Global Environmental Policy

Transcription

1 Global Environmental Policy I. Purpose General Motors Company (GM) is proud of its long-standing commitment to protect human health and the environment. As a responsible corporate citizen, we continually assess the environmental impacts of our activities, products and services as a basis for our Global Environmental Policy and are committed to reducing or eliminating wherever practicable these impacts through the establishment of appropriate objectives and targets. This policy establishes a globally consistent standard intended to protect the environment by establishing sound design, engineering, manufacturing and distribution practices that support compliance while minimizing negative environmental impacts. II. Principles and Values The foundation of this policy is a set of core principles and values that have been in place for more than 20 years. Environmental Principles As a responsible corporate citizen, GM is dedicated to protecting human health, natural resources and the global environment. This dedication reaches further than compliance with the law to encompass the integration of sound environmental practices into our business decisions. The following Environmental Principles provide guidance to GM personnel worldwide in the conduct of their daily business practices. 1. We are committed to actions to restore and preserve the environment. 2. We are committed to reducing waste and pollutants, conserving resources and recycling materials at every stage of the product life cycle. 3. We will continue to participate actively in educating the public regarding environmental conservation. 4. We will continue to pursue vigorously the development and implementation of technologies for minimizing pollutant emissions. 5. We will continue to work with all government entities for the development of technically sound and financially responsible environmental laws and regulations. 6. We will continually assess the impact of our plants and products on the environment and the communities in which we live and operate with a goal of continuous improvement. In addition, as an integral part of our commitment to conserve resources: We are committed to energy conservation and will continue to pursue the use of renewable energy sources to power our operations. We are committed to responsibly using water and taking actions that preserve water quality and conservation across our operations. United Nations Global Compact In 2015, GM joined the United Nations Global Compact, which endorses a framework of principles in the areas of human rights, labor, the environment, and anti-corruption. GM s commitment supports the Global Compact s ten principles and the company s intent to maintain the

2 principles and to evaluate related global best practices that may be applicable to GM. Of these ten principles, Environment is specifically tied to Principles 7, 8 and 9, which state: UNGC Principle 7 Businesses should support a precautionary approach to environmental challenges. UNGC Principle 8 Businesses should undertake initiatives to promote greater environmental responsibility. UNGC Principle 9 Businesses should encourage the development and diffusion of environmentally friendly technologies. III. Policy Owner, Policy Contact, Policy Interpretation The Executive Director, Global Regulatory Affairs, Environment, Energy, and Safety Policy or his/her designee is the owner of this policy and is responsible for policy interpretations. The policy contact is the Manager, Environmental Policy. IV. Applicability This policy applies globally to all GM Operating Units (including their employees globally). In addition, this policy applies to consultants, agents, sales representatives, distributors, independent contractors, and contract workers (collectively, GM Representatives ) when they perform work for GM. V. Superseded Policy Environmental and Energy Policy (Policy PPC-08) Environmental Safety & Hygiene Policy (EH&S-01) VI. Compliance This Policy is mandatory and is subject to audit by GM Audit Services. VII. Definitions GM Operating Unit Manufacturing and non-manufacturing locations where GM designs and builds vehicles and components, and all other locations where GM conducts business to support its operations. These locations include but are not limited to assembly, stamping, global propulsion systems, components, distribution centers, warehouses, training centers, technical and engineering centers, proving grounds, as well as office buildings. GM Operating Unit does not include: i. a subsidiary (including a joint venture) in which GM owns directly or indirectly less than fifty percent (50%) of the equity or which GM otherwise does not control; ii. third party suppliers with contractual operational control operating on GM-owned or GMleased property; and iii. dealerships where the real estate is owned or leased by GM, but the dealership is operated by a third-party under a franchise or other agreement; provided, however, that in the event a dealership is operated directly by GM, such dealership would be considered a GM Operating Unit for purposes of determining applicability of the EPC. 2

