April 10, 2012

To All Stakeholders:

Trinidad Cement Limited is pleased to reaffirm its support and commitment to the principles of United Nations Global Compact - Human Rights, Labour, the Environment and Anti- Corruption.

It is in the interest of our company to operate responsibly and develop products and services that help address social and environmental challenges. We aim to:-

• Continually improve our efforts to corporate sustainability leadership and involve our employees in our social responsibility projects.
• Participate in local networks or seek ways of benefiting from the transfer of knowledge and expertise.
• Listen and respond to the varied concerns of all our stakeholders

In this our first Communication on Progress, we have provided a framework of our policies and actions which reinforce the principles of the Global Compact as part of our business strategy, culture and operations. We also commit to share this information with our stakeholders using our primary channels of communication.

Sincerely
TRINIDAD CEMENT LIMITED

Satnarine Bachew
General Manager

• Trinidad Cement Limited (TCL) operates the only cement manufacturing plant in Trinidad and Tobago. The plant is a wet process with its quarry operations at Mayo Village which is approximately 25 miles east of Claxton Bay (south central of Trinidad), where the cement is manufactured and port facilities, sales and administration offices are located.

• As an employer of choice for the past 58 years TCL is an equal opportunity employer. This means that we will extend equal opportunity to all individuals without regard for race, religion, colour, gender, nationality, age or disability. The company’s policy affirms the Company’s commitment to the principles of fair employment and the elimination of all vestiges of discriminatory practices that might exist. We encourage all employees to take advantage of opportunities for growth and development within the organisation.

• The culture of TCL is one that is shaped by the core values of Honesty and Integrity, Fairness and Equity, Mutual Respect and Support, Accountability and Responsibility, Trust and Transparency. These values guide and shape our actions and behavior and lay the foundation for key behavioral competencies of Leadership, Innovation, Initiative, Ownership, Results Orientation and Relationship Management, which drive excellence in the way we conduct our business and ultimately help us to achieve our vision as a sustainable world class company.

• TCL’s policies are in compliance with all applicable laws, including without limitations, laws relating to industrial relations and employment, discrimination, health, safety, competition and securities trading. No employee has the authority to violate any law or to direct another employee to violate any law on behalf of the Company.

• Each employee must comply with the company’s Code of Ethics and Business Conduct and sign the appropriate acknowledgement form. Failure to comply with any of the provisions of the Code subjects the employee to disciplinary measures up to and including termination.

• Laws and customs vary throughout the world but all employees must uphold the integrity of TCL under internationally proclaimed human rights. When conducting business in other countries, it is imperative that employees comply with applicable laws.

• Suppliers and Contractors are also required to adhere to the ethical conduct and values of the company as well as those enshrined in our policies.

• The company’s continuing theme of “… a balance that works” focuses on the economic, social, wellness and environmental concerns of all employees.

• Respect for human rights has been intensified as reflected in the company’s approach to its developing CSR efforts. Such initiatives have been redirected to target more sustainable initiatives focusing on societal issues and also providing a more strategic way to contribute to causes and at the same time connect TCL and its product with the cause. During the year some of the projects undertaken were as follows:

 Partnering with the Government of Trinidad and Tobago Ministry of Housing, to address the special housing needs of the physically challenged. The outcome resulted in TCL donating cement towards the installation of wheelchair ramps as well as providing technical assistance re international standards for the construction of ramps for the physically challenged. TCL’s General Manager with support from Marketing Manager distributed the cement donations to approximately 20 applicants with assistance from the various hardwares in the communities.

 A direct contribution of 500 sacks of cement to the Sod-Turning Ceremony to begin the rebuilding of the Credo Centre for homeless street children.

 TCL hosted its annual Underprivileged Children’s Christmas Party on Tuesday 20th December 2011 at Gordon Square Park, Mayo Village. Approximately 186 children were treated to snack bags and gifts distributed by employee volunteered Santa.

