Subway Systems Australia Pty. Ltd. Australian Packaging Covenant (APC) Action Plan th February 2012

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1 Subway Systems Australia Pty. Ltd. Australian Packaging Covenant (APC) Action Plan th February 2012 Subway Systems Australia Level 1, 42 Amelia St Fortitude Valley QLD 4006 T F ssa@subway.com 1

2 Executive Summary Director s Note "Eat Fresh, Live Green" is our way of letting you know we are committed to making a positive impact in all that we do. The SUBWAY team is committed to providing a variety of great tasting, healthier food choices while reducing our environmental footprint and creating a positive influence in the communities we serve around the world. Where feasible, we plan to: Reduce or eliminate unnecessary packaging; Reduce the amount of source material; Shift to more sustainable substrates; Increase recycled content, recyclability, degradability and compostability; Optimize case configurations to improve logistical efficiencies; and Reduce landfill waste stream. This plan outlines our commitment to the APC and the specific actions we plan to undertake which will address Covenant Goals and KPI s. Brian Tap Regional Director, Subway Systems Australia Subway Systems Australia Subway Systems Australia (SSA) is the Franchisor of the Subway System in Australia. Subway Systems Australia does not currently run any other brands. SSA operates as Brand Owner as defined by the APC supply chain requirements. Covenant Contact Officer For any inquiries on the Australian Packaging Covenant Plan for Subway Systems Australia Pty. Ltd. please contact: Ben Miles, Regional Marketing and Profitability Manager, Subway Systems Australia Pty. Ltd. Ph miles_b@subway.com PO Box 313 Fortitude Valley QLD 4006 Subway Systems Australia Pty. Ltd. - APC Action Plan 2

3 Our Commitment Our vision is to make Subway Restaurants and their operations as environmentally and socially responsible as possible. We strive to conduct business in a way that has a positive impact on the environment while improving the lives of our customers, franchisees, employees, vendors and communities worldwide. We believe that using good, environmentally sound business practices help increase our franchisees' profitability, improve our customers dining experience as well as help protect the planet. We are committed to: Continuing to evolve our menu of great tasting, healthier options as well as providing access to nutrition and healthier lifestyle information; Striving to ensure our food meets the highest quality and safety standards; Find sustainable and cost effective solutions that serve the business needs of our franchisees; Focusing our sustainability initiatives on energy efficiency, water & resource conservation, waste reduction, sustainable sourcing and supply chain management; and Encouraging our franchisees to contribute to their communities, promote diversity and consider environmentally friendly options and business practices such as building Eco-Restaurants. As a nutritional leader, the SUBWAY brand is committed to offering a full range of great tasting options for our customers around the world. Nutrition information is available on-line and in our restaurants so customers can make better informed meal choices. We are working continually to improve our menus and the nutritional benefit of our food, such as working closely with industry bodies such as The Australian World Action on Salt and Health (AWASH) to continually review the amount of sodium in our products and reduce/ remove as much salt as possible. Working with our franchisee owned Independent Purchasing Companies and Cooperatives (IPCA) around the world, the SUBWAY brand is committed to pursuing sustainable initiatives that focus on energy efficiency, water and resource conservation, waste reduction, sustainable and ethical sourcing and supply chain management. We fully support principles of responsible farming, fishing and animal husbandry for the long term sustainability of the earth's natural resources. Subway Systems Australia Pty. Ltd. - APC Action Plan 3

4 As a global brand, we continue to make strides in sustainable packaging, cleaning products and waste management as well as to look for more efficient equipment and operational practices. Thanks to the work of SUBWAY franchisees and the IPCA, many eco-friendly solutions have become part of our standard specifications and every day we work on more. All SUBWAY restaurants are individually owned and operated by independent franchisees. Many SUBWAY franchisees pride themselves on being active, caring members of their communities and encouraging diversity. Also, many choose environmentally friendly options and business practices such as building Eco-Restaurants that, among other things, conserve electricity and water and reduce waste through recycling and/or composting where facilities exist. Currently we have 14 Eco-Restaurants open and operating worldwide, and more are being considered both here in Australia and around the globe. We are proud of what we have accomplished so far, but we know there is more to do. Together we can make a difference. Subway Systems Australia Pty. Ltd. - APC Action Plan 4

