CCSI Corporate Policies

Environmental Policy

Policies and Procedures

Consolidated Contracting Services, Inc. (CCSI) and its employees are committed to owning the environmental stewardship of every project we undertake. Our goal is to exceed regulatory requirements, as well as those requirements set forth by our clients.

The CCSI environmental policy is to identify and comply with all regulatory requirements that apply to any aspect of the construction operation. This may include federal state, regional, and/or local regulations. At each level of government, there are several different regulations that impact many segments of the environment the protection of air, water, land and natural resources.

CCSI is dedicated to protecting the environment and the health of our employees on all projects. We strive to reduce the impact of our work on the environment, make efficient use of energy and natural resources, and minimize our carbon footprint.

CCSI has identified the following areas of environmental impact and has adopted specific procedures in order to comply with federal, state, and local laws. All CCSI employees and subcontractors are required to adhere to these procedures. Where local or state regulations require different or more stringent controls, they shall be incorporated.    

Air Pollution

Construction-related air pollution can be caused by dust, vapors, fumes, mist, gas, smoke, or odorous substances. Therefore, an air pollution control plan will be developed to ensure air pollution does not extend the site boundary in quantities and/or duration that exceed or contribute to exceeding government laws, regulations and standards, or that cause deterioration of the "quality of life" and create a nuisance in neighboring properties.

The following are examples of construction-related activities that potentially generate air pollution:

  • Site preparation and civil engineering work (e.g., grubbing, clearing, scraping, excavating, piling and filling) that can produce dust or emissions
  • Vehicular traffic dust from exposed earth and gravel surfaces
  • Soil treated with lime, pesticides, fungicides, dust suppressants or fertilizers
  • Surface preparation and coating that can create dust, vapors or spray from sand/bead blasting, painting, epoxy coating, hot tar roofing, and asphalt paving
  • Mobile equipment that generates dust, vapors and spray to include portable concrete batch plants, rock crushers, chippers, thermal treatment of debris and soils, tank vents and portable electrical generators
  • Demolition activities that can create dust, asbestos or lead during removal of buildings, structures, pipes and tanks

Site Preparation and Traffic

Often, in some jurisdictions, a dust control permit must be obtained prior to commencement of work. A building permit will not be issued unless a dust control plan has been prepared and submitted. If this is the case, CCSI will obtain a copy of the applicable dust control plan/permit from the subcontractor prior to beginning of construction.

At a minimum, an effective dust control plan must include:

  • Criteria and frequency for applying water to potentially dusty areas of the site subject to vehicular traffic (e.g., access roads, internal site roads, areas disturbed by heavy earth moving equipment, etc.)
  • A log that specifies the location, the time(s) of day, number of times per day and amount of water to be applied per day to each location. The log is to be filled out by the driver of the watering truck and remain onsite at all times for inspection
  • Provisions for determining when additional dust control is necessary (e.g., windy days, increased traffic, newly exposed soil, etc.)
  • Areas that require the placement of aggregate to keep dust down (e.g., heavily traveled roads, equipment staging areas, etc.)
  • Copies of permits required by local agencies for on-site water storage. (Some water storage arrangements (e.g., surface impoundments) require significant permitting lead time or are disallowed by local agencies)
    • NOTE: NEVER use dust suppression chemicals (including oil) without prior approval of site EHS personnel

Construction Material Surface Preparation and Coating

The construction of roads, buildings and other structures often requires the surfaces to be prepared prior to applying surface coatings. These activities, along with the surface coatings themselves, can result in the generation of air pollutants. In preparing the surfaces, sand or bead blasting is often used, which generates aggregate and metal dust particles. The application of surface coatings (e.g., epoxy coatings, paint, hot tar roofing and asphalt paving materials, etc.) can generate fumes, vapors and strong odors.