 Provision of water to its fenceline communities of Claxton Bay and Mayo. By formal arrangement, a 4” water line between Claxton Bay and Mayo distributes water to residents for agriculture and domestic use.

 Proper Cement Handling and Storage, Curing of Concrete and Mortar and the Use of Ad – Mixtures in Concrete were the focus of a recent one-day workshop facilitated by Trinidad Cement Limited (TCL) for Habitat for Humanity T&T. This was the first of several similar workshops to be held for that organisation’s staff, home partners, masons and volunteers.

 http://www.tclgroup.com/media-room/article/2011/12/14/tcl-hosts-concrete-technology-workshop-for-habitat-for-humanity

• The success of TCL’s efforts as a team is dependent on its communal dedication, competence, efficiency, adaptation and conduct. Because of this, TCL ensures that performance is monitored regularly and in a manner that is fair and objective.

• All employees are obligated to promptly report any suspected violations of the Code of Ethics or of applicable laws, rules or regulations by any employee or manager regardless of the person’s status or position within the company.

• Reportable complaints will include but are not limited to the following:
 Commission of a criminal offence
 Failure to observe a legal obligation or to comply with an instrument of governance
 Miscarriage of justice
 Endangering health, safety or the environment
 Administrative malpractice (financial or non-financial)
 Professional malpractice
 Improper conduct or unethical behavior
 Suppression of concealment of any information relating to any of the above

• If an employee becomes aware that another employee has violated the Code or any applicable laws, rules or regulations, he or she must report the violation in accordance with procedures set forth within the document. The company prohibits retaliation against an employee who in good faith reports a possible violation.

• TCL requires that an annual performance appraisal be prepared and conducted for all permanent employees who have been in the employ of the Company for at least six (6) continuous months before he/she is reviewed. The appraisal year runs from October to November with quarterly appraisals being conducted on an informal basis and year end appraisals being submitted at the end of September in each year. All evaluations should be conducted in a fair and equitable manner and provide both the employee and the company with a way of measuring the employee’s efficiency and effectiveness as a Team Member. The results of the evaluations will also allow the department’s manager to make decisions regarding training, compensation, promotion, job assignments, retention and long-range planning, including succession planning. Employee’s performance evaluation is conducted in a way that allows you to be an active participant, thereby helping you to contribute to their development in a direct way.

• Current and future activities on CSR projects and its outcome are reported at monthly management meetings as well as at meetings of the Board Operating Committee. Additionally the report of activities is prepared and submitted for inclusion in the company’s Annual Report.

• The company’s Reward and Recognition Programme reinforces behaviors by rewarding results and in so doing, and at the same time instills a recognition culture where this becomes “a way of life” within the organization. It is one of several initiatives that TCL recognizes as being necessary for shifting cultural norms from a construct of entitlement to one of reward for performance.

• No claim regarding Human Rights was reported in the period covered by the COP.

• TCL fully respects, support and continues to uphold the freedom of association of its employees and the effective recognition of the right to collective bargaining.

• Through the Company’s relationship with Unions and other representative associations, it is expected that the long-term development of the Company is sustained, both to the benefit of the employees and of the Company, by maintaining a level of competitiveness adapted to its economic environment.

• Contracted labour as and when engaged is required to be paid not less than the minimum rate for the particular job classification. The company ensures that contracted workers are also covered by Workmen’s Compensation and adhere to the Code of Ethics and Business Conduct of the company.

• Collective Agreements have been signed between Trinidad Cement Limited and the representing Trade Unions on behalf of employee members. These agreements are intended to promote economic and efficient operation of the working of the Company, avoid industrial disturbances and achieve the highest level of employee performance consistent with safety and good health.

