Helical Bar - Environmental Management System. January 2014



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Transcription:

Helical Bar - Environmental Management System January 2014

Contents 1 Introduction... 1 1.1 Overview... 1 2 Environmental aspects and impacts register... 2 2.1 Definitions... 2 2.2 Register of environmental impacts and aspects... 2 3 Environmental policy and objectives... 4 3.1 Definitions... 4 3.2 Environmental Policy and objectives... 4 3.3 Corporate Responsibility Policy... 5 4 Environmental targets... 7 4.1 Definitions... 7 4.2 Environmental targets... 7 4.3 Environmental target monitoring procedure... 10 4.4 Corporate Responsibility targets... 10 5 Implementation and operation... 11 5.1 Management responsibilities... 11 5.2 Operational control... 12 5.3 Training... 12 5.4 Internal communications... 12 6 Environmental monitoring and measurement... 13 6.1 Definitions... 13 6.2 Monitoring and measurement... 13 6.3 Monitoring and measurement procedure... 15 6.4 Management Review... 16 6.5 Internal Audit... 17 A1. Sustainability Project Management Checklist... 18 A2. Environmental checklist included as part of due diligence procedures... 21 6.6 Responsibility... 21 6.7 Timing... 21 6.8 Procedure... 21 6.9 Checklist... 21 A3. Management Review process... 23 A4. Performance measurement procedure for managed portfolio... 24 6.10 Responsibility... 24 6.11 Timing... 24 6.12 Procedure... 24 6.13 Performance Measurement tool... 24 A5. Legal Compliance Checklist... 25 6.14 Responsibility... 25 6.15 Timing... 25 6.16 Procedure... 25 6.17 Compliance Checklist... 25 A6. Contractors Checklist... 27 6.18 Responsibility... 27 6.19 Timing... 27 6.20 Procedure... 27 6.21 Checklist... 27

1 Introduction 1.1 Overview This document has been prepared to provide the framework for key components of an Environmental Management System (EMS). It covers 100% of head office operations, 100% of UK managed assets where we have direct control (i.e. multi-let properties) and 100% of development projects. EMS coverage excludes Joint Ventures. The EMS is structured under the following headings, which are intended to reflect the key components of a good practice EMS: Environmental aspects and impacts register Environmental policy and objectives Environmental targets Environmental monitoring and measuring Environmental legal compliance Implementation and operation Management responsibilities Management review and internal audit These key components enable Helical Bar to demonstrate to socially responsible investors and other interested stakeholders how we are addressing the environmental risks associated with our business activities. The suggested approach places a particularly strong focus on environmental performance improvement through the ongoing use of both targets and Key Performance Indicators. The diagram below illustrates how the different elements listed above (and further developed within later sections of this document) fit together to form an effective EMS. Figure 1 Overview of an effective EMS 1

2 Environmental aspects and impacts register 2.1 Definitions ISO 14001 describes environmental aspects as: Elements of an organisation s activities, products or services that can interact with the environment. ISO 14001 describes environmental impacts as: Any change to the environment, whether adverse or beneficial, wholly or partially resulting from an organisation s activities, products or services. 2.2 Register of environmental impacts and aspects Based upon a detailed analysis of Helical Bar s portfolio of developments, investments, and trading properties, a register of environmental aspects and impacts based upon the company s core business activities has been developed. Helical Bar has prioritised those environmental impacts considered to be of highest significance to the company. This was undertaken on the basis of the following criteria: Helical Bar s ability to directly control the particular environmental impact (it was agreed that Helical Bar has control over all impacts except those that arise directly as a consequence of tenants/contractors own activities, where it can only seek to influence their actions). The likelihood/frequency of a particular impact occurring as a result of a particular activity. The severity of the consequences of a particular impact occurring. The figure below lists only those environmental impacts that were considered to be of HIGH significance. A more complete spreadsheet listing all the environmental impacts according to low, medium and high significance has been prepared and is also retained by Helical Bar. Impacts and aspects relating to single-let assets (where Helical Bar retains no management control e.g. in the case of FRI leases) have been excluded from the figure below given that we can have little to no impact on the environmental performance of such buildings once occupied. The significant environmental impacts identified in this way formed the basis for reviewing Helical Bar s environmental policy and objectives, and in particular for suggesting the environmental targets. 2

Figure 2 Impacts and Aspects Register Activities, products and services Acquisition Environmental aspects Helical Bar Control or Influence Environmental impacts Significance All sites Site selection Control Land use, biodiversity High High Site evaluation Control Emissions to land/water High Existing buildings Building survey Control Hazardous materials High Property management (all multi-let building types) Offices (multi-let) Retail (multi-let retail park) Retail (multi-let shopping centre) Industrial (multi-let) Construction/refurb works (all property types) Property development and refurbishment (all building types) Design Construction/demolition High High Energy use Control Emissions to air (climate change) High Water use Control Resource depletion High Waste management Influence Resource depletion, emissions to water/air/land High High Energy use Control Emissions to air (climate change) High Waste management Control Resource depletion, emissions to water/air/land High Landscaping/planting Control Biodiversity/ ecology High Transport Influence Emissions to air (climate change) High High Energy use Control Emissions to air (climate change) High Water use Control Resource depletion High Waste management Control Resource depletion, emissions to water/air/land High Cleaning Control Emissions to water High Landscaping/planting Control Biodiversity/ ecology High Transport Influence Emissions to air (climate change) High High Energy use Control Emissions to air (climate change) High Water use Control Resource depletion High Waste management Influence Resource depletion, emissions to water/air/land High Spillages/contamination Influence Emissions to water, emissions to land High High Materials selection Control Resource depletion (e.g. deforestation) High High High Energy use Control Emissions to air (climate change) High Procurement Control Resource depletion High Landscaping/planting Control Biodiversity/ ecology High Transport Control Emissions to air (climate change) High Waste management Control Resource depletion, emissions to water/air/land High High Spillages/contamination Influence Emissions to land, emissions to water High Procurement Control Resource depletion High Transport Influence Emissions to air (climate change) High Noise, dust Influence Nuisance High 3

