Classification | Internal

Document Submittal Form

Document
Contractor submittal 13-151000-4800000331-NAP-ENV-PLN-000002
no.

Contract no. 4800000331/000 Date 28-Jan-23

To PMC NEOM/AECOM

Rev
Document no. Type Description Action required
no.
Approval Comments
13-151000-4800000331-NAP-ENV- 4800000331/000 - Sustainability Management
Plan 01
PLN-000002 Plan for Back Bone and Infrastructure Other
Information

Contractor authorized signatory

Name Abdulaziz Ali Date 28-Jan-23

Signature

PMC’s comments

Exception as noted revise

No exception taken Revise and resubmit
Status code and resubmit for record
Rejected Review not required Issued for Construction

Engineer’s name Date

Signature

Received by Contractor
Name Date

Signature

Classification | Internal
Classification | Company General Use

PLAN
4800000331/000 - Sustainability Management
Plan for Back Bone and Infrastructure

13-151000-4800000331-NAP-ENV-PLN -000002 Rev.01 January-2023

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Document history

Revision code Description of changes Purpose of issue Date

01 First Issue For approval 28.01.2023

Document approval

Prepared by Approved by
Name Abdul Aziz Hashim Houssam
Nakouzi
Job Title Environment Manager Project Director

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Contents
List of Figures ................................................................................................................................................................. 4
List of Table .................................................................................................................................................................... 4
ACRONYMS & ABBREVIATIONS ............................................................................................................................. 5
Terms & Definition ......................................................................................................................................................... 6
EXECUTIVE SUMMARY ............................................................................................................................................. 7
INTRODUCTION ......................................................................................................................................................... 8
1. PROJECT DESCRIPTION ................................................................................................................................. 8
2. PURPOSE & SCOPE .......................................................................................................................................... 9
3. Sustainability Management for NEOM ............................................................................................................. 10
3.1 Sustainability Management Program Level Objectives ................................................................................ 10
3.2 Sustainability Management Project Level Objectives ................................................................................... 10
4. ROLES & RESPONSIBITIES .......................................................................................................................... 12
5. PROCEDURE ................................................................................................................................................... 13
5.1 Communication .............................................................................................................................................. 13
5.1.1 Internal Communication ............................................................................................................................ 13
5.1.2 External Communication ........................................................................................................................... 13
5.2 Sustainability Meetings ................................................................................................................................. 14
5.3 Data and Document Control .......................................................................................................................... 14
5.4 Reporting and Deliverables ........................................................................................................................... 14
5.4.1 Reporting Framework and Deliverables ........................................................................................................... 14
5.5 Performance Assurance ................................................................................................................................. 15
5.5.1 Performance monitoring ................................................................................................................................... 15
5.5.2 Sustainability Audits and Inspections............................................................................................................... 15
6. Risk Management .................................................................................................................................................. 16
7. TRAINING & AWARNESS PLAN ................................................................................................................. 16
7.1 Project Environmental and Sustainability Policy ................................................................................................ 16

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List of Figures
Figure 1: Site Layout and activities locations .............................................................................................................. 10

List of Table
Table 1: Project sustainability objectives .......................................................................................................................... 12
Table 2: Roles and responsibilities .................................................................................................................................... 13
Table 5: Schedule for Sustainability Auditing .................................................................................................................... 16

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ACRONYMS & ABBREVIATIONS

KSA Kingdom of Saudi Arabia

CAT Carbon Accounting Tracker
CEMP Construction Environmental Management Plan
CWMP Construction Waste Management Plan
EBS Environmental Baseline Survey
ECI Early Contractor Involvement
EMS Environmental Management System
EPD Environmental Product Declaration
ESIA Environmental and Social Impact Assessment
GAMEP General Authority for Meteorology and Environmental Protection
GHG Green House Gas
GIA Gross Internal Area
IFC International Finance Corporation
IMO International Maritime Organization
MSDS Material Safety Data Sheet
OWMP Operational Waste Management Plan
PPE Personal Protective Equipment
SIP Sustainability Implementation Plan
RSP Registered Service Providers
CA Corrective Action
CAR Corrective Action Request
HSE Health, Safety, and Environment
HSEM HSE Manager
NCR Non-Conformity Report
PAR Preventive Action Request
Sub-Con Subcontractor
TBT Toolbox Talk
EO Environmental Officer

