1. In 2019, there have been 6 irregularities issued to date, with additional cases being investigated. Thus, additional management attention is warranted. In relation to these irregularities, 5 NA refining employees and 8 Contractors have been terminated. It has been at least 10 years since NA refining has had that many employee irregularities in one quarter.

2.Sessions should be focused on driving out bad behaviors and not in managing the number of irregularities. Clear leadership expectations, prompt reporting, and holding workforce accountable is paramount to address unacceptable behavior. Employees should be encouraged to report any possible violations and be recognized accordingly, particularly if the suspect behavior may impact site SSHE compliance and IOL’s reputation.