3 Environmental policy and objectives 3.1 Definitions ISO 14001 describes the environmental policy as: A statement by the organisation of its intentions and principles in relation to its overall environmental performance which provides a framework for action and for the setting of its environmental objectives and targets. ISO14001 defines an environmental objective as: An overall environmental goal, arising from the environmental policy, that an organisation sets itself to achieve, and which is quantified where practicable. 3.2 Environmental Policy and objectives Helical Bar s environmental policy and objectives statement was first adopted in 2001. The policy and objectives relate specifically to the most significant environmental impacts arising from the company s core activities, as represented by those that are within Helical Bar s direct control, their frequency of occurrence and the severity of the ensuing consequences. It is listed in full below: Helical Bar plc is a property development and investment company. Our activities comprise the development of commercial, industrial, residential and mixed use property and the ownership and management of a portfolio of offices, industrial and retail properties in the UK. We recognise our responsibility to reduce any adverse environmental impacts arising from our business activities and we work within existing regulatory frameworks to comply with all relevant environmental legislation as a minimum through our operations. Our overall goal is to operate in a sustainable manner throughout our operations. Our response to environmental issues is practical and pragmatic and reflects our desire to be a responsive, flexible and collaborative partner and landlord. The following environmental objectives apply to our UK operations. They provide a framework for performance targets which we commit to monitor and report on to ensure compliance, and to meet evolving client and investor expectations in moving towards being a sustainable business: We will integrate environmental considerations through passive design in new and refurbished buildings, seeking wherever possible to achieve good practice standards. We will limit our consumption of natural resources, including energy and water in an attempt to maximise 4

efficiency and reduce our carbon footprint. We will implement appropriate waste management practices, seeking to reduce, re-use and recycle before disposal to landfill. We will protect and enhance the landscape and biodiversity wherever practical. We will endeavour to source timber from legal sustainable sources and where possible, from well managed sources certified by third-party certification bodies accredited by the Forest Stewardship Council. We will prohibit the use of materials and substances that have potentially hazardous effects on the environment, human health and wellbeing. We will investigate pollution and other environmental liabilities as part of our due diligence procedures when acquiring new assets. We will minimise the risks of pollution from emissions to air and/or water or land contamination, particularly during construction or demolition. We will minimise carbon emissions associated with transport to our managed assets and construction sites wherever possible. We will reduce exposure to extreme weather risks such as flooding and subsidence through appropriate design and asset appraisal. We will ensure that project teams managed by Helical Bar refer to our Sustainability Project Management Checklist to ensure a consistent standard of environmental management is applied to our projects. We will encourage the sharing of good environmental practices across our operations. We will work closely with our tenants in order to improve their own environmental performance. We will seek to reduce the adverse environmental impacts associated with our own office management practices and procurement policies. We will monitor and review our performance against our environmental objectives on a regular basis in order to demonstrate that we are achieving the standards that we set ourselves and ensure their ongoing relevance. The Policy is reviewed annually by the main board and is implemented by management representatives working with our project teams and managing agents. Signed: Michael Slade Chief Executive Last updated: September 2013 3.3 Corporate Responsibility Policy Our corporate responsibility objectives, developed in 2009, also overlap with a number of significant environmental impact areas. These are listed below in full: We will take necessary action to ensure that we minimise our impact on the environment, by adhering to the commitments outlined in our Environmental Policy. We will implement considerate construction practices on all developments and refurbishments, including consulting with local communities and stakeholders on large schemes. We will apply appropriate sustainable procurement standards for our development and asset management 5

activities, focusing on labour standards and environmental compliance. We will work collaboratively with our Joint Venture partners and project teams to understand their needs, delivering pragmatic and practical solutions to their sustainability challenges. We will ensure that all of our developments sites and assets implement appropriate health and safety practices in line with regulatory requirements, to protect our contractors, sub contractors, tenants and employees. We will respect the principles of equality and diversity in our employment practices. We will work with our tenants to ensure that we manage our assets in line with their occupation requirements. We will seek to understand and respond to our investors evolving concern for sustainability in the context of real estate development and management. 6

