Princes Square Shopping Centre Sustainability Policy June 2014
Contents 2 Sustainability Policy
Princes Square s Environmental Management System (EMS) describes our strategy for managing our environmental aspects and lays down the foundation for continual improvement. This EMS sets out our vision, objectives and priorities for effectively managing our environmental obligations. Following these policies ensures that Princes Square Shopping Centre fulfils its responsibility to our client, stakeholders, occupiers, local community and future generations through the protection of the environment and also ensures our statutory compliance. Our EMS includes two documents: 1. Princes Square Sustainability Policy Provides a framework for effectively managing our significant environmental aspects and impacts. Includes: Glossary Legal Register 2. Sustainability Assessment Provides a site specific platform for identifying our environmental aspects, evaluating legal and system compliance, and establishing our environmental action plan for achieving our environmental objectives.
2 Sustainability Policy Scope Princes Square Shopping Centre comprises a mix of retail and restaurant units, showcased over 5 levels under a glass ceiling and built around a central courtyard space., located in central Glasgow. Vision The Management Team at Princes Square recognises that our business activities and services have both direct and indirect impacts upon the environment. Our policy is to minimise these impacts, prevent pollution, reduce energy consumption, reduce waste, comply with our legal obligations and to continually improve our environmental performance. Objectives Promote environmental initiatives, and best practice Comply with legislation Comply with SEPA Pollution Prevention Guidelines. Reduce energy consumption Minimise wastage Improve and increase recycling; our target is zero to landfill. Engage with environmentally responsible suppliers and contractors Encourage community engagement. Priorities Legal compliance Client requirements Cost control Pollution prevention Achieve ISO14001 certification Signed: Date: June 2014
The following diagram illustrates the methodology implemented throughout this environmental management system (EMS) to ensure continual improvement in our environmental performance. BENCHMARKING MANAGEMENT REVIEW POLICY SYSTEMS PLANNING & DEVELOPMENT POSITIVE REPORTING TRAINING CLOSE ACTIONS SUSTAINABILITY ASSESSMENTS MANAGE ACTIONS CORPORATE SOCIAL RESPONSIBILITY RECORD FINDINGS & IDENTIFY ACTIONS
Operations Manager Management Surveyor Client Management Team Security Contractors
Purpose Scope Accountability Responsibility To maintain a culture which promotes the highest standards of environmental management. To ensure that all environmental aspects are identified and that objectives and targets are set to minimise detrimental impacts and to promote positive impacts Operational Management of Princes Square Shopping Centre Operations Manager and Surveyor All staff 5.1 ENVIRONMENTAL PLANNING PROCEDURES REF. PROCEDURE RESPONSIBILITY REVIEW REFERENCE, MEASURING & MONITORING, KPI, FORMS 5.1.1 Promote a culture in which environmental management is recognised, valued and demonstrates commitment to continual improvement. Operations Manager and all site staff Annual EMS, RiskWise, Sustainability Assessment, H&S audits 5.1.2 Princes Square will communicate the Policy, objectives and targets to all stakeholders and occupiers via our website, memos and notice board. Operations Manager and all site staff Annual Policy
5.1 ENVIRONMENTAL PLANNING PROCEDURES REF. PROCEDURE RESPONSIBILITY REVIEW REFERENCE, MEASURING & MONITORING, KPI, FORMS 5.1.3 Princes Square will define the environmental aspectswe control and those that we can influence. Significant environmental aspects identified are taken into account in establishing, implementing and maintaining our environmental management system (EMS). Our objectives will take into consideration technological advances as and when they are developed. Operations Manager, Consultantsand Surveyor Annual EMS, Sustainability Assessments, Energy Reports etc... 5.1.4 The OperationsManager will ensure systems and processes are in place to achieve our objectives, Annual EMS, RiskWise, Sustainability Assessment, H&S audits
5.1 ENVIRONMENTAL PLANNING PROCEDURES REF. PROCEDURE RESPONSIBILITY REVIEW REFERENCE, MEASURING & MONITORING, KPI, FORMS 5.1.5 Princes Square will maintain an upto-date legal registerapplicable to our significant environmental aspects. 5.1.6 Princes Square will determine what site specific environmental obligations arise from client and lease obligations. Operations Manager & Consultant Annual Legal Register Section 9 Surveyor Annual Client Contract, Leases, Client KPI requirements 5.1.7 Legal and client obligations are taken into account in establishing, implementing and maintaining our EMS. Operations Manager Consultantsand Surveyors Annual EMS, Sustainability Assessments, Client Reports 5.1.8 Princes Square will establish targets for reducing environmental impact and promoting positive impacts where feasible and financially viable. Operations Manager, Consultants and Surveyor Annual EMS, Sustainability Assessments, Energy Audits, Client Reports
