RILA S 2017 RETAIL SUSTAINABILITY MANAGEMENT LEADERSHIP MODEL

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1 RILA S 2017 RETAIL SUSTAINABILITY MANAGEMENT LEADERSHIP MODEL About the RILA s Retail Sustainability Management Leadership Model How to Use the Model The Model is a tool for retail sustainability executives to identify the management practices that will drive improved corporate and environmental performance. The Model is a tool that can be used for individual company and industrywide purposes. The Model is divided into seven sections, including: n Strategy & Commitment n People & Tools n Visibility n Retail Operations n Supply Chain n Products n Sustainability / CSR Issues It is intended to identify possible pathways to strong environmental sustainability programs in retail. The leading practices are currently only performed by a few companies at most; and not every company can/will achieve every leading practice. Process to Develop the Model The foundation for this Model is based the Retail Industry Leaders Association s (RILA) primary knowledge of the industry and sustainability programs, and confirmed through secondary research. It represents the collective knowledge of many industry experts through three review periods in 2015 and update reviews in 2016 and 2017 that solicited input from environmental nonprofits and experts, and numerous retailers. Individual retailers can use the Model to: n Identify the maturity of their program and opportunities for improvement n Facilitate internal conversations about the sustainability program s development n Access more funding for sustainability programs n Train employees with sustainability responsibilities n Obtain buy-in from leadership and other departments n Evaluate internal and external perception, and then evaluate gaps Program dimensions that were determined to be critical for embedding sustainability into a company s corporate culture have been noted. Retailers should focus efforts on driving improvements in these key dimensions. Retailers can refer to the Sustainability Resource Library for specific tools, case studies, and further opportunities to help them progress the maturity of their programs. Scope of the Model This Model specifically focuses on environmental impacts associated with a retailer s operations; subsequent versions may build upon this first version to include aspects of social, community, and diversity impacts as well. It will be updated periodically Other related Models include the RILA Retail Energy Management Leadership Model and the ELEVATE Responsible Sourcing Management Model. Visit to learn more about RILA s Retail Sustainability Initiative. RILA Sustainability Program Sponsors 1

2 COMPANY S SUSTAINABILITY MANAGEMENT MATURITY Note: These dimensions are solely intended to be possible pathways to sustainability optimization; the leading practice is currently only performed by a few companies at most; and not every company can/will achieve every leading practice. Dimensions Initiating Progressing Excelling Leading Transforming STRATEGY & COMMITMENT 1 Reduction strategy and goals Ad hoc efforts, no formal sustainability program or program relies on volunteers only Defined sustainability team with responsibilities on short and long-term sustainability strategy Sustainability strategy is primarily focused on operational priorities rather than sourcing or merchandising practices Defined sustainability team aligns with various key departments on sustainability strategy for the short-and long-term Sustainability strategy encompasses operations, merchandising, and sourcing practices Sustainability strategy aligns across departments and with overall corporate strategy Incorporates internationally recognized standards (e.g., UNGC, SA8000, etc.) into long-term organizational strategy Balanced scorecard (people, planet, and profit) system in place for reviewing strategies and projects Sustainability strategy and corporate strategy are fully aligned Sustainability strategy/results regularly reported to executives and the board CEO regularly incorporates sustainability strategy in meetings and communications (e.g., employee town halls / investor calls, etc.) 2 Materiality / Risk Identification 3 Ad hoc efforts to identify sustainability risks and opportunities Goals Annual goals based on cost saving only Basic sustainability goals that are benchmarked against peers Assesses risks and opportunities through a formal materiality process including stakeholder consultation Short- and long-term sustainability goals, mostly focused on operations Efforts in place to benchmark sustainability goals against peers Assesses risks and opportunities and conducts bi-annual review Assessment incorporates a timeframe of 3-6 years Identifies absolute reduction goals for most of the material risk categories (i.e., energy consumption, water, waste/recycling, sourcing, consumer education) Routine and comprehensive benchmarking efforts in place to prioritize focus areas Individual departments (e.g., sourcing, operations) review materiality assessment Uses the same processes to review sustainability risks and opportunities as corporate risks and opportunities Assessment incorporates a timeframe of more than 6-10 years Defines comprehensive, aggressive, and cross-functional goals addressing all material risk categories Goals address most aspects of sustainability Includes separate goals focused on supply chains, products, sourcing, and marketing Integration of sustainability and corporate risks Assessment incorporates a timeframe of more than 10 years Uses global and local context of environmental conditions and aligns with science-based targets to set appropriate goals Quantitatively links profit goals with sustainability goals 2

