Mouchel. Environmental Policy and Management Plan

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1 Environmental Policy and Management Plan

2 Environmental Policy and Management Plan Contents Part 1 - Statement of Policy Part 2 - Organisation Part 3 - Management Plan Environmental Policy and Management Plan

3 Environmental Policy and Management Plan Part 1 Statement of Policy Environmental Policy and Management Plan 1

4 Environmental Policy Statement works with clients to deliver projects and provide better everyday services to people and communities. Our services deliver many environmental benefits and improvements; however, we recognise that there is also a cost to the environment in the delivery of our services. We are committed to conducting our business in an environmentally responsible and sustainable manner. We will comply with all relevant environmental legislation and other requirements, and where practicable, minimise any adverse environmental impacts that may result from our operations. In implementing our policy, we aim to: Take into account the direct environmental impacts of our operations, including those of our offices, staff travel, and the procurement of materials and services; Work with our clients and the supply chain to identify and mitigate the environmental impacts associated with the projects and services we deliver; Prevent pollution from delivery of our services and projects; Monitor, measure and communicate (both internally and externally) the environmental performance of our activities in order to drive continual improvement in areas of significant risk and opportunity; Provide a culture of environmental awareness for our staff through training and communication. As part of our commitment we have set objectives and targets, which will be reviewed annually as an integral part of our business planning and strategy development. We believe that through the implementation of this policy and our management systems we are able to meet our commitments, and in addition look beyond simple compliance towards best practice. Grant Rumbles Chief Executive Officer September 2013 Environmental Policy and Management Plan 2

5 Environmental Management Plan Part 2 Organisation & Responsibilities Environmental Policy and Management Plan 3

6 Environment Organisation Structure Director Responsible for SHEQ Chief Executive Notes This chart demonstrates SHE team and management reporting and communication lines. Head of SHEQ Operating Group Directors Compliance & Systems Manager Safety. Health & Environmental Manager SHE Business Partners Managers Compliance & Systems Advisors Safety, Health & Environmental Advisors Environmental Coordinators Key Reporting line Communication line Environmental Policy and Management Plan 4

7 Responsibilities The Chief Executive The Chief Executive has overall responsibility for environmental standards and the environmental policy in Group and for ensuring so far as is reasonably practicable that the Board of Directors is adequately informed on environmental matters. The Board of Directors The Board is collectively responsible for providing leadership around environmental standards and for ensuring so far as is reasonably practicable that decisions made are consistent with environmental policy. It will satisfy itself that competent resources exist to manage environmental aspects and that adequate resource is made available for environmental policy to be implemented. The Executive Management Team (EMT) The EMT has executive responsibility for environmental matters in the company and for ensuring so far as is reasonably practicable that the Environmental Policy is applied in all areas of the business. Director responsible for SHEQ The Director responsible for SHEQ is responsible for implementation of the Environmental Policy, for liaison with the Board, and for securing the necessary resources to implement the Policy. Head of SHEQ The Head of SHEQ is responsible for developing and implementing Environmental Policy, strategy and objectives for achieving continual improvements; ensuring the adequacy of resources made available for supporting delivery of the environmental management system; providing the systems and procedures for environmental management; for the control and review of the environmental management system including the monitoring and reviewing of compliance with procedures and for ensuring so far as is reasonably practicable the adequacy of the systems, communication and facilities for health and safety in the business. Environmental Policy and Management Plan 5

8 Other Responsibilities A number of other individuals have specific responsibilities in the delivery of the requirements of this policy. These are as given below. Group Safety, Health & Environmental Manager The Group Safety, Health & Environmental Manager is responsible for managing the specialist environmental resources in the business, for providing the systems and procedures for environment, advice on environmental matters, implementing a programme of office inspections and Job Hazard Analyses, and for implementing the company s Group-wide strategy for environment and competency management and training. SHE Business Partners The nominated SHE Business Partner ensures so far as is reasonably practicable the adequacy of environmental communications between the Operating Groups and the Group Safety, Health and Environment team. The SHE Business Partner is responsible for applying and adapting the Groupwide systems and procedures to business steam requirements and for identifying and communicating what advice and other environmental resources are required from Group to the business. Group Safety, Health and Environment Advisors The Group Safety, Health and Environment Advisors are responsible for providing advice, support, inspection and controls relating to environmental issues in the business. In addition, throughout they support the provision of training awareness and a culture of environmental responsibility, and communicate and champion good practice and innovation in the field of environmental and sustainability management. SHEQ Compliance & Systems Manager The Compliance & Systems Manager is responsible for the development and implementation of efficient and effective processes and systems to enable the business to comply with all relevant safety, health, environmental and quality management requirements. This includes the deployment of resources within the Compliance & Systems team to deliver a company-wide audit programme that provides operational management with clear assurances of SHE compliance levels, and appropriate management information to allow continual improvement / lessons learned. Compliance Advisors Compliance Advisors are responsible for delivering an audit programme of processes and systems to ensure the business complies with all relevant health, safety, environmental and quality management requirements. To assist the business in meeting operational requirements by providing specialist advice and support in the development of systems and processes that meet client requirements. Environmental Policy and Management Plan 6