NEO NEOM Environmental Office

NAP Nesma and Partners

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Terms & Definition

Project Sindalah Island BackBone and Infrastructure

Client NEOM
Contractor/Company NESMA & PARTNERS CO. LTD
Sub-Contractor Rawabi Specialized Contracting Company (RSCC)
Sustainability Sustainability is about creating projects which have positive
outcomes for society and the environment. The goals of
sustainable construction include: sourcing renewable and
recyclable resources and reusing materials where possible to
avoid sending waste to landfill.
Awareness All of the activities aimed at providing knowledge for the
identification, reduction, and management of risks in the
workplace.
Chemical Hazards Potential hazards that expose employees to chemical means;
i.e., fumes, gases, vapors, liquids, mists and particulates.
Correction/Treatment Action to eliminate a Non-Conformity.
Corrective Action Action to eliminate the cause(s) of a detected non-conformity
or other undesirable situation.
Emergency Any deviation from normal operating procedures which lead to
situations posing a danger to people, environment and property.
Environment Surroundings in which an organization operates including air,
water, land, natural resources, flora, fauna, humans and their
interrelation.
Environmental Aspect An element of an organization’s activities, products or services
that may interact with the environment.
Environmental Impact Any change to the environment, whether adverse or beneficial,
wholly or partially resulting from an organization’s
environmental aspects.
Hazardous Waste The Wastes (includes liquids, semi-solids or combination
gaseous material) or a combination of solid wastes which,
because of the quantity, concentration, or physical, chemical, or
infectious characteristics, may pose a substantial health hazard
to man and/or his environment when improperly treated, stored,
transported, disposed of, or otherwise managed.
Spill / Leak Any release of hazardous material or hazardous waste into the
environment.

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EXECUTIVE SUMMARY

This document is the Sustainability Management Plan for the BackBone and Infrastructure works of
Sindalah Island. Sindalah Island is located near the Ras Gasabah Peninsula and is part of the
complex that makes up the Tiran Island Group. It is an internationally recognized area of
conservation importance.

Nesma and Partners (here after called the Contractor) was appointed by NEOM to undertake the
project work compromises to installation and testing of utilities (MV cables, water network system
for irrigation, portable water & water for fire hydrants, Sanitary waste vent and storm water
drainage piping, installation of network for domestic water, metal duct installation and cladding,
diffuser register and grill, refrigerant and condensate drain piping and installation of air handling
units), TSE Storage Steel Tanks (Design and Build), Irrigation Pump Station Building Golf Course
Maintenance Building, Waste-water Treatment Plant (WWTP), (Design and Build)Sub-surface
Water Treatment Plant (Design and Build). NAP will complete the construction work according to
the levels, dimensions and coordinates provided in the approved details design drawings. The NAP
shall procure, construct and install and commission the project based on detailed design
documentation. Any change in specifications shall be notified to the NEOM and prior approvals
shall be obtained before proceedingwith works.

This Sustainability Management Plan describes the processes, procedures and initiatives that the
Contractor will implement to meet the sustainability obligations specified in the contract. The
Sustainability Management Plan describes how the Contractor will formally implement sustainably
management techniques, which will achieve the Project sustainability policies, objectives and targets.

The Sustainability Plan represents the overarching management plan for control of sustainability
requirements and will be used as a guide to inform the development of the Sustainability Plan in the
design and construction phase. Project level sustainability objectives were identified and will be
implemented during the design and construction phase.

During the detailed design phase, sustainability aspects will be integrated into the design of project
work as far as practicable. The Contractor and the design consultant will attend meetings and
planned the design and construction program.

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INTRODUCTION

The Kingdom of Saudi Arabia will develop NEOM as a world-class region with a focus on developing
technologies, sustainable development and providing favorable working conditions. Sindalah Island (the
'Project') will be developed by NEOM into a year-round luxury destination with high- end accommodation
offering a variety of activities and amenities, including a marina, golf, retail, fine dining, and performance
area. Island is to be developed as one of the first flagship destinations under NEOM. The island of Sindalah
is a part of the Tiran Island Group, part of the Ras Gasabah Peninsula. The island's importance for
conservation is recognized internationally. There are environmental attributes in Sindalah that NEOM
values, but which are sensitive and can easily be damaged or degraded. There must be great care taken to
ensure that all construction activities that may affect the sensitive attributes available in Sindalah Island are
planned and executed in a way that minimizes those risks.