3 STRATEGY & COMMITMENT (continued) 4 Governance & Executive Engagement Ownership and accountability for sustainability is confined to one function (e.g., Environmental Health and Safety) Dedicated sustainability executive to design, manage, and continuously improve sustainability program and initiatives Sustainability council comprises senior leaders from key functional roles and meets periodically Accountability is clearly defined for sustainability goals and initiatives Board and company leadership develop and/or endorse goals and initiatives to improve sustainability Sustainability council comprises executives, defines priorities, and periodically reports to senior leaders Senior management s sustainability roles are clearly defined Board oversees and endorses sustainability goals and initiatives Dedicated executive champion for sustainability appointed by board Executives from all of the relevant parts of the business are engaged (e.g., strategy, innovation, finance, HR, legal, marketing, sourcing) Board and key executives held accountable for sustainability performance Dedicated Chief Sustainability Officer reports directly to CEO CSO & CEO partner to demonstrate business relevance of program to investors and other stakeholders 5 Corporate Values The corporate values and/or mission implicitly addresses sustainability, responsibility, stewardship, ethics, and/ or community values The corporate values and/or mission explicitly mention sustainability, responsibility, stewardship, ethics, and/ or community values The story of the company s history refers to principles of sustainability and/or stewardship; and that story is wellknown throughout the organization The corporate values and/or mission mention sustainability, and that ethos is reinforced in all major internal corporate communications, meetings, and events Senior executives regularly refer to the corporate values and history in terms of a sustainability and responsibility ethos, and use that to set the tone for the corporate culture 6 Incentives Sustainable business and leadership practices factor into annual evaluations and compensation in ad hoc ways Performance evaluation and compensation considers multiple balanced goals and performance metrics Include basic sustainability goals for select leaders as part of metrics Includes sustainability metrics in annual reviews and performance ratings for each business function Rewards (monetary or non-monetary) biggest contributions to sustainability performance Reviews mid-level management processes regularly and links it to sustainability performance Provides some incentives to influence positive personal behaviors for all employees (e.g., hybrid car or mass transit subsidy) Links executive compensation to sustainability performance Invests in incentives to influence positive employee behaviors (e.g., charging stations for electric vehicles at store or office parking lots) 3

4 PEOPLE AND TOOLS 7 Stakeholder Engagement Identifies key stakeholders to the business Identifies some stakeholder concerns on a periodic basis but no defined method of proactive engagement Assesses stakeholder concerns systematically through materiality analysis Establishes and communicates methods of stakeholder engagement Addresses stakeholders concerns through materiality analysis and identifies some KPIs from the process Builds relationships with key stakeholders Identifies comprehensive list of KPIs through stakeholder engagement process Establishes and communicates methods of stakeholder engagement by type and stakeholder group, including frequency of engagement Incorporates feedback from key stakeholders into sustainability strategy Consistently monitors and reports publicly on KPIs identified through stakeholder engagement 8 Human Resources and Corporate Communications Engagement (for Employee Engagement) Educates through environmental awareness signage in stores Works with HR to develop store sustainability team(s) or sustainability advocates to monitor on-site performance and provide feedback to corporate sustainability team Works with corporate communications team to solicit sustainability suggestions from corporate employees Hosts events for corporate employees to learn about sustainability in their retail roles and in their home (e.g., Earth Month events) Posts store sustainability performance (e.g., energy consumption, waste/ recycling generation) for all store associates to compare their store to other similar stores With corporate communications team, develops and maintains online platform for employees to review store and company sustainability performance and