
required in the e-Stewards standard 4.5.1.2.

8.12 Evaluation of compliance

URT has established, implemented and maintains a procedure for periodically evaluating
compliance with applicable environmental, quality, health and safety legal requirements.

A legal compliance audit, conducted by a qualified internal employee or external
consultant, shall be performed at a minimum once every Svo three years. URT will keep
records of the results of the periodic evaluations.

URT has evaluated compliance with other requirements to which it subscribes. URT has
cambined this evaluation with the legal compliance audit. URT will keep records of the
results of this evaluation.

8.13 Corrective Action and Preventive Action Program

URT has established. implemented and maintains a procedure for:
a) defining the process to identify, with criteria, record and/or escalation issues
requiring action.
b) identifying and correcting nonconformities (including customer complaints} and
taking action to mitigate their environmental, health and safety impacts

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c) investigating nonconformity{ies) , determining their cause(s) and taking actions in
order fo avoid their recurrence,

d) investigating potential nonconformity(ies) and determining their cause(s) ,

e) evaluating the need for action(s) to prevent nonconformity(ies) and implementing
appropriate actions designed to avoid their occurrence,

f) determining and implementing action needed,

g) recording the results of corrective action(s) and preventive action(s) taken, and

h} reviewing the effectiveness of corrective action(s) and preventive action(s) taken.

URT shall take action to eliminate the causes of actual and potential nonconformities in
order to prevent reoccurrence. Actions taken appropriate to the magnitude of the
nonconformities, preventive actions and the environmental, health and safety impacts
encountered.

URT shall ensure that any necessary changes resulting from nonconformities, correction
or preventive actions are made to environmental, health and safety management system
documentation.

URT has established a Condition Reporting Database (Spiceworks) process that
empowers all employees and contractors to identify and communicate to management
any adverse condition that requires review. The process may also be utilized for the
escalation of urgent issues requiring immediate corrective action.

All employees are encouraged to utilize the Condition Reporting Database to document
and communicate issues or adverse conditions. Top Management shall review
submitted reports and allocate necessary resources to address the issue including
actions requiring immediate corrective action and escalation. Escaiated issues are
defined in the Nonconformity, Corrective and Preventive Action procedure.

Related and Supporting Documents -
AO8CO4P01 Nonconformance, Corrective and Preventive Action

AQSCO4W01 Condition Reporting Database Process
8.14 Control of nonconforming product

URT shall ensure that product which does not conform to product requirements is
identified and controlled to prevent its unintended use or delivery. URT has astablished,
implemented and maintains a procedure to define the controls and related
responsibilities and authorities for dealing with nonconforming product.

Where applicable, URT shall deal with nonconforming product by one or more of the
following ways:
a) by taking action to eliminate the detected nonconformity;
b) by authorizing its use, release or acceptance under concession by a relevant
authority and, where applicable, by the customer,
c) by taking action to preclude its original intended use cr application;
d) by taking action appropriate to the effects, or potential effects, of the
nonconformity when nonconforming product is detected after delivery or use has
started.

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When nonconforming product is corrected it shall be subject to re-verification to
demonstrate conformity to the requirements.

Records of the nature of nonconformities and any subsequent actions taken, including
concessions obtained, shall be maintained.

Related and Supporting Documents

A08C04P01 Nonconformance, Corrective and Preventive Action
8.15 Records

URT recognizes the importance of completing and maintaining records. Records
relevant to the Environmental, Quality, Health and Safety Management System and
providing evidence of conformity to requirements shall be maintained in accordance with
the Control of Records procedure.

Related and Supporting Documents
AO0BCO2PM1 Contro! of Records Procedure

8.16 Internal Audits

URT utilizes internal audits to ensure program compliance, continuous improvement and
regulatory compliance. The URT Internal Auditing procedure provides the steps for
scheduling, conducting, and documenting internal audits. The procedure also identifies
responsible individuals.

Related and Supporting Documents

A08C01P01 Internal Audit Procedure
8 ACT
9.1 Management Review

URT's Tap Management shail review URT's Environmental, Quality, Heaith and Safety
Management System, at least annually, to ensure its continuing suitability, adequacy
and effectiveness. The Management Review procedure details the steps required when
conducting the review. The procedure also outlines roles and responsibilities of Top
Management during the review.

Related and Supporting Documents
A0S9CO1P01 Management Review

é-Stewards Standards
9.2 Analysis of data
URT shall determine, collect and analyze appropriate data to demonstrate the suitability

and effectiveness of the EQH&S management system and to evaluate where continual
improvement of the effectiveness of the FQH&S system can be made. This shall include

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data generated as a result of monitoring and measurement and from other relevant
sources.

The analysis of data shall provide information relating to;
a) customer satisfaction,
b) conformity to product requirements,
c) characteristics and trends of processes and products including opportunities for
preventive action, and
dc) suppliers

Related and Supporting Documents
AO9C02P01 Analysis of Data and Continual Improvement

9.3 Continual improvement
URT shall continually improve the effectiveness of the EQH&S management system

through the use of the EQH&S policy, EQH&S objectives, audit results, analysis of data,
corrective and preventive actions and management review.

Related and Supporting Documents
A09C02P01 Analysis of Data and Continual improvement

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Evaluation of Compliance Procedure

URT

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Evaluation of Compliance Procedure

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Evaluation of Compliance Procedure

4.0 Purpose
To establish, implement and maintain a procedure to periodically evaluate compliance with

applicable legal requirements and other requirements to which it subscribes.

2.0 Responsibility and Authority

The EHS Department shall have the responsibility and authority to ensure conformance to the
activities described in this procedure.

3.0 Requirements
3.1 The Environmental Management Representative (EMR) shall ensure that legal and other

requirements compliance evaluation audits are done either with qualified internal
sources or contracted with qualified external sources.

3.2 The legal compliance and other requirements audit shall be conducted at least once
every other year.

3.3 The audit frequency may be increased when nonconformance to legal and other
requirements are identified and/or it is deemed necessary.

3.4 The evaluation of the compliance audit shall be based on the Legal and Other
Requirements Summary List.

3.5 Nonconformities from the compliance audit shall be tracked in the Corrective and
Preventative Action Procedure.

3.6 The EHS dept. shall report compliance audit findings at the next Management Review
meeting or senior managers weekly meeting.

4.0 References
A04C01F01 Legal and Other Requirements Summary List
A08CO4P01 Nonconformity Corrective and Preventive Action Procedure

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