• Orientation is a formal welcoming process that is designed to make the new employee feel comfortable, informed about the company, and prepared for their position. As an employer of choice, the company ensures that the welcome to new employees to the organization is warm and encouraging. Orientation is organized in such a way that there is mutual understanding on working together. A smooth and thorough orientation results in a positive integration into the Company’s operations and will lead to our partnership being a more productive and rewarding experience.
• An Employee Handbook is also provided to all employees to familiarize all with the company’s policies and procedures. The document is essential in answering the basic questions. The handbook is modified as necessary except where changes are governed by a Collective Agreement.

• All the above documents mentioned are available on intranet and can be accessed by most employees on computers. Individuals without intranet tools are presented with a hardcopy.

• TCL values good labor relations and ensures that a continuous communication with employee representatives exists. Employees are encouraged to solve problems by discussing them openly with their supervisors/managers or the Human Resources Department. Non-crisis meetings are also held regularly between the Union and Management to address any issues which may arise in the employment relationship.

• Training sessions are held with supervisors so that they fully understand each clause of the Collective Agreement to address any labour risks for peaceful resolutions.

• The company had embarked on a Communications Assessment to analyse existing internal communications channels and tools i.e. newsletters, memos, brochures, annual reports, personnel forms, speeches, meetings, e-mails, etc. to ensure that every employee was receiving appropriate information and messages from the company effectively. By way of informal interviews with employees (randomly selected), focus group meetings and electronic surveys and based on the findings, a proposal was submitted for the way forward for more effective interaction throughout our company.

• Improvement of Communication efforts largely reflected the need for timely information, greater honesty, sincerity, trust and credibility in dealings between management and employees, more interaction and communication between management and employees and greater feedback from management. These were all thought to lead to more effective communication and less misinformation.

• Additional comments included the need to ensure that persons responsible for communicating critical information are trained to do so, the need to provide all employees with access to computers and greater use being made of notice boards.

• Much more attention should be paid to engaging the employees in ways which provide greater insight to wider business context and their individual roles and responsibilities in the success of the company. Many employees expressed the desire to have upfront discussions and agreements with their Supervisors and Managers on timely and prioritizing of deliverables.

• TCL has recognized that its business have an impact on the environment and is committed to ensuring that this impact is minimised or reduced where practicable. TCL seeks to ensure that the resources and materials used by its business are sustainable and capable of being recycled; are used effectively with the minimum of waste; that were practicable, utilised technologies, materials and processes which do not have an adverse impact on the environment and where such impact is avoidable it is mimimised and that suppliers and contractors have the same objectives.

• Environment Goals for 2012
1. Focus on Pollution Prevention
2. Comply with all legal and other requirements
3. Maintenance of the certification of TCL’s ISO 14001 Environmental Management system
4. Continual Improvement of TCL Environment
5. Embark on more Environmental CSR Initiatives.
6. Increase employee environmental awareness and education.
7. Introduce and revamp (where needed) Recycling Initiatives

• TCL is required to report all environmental and social events that may have caused damage; caused health problems; attracted the attention of outside parties; affected project labor or adjacent populations; affected cultural property; or created liabilities.

• No exceedances with the Noise Pollution Rules, 2011 were recorded.

• TCL’s Stack Emissions Testing on Kiln 3 was conducted from 11th to 15th April, inclusive using approved US EPA Methods. Below is a summary of results of the stack emissions testing.
Parameter Average EMA’s Permissible Limits
Particulates 2028 mg/Nm3 100 mg/Nm3
Lead and its components 0.11 mg/Nm3 0.5 mg/Nm3 as lead
Antimony and its components Below Detection Limit 5 mg/Nm3 as antimony
Arsenic and its components Below Detection Limit 0.8 mg/Nm3 as arsenic
Cadmium and its components Below Detection Limit 0.005 mg/Nm3 as cadmium
Mercury and its components Below Detection Limit 0.05 mg/Nm3 as mercury
Heavy Metals (other)-
Mainly Barium and Zinc 6.55 mg/Nm3 5 mg/Nm3 as heavy metals
Oxides of Nitrogen (NO) 2563 mg/m3 500 mg/m3
Sulphur Dioxide (SO2) Below Detection Limit 1000 mg/m3
Carbon Monoxide (CO) 20 mg/m3 1000 mg/m3

• With respect to the particulate levels obtained (2028 mg/Nm3) this may have been as a result of some upset conditions in kiln 3 which occurred on the 14th and 15th April, 2011. It was observed that the particulate levels recorded were unusually high. Stack Emissions testing will again be conducted in 2012 to also assist in determining if levels are repeatedly high.