submit ideas to reduce environmental footprint With HR, provides collaborative forum for high-initiative employees to receive recognition for their sustainability efforts while sharing best practices with colleagues With HR, develops and administers employee orientation and ongoing training programs Embeds sustainability into existing HR and corporate communications roles Holds highly visible senior leadership meetings on sustainability where store employees, sourcing, merchants, logistics, and other staff are recognized Through existing HR and corporate communications channels, regularly educates employees on company sustainability vision and business case to underscore relevance to employee daily work Trains in-store employees to educate customers about company s sustainability/eco-awareness efforts 9 Funding Mechanisms Minimal funding dedicated for sustainability programs Basic mechanisms to track ROI of sustainability efforts Ad hoc funds for sustainability programs (e.g., energy efficiency, recycling programs, marketing, etc.) Conducts some adjustment of ROI on internal projects to account for sustainability metrics Dedicated fund for sustainability programs (e.g., energy efficiency initiatives, recycling programs, etc.) Key retail functions include sustainability budgeting (e.g., distribution, sourcing, merchandising, store operations) All corporate funding requests routinely include relevant sustainability metrics ROI of projects considers total cost of ownership and reputational value Corporate funding requests always include sustainability metrics relevant to the division or business unit Sustainability-related funding on an upward trajectory over time 10 Corporate Giving, Foundation, and Volunteerism Ad hoc giving and volunteering, mainly to local charities Identified head of corporate giving Centralized tracking and reporting of giving and volunteer efforts Coordinated product and/or food donations, and volunteering, perhaps with nationwide nonprofit partner Customer-facing messaging about corporate philanthropic efforts Strategic and signature giving and volunteer campaigns targeting specific constituents in local communities Coordinated international, national, and local efforts Strategic programmatic partnerships with NGOs and others to address specific needs of supply chain workers 11 Business Innovation Mechanisms Ad hoc channels in place to invest in sustainable innovation (e.g., 3D printing, RFID innovations, mobile, etc.) Innovation mechanisms in place - sustainability is a criteria but not weighted to receive favorable score Innovation mechanisms in place to invest in sustainable innovations Solicits ideas from employees, suppliers, and external stakeholders Dedicated team to create and invest in sustainable innovations Innovation fund and dedicated team in place to invest in retail innovation around sustainability Chief Innovation Officer incorporates sustainability and continuous improvement into goals 4

5 VISIBILITY 12 Metrics & Measurement Ad hoc metrics defined for sustainability Limited set of sustainability metrics focused mainly on operations Basic Excel spreadsheets used to track metrics Metrics informed by materiality assessment and aligned to global frameworks (e.g., GRI, IIRC, SASB) Sustainability metrics tracked for some regions of the global business Measurement tools track metrics Sustainability metrics focused on all material aspects, including innovation Sustainability metrics tracked for all of the most relevant regions of the global business Automated measurement tools; IT systems in place to periodically track the majority of sustainability metrics Comprehensive metrics defined to cover all aspects of sustainability; linking people and planet with profit Material metrics chosen from most global frameworks with rationale for metric selection clearly communicated Metrics captured consistently across global organization 13 Storytelling through Reporting & Communicating Regularly published report contains cursory mention of sustainable business practices Some limited sustainability/csr information is available on website (e.g., a dedicated web page, or grouped with corporate philanthropy) Company either publishes a sustainability report on a regular basis, or provides detailed web pages covering all aspects of sustainability Sustainability report includes both quantitative metrics and qualitative stories Sustainability information is readily accessible in multiple formats and sustainability goals publicly articulated and tracked Includes a balanced and honest discussion of challenges as well as progress Discloses climate change, water, or forest-risk impacts as part of the Carbon Disclosure Project (CDP) Scores in top of peer groups in sustainability measures and indices (e.g., Dow Jones Sustainability Index, CDP) Uses 3rd-party standards (e.g, GRI) Sustainability statements are independently audited Communicates sustainability programs in multiple, accessible formats (e.g., websites, product marketing and labeling, advertising) Uses integrated reporting Focused multi-channel sustainability campaign with features such as an interactive sustainability website Communicates sustainability