4 Environmental targets 4.1 Definitions ISO 14001 defines environmental targets as: Detailed performance requirements, quantified wherever practicable, applicable to the organisation or parts thereof, that arise from the environmental objectives and that need to be set and met in order to achieve those objectives. 4.2 Environmental targets Helical Bar has been setting targets since 2004. These targets have historically, and continue to form the basis of an Environmental Management Program (EMP), ensuring that we are implementing the environmental policy and objectives in line with a commitment to continuous improvement. Figure 3 below shows that Helical Bar is committed to at least one target (internal and external) against each objective, thereby demonstrating how these objectives are being implemented. In view of the fact that Helical Bar s objectives are broad enough to cover different areas of activity (e.g. energy conservation is relevant to both development and investment), there are in a number of cases several targets against one objective. Figure 3 Environmental targets OBJECTIVE: We will integrate environmental considerations through passive design in new and refurbished buildings, seeking wherever possible to achieve good practice standards. External target: Exceed current Part L Building Regulations for target emissions rate in all new and refurbished buildings through passive design and energy efficiency Responsible OBJECTIVE: We will limit our consumption of natural resources, including energy and water in an attempt to maximise efficiency and reduce our carbon footprint. External target: Reduce landlord purchased energy consumption by 5% at each of our managed assets from 2013 baseline Responsible Asset Manager External target: Measure performance indicator for energy consumption at each of our managed multilet office assets against lettable area and achieve a 5% reduction from 2013 baseline. Asset Manager External target: Reduce landlord purchased water consumption by 5% at our managed assets from 2013 baseline External target: Measure performance indicator for water consumption at each of our managed multi let office assets against occupancy. Maintain less than 0.50 m 3 per m 2 average water consumption for offices. External target: Measure and report our carbon emissions associated with energy use for our managed assets. Asset Manager Asset Manager Asset Manager 7

External target: Monitor energy consumption on each construction site and set appropriate reduction targets External target: Monitor water consumption on each construction site and set appropriate reduction targets OBJECTIVE: We will implement appropriate waste management practices, seeking to reduce, re-use and recycle before disposal to landfill. External target: Divert at least 50% of construction and demolition waste from landfill for all new developments and major refurbishments Responsible External target: Achieve a recycling rate of 35% at managed properties where robust waste data is available Asset Manager OBJECTIVE: We will protect and enhance biodiversity and ecology wherever practical. External target: Conduct ecological assessments on all new sites prior to construction and take appropriate mitigating and enhancement actions Responsible External target: Develop site specific Biodiversity Action Plans as appropriate on individual sites. External target: Require project teams to source timber, if used, from sustainable sources and aim for a minimum of 50% chain of custody certified timber to Forest Stewardship Council and or Pan European Forestry Council certification.. OBJECTIVE: We will prohibit the use of materials and substances that have potentially hazardous effects on the environment, human health and wellbeing. Internal target: Review the standard list of prohibited materials that are used for both refurbishment and construction works and ensure this is incorporated within standard design specifications. Responsible OBJECTIVE: We will investigate pollution and other environmental liabilities as part of our due diligence procedures when acquiring new assets. 1 Internal target: Review the standard due diligence checklist to ensure that all sites being considered for acquisition are audited to identify the presence of possible contaminants or hazardous substances. Responsible OBJECTIVE: We will minimise the risks of pollution from emissions to air, water and/or land contamination, particularly during construction or demolition Responsible 1 See appendix A2 for the environmental checklist used during the due diligence process. 8

External target: Zero pollution incidents and enforcement notices Internal target: Investigate feasibility of monitoring emissions to air and water at construction sites and record. OBJECTIVE: We will work closely with our tenants in order to improve their own environmental performance. External target: Provide appropriate information and support to building occupiers and managing agents to ensure optimum operation and efficiency of buildings Responsible Asset Manager OBJECTIVE: We will minimise carbon emissions associated with transport to our managed assets and construction sites wherever possible. Internal target: Provide information to tenants on local cycle routes where secure cycle storage has been provided and public transport options where available. Responsible Asset Manager OBJECTIVE: We will reduce exposure to extreme weather risks such as flooding and subsidence through appropriate design and asset appraisal. External target: Ensure flood risk is assessed for all land purchased and acquisitions Responsible OBJECTIVE: We will ensure that project teams managed by Helical Bar refer to our Sustainability Project Management Checklist to ensure a consistent standard of environmental management is applied to our projects. External target: All projects to utilise the Sustainability Project Management Checklist from site acquisition to post practical completion 2 Responsible External target: Ensure Principal Contractor completes and updates the Contractors Checklist throughout the life of the project 3 OBJECTIVE: We will encourage the sharing of good environmental practices across our operations. Internal target: Provide a good environmental practice poster to all managed assets to encourage knowledge sharing and update annually. Responsible Asset Manager OBJECTIVE: We will work closely with our tenants in order to improve their own environmental performance. Responsible 2 A complete copy of the Sustainability Project Management Checklist can be found in the appendix A1. It provides an overview of the processes, responsibilities and procedures relating to the consideration of sustainability issues throughout the design process. 3 A complete copy of the Contractors checklist is at Appendix A6.It provides a data collation tool against the KPis measured under the EMS. 9