Key elements associated with these activities include:

  • Owner pre-approval for all material/chemical to be used for bead and sand blasting, for coating or painting, and for any solvents associated with these activities prior to any of these materials arriving on the project site
  • Dust or particulate suppression control for all bead/sand blasting and spray painting activities to prevent material from traveling beyond the immediate work area. Sheeting material should be used to separate the work area from the rest of the site
  • Surface preparation and coating activities performed outdoors should not be performed during windy conditions unless performed within enclosed, protected areas. Precautions must be taken to ensure that dust, particulate and other air-borne pollutants never impact sensitive receptors (e.g., employees, residents, local creeks, lakes, estuaries, wetlands or protected flora or fauna, etc.)
  • Waste produced by surface preparation and coating activities must be taken to the site hazardous waste accumulation area

Demolition

The demolition of buildings, tanks, piping systems, etc., can often result in the release of air pollutants. Depending on the age of the building, the materials of construction could contain asbestos or lead-based paint. Ductwork or pipes may contain residual chemicals of concern (e.g., arsenic, adhesives/coatings, solvent or petroleum vapors, etc.). Tanks may contain materials that can release vapors or pose a potential hazardous situation when being removed.

Key elements associated with all demolition activities include the following:

  • State/local permits are usually required for demolition of asbestos-containing/coated structures, pipes and equipment, or for removal of underground fuel/chemical tanks. A certified asbestos removal contractor shall be used for any asbestos removal activity. All permits and licenses must be available for review
  • Sand/bead blasting of metal (interior/exterior) tanks, heavy equipment and steel structures generates spent abrasive material and residual rust and paint chips. The paint being removed may contain lead, requiring additional steps be taken to prevent the release of these materials or contact with any sensitive receptors (e.g., employees, residents, local creeks, lakes, estuaries, wetlands or protected flora or fauna, etc.). Prior to removal of any surface coating material, the Project Manager and qualified subcontractors must determine if the materials contain lead or other potentially harmful substance
  • Prior to removal, dismantling, or disassembly of tanks, pipes, pumps or valves, they must be checked to verify that they contain no liquids, sludge or residues. These residues must be removed in accordance with government, owner, and contractor requirements prior to demolition

Application of Chemicals to the Soils

Chemicals are often applied to the surface of soils for purposes of stabilization/moisture control (lime), sterilization (pesticides, fungicides) or to support landscape plantings. Site specific approvals/permits are not required by local jurisdictions, however, there may be local restrictions prohibiting the use of certain chemicals because of the site's proximity to sensitive receptors (e.g., employees, residents, local creeks, lakes, estuaries, wetlands or protected flora or fauna, etc.).

Key elements to consider before purchasing or applying chemicals to the soil/ground are:

  • Certain chemicals can only be applied by trained and licensed/permitted individuals
  • All licenses and permits must be available for review
  • Are there any adverse conditions that can cause chemicals to leave the construction site and threaten sensitive receptors? For example, chemicals should never be applied while it is windy or raining. Chemicals should never be stockpiled and exposed to rain water or wind
  • Chemicals should only be applied as specified by the manufacturer

Other Environmental Contamination & Land Use Considerations

In addition to air quality, listed below are areas of special concern. Therefore, CCSI maintains corresponding procedures as construction activities and conditions dictate.

Hazardous Materials

  • There will be no on site bulk liquid fuel storage
  • Equipment refueling shall utilize off site fueling resources
  • In the event of a spill of one quart or more of petroleum type product and/or hazardous substance, the CCSI manager will coordinate containment with the applicable contractor. Once the spill is contained, CCSI will coordinate clean up and disposal with the owner
  • All work will actively stop in the immediate area of the hazardous material spill and will not resume until the area has been cleaned and released by the CCSI manager
  • A 20-pound ABC Fire Extinguisher will be placed near the spill area, no closer than 25 feet and no further than 50 feet, and shall remain until remedial activities are complete
  • Perform an environmental site assessment
  • Create and implement a soil management plan
  • Create and implement a fire management plan

Biological Resources

  • Perform pre-construction biological clearance surveys
  • Minimize vegetation removal

Cultural Resources and Paleontology

  • Conduct archaeological inventory of all areas that may be disturbed during construction
  • Avoid and minimize impacts to significant or potential cultural resources wherever possible
  • Train construction personnel to identify cultural and paleontological resources