as integrated with brand ethos 14 Storytelling through Pointof-Purchase Consumer Education Few products are explicitly designed to reduce negative environmental impacts Limited education for consumers to learn about sustainability dimensions of products Some specifically designated products offered have sustainability benefits; ad hoc communication on the benefits of those products High percentage of products offered have specific sustainability benefits; regular communication on the benefits of those products Provides some information or tips to consumers to use products/services in a responsible way (e.g., Please recycle this cup, Wash this garment in cold water ) Dedicated online storefronts encourage consumers to select products with sustainability benefits Provides consumers with tools or incentives for sustainable behavior change even after the purchase (via website, product packaging, etc.) Significant in-store signage or sections dedicated to products with advanced sustainability benefits Engages consumers about products with sustainability benefits (e.g., catalogs, web filters, icons, online calculators, product stories) Actively engages with customer even after the purchase (via website, product packaging, etc.) to mitigate any environmental impact of products Most own-brand products have advanced sustainability benefits, and communicate benefits on packaging 15 Storytelling through Marketing Campaigns Ad hoc sustainability-related marketing campaigns Regular sustainability-related marketing programs Tend to focus on specific themes or times (e.g., Earth Day) Ongoing efforts and funding related to marketing sustainable products and services Dedicated sustainability-focused marketer within marketing team Marketing effectiveness metrics focus on reputation/brand value Significant marketing budgets for sustainability-related marketing Marketing effectiveness metrics include financial ROI 16 Collaborative Involvement Ad hoc peer engagement on sustainability issues Actively shares sustainability information with peers Member of one or more industry associations focused on sustainable supply chain issues Actively collaborates with peers to make positive impact within industry Premier member of one or more industry associations or multilateral groups focused on relevant sustainability issues Partners with NGOs, governments, academia, or other institutions to identify improvement opportunities Takes a leadership role in developing new tools or capabilities that will enable peers to improve sustainability impact or supply chain sustainability performance 5

6 RETAIL OPERATIONS 17 Stores / Corporate Offices (Green Building & Land Use) Construction, renovation, and leasing decisions adhere to local regulations, but little or no green standards Environmental impact, energy use, and occupant health are considered in a minor way Incorporates some green building opportunities into construction, renovation, or leasing projects Opportunities are limited to lower-cost options (e.g., efficient toilets, faucets, light bulbs, and ceiling fans; recycled / reclaimed flooring; low-voc paint) Small percent of facilities have ENERGY STAR or LEED certification Routinely incorporates sustainability metrics into construction, renovation, and leasing decisions Accounts for sustainability factors (e.g., recycling infrastructure, alternative transportation for customers, etc.) in store site selection Higher percent of facilities have ENERGY STAR or LEED certification Majority of store site incentivizes customers to practice sustainable behaviors (e.g., premium parking spaces for hybrid or electric vehicles) At least half of facilities have ENERGY STAR or LEED certification Implements smart landscaping at some store and warehouse sites to improve water efficiency Green building and certification (LEED, BREEAM, Living Building Challenge, ENERGY STAR, etc.) is expected on all projects, except in extreme cases Routinely employs smart landscaping, solar panels, wind turbines, or other technologies in the design and construction of new stores and warehouses 18 Warehouses/ DCs Storage facilities employ ad hoc ecoefficient technologies or practices Emissions are compliant but not fully inventoried Programs are in place to minimize waste and improve work flow Upgrades moving technologies (forklifts, automated belts, etc.) with energy-efficient power sources Installs low-energy lighting, HVAC, and refrigeration equipment Redesigns warehousing facilities in order to optimize space and reduce energy consumption Continuously minimizes footprint and resource consumption to create best uses for storage space and replaces nonsustainable products Regularly adds new technology to reduce energy consumption in moving and storing goods within warehouses Incorporates green standards for all new warehousing to minimize energy and safety costs Incorporates green standards for all new warehousing or retrofits existing warehousing to minimize energy and safety costs Develops partnerships with customers, upstream processes, and transportation vendors to maximize flow of goods through facilities while minimizing energy and waste 19 Data Center & Applications Application