9 Business Stream Managing Directors Business Stream Managing Directors have overall responsibility for environmental matters associated with their Business Stream in. They will, in liaison with their SHE Business Partner(s) and the Group Safety, Health and Environment Team ensure so far as is reasonably practicable that staff in their part of the business have sufficient training, support and resources to adequately discharge their role. Operating Group Directors Operating Group Directors have overall responsibility for environmental matters associated with their Operating Group in. They will, in liaison with their SHE Business Partner and the Group Safety, Health and Environment Team ensure so far as is reasonably practicable that for those staff whom they have direct line management responsibilities for have sufficient training, support and resources to adequately discharge their role. Managers All managers whether employed in an operational or support services capacity are responsible for ensuring so far as is reasonably practicable that the Environmental Policy, and good environmental practices, are applied in areas for which they are responsible and must ensure so far as is reasonably practicable the effective management of environmental risks including those associated with contractors. Their main responsibilities include: Understanding the Environmental Policy. Ensuring that employees directly reporting to them are properly trained, competent and adequately instructed in the environmental arrangements required for their work. Ensuring that work is carried out in accordance with environmental management system procedures Regularly reviewing performance including findings from audit and inspections to ensure corrective actions identified are implemented. Project Managers are responsible for the identification and maintenance of environmental records relating to individual services and projects. Project Environmental Coordinators Environmental Coordinators support local management in the implementation of environmental good practice and assist in communications between the business and the Group Safety, Health and Environment Team. They provide co-ordination and support to teams within their division or business unit; facilitate and support the delivery of local environmental objectives and targets, as applicable; act as a key communicators for environmental issues and are the key interface for the Group Safety, Health and Environment Team. Office Environmental Coordinators Office Environmental Coordinators ensure that environmental issues relating to the office environment are managed and complied with, supporting the office or facilities manager where this role is held by another member of staff. They coordinate and promote environmental campaigns and initiatives, facilitate and support the delivery of local office environmental objectives and targets and report on office-based environmental performance such as the use of energy, water and paper and the production of waste within the office environment. Environmental Policy and Management Plan 7

10 Employees All employees have responsibilities to: Cooperate as required to enable to meet its environmental duties. Follow instruction and guidance from training awareness, briefings and risk assessments and other guidance issued by the local coordinators and the Group Safety, Health and Environment Team. Follow environmental good practice outlined in industry standards and guides, as relevant to the services and activities. Report any shortfalls in environmental arrangements or any environmental incidents or near misses. Environmental Policy and Management Plan 8

11 Environmental Policy and Management Plan Part 3 Management Plan (Arrangements) Environmental Policy and Management Plan 9