Land Use

  • Work with adjacent land owners to limit and mitigate construction impact

Water Contamination

  • In order to prevent the contamination of water, the contractor, if necessary, will berm and line all areas where there is the potential of water contamination
  • Before construction begins, the contractor will properly construct the work site to properly allow for drainage of run-off water into collecting areas or existing drainage system
  • The contractor will contain all run-off water until disposal can be arranged by CCSI

Site/Project Specific Environmental Considerations, Procedures & Plans

  • Wildlife Awareness
  • Use of Chemical Toilets
  • Dust Control SWPPP
  • Equipment Exhaust
  • Noise Control
  • Traffic Control
  • Use ultra-low diesel fuel
  • Restrict vehicle idle time whenever possible
  • Properly maintain equipment
  • Use particle traps to reduce diesel particulate matter where possible
  • When necessary to protect employees from the excess amount of dust created from the construction activities, respirator protection will be enforced
  • In the event the contractor’s plan to use sprays, chemicals or other items that have the potential of contaminating the air, they will coordinate all activities of this nature with the CCSI manager before proceeding
  • Any additional site specific requirements

Commitment to the Environment

CCSI will hold a high standard to its employees, vendors and subcontractors in an effort to minimize impact on the environment. We will continue to look for ways to reduce, reuse and recycle, as well as improve our office and construction site consumption of waste sent to the landfill. CCSI will review maintenance procedures on equipment to assess performance and limit pollution. Finally, we will identify areas where we can improve and take necessary action to bring CCSI up to the highest level of responsible care for the environment. 

Human Rights and Social Policy 

Policies & Procedures:

As a socially responsible company, Consolidated Contracting Services, Inc. (CCSI) has concern for the well-being of people and communities. We conduct business fairly and ethically, respect all human rights and comply with laws and regulations. CCSI will not tolerate any unlawful harassment or discrimination in employment. Violation of this policy can result in immediate termination of employment.

Our employees’ human rights are respected across all company operations. We aspire to create an inclusive and respectful work environment; one in which employees recognize each other’s worth and dignity. Any conduct that detracts from the worth and dignity of our employees is contrary to our values and has no place in our culture. We also are committed to showing respect to all people with whom we do business. 

The following is a list of CCSI’s hiring and orientation policies as represented in our Employee Handbook.

Equal Opportunity

CCSI is an equal opportunity employer. In all aspects of employment, we are committed to treating all employees without regard to race, color, national origin, ancestry, religion, sex, pregnancy and childbirth, sexual orientation, gender, marital status, age, physical or mental disability, medical condition, genetic characteristics, or veteran status as those terms are defined by law.

Policy against Harassment

As part of its commitment to equal opportunity, the company strictly prohibits harassment of employees in the workplace based on race, color, national origin, ancestry, religion, sex, pregnancy and childbirth, sexual orientation, gender, marital status, age, physical or mental disability, medical condition, genetic characteristics, or veteran status as those terms are defined by law. Harassment includes all forms of offensive or unwelcome physical or verbal conduct based on any of these factors that unreasonably interferes with an employee's work or creates an offensive or hostile working environment.

Sexual Harassment

Sexual harassment of all types is specifically prohibited. Sexual harassment of employees in the workplace is illegal, unacceptable, and will NOT be tolerated. This policy applies to all supervisors and employees of the company. It shall also apply to customers, vendors, and other persons in the workplace whom the company knows or has reason to know is violating this policy, provided the company has sufficient control over the individual's actions. All company personnel are expected to avoid any conduct that could be construed as unlawful harassment by any employee. .

Complaints

Any employee, who believes he or she has been unlawfully harassed, or has any other complaint under this policy, should bring the matter to the attention of supervision immediately, and provide a full and accurate report of the underlying facts. Employees are urged to report first to their immediate supervisor, but this is not required if the employee feels uncomfortable in doing so or if the employee believes his or her supervisor is violating this policy. In all cases, employees are free to report such problems directly to any officer of the company, the Human Resources department or the president. Employees are encouraged but not required to present their complaints in writing, and should identify any witnesses, as well as any relevant documents or other evidence.