3 VIII. Policy GM Operating Units are responsible to understand and comply with all applicable laws and regulations, as well as conform to any applicable GM policies, standards, procedures and performance criteria. In the absence of an equally protective or more restrictive country legal standard, each GM Operating Unit must: Environmental Requirements Provide qualified resources and adequate budgets to manage environmental activities. Develop, implement, sustain, regularly assess and improve the management system in order to achieve continual improvement of environmental performance. Management systems must be relevant to the size and complexity of the operation, and perform at a level that is consistent with (has the appropriate elements), or exceeds globally recognized management systems standards (e.g., ISO standard for environmental systems, GM Global Manufacturing System). In the evaluation, formation, and management of joint ventures (JV), GM must ensure that environmental requirements are incorporated into the JV Agreement. Install and maintain structural containment and/or administrative controls to prevent releases of chemicals and other materials of concern from: stationary aboveground tanks used to store process fluids and liquid wastes, tanker truck loading/unloading areas, and storage areas for portable containers. Provide accurate and timely environmental metrics and data through sound reporting practices. This data is the basis for internal and external reporting. When known impacts to human health and environment exist, GM must take action to determine the nature and extent of such condition, and where shown to be necessary, develop and implement a corrective action plan. Identify, characterize, document and properly dispose of all waste materials in a legally compliant manner that considers the waste hierarchy: prevent, minimize, reuse, recycle, energy recovery and disposal. Conserve resources by setting targets related to energy, carbon and water usage. Document and describe performance requirements to manage air emissions generated from its operations. Document and describe performance requirements to manage stormwater, process wastewater, and sanitary wastewater generated from its operations. For GM Operating Units that discharge process and/or sanitary wastewaters directly to surface waters, a wastewater treatment plant must be installed and properly maintained. Prior to entering into transactions that involve an interest in real property, perform an evaluation of facility operations and property environmental conditions to gauge and understand potential environmental risks and liabilities. Secure all necessary environmental permits and comply with such permits as required by the applicable laws and regulations. Periodically evaluate the structural integrity of underground storage tanks and associated ancillary piping, and establish construction requirements for all new underground tanks used to store process fluids and liquid wastes. Policy Governance and Oversight The Environmental Compliance Oversight Committee (ECOC) provides environmental policy governance and oversight. The ECOC is chaired by the Executive Director, Global Regulatory Affairs, Environment, Energy, and Safety Policy and the Executive Vice President of Global 3

4 Manufacturing. Additional committee members include: the General Auditor, Legal Staff Environmental Practice Area Manager, and the Vice President of Sustainable Workplaces. The ECOC was formed at the direction of the GM Executive Oversight Committee (management leadership group appointed by the Board of Directors and Chief Executive Officer) and meets at a minimum of three times per year, or as required, to establish policy direction and monitor the compliance status of GM s environmental management systems. If requested, the ECOC will periodically report out to the GM Executive Oversight Committee on the status of GM s environmental compliance. In the annual review and oversight of the environmental policy, GM is committed to engage external stakeholders in the policy development process. Oversight Roles and Responsibilities All employees are required to follow this policy. The following key groups provide oversight: Public Policy Center Responsible for driving policy development and monitoring policy implementation. Sustainable Workplaces Eco-System Services Budgets for and manages global environmental resources (includes corporate, regional and plant environmental staff). Develops and implements environmental procedures and control programs that support policy and compliance. Supports the development and implementation of the GM Operating Unit environmental programs and actively monitors the level of environmental compliance/conformance with legal and policy requirements. Legal Staff Provides legal advice to support compliance at the policy development level as well as providing support to GM Operating Unit compliance programs. Audit Services Responsible for periodic auditing of GM Operating Units to ensure that effective risk and control practices are in place and operating in a globally consistent and compliant manner that at a minimum meets legal requirements and this policy. GM Operating Units Understand and comply with all applicable environmental laws and regulations, as well as any applicable GM environmental policies, procedures, standards, and performance criteria and provide appropriate resources and adequate budgets to ensure that all employees understand and execute their day-to-day environmental responsibilities. Ensure that all projects are funded to meet all GM environmental policies, procedures, standards, and performance criteria. Performance Self-Assessments As part of a robust management system, each GM Operating Unit must establish a process to periodically monitor the level of compliance to country specific laws and regulations and conformance to GM environmental policies, standards, procedures and performance criteria. These self-assessment activities must be capable of driving effective corrective and preventative action. Assessments must be conducted in full conformance with the requirements outlined in company procedures and the GM Operating Unit s management system(s). Record Keeping Governmental laws and regulations require specific documents and records to be maintained. Additional record keeping requirements may be specified in operating permits, licenses, consents or by other GM policies. Record keeping requirements may include many types of records, such as incident reports, manifests, monitoring data, and training records. All GM Operating Units must fully assess their record keeping responsibilities and implement a program that ensures a level of compliance that is accurate, truthful and complete. 4

5 Reporting Certain laws require timely notification and/or reporting to government agencies for certain types of incidents (e.g., injuries, chemical releases, etc.). The GM Operating Unit must understand all of its reporting obligations and ensure that a process is in place to report all compliance information timely, accurately and responsibly to corporate staffs and regulatory authorities. In addition, GM Operating Units must provide accurate and timely environmental metrics and data through sound reporting practices. This critical data is the basis for internal and external reporting. However, no internal corporate reporting is required as part of this policy. Speak Up for Safety Employees responsible for compliance with environmental laws, regulations and this policy may discover issues related to safety. It is GM s expectation that employees will Speak Up for Safety, either openly or anonymously, when they become aware of a workplace or vehicle-related issue. Employees are encouraged to report concerns first to their supervisor, HR contact, Legal Staff contact, or local leadership. In cases where an individual is uncomfortable reporting through established internal channels, reports can be made using the Speak Up for Safety or the Awareline program, if appropriate to do so in their region. IX. Related Regional/Country Policies Dangerous Goods Compliance Policy DGT-01 Global Safety and Industrial Hygiene Policy S&IH-01 Global Environmental Performance Criteria (EPCs) Executive in Charge: Executive Director, Global Regulatory Affairs and Environment, Energy & Safety Policy 5