12 Environmental Management Plan 1. Scope places a high value on conducting our business in an environmentally responsible and sustainable manner. We commit to complying with all relevant environmental legislation and other requirements, and where practicable, to minimising any adverse environmental impacts that may result from our operations, and to working with our clients and the supply chain to identify and mitigate the environmental impacts associated with the projects and services we deliver. The scope and purpose of this Environmental Management Plan (this Plan) is to support delivery of the Environmental Policy and associated objectives and targets and to describe the key elements of the Environmental Management System (EMS). These environmental arrangements and the Environmental management system apply to all employees and others working under its control and/or affected by its activities, regardless of work location and/or Operating Group. This Plan is supported by procedures and documents which are identified throughout this document. Procedures are implemented to ensure relevant environmental controls and objectives are being achieved. The procedures communicate what activities need to be done, when they must take place, and how they are completed. Local procedures and instructions are developed at an individual contract and project level when existing generic procedures identified here do not fully cover contract requirements and risks. s EMS is externally certified to ISO 14001:2004. Environmental Policy Statement ; displayed on office noticeboards 2. Environmental Policy Review monitors the effectiveness of this Plan, including the Policy Statement. Review of the environmental performance of and the functioning of the Plan is the responsibility of the Director Responsible for SHEQ. This Plan is reviewed at least annually or after any fundamental change in either the environmental management system or in the services and activities of the business. The review identifies changes to be made, and ways in which company environmental performance can be improved. 3. Environmental Aspects The activities carried out and services provided by have been reviewed. The review identified the environmental aspects and impacts of these activities and environmental legislation and other requirements applicable to them. A Register of Aspects and Impacts has been produced from this process and is reviewed at least annually or after any fundamental change in either the environmental management system or the services and activities of the business. Operational control is applied to all activities associated with significant environmental aspects and legal requirements within the scope of the EMS. For individual projects or jobs, any other particular environmental aspects and impacts are identified within project specific documents at the planning stage. P406 Environmental Aspects and Impacts Environmental Policy and Management Plan 10

13 G406-** Register of Aspects and Impacts 4. Legal and other requirements The legal and other requirements relevant to services and activities carried out by the business are identified in the Legal and Other Requirements Register maintained by the Group Safety, Health and Environment Team. These are reviewed regularly in accordance with procedure, and significant changes are communicated and consulted on with the business through the local coordinator networks. For individual projects or jobs, any other particular environmental legal or other requirements are identified within the project specific documents at the planning stage. P405 Environmental Legal and other Requirements G Environmental Legal Register 5. Objectives, targets and programme(s) is committed to continually improving its environmental performance. This is driven by the setting of environmental objectives and targets at Group and Operating Group levels, in line with the SHEQ Excellence Strategy and vision for In setting annual objectives and targets the following are considered: SHEQ Excellence Strategy, 2018 Vision and Commitments; Legal requirements, government strategies and technological options; Significance of the environmental impacts; Views and aspirations of clients and any other interested parties. The Head of SHEQ, the Safety, Health and Environment Manager and the SHE Business Partners establish corporate environmental objectives, as a result of the review, for relevant functions and levels within. The objectives are measurable, timely, ensure legal compliance and meet industry requirements. These objectives will be reviewed at regular and planned intervals. The Head of Assurance, the Safety, Health and Environment Manager and the Group Safety, Health and Environment Team monitor the suitability, effectiveness, implementation and achievement of these objectives. As part of the business planning process, Operating Group Directors and SHE Business Partners establish Operating Group specific environmental objectives for relevant functions and levels within those Operating Groups. Such objectives align to, but are not restricted to, corporate objectives and are measurable (where practicable), timely, ensure legal compliance and meet industry requirements. Operating Group Directors, SHE Business Partners and Managers monitor the suitability, effectiveness, implementation and achievement of these objectives and report these back to Group Safety, Health and Environment at regular and planned intervals for review. P401 Group Environmental Commitments SHEQ Excellence Strategy Operating Group Business plans Held locally Environmental Policy and Management Plan 11

14 6. Environmental Risk and Opportunity Assessment and Management The implementation of a risk and opportunity assessment process enables to identify and manage significant environmental negative impacts, and to realise positive opportunities for improvement, that may arise as a result of activities both inside and outside of the workplace. Managers ensure that they manage all environmental risks in relation to a project or scheme. Responsible Managers have a duty to focus on real risks and to protect both the environment and our business by eliminating those risks. Environmental risk and opportunity assessment and management is carried out in line with P403 Environmental Assessment and Management. The tools provided to support staff in this process allow for the identification of aspects with legal implications, provide information on minimum compliance requirements and encourage the consideration of sustainable design solutions. Throughout the business there are a number of specialist teams with particular expertise and it is incumbent on them to keep abreast of current developments and best practice. All staff are encouraged to consult subject matter experts as and when the need arises. To ensure environmental risks and opportunities are identified, managed and communicated appropriately, Project Managers are responsible for ensuring that risks, constraints and controls associated with the work are reviewed at appropriate intervals or after any significant change. P406 Environmental Aspects and Impacts P403 Environmental Risk Management F Designers Environmental Risk and Opportunity Appraisal 7. controlled offices and premises The Regional Facilities Manager and/or the senior manager with responsibility for the premises and its budgetary control is responsible for ensuring that the office complies with legal and other requirements. This includes reviewing specific controls to ensure compliance requirements are met and approving the controls on a regular basis including after any significant change, incident or significant audit finding. The Regional FM/senior manager is also responsible for ensuring an Office Environmental Coordinator is appointed and, where possible, a deputy is available. The Office Environmental Coordinator at the local office is responsible for ensuring compliance with office environmental requirements through the completion and regular review of the Office Environmental Workbook. Office Environmental Workbooks are maintained for each office where has control under the lease agreement. Office environmental issues include: Assessment of office contractors directly employed by ; Duty of Care compliance in relation to waste generated from the office; Recording of utilities consumption and regular reporting to the Group Environment Manager for monitoring and carbon foot printing. Office Environmental Coordinators are responsible for the control and maintenance of office environmental records, licences, and certificates. P404 Office Environmental Management F Office Environmental Workbook Location specific document stored locally for each site where has office management responsibilities G Office Environmental Workbook User Guide Environmental Policy and Management Plan 12