NESMA was engaged by NEOM to execute early earth work for development of Sindalah Island. The
project work compromises to complete the installation of utilities and construction of supporting facilities
for Golfcourse according to the levels, dimensions and coordinates provided in the approved details design
drawings. NESMA shall procure, construct/install and commission the project based on detailed design
documentation. Any change in specifications shall be notified to the NEOM and prior approvals shall be
obtained before proceeding with works.

1. PROJECT DESCRIPTION

Sindalah Island is located near the Ras Gasabah Peninsula and is part of the complex that makes up theTiran
Island Group. It is an internationally recognized area of conservation importance. Sindalah Island represents
one of the geological icons of NEOM, leveraging on its exceptional marine characteristics and beauty. At a
length of 2 km and a maximum width of 700 m, the Island amounts to a total land area of approximately
840,000 m2. The Island is located 5 km from the mainland of Saudi Arabia and can be accessed within 15
minutes via boat. Elevated at an average of 4 m above sea level, the Island has a maximum elevation of 23
m. Composed of a topography consisting of mostly rocky and moderately sandy terrain, with pristine water
and coral reef, the Island is rich with nature and surrounded by a diverse range of conservation assets such as
coral reefs, turtle nesting beaches, seagrass meadows and important bird nesting areas.

Sindalah Island is a fossilized coral Island in a near-pristine conservation status and represents a very
ecologically sensitive environment. The Island and its surrounds were designated as ‘Environmentally
Sensitive’ in a study undertaken by King Abdullah University of Science and Technology to inform
NEOM’s regional land-use planning Such areas may be considered for classification, by NEOM, as a marine
reserve. A number of species have been observed on the Island or in the vicinity which have been classified
by the International Union for Conservation of Nature (IUCN) as being Critically Endangered (CE),
Endangered (EN) or Vulnerable (VU) to extinction. Access to the site is restricted to pre-arranged yacht
bookings and visitations. Public access on a ‘walk-on’ basis is prohibited.

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Fig-01 Site Layout and activities locations

2. PURPOSE & SCOPE

The sustainability policy for the Sindalah Island Project and specific goals are included below:

• Proactively work to plan, design and construct the Sindalah Island Project balancing economic,
environment, stakeholder and community values.
• Proactively work to identify sustainability benefits, opportunities and “wins” that can be designed
and implemented on project.
• Design and implement the Strategies for LEED Rating System for the iconic station,
namely; Sindalah Island Project in line with contract and associated construction and procurement
requirements.
• Protect the environment; minimize and mitigate unavoidable impacts; restore
• environmental resources as needed; and use resources efficiently and prudently through affirmative
procurement practices.
• Leave a legacy of ‘Zero Accidents’ on the project, as well as in the greater project
community by implementing a comprehensive HSE program.
• Proactively work with our customer to build positive stakeholder relationships and communicate
transparently and effectively about project construction environmental impacts with project
stakeholders and within local communities.
• Design and implement a Social Investment and Outreach Program, through which the project will
contribute time, expertise and / or money to local community initiatives.

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3. Sustainability Management for NEOM

In line with the KSA Vision 2030, the NEOM Project aims to become a sustainable development during the
construction and operational phases. NEOM aims to create an example of sustainable development capable of
informing, inspiring, and empowering people to make effective change in their lives that allow them and nature to
flourish side by side.
3.1 Sustainability Management Program Level Objectives

To deliver NEOM high aspirations for sustainability across the development a Sustainability Framework
has been created. The Framework was developed to provide unique sustainability targets to inform the
development and operation of NEOM.
The objectives of the sustainability framework are to set meaningful, aspirational but achievable targets, to
measure, track and document progress against these targets as the design develops, to ensure Flexibility
across scales, to enable integration across the business, and to be rooted in scientific evidence, innovation
and latest thinking as relevant to sustainability in the context of the NEOM Project. The objectives include:

• To inform the planning, management and the evaluation of activities, in the region;
• To inform the sustainable development of NEOM;
• To set meaningful, aspirational but achievable targets;
• To measure, track and document progress against these targets as the design develops;
• To identify ownership and responsibilities, as well as integrate the various project team members in
such a way that allows different disciplines to best utilize their skills to deliver against a mutually
agreed common set of sustainability outcomes;
• To ensure flexibility across scales, time and project type to enable integration across the business;
and to ensure strong scientific evidence, innovation and latest thinking on sustainability are adopted
in NEOM.

