Our risk management framework Reviewed quarterly by our executive committee
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- Evelyn Bell
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1 Our risk management framework Reviewed quarterly by our executive committee Our risk management framework helps us identify and mitigate risks. It is reviewed quarterly and updated to reflect changes particularly in relation to environmental legislation and regulation and climate change. Risk Mitigation Commentary Corporate responsibility Adverse publicity arises through failure to address environmental issues Group Environmental Policy subject to annual audit and compliance reviews. Engagement with government and industry to anticipate changes to environmental legislation. Annual CR report to GEC and Hammerson Plc Board by Head of Sustainability. Quarterly reports to the retail executive, including performance against corporate measures. Annual CR Report includes performance against targets. Environmental aspects included in acquisitions due diligence checklist. One day accredited environmental training course provided to over 525 employees both direct and contract. ISO accreditation in place at five shopping centres. Environmental coordinators have been employed at six shopping centres managed by Hammerson Operations Limited. Hammerson is committed to rolling out ISO across the UK retail portfolio. We are currently reviewing the potential for including all UK shopping centres under a Hammerson UK accreditation. Workman manage all retail park assets and are ISO14001 accredited. The Environmental Co-ordinator role has been very effective in delivering ISO accreditation and ongoing operational savings through on site environmental management. Financial loss and adverse publicity arises through failure to meet published CR measures or comply with published CR principles CR Board Chaired by CEO, monitors compliance with principles and performance against measures. A new CR data management system has been created to bring all data in-house to improve ability to monitor performance. Regular quarterly updates from asset managers to the retail executive on progress against CR measures and list of actions. Launch of supplier questionnaire to ensure supply chain is aligned to Hammerson goals. Hammerson completed an independent review of stakeholder panel options and decided to implement in CR report has been independently verified since Reporting framework to be reviewed alongside development of new medium term targets in 2014 Reputational risk linked to public consultation Revised community consultation principles reflecting areas set out in Localism Act. Consultations held in Merthyr Tydfil, Croydon, Leeds, Cramlington including surveys and videos to capture feedback. Full stakeholder audits completed. Separate key stakeholder briefings as well as wider public consultation held. Consultation websites and social media engagement throughout the lifetime of developments. Consultation principles and use of social media to widen participation embedded into consultation.
2 CR Strategy Implementation of a strategy inconsistent with the market environment CR strategy is regularly reviewed through the internal governance process and through our work with independent advisers. The target review and resetting process that will take place during 2014 will be supported by independent advisors and will include. The process included: Benchmarking study and peer group mapping Interview with employees and external stakeholders Senior management workshops Ignore the future impact of climate change on our portfolio Completed a portfolio wide review of climate change impacts. We are committed to reducing carbon emissions, and our exposure to increases in carbon tax Our design standard requires all new developments to be designed to withstand predicted climate change Assess design team experience in designing for future climates and support where necessary Flood risk review to be updated during 2014 Review of potential climate change impacts on the business to be commissioned in 2014 Ensuring our assets are resilient to future climate scenarios will be critical to their long standing success as retail assets and as investments. This is therefore a particular focus for the business presently. 2
3 Property development Failure to address sustainability in development programme Failure to understand the 2010 Part L regulation and plan for 2013 Projects are delivered in accordance with the sustainability management framework. Projects follow a full Sustainability Implementation Plan or an abbreviated fit out/refurbishment version. Sustainability design workshops are held at the start of new projects to set the parameters for the project. Projects are reviewed against the corporate design standard reviewed and updated in Pre Qualification Questionnaires are used within the tender process to ensure design teams are sufficiently skilled to deliver sustainability objectives Community engagement plans are produced for each development and relationships with local providers developed to ensure effective on the ground delivery Each project has been reviewed against the standard to understand the implications. In London, all projects are designed to achieve 25% below 2010 (equivalent to the GLA planning requirement of 44% below Part L 2006 and exceeding the requirements of 2013 Part L) Sustainability training workshops are being held with our development and project management teams with a focus on this area. New improved community plans have been piloted at Silverburn and Westquay inclusive of lessons learnt from Marseille. Our existing design standard anticipated this change and set a target far exceeding 2010 Part L on all projects. Failure to understand the 2011 and forthcoming 2014 BREEAM regulation Failure to be a member of Local Enterprise Partnership, which has replaced the RDA All new developments complete a BREEAM 2011 pre- assessment. Engagement with tenants continues with retailers to explain the requirements placed on them in order for new projects to achieve BREEAM Excellent. A new BREEAM Excellent lease has been created in the UK and will be implemented at Leeds and Watemark Place, Southampton. This ensures that all retailers commit to achieve BREEAM credits. We ensured we formed part of each LEP submission where we have either existing assets or new developments planned. BREEAM training in 2009 for French development managers. Marseille remains on target to achieve BREEAM Excellent. BREEAM ratings completed on all new projects. Local senior management are involved in local LEPs and monitor progress. 3
4 Property investment Acquisition of properties that fail to meet sustainability standards Acquisition checklist up dated to includes requirement for energy performance certificates and Carbon Reduction Commitment and climate change impact reviews. Failure to register for the Carbon Reduction Commitment Energy Efficiency Scheme (CRC EES) A CRC EES steering committee established to manage across the portfolio. Regular updates given for GEC and Hammerson plc Board. New metering strategy for the investment portfolio. Carbon Trust certification completed where possible. Continuing to engage with industry bodies and Government Third party audit of our CRC EEX process implemented for phase 2. Hammerson volunteered to be audited and passed without any complications. Hammerson gave four CRC EES presentations to service charge consultants. Hammerson continues to work with the BPF on all CRC consultations. Energy Act ability to transact property in 2018 based on energy certification rating Obtained EPCs for all shopping centres assets as part of readiness for sale initiative. These have been assessed to identify EPC risk across the portfolio Programme of work initiated in 2014 to reduce exposure to EPC risk by reviewing E,F and G rated units and prioritising units with a lease event prior to 2018 for assessment for works. Energy audits and long-term energy improvement plans are in place at all assets. Green Leases ask all tenants to monitor energy consumption and work with the landlord to improve their performance and that of the managed asset. Hammerson is working with the BBP to develop a voluntary Landlord Energy Certificate. Lack of appropriate environmental management system ISO is being implemented at Hammerson managed shopping centres in the UK. We are reviewing implementing company level accreditation rather than asset level accreditation. Our Environmental Co-ordinators working at asset level ensure effective implementation of our EMSs on a day to day basis. Civil unrest Implemented a co-ordinated response to manage both the immediate and long term impacts. Grenelle de l Environment Energy audits and energy plans Landlord data collection Legal update Addendums for leases have been implemented where required for our French assets. 4
5 Business organisation and human resources Failure to provide staff with the knowledge and tools to implement sustainability programme One - day department- specific CR training courses held. Two- day staff induction course includes sustainability. ISO EMS IOSH accredited training held for staff at Hammerson managed shopping centres. Senior management training held on the Grenelle d Environment in France. Talent management and succession planning process in place. All staff in France have been made aware of the implications of the Grenelle de l Environment through staff presentations, announcements and CR newsletter. Failure to implement an appropriate health and safety strategy A detailed description of the approach to managing Health and Safety is included on the Hammerson website. In response to investor engagement and indices feedback, we have explained our Health & Safety Policy. 5
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