No Retaliation

No employee shall be subject to any form of retaliation for reporting any violation or participating in any investigation under this policy. Employees who believe they have been retaliated against in violation of this policy may utilize the same complaint procedure described above.

All Forms of Harassment are Forbidden

This policy also applies to unlawful harassment based on any of the other illegal criteria set forth in the company's Equal Employment Policy, including race, color, religion, national origin, age, pregnancy and childbirth, sexual orientation, gender, disability, marital status, medical condition, genetic characteristics, or veteran status as those terms are defined by law.

Contractors and Consultants

This policy applies to part-time and temporary employees, leased employees and individuals providing service to the company under contract such as consultants and other independent contractors. Any reference to "employees" in this policy includes all such individuals, as well as regular employees.

Mandatory Training for Supervisors

CCSI requires formal training for all supervisors on how to identify, prevent, eliminate and respond to complaints about unlawful harassment, including the legal remedies available under state and federal law for harassment and retaliation. All supervisors must undergo at least two hours of classroom or other effective interactive training on the prevention of unlawful harassment at least every two years. Employees who are promoted or transferred into supervisory roles must undergo two hours of such training within six months after such promotion and transfer.

Orientation for New Hires and Training for Employees

CCSI provides orientation on this policy for all new employees at the time of hire. From time to time, the company also makes training available to non-supervisory employees.

Commitment to Human Rights & Social Responsibility 

CCSI maintains explicit commitment to all human rights and standards, as stated in the Universal Declaration of Human Rights. Furthermore, we uphold all laws in regard to no child labor, freely chosen employment, minimum wage, hours/overtime, benefits, and freedom of association.

Additionally, our suppliers and subcontractors are actively encouraged to observe these human rights standards within their work. Compliance and integrity are at the core of everything we do at CCSI, and we will continue to have the highest standards for human rights and social responsibility.

Anti Corrpution Policy 

Policies & Procedures

CCSI recognizes that the manner in which it responds to its ethical, social and economic responsibilities is critical to its business success. We aim to demonstrate these responsibilities through our actions and corporate policies.

CCSI strives to be open, honest and have a positive impact on each of its stakeholders including its customers, employees, suppliers, business partners and the communities that we operate in. We will support all laws relevant to countering bribery and corruption in all the jurisdictions in which we operate.

It is our policy to conduct all of our business in an honest and ethical manner. Bribery and corruption are not tolerated. We are committed to acting professionally, fairly and with integrity in all of our business activities.

The following is a list of CCSI’s anti-corruption policies and procedures as contained in our Employee Handbook.

Business Conduct and Ethics

CCSI will conduct its business honestly and ethically wherever we maintain operations. We will constantly improve the quality of our services, products and operations and will maintain a reputation for honesty, fairness, respect, responsibility, integrity, trust and sound business judgment. We will not compromise our principles for short-term advantage. We believe the ethical performance of the company is the sum of the ethics of the men and women who work here. Thus, all employees are expected to adhere to highest standards of personal integrity.

No bribes, kickbacks or other similar remuneration or consideration shall be given to any person or organization in order to attract or influence business activity. Officers, managers and employees shall not offer or accept gifts, gratuities, fees, bonuses or entertainment, in the course of their employment.

Officers, managers and employees agree to promptly disclose unethical, dishonest, fraudulent and illegal behavior, or any violation of company policies and procedures, directly to management.

Conflicts of Interest

Situations of actual or potential conflict of interest are to be avoided by all employees. Personal or romantic involvement with a competitor, supplier or subordinate employee, which impairs, or might impair an employee's ability to exercise good judgment, creates an actual or potential conflict of interest and should be avoided. Any employee involved in any of the types of relationships or situations described in this policy should immediately disclose the conflict or potential conflict to his/her immediate supervisor, or any other appropriate supervisor. If an employee is unsure if his/her conduct or relationship constitutes a conflict or potential conflict of interest, the employee should discuss it with his/her immediate supervisor, or any other appropriate supervisor. If an actual or potential conflict is determined, CCSI may take whatever corrective action appears appropriate according to the circumstances. Failure to abide by this policy or to disclose a conflict or potential conflict shall constitute grounds for disciplinary action, up to and including termination of employment.