5 The History Of the Subway Brand The Seventeen-Year-Old Entrepreneur Back in 1965, Fred DeLuca set out to fulfill his dream of becoming a medical doctor. Searching for a way to help pay for his education, a family friend suggested he open a submarine sandwich shop. With a loan of $1,000, the friend Dr. Peter Buck offered to become Fred s partner, and a business relationship was forged that would change the landscape of the fast food industry. The first store was opened in Bridgeport, Connecticut in August, Then, they set a goal of having 32 stores opened in 10 years. Fred soon learned the basics of running a business, as well as the importance of serving a well-made, high quality product, providing excellent customer service, keeping operating costs low and finding great locations. These early lessons continue to serve as the foundation for successful Subway Restaurants around the world. The SUBWAY Franchise By 1974, the duo owned and operated 16 submarine sandwich shops throughout Connecticut. Realizing they would not reach their 32 store goal in time, they began franchising, launching the SUBWAY brand into a period of remarkable growth which continues to this day. Subway Systems Australia Pty. Ltd. - APC Action Plan 5

6 A Fresh Future Today, the SUBWAY brand is the world's largest submarine sandwich chain with more than 36,000 locations around the world. We ve become the leading choice for people seeking quick, nutritious meals that the whole family can enjoy. From the beginning, Fred has had a clear vision for the future of the SUBWAY brand. As we continue to grow, we are guided by his passion for delighting customers by serving freshly prepared, delicious, made-toorder sandwiches. Subway Restaurants in Australia The first Australian Subway Restaurant opened in Perth in 1988, today there are over 1,300 Stores across Australia. All Subway Restaurants in Australia are franchisee owned and operated, and the AUS/NZ Region is the most developed Subway Restaurant market outside of North America. Subway Restaurants Australian Headquarters are in Brisbane, Queensland. The Brisbane Regional Office oversees all operations for Australia and New Zealand. Subway Restaurant located in Norwood, South Australia Our Vision Be the #1 Quick Service Restaurant chain in the world Our Mission Delight every customer so they want to tell their friends, with great value through fresh, delicious, made-to-order sandwiches, and an exceptional experience. Subway Systems Australia Pty. Ltd. - APC Action Plan 6

7 SUBWAY Packaging Items Category Paper wrap Plastic Bags Paper Bags Cups and Lids Hard plastic container Utensils Marketing Material Product Materials Deli Paper 100% Virgin Paper Napkin Paper - 100% recycled content Prep Tray Polyethylene lined SBS paper Sub Wraps Paper % recycled content Can Liners Polyethylene Blend Catering Tray Bag Polyethylene Blend Poly Sub Bag High Density Polyethylene (HDPE) blend T-Shirt Bag High Density Polyethylene (HDPE) blend Paper Sub Bags Paper - 40% recycled content Paper T-Shirt Bags Paper - 40% recycled content Specialty Bag Paper - 50% recycled content Specialty Pouch Paper - 50% recycled content Cold Cup - Sm/Lg - Lid High Impact Polystyrene (HIPS) Cold Cup - Small Polyethylene lined SBS paper Cold Cup - Medium Polyethylene lined SBS paper Cold Cup - Large Polypropylene (PP) Cold Cup - Large - Lid High Impact Polystyrene (HIPS) Hot Cup - Small Polyethylene lined SBS paper - 12% recycled content Hot Cup - Large Polyethylene lined SBS paper - 12% recycled content Hot Cup - Lid High Impact Polystyrene (HIPS) Portion Cup High Impact Polystyrene (HIPS) Portion Cup Lid High Impact Polystyrene (HIPS) Catering Tray Polystyrene (PS) Catering Tray Lid Polyethylene Terephthalate (PET) Salad Bowls Polyethylene Terephthalate (PET) - 25% Post Consumer Resin Salad Bowl Lids Polyethylene Terephthalate (PET) - 25% Post Consumer Resin Knife & Fork Kit Polypropylene (PP) Spoon Polypropylene (PP) Straws Polypropylene (PP) Promotional Translite Polypropylene Window Cling PVC + PE coated triplan white cardboard backing Floor Stand Paper (Hi bulk artboard) - FSC certified Instruction Sheet Paper - FSC certified Sandwich Unit Cling Synthetic resin or plastic consisting of polyvinyl chloride or polymer 4-Cup Carrier SUS Paperboard Giant Sub Carriers Corrugated Initial Review Date* Q Q Q Q Q Q Q * Please Note: The review date of each product category states when a review is expected to commence. This review period may take up to 6 Months before completion. Decisions * Please The review of date of each productitem category a review is expected to commence. review periodmay may be take up to 6 Months before on thenote: future direction each packaging will bestates madewhen during this time but implementation of This desired changes completed at a later datecompletion. due to the Decisions business on the future direction ofand eachavailability packagingof item willproduct. be madedecisions during thismade time but implementation of desired changes be completed at APC a laterplans. date due to the business requirements and availability requirements each as a result of the review will be statedmay in future submitted of each product. Decisions made as a result of the review will be stated in future submitted APC plans. 7