15 8. Competence, Training and Awareness Managers are responsible for ensuring that any specific training needs are identified and appropriate training arranged in consultation with SHE Business Partner and/or Safety Health and Environment Advisors, and, where applicable, employee representatives, so as to ensure competency of employees and persons working under their control. Specific levels of environmental training will be initially set at group level and further by the Operating Groups in consultation with SHE Business Partner and/or Safety Health and Environment Advisors. Training will also be provided if new technology or new working methods are introduced. All new employees are given an initial Safety Health and Environment induction relevant to their roles and activities undertaken within one week of the commencement of employment, and will be advised of emergency procedures on their first day. All employees whose work may have a significant impact on the environment receive training on the: requirements of the environmental policy, procedures and the EMS; significant environmental impacts associated with their work; environmental benefits of improved performance; and consequences of not complying with procedures. All employee records of training or related competency requirements (relevant to their roles and activities) are held either electronically via the company training and competency system (RIVO Safeguard Training Portal), or within local hard copy files. P202 Induction P227 Training 9. Communication, participation and consultation with employees, and others working under s control and/or affected by its activities. In order to encourage participation, shared knowledge and best practice, consults and communicates with employees and others working under its control and/or affected by its activities on matters affecting the environmental aspects of their work. Employees are encouraged to make suggestions that may improve environmental performance within the Company. These may be made to Managers and Office Environmental Coordinators or to any member of the Group Safety Health and Environment Team. The Group Safety, Health and Environment Team, consults on, and cascades any changes to the environmental management system, legislation (new and forthcoming) and any other relevant information to the Environmental Coordinators, in line with P408 Environmental Communications. The Environmental Coordinator is responsible for ensuring that all communications are reviewed for applicability to their business and cascaded to the appropriate staff members. They also ensure that all feedback is passed up to the Group Safety, Health and Environment Team The Environmental Coordinators are encouraged to attend team meetings, including senior management meetings, to report on environmental issues and performance against local objectives and targets. Environmental issues are communicated to the client through regular service and contract review meetings. P408 Environmental Communications Latest Safety Health & Environment in Brief or Lessons Learnt (produced by the Group Safety, Health & Environment Team) Issued to Environmental Coordinators for distribution to al staff and office notice board as appropriate. All editions are found on mportal. Environmental Policy and Management Plan 13