The Anti-Corruption Attachment contains specific information and instruction on the recognition of, and the procedures for, dealing with bribery.

Commitment to Anti-Corruption

CCSI remains committed to full compliance with all applicable anti-corruption laws. We will share and declare information on personal and corporate conflicts of interest and seek guidance from higher authority before acting. We will ensure that our business is conducted in all respects according to rigorous ethical, professional and legal standards.

Our aim is to ensure that our stakeholders have confidence in the decision-making and management processes of the procurement service through the conduct and professionalism of all staff. All groups and individuals with whom we have a business relationship will be treated in a fair, open and respectful manner, and  competition will be reasonable and based upon the quality, value and integrity of the products and services being supplied.

Supply Chain Code of Conduct 

The Consolidated Contracting Services, Inc. (CCSI) Supply Chain Code of Conduct encompasses several important programs which are essential to CCSI’s success, as well as the success of our subcontractors and suppliers. They include Environment, Human Rights & Social Responsibility, Health & Safety, and Anti-Corruption. These programs contribute to the betterment of social and economic conditions in the communities served by our clients.

CCSI has identified the following critical characteristics and policies as part of the Supply Chain Code of Conduct and vigorously encourages all vendors/subcontractors to adopt these standards.

Regarding the Environment

  • Written environmental policy that provides the company’s vision and obligation to comply with applicable laws and regulations exists
  • Environmental program oversight provided by an officer or majority owner
  • Environmental program addressing conformance of its second tier subcontractors and suppliers to applicable laws, regulations, and legal requirements
  • Internal environmental program compliance audits
  • Documented processes to report spills and releases, investigate environmental violations, and corrective action procedures
  • Environmental performance tracking reports to be made available upon request

Regarding Human Rights and Social Responsibility

  • CCSI requires subcontractors/vendors to respect human rights and comply with all applicable laws and regulations
  • We will not tolerate any unlawful harassment or discrimination in employment
  • Supplier Diversity policy statement which encourages and promotes providing diverse business enterprises (DBEs) such as women, minority, and disabled veteran-owned businesses, the maximum practical opportunity to compete for business
  • Documented Supplier Diversity program
  • Supplier Diversity program oversight is provided by an officer or majority owner
  • Measurable goals for DBEs participation in bid opportunities

Regarding Health and Safety

  • Written safety policy that provides the subcontractor’s and supplier’s vision and obligation to comply with applicable laws and regulations
  • A safety management program
  • Written and implemented injury and illness prevention plan or its equivalent
  • Safety program oversight provided by an officer or majority owner
  • Safety program addressing conformance of its second tier subcontractors and suppliers to applicable laws, regulations, and legal requirements
  • Safety training for employees, subcontractors, and suppliers to include client’s site work rules, safety practices, and safety requirements
  • Documented processes to report injuries, investigate safety violations and injuries, and documented corrective action procedures.
  • Safety reports available upon request

Regarding Anti-Corruption

  • Written Ethics and Compliance or Code of Conduct policy statement
  • Documented Ethics and Compliance program
  • Ethics and Compliance or Code of Conduct policy addressing the obligation to comply with applicable laws and regulations
  • Ethics and Compliance or Code of Conduct program oversight provided by an officer or majority owner
  • Ethics and Compliance or Code of Conduct distributed to all employees
  • Process in place for employees to report issues or concerns regarding legal or ethical violations
  • Policy in place and communicated to employees that prohibit retaliation against employees for raising ethics issues or concerns

Commitment to Responsible Supply Chain Management

CCSI will require that our subcontractors and suppliers provide documentation of the policies, programs and performance reports which show full compliance with CCSI’s Supply Chain Code of Conduct. 

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