How about you start with a declaration of core values: The business accepts its responsibilities for H&S matters under its controls, it works with its employees to promote health and safety etc.

You can also say that as a minimum it expects all of its divisions to comply with local laws. You can mention regulations that apply across the whole of the EU or EEA.

Finally you can make it clear that the local H&S people should create there own policies which embody these core values etc.

We have a H&S policy (one-pager) that works in all our jurisdictions (UK, middle East, Asia).  You should be able to make a policy statement that works for all with only a little careful wording – it’s not going to be your policy in any place to disregard the law and worker safety, I’d have thought.

We are principally UK-based (UK staff is about two-thirds of the total).  We write our procedures for the UK but mindful of the non-UK locations, so for example our procedures refer to PPE being compliant to appropriate standards rather than saying 'BS xyz' and another tier of documents lists out what the 'appropriate standards' are.  You have to have different PPE standards - our people on site in UAE have no need of hi-vis winter coats.

In general, the UK is more onerous and more specific than the other statutory regimes we operate in.  We generally therefore apply UK standards everywhere - things like (for example) only the UK has DSE regs, but our procedures mandate workstation assessment and eye tests and staff do those everywhere. Covid has been a bit different - one of our offices for example is in a place where it is now mandatory to have a weekly Covid test, which needs paying for, and the company is funding those.  Therefore, I can’t honestly say we adopt whatever is most onerous among all the jurisdictions we work in – it is mostly the case of we use UK practice or local practice, whichever is highest, but don’t always carry those higher standards back to the UK.

Some places have laws or practices that just don't makes sense elsewhere – for example some of the hotter climes have mandatory non-working periods at the hottest part of the day for part of the year.  Where it's law it's straightforward - you can put a catchall in procedures that says 'don't break the law where you are'.  Where it's customary practice it's a bit more difficult sometimes, but we then have local documents.

worked in a number at a global level in the past...it depends where the appetite for the change is coming from...I was lucky straight from the board...

You have to adopt a hierarchy in the first instance...global, regional, site etc

Divide the existing up in this way then...start with individual site documentation (the good bits) and see what can become regional documentation, look to where you have best practice or stricktest regulatory regime and see how easy it is to make them Global docs... etc etc..the objective is to eventually get everyone to a level that is generally above the minimum legislative requirements...for instance there was no real vehicle maint standard in Asia so we adopted the European/UK standards there...in general all of the standards were driven primarily from US/Europe...

If a site/region say they can't do that because of legislation... so long as your standard is better than the legislation and encorporate all the bits then you are good...takes some time but it works...if you need anything more then please let me know...it can work out to be utopia but you need to couple this with a good behavioural program roll out...maybe not at the same start but eventually running concurrently...bit of food for thought...enjoy :)