3.2 Sustainability Management Project Level Objectives

The purpose of this Sustainability Management Plan (SMP) is to embed project level sustainability
objectives, commitments and targets into the Project delivery management systems. The key objective of
the SMP is to ensure the effective implementation of the Project Sustainability Strategy during the design
and construction of the Sindalah Island Project. Project specific sustainability objectives are provided in
Table 1.

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Table 1: Project sustainability objectives

Requirement Objectives Targets

Resource Efficiency

Non-polluting Materials To ensure the use of healthy/ low VOC No asbestos containing materials; 80% low
and toxicity materials. VOC/or bio- degradable coatings/other treatments

Low ConstructionWaste To minimize the impact of construction <6.5 tonnes/100m2 GIA;

waste that is generated 75% diversion inert waste and 95% diversion non-
Hazardous waste from landfill by weight.
Regional Materials To reduce the embodied carbon associated Transport distance travelled by materials is not
with the transportation of materials and to greater than 1000 km.
help stimulate the KSA economy

Responsible sourcing To avoid negative ecological and social 100% of construction materials shall be procured
Construction Materials impacts through ethical sourcing materials from the Government approved and licensed
sources.
Nature

Construction Environmental Social To ensure that the environment is Comply with ESIA requirements
Management plan protected during construction

Minimize plastic use To reduce use of plastic in general and 3% reduction of overall disposable plastic
remove as far as possible any unnecessary materials during the construction period –
single use plastics. monitored quarterly.
Ecologically Sensitive Lighting To minimize impact of light pollution on Comply with ESIA requirements
ecology - turtle nesting is a particular risk
for instant

Change and enhancement of To enhance ecological value wherever

biodiversity possible for the project through the
creation and management of habitats and
ecological features.

Health and Wellbeing

Smoking Ban To discourage smoking and protect non- 100% implementation smoking ban at work
smokers from environmental tobacco spaces/non-smoking areas. Smoking to be allowed
smoke in outdoor environments only at specific locations.

Economy

KSA National Priority To support KSA's economy and provide Report monthly, the % of workforce that are KSA
local jobs. Connected to Vision 2030 Nationals
Staff Experience

Work & Labor Condition To ensure that a high standard of work and Compliance with IFC Performance Standard 2
labor conditions is provided throughout Labor.
the Project.
HSE & Welfare Training To ensure a high standard of health and Implementation of training/awareness as per the
safety Contractors training plan and Construction
Environmental Management Plan.

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4. ROLES & RESPONSIBITIES

NEOM will be responsible for the Project’s overall sustainability management, and will manage the Contractors in
accordance with the requirements of NEOM sustainability management policy and framework.
The Main Contractor for Project construction is Nesma & Partners. The Contractor is responsible for managing
sustainability aspects of its works and activities, including sub-contractors (if any) workingunder its management and
supervision.
Roles and responsibilities of NEOM Sindalah Island Project Organization and the Contractor are givenin Table 2.

Role Name and Contact Details Responsibilities

Sustainability management duties will be divided between the
CEM, PM & CM of the project to make sure that during the
project the SMP will be fully followed and Sustainable
protocols to be implemented. The duties include:
• Formulate a sustainability strategy for the Project in the
form of a Sustainability Management Plan in line with
relevant SIPs requirements.
• Identify the persons with responsibility for
implementation of the SMP within Contractor’s team,
monitor, and audit and provide training as and when
Sustainability Management CEM required to ensure smooth and efficient process.
PM • Compilation and submission of corresponding body of
CM evidence against each relevant requirement to NSO at
relevant project stages.
• Meeting minutes from the introductory project
meeting and all subsequent IDP workshops/sustainability
management
• Ensure that applicable SIPs performance requirements are
incorporated in relevant designs and also include in
relevant contractor procurement and construction
documentation.
• Provide regular, monthly, Sustainability Management
Progress reports, Carbon Accounting, Material
Tracking and othercompliance technical notes, generally
as per SIPs requirements and NEOM
• Sustainability Office advice.