External target: Provide appropriate information and support to building occupiers and managing agents to ensure optimum operation and efficiency of buildings. Asset Manager OBJECTIVE: We will seek to reduce the adverse environmental impacts associated with our own office management practices and procurement policies. External target: Maintain energy consumption at current levels for 2013. External target: Maintain water consumption at current levels for 2013. Responsible Internal EMS Focal Point Internal EMS Focal Point 4.3 Environmental target monitoring procedure Internal EMS Focal Points nominated within Helical Bar representing both the Development and Investment teams of the business meet with external environmental consultants, RPS, on a quarterly basis to discuss progress against the targets outlined above. The meetings serve as a forum to discuss challenges related to target delivery. They also serve an external audit function, ensuring that appropriate systems and processes for data collection are in place at both site and corporate level. All relevant information from these meetings is passed back to the target owners. 4.4 Corporate Responsibility targets Helical Bar defined its Corporate Responsibility Policy in 2009 with clear objectives addressing social issues such as health and safety and equality. In support of these objectives, measurable targets have been defined where appropriate and listed in Figure 4 below. Figure 4 Corporate responsibility targets OBJECTIVE: We will implement considerate construction practices on all developments and refurbishments, including consulting with local communities and stakeholders on large schemes. External target: Ensure all principal contractors are registered with the Considerate Constructors Scheme and achieve at least a pass score. Responsible External target. Consult with communities during the planning stages of all major schemes and provide a point of community liaison during the construction period. OBJECTIVE: We will ensure that all our development sites and assets implement appropriate health and safety practices in line with regulatory requirements, to protect our contractors, sub contractors, tenants and employees External target: Achieve zero reportable accident/incidents throughout 100% of the managed assets. Responsible Asset Manager External target: Achieve zero reportable accident/incidents on 100% of our construction sites. 10

5 Implementation and operation 5.1 Management responsibilities The environmental policy has been approved by the Helical Bar Board of Directors and is endorsed by the Chief Executive Michael Slade. The organogram below depicts how responsibility is delegated throughout the organisation. Day to day responsibility for the EMS has been allocated to named individuals, who are the identified EMS Focal Points within the Investment and Development teams: Richard Bathgate (Asset Management Executive) Nikki Gibbard (Development Surveyor) 11

Operational implementation of the EMS rests with Helical Bar s internal staff, managing agents and external consultants including Tanya Lloyd-Jones, a consultant at RPS who should be contacted for any specific queries with regards to the EMS (jonest@rpsgroup.com). 5.2 Operational control There are a range of procedures in place to ensure systematic implementation of the EMS by external consultants and internal staff alike. For example, in the context of design and construction, Helical Bar utilises a Sustainability Project Management Checklist (see appendix A1) which is systematically applied on all projects from site acquisition through to post practical completion. Its purpose is to provide design teams with a reference to ensure the consideration of sustainability at key phases of design. The checklist is also used as a means to gather appropriate KPI data related to development impacts (through specification of contractual requirements to provide sustainability data) thereby enabling reporting of progress against environmental targets. RPS fulfils an audit role in regards to compliance against the checklist, ensuring the checklist is properly utilised at appropriate stages of a project. At the site acquisition stage, we have an environmental checklist which is included as part of the due diligence process (see Appendix A2). For all property (or company) purchases, the environmental risks included in this checklist are assessed and reported on to the Helical Bar Board. See also section 6.3 for details of monitoring and measurement procedures at managed assets and on development sites. 5.3 Training Appropriate training is provided to all staff involved in the implementation of the EMS. This includes annual one on one sessions with individuals responsible for target delivery to ensure that monitoring and measurement procedures are accurate and robust for reporting of progress against targets. 5.4 Internal communications The EMS and operational procedures are stored on the company s server and can be accessed by all staff. A copy of this document has also been circulated to all members of staff. 12

6 Environmental monitoring and measurement 6.1 Definitions ISO 14001 defines environmental performance evaluation as: A process to facilitate management decisions regarding an organisation s environmental performance by selecting indicators, collecting and analysing data, assessing information against environmental performance criteria, reporting and communicating, and periodically reviewing and improving this process. An environmental performance indicator is a specific expression that provides information about an organisation s environmental performance 6.2 Monitoring and measurement Helical Bar uses Key Performance Indicators (KPIs) to monitor performance in meeting its objectives and targets. The purpose of these indicators is to establish a baseline of performance against which quantifiable improvement targets can be set and objectively assessed. This section identifies the indicators against which Helical Bar measures its significant environmental impacts. They have recently been revised to reflect the reporting requirements of the latest set of environmental targets. Figure 4 Environmental Key Performance Indicators Environmental aspects Acquisition Site selection Property Management Offices (multi-let) Energy use Energy use Energy use Energy use Environmental impacts Land use, biodiversity Emissions to air (climate change) Emissions to air (climate change) Emissions to air (climate change) Emissions to air (climate change) Environmental performance indicators Units Industry benchmarks Proportion of sites acquired for development that are previously developed land Total energy use in managed investment portfolio (Landlord controlled electricity (kwh) and gas (kwh) consumption) Energy efficiency in managed investment portfolio (Landlord controlled electricity (kwh) and gas (kwh) consumption) Total carbon emissions from managed investment portfolio (Landlord controlled electricity (kwh) and gas (kwh) consumption) Carbon intensity from managed investment portfolio (Landlord controlled electricity (kwh) and gas (kwh) consumption) 13 % (by area) kwh kwh/m 2 (net lettable area)/year kgco2 kgco2/m 2 (net lettable area)/year No industry benchmarks available but national statistics and targets to compare with. CIBSE TM46: Energy Benchmarks CIBSE TM46: Energy Benchmarks CIBSE TM46: Energy Benchmarks CIBSE TM46: Energy Benchmarks