8 8 1. Design - Optimise packaging to achieve resource efficiency and reduce environmental impact Performance Goals and KPI s Actions Responsibility Baseline Data Target Milestones Review the SPG to understand Global Corporate Social Responsibility Team Compare SPG guidelines to our Incorporate all relevant aspects of SPG Q requirements for assessment of current current 2015 Strategic Plan for into our current 2015 Strategic Plan practices Corporate Social Responsibility and assess differences KPI 1: Implement the Sustainable Packaging Guidelines (SPG) for design or procurement of packaging. Education of all stakeholders on the SPG to give relevant persons ability to assess packaging requirements that meet the SPG standard Develop an assessment process to determine SPG opportunities for future product development Review existing packaging range in line with dates set out in assessment schedule ( Subway Packaging Items Table, p7 ) Key Stakeholders Global Corporate Social Responsibility Team Corporate sustainable packaging guidelines Review not yet conducted Educate all relevant stakeholders on the importance of the SPG, and how we can use the guidelines within our current structure Global Corporate Social Responsibility Team Review of existing product material as outlined in Subway Packaging Items Table, p7 of this document To have assessment process in place, with new packaging to be reviewed inline with SPG where possible Understand how SPG could be implemented for these products and look to review for opportunities where appropriate Please refer to timeline outlined in Subway Packaging Items Table, p7.

9 9 2. Recycling - The efficient collection and recycling of packaging Performance Goals and KPI s Actions Responsibility Baseline Data Target Milestones Global Corporate Social Responsibility Team Various recycling and composting currently in place in other countries in which the Subway Brand operates Working with the global team, review existing in-store Subway recycling programs from around the world to determine feasibility and appropriateness for Australian implementation Investigation and testing of in-store recycling program to determine potential for rolling out to all Australian locations Q Work with Franchisees to determine Country Corporate Social Responsibility Team, large scale industrial bin recycling Operations, Franchisees opportunities on-site where they do not currently exist with landlord Currently Franchisees in Shopping Centre & Shopping VIllage locations have access to industrial garbage and recycling bins Investigation within locations where a separation of waste and recycling does not occur, and work with the Franchisee/Landlord to investigate opportunities for improvement Q KPI 3: On-site recovery systems for recycling used packaging Assist Franchisees in determining paperwork recycling guidelines for instore business management where the Restaurant has office facilities on-site (i.e. Paper, Print Cartridges, Stationery, etc.) Operations Team, Franchisees Current global recycling policy and practices Review global policy and adjust as necessary for Australian Region. Development of communication plan to Franchisees Explore feasibility of a recyclable corrugate program with a key suppliers. The exploration will investigate opportunities for a supply chain recycling program as a part of delivery schedule Subway Independent Purchasing Company of Australia Best Practice examples from global operations Investigation of opportunity for recycling collection program with our distribution suppliers Q KPI 4: Policy to buy products made from recycled packaging Review existing policy that shows a Country Corporate Social Responsibility Team commitment to increase the recycled content, recyclability, degradability and compostability where feasible, and look to expand/incorporate further aspects of APC suggestions to meet the policy standard. Current Global Policy in place. Current packaging items with recycled content include: Napkins 100% recycled content Subwrap 30-40% recycled content Specialty bag & pouch 50% recycled content Salad bowls & lids 25% recycled content Review and prioritise feasibility exploration of potential opportunities to increase the amount of recycled content without negatively impacting functionality or cost, Ongoing