• Detail proposed roles and responsibilities of any

Sustainability Management • Supervisors assigned support staff to the Sustainability Management.
support staff • Lead Engineers • Provide relevant organogram, if necessary, to illustrate
proposed structure.
The role and responsibilities of the Contractor during the
design (if applicable) and construction stage of the Project in
relation to Sustainability is inclusive of, but not limited to,
Contractor Nesma & Partners the following:
• Provide necessary support to the projectSustainability
team.
• Review Sustainability Management Plan requirements
and ensure their timely incorporation in relevant design (if
applicable), procurement and construction documentation.
• Attend Integrated Design Process workshops.
• Allocate resources and put in a robust set of
procedures for the aspects of the Sustainability
Management plan requiring early/immediate attention,
such as SIPs compliant materials procurement,
early commissioning activities, carbon accounting and
reporting, appointment of specialists.
• Provide an advice on constructability, materials
alternatives (if necessary) and systems commission-ability
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in relation to Sustainability Management Plan
requirements, in a timely manner.
• Identify Sustainability Management Plan implementation
risks and opportunities and communicate to Sustainability
team and Neom Sustainability Office.
• Provide regular reports in line with Sustainability
Management Plan requirements.

The role of Neom Project Manager (PM) for this Project is

Neom Development Project inclusive of, but not limited to the following:
Management (PM) • Oversee, check and review the performance of
Sustainability team, Contractor and their Sub-contractors
against the targets set within the Sustainability
Management Plan.
• Report any non-compliance and/or lack of progress to
Neom Sustainability Office, upon the occurrence of the
non- compliance.
• Facilitate the flow of information to and from the
Sustainability team/Contractor.
• Monitor Project sustainability program deliverables.
The role of the Neom Sustainability Office is inclusive of, but
not limited to, the following:
Neom Sustainability Office • Assign targets to the Project(s)
(NSO) • Review and agree deliverables with the nominated
Sustainability team and wider Project Team. Oversee,
audit, and guide the Sustainability team and Contractor
to ensure coordinated and timely implementation of the
Sustainability Management Plan.

5. PROCEDURE

5.1 Communication

Internal and external interfaces need to be properly managed to ensure effective implementation of the SMP
and proper management of construction activities. Internal interfaces are those between NEOM, the
Contractor and sub-contractors; while external interfaces consist of those between NEOM Contractor and
the authorities/ stakeholders.
5.1.1 Internal Communication

The Contractor’s Sustainability team will be responsible for the planning and implementation of internal
communication concerning sustainability issues across the Project. Internal communications on
sustainability issues for the Project will be primarily aimed at achieving the following:
• Promoting sustainability awareness;
• Informing employees and sub-contractors about Project sustainability standards and
requirements;
• Informing employees and sub-contractors about sustainability risks;
• Communicating sustainability performance with NEOM; and
• Soliciting feedback on sustainability issues from NEOM.

5.1.2 External Communication

External communications during the construction phase are primarily designed to keep key external
stakeholders apprised of Project environmental and social performance and current environmental or social
initiatives. External communication will include:
• Reporting Project environment/sustainability performance, if required by authorities;
• Informing authorities of any occurrences of environmental non-compliance and the
corrective actions implemented to prevent any recurrence; and
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• Informing local communities of any key upcoming construction activities.
No environment/ sustainability related information will be sent to an authority or lenders without prior
Consent of NEOM.

5.2 Sustainability Meetings

The Contractor’s sustainability team will meet regularly to discuss any issues with the implementation of
sustainability activities or environmental management on-site, any amendments to plans that might be
required or any new / changes to construction activities.

Monthly meetings will be scheduled with NEOM. The purpose of these meetings would be to
communicate ongoing sustainability performance and to identify any issues to be addressed. In
addition, sustainability team members will participate in toolbox talks on at least bi-weekly basis. This
forum will provide an opportunity for the sustainability team members to communicate on
performance against the SMP, to advice on any upcoming sensitive sustainability matters for future
work areas and to receive feedback from on-site personnel.