development has ad hoc awareness of potential techniques for greening Sizing and layout of owned or contracted data center infrastructure is ad hoc and geared towards meeting current needs There are ad hoc decisions around green IT considerations Reduces redundant functions in inventory of applications Employs some efforts to consolidate applications Takes advantage of new efficiency methodologies in application development Identifies and monitors some green metrics around power, cooling, and airflow Considers and tracks green impact along with other business objectives in data center Shares applications and related platforms across business units Software development lifecycle regularly uses new efficiency technologies (e.g., virtualization, SOA and other sharing and flexible technologies) Follows green technology standards throughout organization Fully leverages enterprise software across the organization to maximize use/capabilities Actively tracks green metrics against business green objectives Participates in ENERGY STAR recognition program for energy efficient data centers All data center build outs or contracts must pass through a rigorous green evaluation process before approval Seeks to improve ENERGY STAR scores for all data centers Employs effective big data strategies to analyze sustainability data and metrics 6

7 SUPPLY CHAIN 20 Transportation / Logistics Aware of impact of transportation decisions on the environment Baseline emission measurements Sustainable transportation initiatives are in early planning stages Employs improved blend of rail, road, and air transportation modes Includes capacity management as a criteria in managing distribution Uses or tests some alternative fuels in transportation vehicles Participates in EPA SmartWay Packaging and transportation system designs concurrently occur to optimize flow of goods and minimize space and energy usage Develops innovative shipping mechanisms to maximize load capacity Uses reusable containerization for nearly all products Recognized EPA SmartWay Carrier and Shipper with a high ranking score Demonstrates reduction of environmental impact by optimizing transportation and warehouse network Replaces vehicle fleet with green vehicles Considers emissions when selecting transportation vendors Forms transportation alliances to maximize load capacity and minimize waste Recognized excellence in reducing environmental impact from transportation strategies 21 Supplier Engagement for Responsible Sourcing (see the ELEVATE Responsible Sourcing Model) Supplier code of conduct addresses various environmental aspects Audits suppliers according to a risk profile or in response to problems Incorporates key sustainability considerations into initial supplier onboarding and ongoing sourcing decisions Supplier code of conduct incorporates all dimensions of recognized industry standards (e.g., SA8000) Delivers some training or guidance to suppliers on sustainability opportunities Performs mix of internal and external audits on a regular basis according to supplier risk profile Works closely with suppliers to remediate sustainability issues Assesses all suppliers according to sustainability criteria Supplier code of conduct includes measurable sustainability metrics that auditors can objectively check Employs expert auditors to check suppliers according to supplier risk profile Tracks supplier sustainability performance quantitatively over time Actively collaborates with suppliers to capture shared savings through improvements in sustainability performance Develops remediation plans in collaboration with supplier and closely monitors quantitative progress against them Sourcing/merchandise teams use sustainability scorecards as integral part of sourcing decisions Hosts annual Sustainability Summit with key suppliers/vendors Encourages vendors to improve and report on sustainability metrics (e.g., energy, waste, water) of their products, possibly leveraging services like CDP Supply Chain Works closely with suppliers to monitor subcontracting arrangements Encourages sustainable manufacturing practices for all products and suppliers, with a focus on ensuring suppliers financial viability Relevant departments test and actively partner with research groups or vendors to design next generation equipment for sustainable performance Defines and executes on appropriate actions with suppliers failing to meet performance criteria 22 Supply Chain Transparency & Traceability Publishes information on suppliers or country of origin to comply with relevant laws Publishes some summary audit statistics (e.g., percentage of factories non-compliant) Publicly discloses where products are made (without factory-specific details) May disclose some anecdotal factoryspecific information Makes audit results available publicly (e.g., through FLA) Supply chain information is available through a number of channels/media Publishes supplier code of conduct and summary of monitoring and enforcement mechanisms Efforts to trace supply chain from suppliers to subcontractors/vendors back to raw materials suppliers Active member of supply chain transparency organizations (e.g., CDP Supply Chain, TSC, SAC) Explains challenges in the supply chain through a number of channels (e.g., website, reports) Works with credible third parties to introduce sustainable best practices (e.g., FSC, MSC) Actively markets supply chain stories to consumers Publishes list of factories and locations, with stories, photographs, or other information on all key suppliers 7