Water use Water use Waste management Waste management Transport Resource depletion Resource depletion Resource depletion Resource depletion Emissions to air (climate change) Total water use in managed investment portfolio (Landlord controlled water consumption) Water efficiency in managed investment portfolio (Landlord controlled water consumption) Waste recycling rate managed investment portfolio (Volume (m3) or weight (tonnes) of following waste streams: cardboard, white paper, colour paper, plastics, metal, wood, glass, hazardous, organic, misc, other ) m 3 m 3 / m2 (net lettable area)/year m 3 CIRIA C657 Water key performance indicators and benchmarks for offices and hotels CIRIA C657 Water key performance indicators and benchmarks for offices and hotels None available. Waste segregated on site and recycled % (by tonnes) None available. Number of cycle locking points per 100 occupants Number per 100 occupants None available Retail and Industrial (multi-let) 4 Energy use Energy use Energy use Energy use Water use Water use Waste management Waste management Transport Emissions to air (climate change) Emissions to air (climate change) Emissions to air (climate change) Emissions to air (climate change) Resource depletion Resource depletion Resource depletion Resource depletion Emissions to air (climate change) Development (design and construction) Total energy use in managed investment portfolio (Landlord controlled electricity (kwh) and gas (kwh) consumption) Energy efficiency in managed investment portfolio (Landlord controlled electricity (kwh) and gas (kwh) consumption) Total carbon emissions from managed investment portfolio (Landlord controlled electricity (kwh) and gas (kwh) consumption) Carbon intensity from managed investment portfolio (Landlord controlled electricity (kwh) and gas (kwh) consumption) Total water use in managed investment portfolio (Landlord controlled water consumption) Water efficiency in managed investment portfolio (Landlord controlled water consumption) Waste recycling rate managed investment portfolio (Volume (m3) or weight (tonnes) of following waste streams: cardboard, white paper, colour paper, plastics, metal, wood, glass, hazardous, organic, misc, other ) kwh kwh/m 2 (common parts areas)/year kgco2 kgco2/m 2 (common parts areas)/year m 3 m 3 /m 2 (common parts areas)/year m 3 CIBSE TM46: Energy Benchmarks CIBSE TM46: Energy Benchmarks CIBSE TM46: Energy Benchmarks CIBSE TM46: Energy Benchmarks None available. None available. None available. Waste segregated on site and recycled % (by tonnes) None available. Number of cycle locking points per 100,000 visitors Number per 100,000 visitors None available 4 Retail includes multi-let shopping centres and retail parks 14

Design Energy use Energy use Water use Water use Waste management Waste management Construction (including refurbishment) Construction (including refurbishment) Spillage/contamination Own office impacts Energy use Water use Waste management Transport All Emissions to air (climate change) Emissions to air (climate change) Resource depletion Resource depletion Resource depletion Resource depletion Neighbourliness Nuisance Emissions to water, emissions to land Emissions to air (climate change) Resource depletion Resource depletion Emissions to air (climate change) BREEAM for Offices BREEAM for Industrial BREEAM for Retail Total energy use on site (site purchased electricity (kwh) and gas (kwh) consumption) Energy efficiency on site (site purchased electricity (kwh) and gas (kwh) consumption) Total water use on site (site purchased water consumption) Water efficiency on site (site purchased water consumption) Construction waste diverted from landfill (Total construction and demolition waste and construction and demolition waste diverted from landfill) Materials from recycled sources incorporated into new build (Total value ( or Euro) of construction materials and % from recycled sources) Proportion of construction sites certified by the Considerate Constructors Scheme Number of complaints received on construction sites BREEAM Rating kwh kwh/ 100k construction cost /year m 3 m 3 / 100k construction cost /year % (by tonnes) BREEAM is a benchmark in itself. None available. None available. None available. None available. % (by tonnes) None available. % by area Number BRE Waste Benchmark data (new build) None available although there may be national statistics. None available. Number of pollution incidents Number None available. Total energy use in head office (kwh) (Electricity (kwh) and gas (kwh) consumption) Total water use in Head Office (Landlord controlled water consumption) Waste recycling rate Head Office (Volume (m3) or weight (tonnes) of following waste streams: cardboard, white paper, colour paper, plastics, metal, wood, glass, hazardous, organic, misc, other) Total business travel emissions (air miles and car miles) kwh m 3 None available None available % (by tonnes) None available kgco2 None available 6.3 Monitoring and measurement procedure An excel spreadsheet tool is issued by Helical Bar to all managing agents responsible for the day to day management of the multi-let offices in the portfolio. The tool specifies the relevant information to be captured across different property types. See appendix A4 for a screenshot of the tool used to collect data at managed properties. 15