10 3. Product Stewardship - Demonstrated commitment to product stewardship Performance Goals and KPI s Actions Responsibility Baseline Data Target Milestones Identify opportunities with suppliers to reduce source material from packaging products as well as inner packaging and master carton packaging for all food, product, equipment and small wares Subway Independent Purchasing Company of Australia Exploration of opportunities already underway. Reduce source material from packaging products where possible, keeping goals in line with supplier capabilities, packaging quality, functionality and cost structure. Q4 2013, Ongoing 10 Identify opportunities with suppliers to optimise pallet case configurations KPI 6: Formal processes for (inner packaging and master carton working with others to improve packaging) to reduce the number of design and recycling of packaging pallets & cartons used, and to reduce the environmental impact of the transport network. This applies to all Food, product, equipment and small wares Subway Independent Purchasing Company of Australia Current pallet case configuration Investigation of opportunity to optimise the master carton & case configurations for top 5 key products Q3 2013, Ongoing Work with suppliers to identify new recycling opportunities from their end of the supply chain, both in-store and before stock gets to our Distribution Centres Subway Independent Purchasing Company of Australia No baseline data Identifiable opportunities determined for optimising case pack size and materials used (including more sustainable substrates) to improve sustainability without affecting functionality or cost Q2 2014, Ongoing Monitor cost effective technological advances to improve degradability and compostability without impacting functionality or cost structure Global Corporate Social Responsibility Team No baseline data Ongoing research and assessment of future opportunities, with a scheduled review every 12 months Ongoing, Annual Review Update training classes, for both new Franchisees/Franchisee workers and existing stakeholders, that update franchisees on the actions taken and Best Practices for sustainable Global Corporate Social Responsibility Team Current Operations Manual guidelines Integrate relevant training topics into on suggested recycling tips for in-store Franchisee Training Course and our operations ongoing University of Subway Resource for store & company staff Q Work to improve the energy efficiency of our restaurants, including investigating more efficient lighting, electronic signage, product preparation equipment, refrigeration, etc. Subway Independent Purchasing Company of Australia Trial of energy efficient globes, efficient signage, efficient in-store equipment, etc. in trial in various locations throughout the world Assessment of current trials underway globally and review for Australian appropriateness, expand/modify as necessary Q1 2013, Ongoing KPI 7: Demonstration of other stewardship outcomes Further our advances in water conservation through extending lowflow taps, motion sensing hand sinks and dual flush toilets in all restaurants, as well as reducing the amount of water/brine used in product preservation where possible. Country Corporate Social Responsibility Team, Operations Team Low-flow taps, motion sensing hand sinks, dual flush toilets in trial across Australia and further water saving initiatives being trialled globally. Some current food products investigated for a reduction in preserving brine/water Initiate a water conservation communication plan to extend the trial work already underway. Aim to review all relevant products for a reduction in preserving brine/water. Encourage combined equipment orders for new locations and remodels Operations Team, Subway Independent Purchasing Company of Australia Current equipment ordering process Working with suppliers and the Subway Independent Purchasing Company of Australia, formulate a plan for how we can combine equipment orders for our projected store numbers per year Q Globally, further our work in investigating ECO-Restaurants which are designed to conserve resources during the development process and set the stage for efficient operations in the future. Global Corporate Social Responsibility Team 14 Eco-Restaurants currently operational around the globe Learn from Eco-Friendly trial restaurants in order to capitalise on chain-wide opportunities for further implementation of specific projects Annual Review Encourage, and investigate strategies for, reduced bag usage by customers where not needed Extend our global investigation of the KPI 8: Reduction of the number of use and availability of reusable bags for customers packaging items in litter Operations Team Operations Team Trial of paper bags in two Australian Understand learnings from paper bag States, as per local legislation, where a trial, investigate and trial further reduction in bag usage has occurred. options for reducing bag usage with Trial of alternative operational the end goal being to have a bag procedures that eliminate the need for reduction strategy for all stores a bag for sandwich only purchases in Subway Restaurants in other countries Reusable bags trialled in Subway Restaurants in other countries Understand trial data of reusable bags. Initiate trial of bags for Australia and gauge customer and Franchisee feedback for future implementation opportunity Review operational procedures where feasible to incorporate recycling Operations Team opportunities as a part of sandwich preparation, that eliminate the need for packaging prior to it entering the litter cycle Elimination opportunities already under trial to remove packaging from the operational process Removal of unnecessary packaging where possible and determine plan & time frame for future regular reviews Ongoing throughout

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