16 Environmental bulletins and legal updates SHEQ Alerts & Notifications Issued to Environmental Coordinators for distribution to al staff and office notice board as appropriate. All editions are found on mportal. Issued to Environmental Coordinators for distribution to al staff and office notice board as appropriate. All editions are found on mportal. 10. Suppliers, Contractors and Subconsultants The use of suppliers, contractors and sub consultants depends on the work being carried out and in some cases by client requirements. is required, at times, to directly employ third parties in the course of its operations. We understand that it is the responsibility and duty of to control and monitor the work activities of the contractors and communicate and inform on relevant environmental matters. All suppliers, contractors and sub consultants directly employed by are managed in line with our vender assurance procedure and active contractor management in order to ensure that they are competent to carry out tasks in an environmentally safe and effective manner. The primary responsibility in managing third parties rests with the hiring manager and they are responsible for confirming and checking the competence of specialist contractors and sub consultants before they start work and for ensuring any environmental risks or opportunities identified by either or the client have been appropriately communicated. Within the office the Office Environmental Coordinator is responsible for checking the competence of individuals delivering specialist services such as air conditioning maintenance, electrical or gas maintenance. Where has influence over the appointment of a third party by the Client, project staff are responsible for ensuring that environmental issues are included when developing contract requirements and specifications, and where applicable, in evaluation of third parties. Where has some direct/indirect responsibilities for the management of suppliers, contractors and/or sub consultants on behalf of clients, Project Managers are responsible for raising environmental issues at the pre construction/work commencement meeting or in work instructions, communicating with contractors about our expectations for their work and monitoring their performance including recording lessons learnt. P105 External Vendors P203 Management of Contractors P405 Office Environmental Management 11. Emergency Preparedness and Planning The potential for incidents and emergency situations is identified by the environmental risk assessment process. Where appropriate emergency procedures are established to cover response to emergencies and managers ensure through communication, participation and consultation that employees understand what to do in case an emergency situation arises in the premises or site in which they work. All staff are made aware of any local emergency procedures through the induction process. Managers are responsible for arranging the testing of emergency procedures where practical. Managers are responsible for ensuring on behalf of our clients, where appropriate and within the scope of our services, that Contractors have emergency plans in place before work commences. Managers are responsible for ensuring that potential for environmental incident is reviewed through management review meetings and taking advice from the Environmental Coordinator(s) and Group Safety Health and Environment Advisors, as required Environmental Policy and Management Plan 14

17 P409 Environment Incident Control 12. Incident Reporting and Investigation All staff are responsible for ensuring environmental incidents and near misses are recorded on Rivo Safeguard or by telephoning the Incident Line. Staff are responsible for contacting the Environmental Coordinator and/or Group Safety Health and Environment Team as soon as possible in the event of a significant environmental incident such as a pollution incident. The Environmental Coordinator and Group Safety Health and Environment Team are together responsible for ensuring that environmental incidents are investigated; the Business Partner and relevant management are responsible for regular review of investigation findings and incident trends. Serious incidents involving the company, its people, its clients, and others affected by its actions are classed as Group Significant Incidents (GSIs) and are reported via the Incident Line. All staff are provided with credit-card sized information cards containing the Incident Line telephone number and guidance on its use. This information is also available through the intranet and on office and site notice boards. Group Significant Incidents are managed in accordance with the Crisis Management Policy. P012 Crisis Management Policy 13. Monitoring and Measurement Procedures are in place to monitor and measure any of s activities which could have a significant effect on the environment; including compliance with legal requirements, measurement of performance indicators, operational controls and achievement of objectives and targets. Internal audits Group Compliance Advisors carry out regular internal audits and maintain a schedule for planned visits for service and project delivery. Inspection and compliance assessments of controlled offices are carried out by Group Safety, Health and Environmental Advisors. Audits and inspections are carried out regularly according to the SHEQ Audit Schedule. Local monitoring and reporting The Environmental Coordinator monitors performance against local objectives and targets and manages an action plan for delivery of these and reports on performance to senior management at business unit / division / Commission meetings. Environmental Coordinators and Office Environmental Coordinators provide regular reports on agreed performance indicators to the Group Safety, Health and Environment Team as requested. Nonconformity, Corrective and Preventative Action Collated data and information is reviewed periodically and any resulting or identified preventative actions are carried out as appropriate. Corrective action is taken following any identified non-conformance with the requirements of the environmental management system or the identification of the potential for a non-conformance. The Environmental Coordinator ensures identified actions arising from audit or local monitoring are managed, and reports on progress and effectiveness of these to the business. P123 Internal Audit Environmental Policy and Management Plan 15

18 P405 Legal and other requirements SHEQ Planned Activities Schedule Located and maintained on mportal 14. Management Review Management review is carried out in line with P128 Management Review. Environment is a standard agenda item at senior management team meetings. Potential for problems, environmental risks and opportunities are reviewed at these meetings with input provided by the Environmental Coordinator. A wider management system review is carried out on a regular basis by the Group Environmental Team. P128 Management Review P405 Legal and other requirements 15. Carbon Management We monitor the Green House Gas emissions that result from energy use within our offices and those from our operational vehicles and business travel. We will set targets to reduce these emissions. We will also work with our customers and suppliers to reduce the indirect Greenhouse Gas emissions that we can influence. Environmental Policy and Management Plan 16

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