Agents and site managers enter the data specified in the spreadsheet into the appropriate cells, and issue the completed information back to Helical Bar on specified quarterly dates. This information is collated and analysed by RPS, so that it can be reported to external stakeholders and to enable the setting of performance related targets. The same tool is used to capture information on the environmental impacts arising from Helical Bar s occupation of 11-15 Farm Street. In support of the above, a legislation compliance checklist (see appendix A5) is updated annually by RPS and completed by the managing agents before March 31 st each year. This is a self auditing mechanism to confirm legal compliance within the managed portfolio. In terms of development of performance measurements, contractors are required to report on the development (design and construction) indicators listed in Figure 4 above. The following process is in place to ensure appropriate performance measurement at development sites: Kick off meeting with contractors in order to formally agree the sustainability KPIs (and add any others) and agree the way in which monitoring will take place over the life of the contract. Contractors provided with guidance on how to meet the sustainability commitments under the contract. Contractors performance monitored on a regular basis. Contractors asked to report on sustainability at all monitoring meetings/site visits and in all reports submitted to the project manager detailing: - If any health, safety or environmental incidents have arisen and the action taken to correct these - Evaluation of performance against the sustainability KPIs in the contracts and where performance is insufficient, the corrective actions that will be undertaken to improve performance - Any measures that have been put in place over and above the contract requirements to improve the suppliers sustainability performance - Any sustainability innovations on the contract. Suppliers asked to report on exceptions from the contract when they arise i.e. to report on any health, safety or environmental incidents. Reporting information is collated by use of the Contractors Checklist at Appendix 6 6.4 Management Review The Management Review is intended to determine whether the EMS is suitable, adequate and effective for its intended purpose. In order to ensure continuous improvement, and to establish whether the company is meeting the objectives and targets it has set itself, Helical Bar commits to undertake a Management Review of the EMS on an annual basis. The objectives of these reviews are amongst other things to: Review the content and appropriateness of the Environmental Policy and objectives in light of industry good practice. Provide a critical evaluation of progress against the corporate environmental objectives and targets. Review the data gathered against environmental performance indicators and seek to establish whether this represents poor, typical or good practice. Helical Bar uses this information to decide on future Environmental Management Programmes and targets. Make recommendations for future targets and action. 16

For further details on the Management Review process see appendix A3. The findings of the Management Review are presented to the Board. 6.5 Internal Audit As part of RPS s ongoing support to the Helical Bar, quarterly meetings are held with all target owners to evaluate progress against targets to date and to identify solutions to any potential barriers to target implementation. A review of progress against targets also takes place on an annual basis. The results of this review are published on Helical Bar s website, included within the Annual Report and shared with the Board. RPS also undertakes an annual internal audit of EMS implementation at both site and corporate level, incorporating the following EMS components: Policy Aspects & Impacts Objectives and Targets Environmental Management Programmes Governance and Responsibility Monitoring & Measurement Legal compliance Management Review Training, Awareness and Competence Communication 17

A1. Sustainability Project Management Checklist 18

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A2. Environmental checklist included as part of due diligence procedures 6.6 Responsibility Acquisition Surveyor &/or Project Manager 6.7 Timing Prior to exchanging contracts on any property (or company) acquisition. 6.8 Procedure As part of the due diligence procedure for all property (or company) purchases, the environmental risks included in this checklist should be assessed and reported on to the Helical Bar Board. The appropriate use of the checklist should ensure that properties (and companies) that are being acquired do not present any unreasonable and unforeseen environmental risks and liabilities, and that once acquired they are kept in a ready-for-sale condition. When the checklist has been completed it should be signed off by the project manager. 6.9 Checklist The following environmental issues should be investigated as part of the acquisition due diligence process: Land contamination A landmark survey should be undertaken to identify historical uses of the site and determine whether contaminated land investigation is required. If more detailed investigations are required, approved consultants should be appointed to undertake soil sampling and/or bore hole surveys. The final contamination report produced should be forwarded to the relevant project manager before formal commitment is made to acquire the property. Note: tax relief may be available for any remedial or monitoring costs should the property be acquired. Hazardous and deleterious materials Building fabric and services surveys should be undertaken to identify any potentially harmful or hazardous materials. These must ultimately be safely removed and disposed of in accordance with regulations covering Duty of Care for Waste and the Special Waste Regulations. Particular care should be taken to identify: - Asbestos - Polychlorinated bi-phenyls (highly toxic substances found as coolants and impregnates in transformers, capacitors and similar equipment). - Refrigerant gases and foams (often used in air conditioning, refrigeration and fire protection systems) - e.g. CFCs and HCFCs. Ecological and archaeological assessment 21

An assessment should be made as to whether the site might be home to any rare or endangered species of flora or fauna. If in doubt, consult with a Local Wildlife Group or the appropriate department in the local planning authority. If development is likely to take place at the site, actions need to be identified to alleviate any harm to these habitats and species. Similar precautions should be applied to both landscape and archaeology/natural heritage on or around the site. Flooding risk If the site is located in an area that is prone to potential flooding, this should identified and reported to the Project Manager, due to the potential increase in insurance premiums. In addition, underground streams should be identified and located, along with the source and destination of the stream. Good practice Additional elements that should be investigated include: Information on the original base specification of the building A full set of the original plans for the building Existence of a BREEAM rating for any existing buildings on site Full health and safety audit of the building (e.g. CDM manuals, etc) Compliance with the Disabled Discrimination Act 22