• Upgrade of Kiln #3 ESP to achieve maximum efficiencies is being conducted in phases. Next project on stream: replacement of collecting plates and hammers in Field 2 of Kiln #3 ESP to improve efficiency.

• TCL continues to maintain the ESPs of both kiln lines in accordance with its Preventive Maintenance Plan.

• Kiln dust is also recycled and mixed with slurry and returned into the kiln so preventing its emission into the atmosphere and further preventing loss of valuable raw material, reducing production cost and increasing profits. This results in an increase in overall production, profits and reduced spillage and emissions into the environment.

• At the Packing Plants the following corrective actions were completed:
1. Dustplant installation at Jumbo bag filling bay
2. Vacuum truck is used to clean spillages to reduce particular emissions
3. Jumbo bag loading area is cleaned more frequently and washed to prevent accumulation of material on the ground which contributes to dust problems

• Corrective actions planned:
1. Replacement of screw Conveyor in Packing Plant #1 to prevent spillages and reduce dusting.
2. Housekeeping issues as a result of material spillages/releases are most times cleaned up as soon as possible.

• Wastewater monitoring is conducted at the TCL Claxton Bay and Mayo facilities on a scheduled basis by an external contractor. For 2011 exceedances with the standards set out by the Water Pollution Rules, 2001 as amended by the Water Pollution (Amendment) Rules, 2006, were recorded for the following parameters:

Wastewater
Parameter
Exceeded Corrective Action Completed Corrective Actions Planned

pH Increased and continual sensitization of The feasibility of installing neutralisation systems
employees to have spillages immediately utilizing either carbon dioxide or acid injection is
contained and cleaned and have reduced being investigated.
material run-off.

Continuous monitoring of the Neutralization chamber,
which was implemented to treat and control pH of effluent
exiting the settling ponds, to ensure optimal functioning.

Total Suspended
Solids(TSS) Settling ponds and drains are monitored more efficiently Drainage cleaning and maintenance plan to be
and cleaning schedule is adhered to. reviewed.
Spillages are cleaned as soon as they occur to prevent Smaller scale settling ponds being looked into
material from getting into the drainage systems. for other areas around Claxton Bay facility.
Increased sensitization of employees- Ongoing.

Oil and Grease Secondary containment (bonded area) for storage of Investigate the application of oil/grease traps
waste oil and oily waste drums was constructed; this and other oil spill control/mitigation measures.
would aid in ensuring contained storage until the drums
are collected for appropriate disposal.
Increased monitoring and instruction (training) of employees Increase focus on sensitization of employees
to prevent any oil spillages/ leakages, and where necessary and contractors as to use of existing
ensure immediate containment and clean-up of such spillages procedures and operational controls.
– Ongoing.

Faecal Coliforms Drains cleaned more frequently; The feasibility of implementing a system for
Septic systems to be maintained more regularly. the treatment of faecal coliforms utilizing
chlorination, ultraviolet disinfection or
bacteriological treatment is being investigated

• TCL was required to conduct wastewater monitoring subsequent to approval of a Quality Assurance Project Plan (QAPP). The QAPP was prepared and submitted in November 2011 and approval has since been received. Waste water monitoring is to now commence.

• TCL will now put in place all necessary prevention and control measures, including any wastewater control/correction technologies, by mid-2015.

• Used oil is also put into the slurry and burnt off in the kiln, once again preventing pollution and increasing savings by producing energy in the kiln.

• Spilt cement is collected by a vacuum truck and recycled into the system thereby minimising wastage and pollution.

