AUDITOR’S CHECKLIST FOR USE IN “FIELD TESTING” THE R2 PRACTICES |. FACILITY INFORMATION Adress: ee Es HEE Malaysia ll, R2 PROVISIONS Provision 1 ~ Environmental, Health, and Safety Management System ‘ R2 Requirement yn Auditor Comments 1. | Does the recyclerhave awniten | Y_| Facility has created system and is in the process EHSMS? [section (@)] of becoming ISO 14001 & 9001 certified. Written programs and systems in place - Reviewed by auditor 2. | Isthe EHSMS reviewed atleast. | Y_| It is a new system but ISO mandates annual ‘annually and updated as needed system reviews and quarterly check-ups. (2.9.28 products andior technologies change)? [secton (a 3. | Does the EHSMS include goals and | Y | Yes ~ reviewed by auditor procedures and require the ‘organization to systematically manage its environmental, heath, ‘and safety matters? [section (a)1)} 4, | Isthe EHSMS based on a"plan,do, | Y | Yes — reviewed by auditor ‘check, act” model for continual improvement? {section (a)(2) and tn aDoes the EHSMS include sections setting forth A. a"reuse, recover, dispose” hierarchy of management strategies covering on-site and downstream materials management? [section (a}(3)(A)] B. an analysis and plan for how the 2 Focus Materials (FMs) should be property managed on-site and ownstream; the "FM Management Plan” [section (a) ey ©. an EHS hazards identifcation and assessment of on-site ‘occupational and environmental risks? [section (a) (3) (C)] D. an emergency response plan ‘outing how it wll respond to and report exceptional releases, accidents, spil, fres, explosions, and other out-of-the-ordinary ‘events that pose risks to worker safety, public health, or the environment? [section (a) (3) (D)] E. the activities undertaken to ‘conform to the requirements of these R2 Practices and listing the documentation necessary to show conformity with these requirements? [section (a) (9) (E}] Yes - reviewed by auditor All downstream materials and waste products are handled within a strict hierarchy that supports the ISO documents. As required by the ISO 14001 standards this is implemented and was reviewed by auditor. Yes ~ reviewed by auditor Yes — reviewed by auditor These activities are performed to achieve and maintain ISO certification. Documentation observed by auditor. Has the recycler provided the ‘emergency response section of its EHSMS to local emergency responders if appropriate or required? [section (a) (3) (D)] Yes — as required by the Malaysian DOE — reviewed by auditor. Provision 2 “Reuse, Recover " Hierarchy of | Responsible Management Strategies 7 Is the section of the recycler's EHSMS stating its “reuse, recover, cisposal’ management strategy consistent with the hierarchy set forth in this provision? [section (a)] ¥ Yes - commitment is within the ISO structure is consistent with the R2 principles — observed by auditor.| |s the material flow (on-site and downstream) consistent with the hierarchy? [section (a)] Yes — reviewed by auditor — both in the written program and site operations Provision 3 — Legal Requirements 9, | Isthe recycter knowledgeable (ie, does it have a complete list) of Federal, State, and local ‘environmental, health, and safety requirements —and, fit exports, the importation requirements of al transit ‘and recipient countries as required in Provision 7 — that are applicable to the operations and transactions in which it engages? [section (a) Yes- the facility is carefully managed in accordance with the Malaysia DOE. Their regulations are much stricter than the US of electronic refurbishment operations. Inspections are frequent and documentation is required monthly, Auditor can confirm nexus with regulations and operations, 10. | Is there sufficient evidence to reasonably conclude that the recycler has the necessary environmental health and safety permits and ‘authorizations from all Federal, State local and foreign governments that are applicable to its operations and transactions? [section ()] ‘Yes — permits and operations reviewed by auditor. 11, | Is there sufficient evidence to reasonably conclude that the recycler is in compliance with ail legal requirements covered by this Provision? [section (a)] Yes — reviewed by auditor 12. | Is there sufficient evidence to reasonably conclude that the recycler has made available, upon request by ‘customers, notice of any material fines, regulatory orders, or violations relating to environmental, health, or safety legal requirements in the previous 3 years and within 60 days after any subsequent fines or regulatory order? [section (b)] Yes - requirement reviewed by auditor and discussed with operator. The facility has not received violations,