A3. Management Review process 1. To conduct the annual EMS management review, the EMS Coordinators will compile information related to the performance of the EMS from the current year and present it to the Board. This information will include, but is not be limited to: A. The processes used to determine Helical Bar s aspects, significant aspects, legal and other requirements, and objectives and targets; B. The level of success towards achieving the objectives and targets; C. Previous discussions with members of the Board relative to the success and direction of the EMS; D. After action reports from environmental incidents and any other communications from external interested parties; E. Changing circumstances that could affect the scope of the EMS; and F. Recommendations for improvement. 2. During the review, the EMS Coordinators will address the following questions, and others that may arise, to assess the suitability, adequacy, and effectiveness of the EMS and develop improvement recommendations (as necessary) in the following areas: A. Are the processes used to determine the aspects, significant aspects, legal and other requirements, and objectives and targets sufficient relative to Helical Bar s environmental policy and its activities? B. Have the Environmental Management Programs (EMPs) which underpin the targets been properly developed, maintained, and resourced to ensure the successful completion of the objectives and targets? C. Is the level of internal and external communication sufficient to achieve the desired level of environmental awareness and participation? D. Has there been any environmental legal non-compliances? 3. The EMS Coordinators will schedule the EMS Management Review session with Board in Q2 of each year. 4. During the EMS Management Review the Board will consider the information presented; ask any clarifications necessary to determine the suitability, adequacy, sustainability and effectiveness of the EMS; and make recommendations they feel are necessary to ensure the system achieves the desired level of environmental performance. Completion of the EMS Management Review will be documented in the minutes of the meeting. 5. If the nature of the Board s recommendations / action items requires that corrective and preventative action be taken, the EMS Coordinators will provide periodic updates on the status of the recommendations / action items to the Board until they are completed. 23

A4. Performance measurement procedure for managed portfolio 6.10 Responsibility Investment Managers (internal) Facilities Management 11-15 Farm Street (internal) Managing Agents (external) 6.11 Timing Quarterly reports to be issued by managing agents to Richard Bathgate and RPS. 6.12 Procedure The Excel spreadsheet tool should be issued by Helical Bar to all managing agents responsible for the day to day management of the multi-let properties in the portfolio. Agents should enter the data specified in the spreadsheet into the appropriate cells, and issue the completed information back to Helical Bar on specified quarterly dates. This information will be collated and analysed by RPS in order to ensure that it can be reported on to external stakeholders and to enable the setting of performance related targets in future. The same tool should be used to capture information on the environmental impacts arising from Helical Bar s occupation of 11-15 Farm Street. 6.13 Performance Measurement tool The tool is an Excel spreadsheet which specifies the relevant information to be captured across different property types. The following image is a snapshot of tool. Oct-Dec 2010 Any data provided in the following cells that is based on estimates rather than documented evidence should be in red text. All the rest should be taken directly from meter readings, invoices, and service charges. Shopping Centre Landlord's grid electricity consumption including car park lighting (kwh) Landlord's gas consumption (kwh) Other landlord's energy consumption - fossil fuel (kwh) Other landlord's energy consumption - renewable (kwh) e.g. geothermal or solar Landlord-only mains water consumption (m 3 ) % waste segregated onsite and specifically sent for recycling (by mass) Q4 2010 0 0 0 0 0 0.0% Office Landlord + tenant electricity consumption (kwh) Landlord + tenant gas consumption (kwh) Landlord + tenant other energy - fossil fuel (kwh) Landlord + tenant other energy - renewable (kwh) Landlord + tenant mains water consumption (m 3 ) N o cycle locking points per 100 occupants Total Q4 2010 0 0 0 0 0 0 Other energy - fossil fuel (kwh) Other energy - renewable (kwh) Mains water (m 3 ) Weight of waste recycled (kg) Own Occupied Offices Electricity (kwh) Gas (kwh) 11-15 Farm Street Total Q4 2010 0 0 0 0 0 0 Totals for all managed and occupied properties Electricity (kwh) Gas (kwh) Other energy - fossil fuel (kwh) Other energy - renewable (kwh) Mains water (m 3 ) Weight of waste recycled (kg) Totals for all managed and occupied properties in Q4 2010 0 0 0 0 0 0 24

A5. Legal Compliance Checklist 6.14 Responsibility Investment Managers (internal) Facilities Management 11-15 Farm Street (internal) Managing Agents (external) 6.15 Timing Legal compliance checklist to be completed annually by managing agents by 31 st March each year. Prior to this RPS will undertake an annual review of the checklist to ensure legal requirements are current. Facilities managers to also undertake quarterly checks. 6.16 Procedure The Legal compliance checklist should be issued by Helical Bar to all facilities managers responsible for the day to day management of agents responsible for the day to day management of the multi-let properties in the portfolio. Facilities managers should assess legal compliance against the requirements and issue the completed information back to Helical Bar on specified meeting dates. This information will be reviewed by RPS in order to ensure that it can be reported on to external stakeholders. 6.17 Compliance Checklist The following is a sample of the checklist: Key Area Key Legislation Summary of Compliance Requirements Relevance to Helical Bar & associated Managing Agents Relevant Authority & Further Information Compliance Yes / No Comments Building Chemical Usage Ecology Energy Environmental Protection Noise and nuisance Transport 25