• Over the past year, Trinidad Cement Limited embarked on a number of external projects as well as internal employees programmes aimed at educating and raising the levels of awareness among employees, communities and other external parties. Some of the projects/programmes/initiatives were:

 A waste management policy ensuring that collection, storage, transportation and disposal of waste was properly managed and recycled as far as possible
 Recycling of ink and toner cartridges was instituted in 2011 and collection bins were placed in strategic areas throughout the administration building for the external agent to collect for recycling
 Celebrating World Environment Day 2011 with activities occurring over a 4-day period culminating on the day itself- June 5th. The activities ranged from a presentation and booth display by the Forestry Division aimed at sensitizing employees, distribution of seedlings to employees, plant sale, distribution of plants to the community and a school in Mayo and a booth display at the EMA Green Lifestyle Show showcasing TCL’s environmental initiatives and environmental achievements via its product-Premium Plus. Premium Plus (blended cement) allows TCL to achieve greater environmental responsibility, by reducing the levels of greenhouse gas emissions emitted into the atmosphere per tonne of cement produced.
 Participation in the Environmental Management Authority Green Business Forum on 23rd and 24th March 2011 at Hilton Trinidad. TCL’s booth highlighted tyres as alternative fuel, low carbon products (TCL premium Plus/Pozzolan), Concrete Roads, Pervious Concrete as well as options for decorative concrete as counters and floors.
 Hosting Safety Village was in September 2011. The village comprised 8 booths each focused on different aspects of safety at TCL. The Safety Village aimed at providing employees with awareness level HSE training to improve their knowledge, understanding and application of HSE in the field and at home. 185 TCL and contractor employees were in attendance.
 TCL Frontage Project- Over 400 plants planted at the frontage area of the Claxton Bay facility.
 Facilitation of ‘School Based Assessment (SBA)’ so as to assist students with the compilation of information on the environment for their related SBA project.
 Annual Holiday Camp for Employees children from July 11th 2011 to August 4th 2011 with emphasis on the theme “Water for Life”.
 September 2011 was designated for the Beach Clean Up Event in Trinidad and Tobago in support of International Coastal Clean-up (ICC) organized by The Energy Chamber and Heroes Foundation at Vessigny Beach on Sept, 17th. TCL provided assistance and support to the Clean-up which was considered the world’s largest volunteer effort to clean up the marine environment and coordinated by the Ocean Conservancy office of Pollution Prevention and Monitoring of Virginia, U.S.

• Discussions are continuing with the Government of Trinidad and Tobago and other regulatory agencies regarding TCL’s proposal for agreement to dispose of used tyres in its cement kiln as a sustainable option for waste management in Trinidad and Tobago.

• The ability for TCL’s product - Portland pozzolanic cement - to meet and exceed international standards as well as TCL’s in-house minimum requirements are measured and assessed at all times throughout the process so as to ensure that all contributing variables are satisfied in order to produce this environmentally friendly cement. These quality processes are highlighted in our quality systems which are ISO 9002 Certified.

• Key Environmental Performance Indicators specific to TCL were developed and are utilized to measure success and the results obtained. There are indicators for different areas including wastewater and ambient air monitoring, internal and external communication, equipment availability and training completed. In addition. TCL is ISO 14001 Certified and as such Environmental Management Systems (EMS) Internal and External Audits are conducted periodically to measure performance and compliance. Since having first received our ISO 14001 certification in December 2006, TCL has undergone Surveillance EMS Audits every six months and has shown signs of continual improvement resulting in the retention of our certification. Additionally daily, weekly and monthly Health, Safety & Environment Inspections are conducted to monitor compliance with legal and other requirementsTCL continues to maintain its ISO 14001 Environment Management System certification as the framework for achieving and reviewing its environmental objectives and targets and for managing adverse environmental impacts of its operations. Employees are appropriately trained and empowered to fulfill their specific roles in the Environmental Management System

• Guided by the World Business Council on Sustainable Development (WBCSD) Cement Sustainability Initiative, TCL has focused on reducing its “carbon footprint” with a target of 0.8 tonne CO2 emissions per tonne of cement. Over 2011 TCL achieved an average level of 0.82 of CO2e per tonne of cement.

