Sustainability & Environmental Responsibility Policy

1. Purpose and intent

Integrates environmental stewardship, resource efficiency and social responsibility into long-term thinking. This policy is intended to provide a consistent reference for decisions, conduct and controls. It should be read alongside applicable laws, contractual obligations and relevant internal procedures. Where requirements differ, the applicable legal requirement and formally approved internal control take precedence.

2. Scope and application

Applies to strategic planning, operational decisions, procurement, resource use and relevant business relationships.

Business partners are expected to observe equivalent standards where these are relevant to the services they provide or the activities they undertake on the organisation’s behalf. Application should be proportionate to role, activity, risk and applicable legal requirements.

3. Core principles

• Prevention: avoid or reduce pollution and environmental harm at source.
• Efficiency: use energy, water, materials and other resources responsibly.
• Circularity: consider waste prevention, reuse, recovery and responsible disposal where relevant.
• Climate awareness: consider material climate-related risks and opportunities.
• People and communities: respect human dignity and consider social impacts.
• Evidence: communicate sustainability performance accurately and avoid unsupported claims.

4. Minimum standards and controls

The following controls describe the expected minimum approach. Specific procedures, approval limits, forms and technical controls may be established separately and updated through controlled internal documents.

• Identify material environmental aspects and impacts associated with relevant activities.
• Set practical objectives for resource efficiency and environmental improvement where appropriate.
• Promote waste prevention, segregation and responsible handling.
• Consider environmental and social criteria in relevant procurement decisions.
• Provide awareness and training proportionate to roles and activities.
• Monitor performance and report material issues accurately.

5. Roles and accountability

Leadership sets direction and priorities. Operational owners are responsible for controls within their areas. Personnel and relevant partners are expected to follow environmental requirements and report incidents.

Any person who is uncertain about the application of this policy should seek guidance before taking action. No individual may override a legal obligation or approved control without appropriate authority and documented justification.

6. Reporting and escalation

Concerns, suspected breaches, control weaknesses and incidents should be raised promptly through the relevant management or designated reporting channel. Urgent threats to health, safety, the environment or the security of information must be escalated immediately. Reports should be handled fairly, sensitively and in accordance with applicable privacy and records requirements.

7. Monitoring, assurance and review

Progress should be evaluated through relevant consumption, waste, incident, compliance and improvement data. Public statements must be supported by evidence and reviewed before publication.

Where improvement actions are identified, they should be assigned to an accountable owner, given a proportionate target date and monitored to closure. Material changes in law, risk, organisational context or operating arrangements should trigger an earlier review.

8. Non-compliance

Failure to follow applicable requirements may result in corrective action, additional training, restricted authority, disciplinary measures, contractual remedies or referral to relevant authorities, depending on the circumstances and applicable law. Any response should be proportionate and follow fair process.

9. Related policies and standards

QHSE; Responsible Procurement; Risk Management; Quality Improvement.

Additional policy requirements

The following provisions expand the practical expectations set out in this policy. They should be applied in conjunction with applicable law, approved internal procedures, contractual obligations and the circumstances of each activity.

Material impacts

Environmental and sustainability considerations should be integrated into relevant planning and decisions. Assessments should consider material impacts, dependencies, resource use, pollution risks, climate-related exposure and applicable stakeholder expectations.

Resource efficiency

Where practicable, activities should seek to reduce unnecessary energy, water and material consumption, improve efficiency, extend useful asset life and prevent avoidable waste. Improvement priorities should be based on relevance, feasibility and measurable impact.

Waste and circularity

Waste prevention should be prioritised, followed by reuse, recovery and recycling where safe, lawful and technically appropriate. Waste must be classified and managed in accordance with applicable requirements. Claims about recovery or recycling should be supported by reliable evidence.

Climate and resilience

Relevant climate-related physical and transition risks should be considered in strategic and operational planning. Resilience measures may include continuity arrangements, resource efficiency, supplier diversification and adaptation of assets or processes.

Measurement and claims

Where environmental performance is reported, boundaries, methods, assumptions and limitations should be explained. No environmental claim should be misleading, exaggerated or presented as independently verified unless that verification exists.

Continuous improvement

Objectives and actions should be proportionate to material impacts and available evidence. Progress, incidents, regulatory developments and stakeholder feedback should inform periodic review.

10. Document governance

This web page is a public policy statement. The controlled internal version, where formally approved, is maintained through the organisation’s document-control process. Approval status, document owner, effective date, review cycle and revision history must be confirmed in the controlled document register before this text is represented as a formally issued internal policy.