8 PRODUCTS 23 Product & Packaging Design and Development Minimal attention given to packaging optimization Ad hoc measures employed to reduce product impacts such as the purposeful merchandising of products using credible certifications (e.g., FSC, fair trade) and general pronouncements or guidelines to suppliers to minimize product and packaging impacts Employs credible criteria to evaluate sustainability performance of most major product categories Collaborates with suppliers to identify, develop, and market product/service innovations that further reduce environmental impact Employs credible criteria to evaluate sustainability performance of all major product categories Sets meaningful business-relevant revenue targets for product sustainability performance (e.g., 30% of sales will come from products that meet design criteria) Designs all products, or works with all suppliers, for a cradle to cradle outlook, using tools based on life cycle and hazard assessments Publicly reports on product sustainability goals and the net benefits of product sustainability performance 24 Owned Manufacturing / Production Basic understanding of sustainability principles and practices Sustainability principles have been incorporated to meet regulatory requirements Develops plans and policies to make manufacturing processes more sustainable (including agricultural practices as applicable) Sets targets for key sustainability KPIs (e.g., waste, GHG, water) inclusive of raw material, manufacturing, and other production activities Measures against those targets and communicates success and improvement opportunities to facilities Benchmarks key environmental and social sustainability KPIs against industry standards and exceeds industry average Sets plans to achieve aspirational goals (e.g., 100% renewable power, zero waste, zero accidents) Uses renewable energy sources in most manufacturing processes with limited exceptions Achieves world class sustainability manufacturing/production levels Publicly reports success against aspirational goals 25 Product & Packaging End-of-Life Stewardship Ad hoc recycling or product take-back initiatives available to customers Some limited mechanisms in place to design own-brand products that consider reuse or recyclability at end of useful life Offers select recycling and product takeback bins in some retail locations Designs some own-brand products to consider reuse or recyclability of product at end of useful life Offers select recycling and product takeback bins in all retail locations Designs a whole line of own-brand products to consider reuse or recyclability at end of useful life Collaborates with other stakeholders (e.g., trade associations, civil society, competitors, value chain) for system change to upcycle/recycle product components Markets product take-back services to consumers as a competitive differentiator Designs all own-brand products to consider reuse or recyclability of product at end of useful life Actively retrieves products at the end of life for reuse and recycling Measures and reports the percentage of reclaimed products and their packaging materials for each product category Begin designing and selling consumer services to mitigate the one-way consumption cycle 8

9 SUSTAINABILITY & CSR ISSUES 26 Employee engagement, wellbeing, development, and inclusion Complies with worker health & safety regulations Defined employee code of ethics or code of conduct Provides basic wellness programs like local courses and awareness campaigns Employee medical benefits and leaves of absence offered at industry norm Defined employee job satisfaction or engagement program; periodic surveys and other mechanisms to measure job satisfaction Wellness program includes benefits (e.g., disease management coaching, nutrition counseling, tobacco cessation, health risk assessments, ergonomic work station support) Employee benefits include industry norm offerings above medical and leave (e.g., flexible work arrangements, tuition reimbursement, savings and retirement benefits, an Employee Assistance Program, and Employee Discounts) Talent Management Program with a competency model in place, development discussions and planning, and an active review process Strategic employee engagement and professional development programs include real-time feedback mechanisms, and are tied to company values, a competency model, and workforce/ development planning Company recognition programs aligned to values and performance Affinity or Employee Resource Groups (ERGs) to connect employees around common interests Wellness programs include fitness challenges, online health management tools, or on-site clinics Employee benefits include competitive elements (e.g., student loan assistance, paid family leave, paternity leave, and healthcare education) Defined workplace inclusion program that actively