Waste Reporting and information 26

A6. Contractors Checklist 6.18 Responsibility Project Managers (internal) Contractors Site Managers (external) 6.19 Timing Site reports to be issued by Contractors Site Managers to RPS. 6.20 Procedure The Contractors checklist should be issued by Helical Bar to all Site Managers responsible for the day to day management of development contracts undertaken on behalf of Helical Bar. Site Managers should enter the data specified in the checklist, and issue the completed information back to Helical Bar on specified meeting dates. This information will be collated and analysed by RPS in order to ensure that it can be reported on to external stakeholders and to enable the setting of performance related targets. 6.21 Checklist Helical Bar Plc is committed to reducing its effect on the environment and has implemented an Environmental Management System. As part of this, we would like our contractors to recognise where they may have an environmental impact whilst working on Helical Bar developments. Site Location / Name: Checklist completed by: Position and Company: Date: Brief description of Project: Helical Bar s Key Requirements Y N Data for energy consumption on site and comparison with 5% target Y N Data for water consumption on site and comparison with 5% target Y N N/A Details of any non-compliances or reportable accidents/incidents Y N Site Waste Management Plan or details of waste collections / quantities and comparison with target to divert 50% construction and demolition waste from landfill. Y N Details of ecology surveys and mitigation measures for the site Y N N/A Complaints Register Y N Evidence that site is registered to Considerate Constructors Scheme and copies of site visit reports, if applicable 27

Y N 50% of all new timber from certified sustainable sources - Y N Timber invoices checked to include Chain of Custody details and passed to project manager General Y N Have measures been taken to minimise any disturbance to nearby residents / commercial properties? If so, do these include: - Restricted working hours according to Local Authority guidance? Y N - Restricted working hours based on direct consultation with neighbours? Y N - Other Y N Hazardous Substance Storage Y N Are any hazardous substances (e.g. oils, fuels, solvents) stored on site? Details / storage arrangements: Y N Are spill kits available on site and is there a spill response plan? Y N Are there surface watercourses or surface drainage systems located within close proximity of any hazardous material storage? If so, have any precautions been taken to protect these from any potential pollution issues? Y N Comments: Waste Y N Is all waste stored in skips? If not, is this: - Due to space constraints? Y N - Other (please detail).. Y N Y N Is waste segregated on site? If not, is this: - Due to space constraints? Y N - Because the waste contractor sorts the waste post-collection Y N - Other (please detail).. Y N Y N Are there appropriate storage areas for building materials on site? e.g. internal areas for timber to prevent damage from weather, vandalism etc. Y N Has a Site Waste Management Plan (SWMP) been compiled and provided to the project manager? If so: Has it been updated at least every 3 months? Y N Was it kept on site during the project? Y N Do all contractors know where it is kept? Y N Has the completed SWMP been handed back to Shaftesbury? Y N 28

Will a copy of the SWMP be kept for two years? Y N How much waste (percentage) has been diverted from landfill?..% For all projects over 300,000, does it include the following points? Types of waste removed from the site Y N Identity of the person who removed the waste Y N Site that the waste is taken to. Y N Targets for resource efficiency Y N Measure put in place to divert waste from landfill Y N Biodiversity For projects over 500,000, are the following points also included? Waste carrier registration numbers of waste carriers Y N A description of the waste Y N Environmental permit or exemption for sites where waste taken Y N Y N Has an ecology report been compiled for the site? Y N Are appropriate protective measures in place for sensitive features e.g. mature trees? Comments? Y N Are any steps being made to enhance ecology at the site? e.g. green roofs, native planting, bird boxes, implementation of a Biodiversity Action Plan. Comments 29

Construction Site Impacts and Issues Y N Are any dust / mud control techniques employed on site? Damping down... Y N Other (please specify).. Y N Y N Is any monitoring of noise undertaken? Comments: Y N Is energy use and CO2 production relating to site activities on the site monitored and reported? Please provide data. Are targets set for energy CO2 production from the above sources? Y N Comments: Y N Is water use monitored and reported? Please provide data. Are targets set for water consumption from site activities? Y N Comments: Y N Are mechanisms in place to prevent water (ground and surface) pollution occurring on site? Y N Y N Have any complaints been received from neighbours? Comments: Y N Were there any invasive species (e.g. Japanese Knotweed, Giant Hogweed) that needed to be managed? Comments: 1.1.11 Timber Y N Was the sustainable sourcing of timber (e.g. FSC, PEFC) agreed in advance with the timber supplier(s) including provision of full Chain of Custody details? 1.13 Arrangements e.g. contract for 70% of all supply to be FSCcertified. Y N Do you estimate the proportion of sustainably sourced timber (i.e. FSC- or PEFC-certified timber) to be greater than 50% for the project? 30

1.15 If possible, provide approximate indication of proportion of certified timber.16 % Y N Was any hardwood used within the development? If so, is 100% from a certified source? Y N Y N Have copies of invoices/delivery notes been provided to the project manager for all timber (including non-certified timber)? This should include confirmation that the sustainably sourced timber has full Chain of Custody details typically this is shown on the invoices after each item with a code such as CU-PEFC-805629 Mixed Sources Min 70% with the supplier s certification details also shown on the invoice. 31