• In 2011 Trinidad Cement Limited (TCL) achieved the International Standards Organisation’s (ISO) 17025:2005 Lab Accreditation for Compressive Strength and Setting Times, under the Trinidad and Tobago Laboratory Accreditation Service (TTLABS) scheme. This achievement is further testimony of the company’s commitment to producing superior quality products for all its users. www.tcl.co.tt

• TCL’s Reward and Recognition Programme TCL seeks to create a ‘green culture’ through recognising and rewarding innovativeness, teamwork, continuous learning, employee commitment and performance. The bulk of the awards are Instant Rewards which seek to recognise individuals and departments for exceptional performance and give immediate recognition to those who exceed in a specific routine task at any point in time.

• In accordance with its published Code of Ethics and Business Conduct employees must not defraud or attempt to defraud any customer, supplier, shareholder or other person with whom TCL communicates or does business. In particular, employees must always make truthful statements, both verbally and in writing about the company’s products, services and financial condition. Any employee found to be attempting fraud or engaging in fraud or bribery will be subject to strict disciplinary action, up to and including termination. The company reserves the right to refer such matters to public authorities for possible criminal prosecution.

• Strict compliance with competition and antitrust laws around the world is essential. Employees and other representatives of the company must avoid even the appearance of such conduct. Such conduct includes – agreements of joint actions between competitors regarding prices, bids, products or territory allocations or divisions, selection of customers or suppliers or limits on production, inventory or research and development; and agreements with customers or licenses regarding the minimum resale price at which they will sell TCL goods and services.

• Material non-public information often called “insider information” shall not be used by employees for their own gain or for the gain of others, friends, relatives or other employees.

• Employees are required to contact the relevant legal department before taking action concerning any specific situation.

• In accordance with the guidelines for whistleblowers, all employees are obligated to promptly report any suspected violations under the Code of Ethics and Business Conduct or applicable laws regardless of the person’s status or position within the company. Failure to report criminal activity can itself be considered a crime and may result in disciplinary action. The company prefers employees to identify themselves when reporting violations or suspected violations as this will better enable the company to investigate the suspected wrongdoing. The company also recognizes that in some cases employees may feel it necessary to remain anonymous. In such instances, employees are still required to make the necessary report. The identity of any persons making an allegation will be kept confidential until a formal investigation is launched. Thereafter the identity of the persons making the allegation will be kept confidential if requested unless this is incompatible with a fair investigation. The company will not disclose the identity of anyone who reports a suspected violation or who participates in a related investigation unless the employee submitting the report authorizes such disclosure or such disclosure is required by law, regulation of legal process.

• The Code of moral principles based on the company’s core values – honesty and integrity, accountability and responsibility, trust and transparency - governs the behavior of a person or group with respect to what is right and /or act as a guide when discretion is required to be exercised. Each employee must comply with the Code of Ethics and Business Conduct and sign the appropriate acknowledgement of receipt form.

• The Code sets out general principles to guide employees in making ethical decisions.

• All employees have a responsibility to understand and follow the Code of Ethics and Business Conduct. Employees are expected to perform their task in keeping with the company’s core business values as it relates to anti-corruption.

• TCL’s Internal Audit has the responsibility to review any systems breaches that the company incurs in a compliance risk or suffers damage likely to derive from its non-compliance with applicable laws, regulations and internal rules falling under the scope of the compliance function or under the domains assigned to it by the Management.
• The Board of Directors, via the governing Audit Committee, meets on a quarterly basis to assess any such reports and recommendation for containment of the compliance risk.
• No claim or request for monetary sanction for corruption was reported in the period covered by the COP.