5.3 Data and Document Control

The Contractor will implement a document control procedure to control the flow of documents within
and between NEOM and subcontractors as per the procedures set in the Contractor's Quality
Management System (ISO 9001). The procedure will also ensure that documentation is:

• Developed, reviewed and approved prior to issue

• Issued for use
• Controlled and stored for the legally required timeframe
• Removed from use when superseded or obsolete
• Archived.
The Sustainability management is responsible for maintaining all documents and records relevant to the
SMP. A register and distribution list will identify the current revision of particular documents, records or
data. Only the construction Sustainability team has the authority to change any of the documentation related
to sustainability issues.
5.4 Reporting and Deliverables

5.4.1 Reporting Framework and Deliverables

The Sustainability management will coordinate the preparation, review and distribution, as appropriate, of
the sustainability documents and records listed below.
• Carbon Accounting Tracker (CAT),
• SIPs Materials Master Tracker (SMMT),
• SIPs Compliance Materials Sheet (SCMS),
• Construction Environmental Management Plan (CEMP)
• Construction Waste Management Plan (CWMP)
• All monitoring, auditing and progress reports/records
• Induction and training records
• Correspondence with NEOM
• Minutes of sustainability review meetings and evidence of any action taken

All documentary evidence will be provided in project specific templates or format agreed withNEOM.

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5.5 Performance Assurance

5.5.1 Performance monitoring

Monitoring the detailed design and construction of Sindalah Island Project will be carried out to
evaluate the sustainability performance ensuring that’s sustainability objectives and targets are being
met and records are accurate and documented.

5.5.2 Sustainability Audits and Inspections

Sustainability audits will be conducted to ensure the effectiveness of the Sustainability Management
processes and systems in regards to the detailed design and construction of Sindalah Island.
Sustainability audits will cover environmental, social and economic issues and priority will be given to
matters that are material to the sustainability requirements and impacts of the Project. Internal
sustainability audits of the system will be conducted at least annually by the Sustainability team (or
delegate). External audits will be conducted at least annually or at specific milestones by NEOM or a
suitably qualified auditor who is not part of the project team. Specific audit plan/methodology including
elements that will need to be checked and verified will be developed as the design / construction is
brought forward. An indicative schedule for sustainability auditing is given in Table 5.

Table 2: Schedule for Sustainability Auditing

Audit No Scope Planned Frequency Auditor Auditee

Audit Dates

1 Construction Stage 25% completion TBD 1 NESMA NESMA

2 Construction Stage 50% completion TBD 1 NESMA NESMA

3 Construction Stage 75% completion TBD 1 NESMA NESMA

4 Construction Stage 100% completion TBD 1 NESMA NESMA

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6. Risk Management

Sustainability risks and opportunities will be integrated with the Project Risk Management. The
Contractor will monitor and review risks and opportunities on monthly basis (monthly
workshops/sustainability management meetings) and at key stages of the project. Key stages of the
project include significant changes to the proposed design, construction methodology, or any other
aspect that would cause a change to the risk profile.

Risks, treatment measures and responsibilities will be recorded in the Risk Register. The Sustainability
management will be involved in the risk and opportunity process, by attending the risk review
meetings/workshops. Risk and opportunity workshop will be held during the detailed design and
construction phases. The workshops will be used to:

i. Identify risks and opportunities;

ii. Rate the risk in terms of likelihood and consequences;
iii. Develop and agree measures to eliminate or control the risk, or capitalize
on theopportunity;
iv. Confirm that the residual risk (after application of measures) is acceptable;
v. Assign the appropriate risk or opportunity owner; and
vi. Document all of the above in a risk register.
The Sustainability team is responsible for taking the agreed actions to mitigate or eliminate the risk, or
capitalize on the opportunity related to sustainability issues. The Sustainability team will provide
feedback to the Project Manager/Risk Manager, who will update the risk register accordingly.

7. TRAINING & AWARNESS PLAN

All personnel (including sub-contractors) are required to attend a compulsory site induction that includes a
sustainability component prior to commencement on-site. This is done to ensure all personnel involved in
the Project are aware of the requirements of the SMP and to ensure the implementation of sustainability
strategy.
The Sustainability team will conduct the sustainability component of the site inductions. The sustainability
component will include, but not be limited to, an overview of the following points as relevant to each
induction group.

7.1 Project Environmental and Sustainability Policy

i. The Project’s sustainability commitments, targets and requirements
ii. Relevant details of the Sustainability Plan including purpose and objectives
iii. Key sustainability issues
iv. Relevant sustainability monitoring, reporting and documentation requirements

A record of all inductions will be maintained and kept on-site. The Sustainability management may
authorize amendments to the induction at any time. Possible reasons for changes to the induction may be
Project modifications, amendments to this SMP or related documentation

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