draws on employees diversity of knowledge, resources, abilities, and experience Goal to be best-in-class employer Career development programs (e.g., crowd-sourced and actionable feedback, company universities, mentoring programs, talent mobility, and developmental assignments that are integrated with succession and workforce planning) Wellness is integrated with company culture and includes programs such as on-the-clock fitness breaks Employee benefits include pace-setting elements (e.g., unlimited vacation) Employee development, wellbeing, and inclusion is recognized for its return on value and integrated with company strategy and values Career development and talent management is based on HR analytics and includes next level practices (e.g., gamification, mobility assignments with external stakeholders, mobile talent pools, individual customization) Global leadership candidates participate in ERGs and the company leverages cognitive diversity to drive innovation Wellness is no longer a program, but a culture of wellbeing thrives and environmental health is also of focus Benefits include progressive offerings (e.g., telemedicine, free electric car charging) 27 Energy & GHG Emissions (see the RILA Retail Energy Management Leadership Model Energy usage is measured or analyzed in ad hoc ways Measures and analyzes current energy usage and future projections of retail portfolio in manual or fragmented way Outdated, inefficient equipment has been replaced Undertakes some investigation of alternative energy sources Draws a minimal amount of energy from alternative sources Develops coordinated energy efficiency policies across operations and value chain Designs and executes systematic energy management program (e.g., data tracking, training of relevant employees) Uses only energy efficient refrigeration equipment and tracks GHG emissions of equipment continually Capital expenditure decisions consider energy cost implications Relies on alternative energy for 25% or more of energy needs, through combination of RECs and onsite generation Sets internal carbon price as means to measure and reduce GHG emissions Relies on alternative energy for 40% or more of energy needs, through combination of RECs and onsite generation Joins external alliances to drive energy/ climate policy 9

10 SUSTAINABILITY & CSR ISSUES (continued) 28 Water & Wastewater Ad hoc strategy to reduce water consumption in retail operations Measures current water usage of stores, warehouses, distribution centers, and offices across some portion of the portfolio Conducts comprehensive water footprint across retail portfolio, including stores, warehouses, distribution centers, and offices to understand where impacts lie Efforts and technologies in place to minimize company s direct water usage, such as low-flow faucets Conducts comprehensive water footprint exercise across value chain, to develop reduction strategy Efforts and technologies in place to recycle water Identifies water withdrawal sources and communicates localized risks Pursues innovative water reduction techniques such as grey water recycling, xeriscaping, storm water management, etc. Identifies water withdrawal sources and remediates any localized risks 29 Waste & Recycling Aware of main sources of waste generation in company operations Measures waste footprint of stores, warehouses, distribution centers, and offices across some portion of the portfolio Ad hoc efforts to reduce and recycle waste at stores, warehouses, distribution centers, and offices Measures waste footprint across retail portfolio, including stores, warehouses, distribution centers, and offices, comprehensively Implements waste minimization programs involving reduction, reuse, and recycling at stores, warehouses, distribution centers, and offices Implements leading waste technologies and policies (e.g., balers for hard-torecycle materials, customer recycling options) Waste reduction targets and continuous improvement method in place for products, supply chain, and operations Commitment to zero waste goals at some retail locations Conducts comprehensive waste footprint exercise across value chain Efforts in place to completely remove hazardous waste from retail operations, product development, and supply chain Commitment to zero waste goals across all locations 30 Chemicals & Toxics Complies with environmental regulations Maintains a list of regulated chemicals or a restricted substance list (RSL) Undertakes beyond-compliance measures to reduce the use of certain chemicals and toxics across the value chain Defines relevant metrics to monitor use of certain chemicals and toxins throughout value chain Defines goals around use of chemicals and toxics in products Understands sources of toxins throughout value chain and why they are present Establishes green chemistry program with the goal of reducing toxics across the value chain Conducts comprehensive assessment of chemicals in products and processes, with an evaluation of hazard and exposure potential Establishes alliances with industry peers to further green chemistry innovation Communicates green chemistry policies to suppliers 10

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