Purpose Scope Accountability To ensure the effective implementation and operation of our EMS. Operational Management of Princes Square Shopping Centre Operations Manager Responsibility All Staff 6.1 IMPLEMENTATION & OPERATIONAL PROCEDURES REF. PROCEDURE RESPONSIBILITY REVIEW REFERENCE, MEASURING & MONITORING, KPI, FORMS 6.1.1 Princes Square will make provision for adequate resources to establish, implement and review our EMS. Operations Manager and Surveyor Annual Budget 6.1.2 Princes Square will appoint a representative to ensure that the EMS is established, implemented, maintained and regularly reported to the Client. 6.1.3 Princes Square will ensure that staff are competent to perform their duties and that they are aware of the importance of following our EMS and procedures Operations Manager Annual Client Reports Operations Manager, Annual Staff Training Records, Contractor Training Records
6.1 IMPLEMENTATION & OPERATIONAL PROCEDURES REF. PROCEDURE RESPONSIBILITY REVIEW REFERENCE, MEASURING & MONITORING, KPI, FORMS 6.1.4 Environmental awareness will be communicated to all site staff and contractors 6.1.5 Princes Square will ensure that a Site Specific Sustainability Assessment is undertaken. These assessments identify the significant environmental impacts and the necessary controls required to minimise them. Operations Manager Annual Staff Training Records, memos, notices, presentations. Operations Manager Every 2 Years Site Sustainability Assessments,. 6.1.6 Operations associated with significant environmental impacts will be controlled by following site procedures, regular briefings and training programmes. 6.1.7 Princes Square will prepare and test environmental emergency response plans to demonstrate effective management during an emergency incident such as: Flooding Spillage/leak Fire (fire-fighters run-off) Operations Manager and all site staff Operations Manager and all site staff 6 monthly Site Sustainability Assessment, Memos, Training Records, Procedures 6 monthly Emergency Plans, Emergency Preparedness Tests
6.2 DOCUMENT CONTROL PROCEDURES REF. PROCEDURE RESPONSIBILITY REVIEW REFERENCE, MEASURING & MONITORING, KPI, FORMS 6.2.1 All EMS documentation will be approved by the Operations Manager prior to loading onto RiskWise. 6.2.2 All EMS related records will be maintained, stored and readily retrievable either through the Events / Inspection Log on RiskWise or in dedicated files maintained by the Operations Manager. Operations Manager Annual EMS, Legal Register, Sustainability Assessment OperationsManager Annual Audits, Inspections, Sustainability Assessments, Energy Audits etc... 6.2.3 All EMS records loaded onto RiskWise will be retained indefinitely and all other records will be maintained for a minimum of 3 years or longer where legislation specifies. OperationsManager Annual Audits, Inspections, Sustainability Assessments, Energy Audits etc...
Purpose Scope Accountability Responsibility 7.1 CHECKING To ensure the effectiveness of our EMS to achieve our objectives Operational Management of Princes Square Shopping Centre Operations Manager and Surveyor All Staff REF. PROCEDURE RESPONSIBILITY REVIEW REFERENCE, MEASURING & MONITORING, KPI, FORMS 7.1.1 The Sustainability Assessment will be reviewed annually to ensure continued compliance. OperationsManager Annual Sustainability Assessment 7.1.2 An annual audit will be established to ensure the effectiveness and adherence to the EMS system in accordance with the requirements of ISO14001. Frequency and location of audits will be based on significant environmental impacts, legal requirements, client obligations and historical evidence stored on RiskWise. Operations Manager and Consultant Annual ISO14001 audit report
7.1 CHECKING REF. PROCEDURE RESPONSIBILITY REVIEW REFERENCE, MEASURING & MONITORING, KPI, FORMS 7.1.3 All non-conformities/actions identified from the sustainability assessments, energy audits and EMS audits will be logged on RiskWise and monitored through to completion by the Operations Manager. 7.1.4 The OperationsManagerwill monitor corrective actions arising from audits, assessments and compliance checks to identify commonality and establish additional controls or actions. Operations Manager 6 monthly RiskWise, H&S audits Operations Manager 6 monthly EMS
7.1 CHECKING REF. PROCEDURE RESPONSIBILITY REVIEW REFERENCE, MEASURING & MONITORING, KPI, FORMS 7.1.5 The Operations Manager will report monthly to the Client on the performance of the EMS including: audits results compliance with legal requirements compliance with other requirements to which Savills have subscribed communication with external interested parties, including complaints status of objectives and targets status of corrective and preventative action follow-up actions from previous reviews operational changes including changes to legislation any recommendations for improvement 7.1.6 Outcomes from the client meetings shall include any decisions and actions related to possible changes to the environmental policy statement, environmental objectives, & other elements of the EMS consistent with continual improvement. Operations Manager and Surveyor Operations Manager and Surveyor Monthly Client Operational Report / Meeting 6 monthly EMS, Legal Register, Client meeting minutes.
Aspects Certification Continuous Emission Environment Environmental Management Environmental Management Audit Elements of an organisation's activities, products or services which can interact with the environment (ISO 14001). A significant environmental aspect is an environmental aspect which has or can have a significant environmental impact. The procedure by which a third party gives written assurance that a product, process, or service conforms to specific requirements. The process of enhancing an environmental management system, to achieve improvements in overall environmental performance, in line with an organisation's environmental policy. One or more substances released to the water, air or soil in the natural environment. Surroundings in which an organisation operates, including air, water, land, natural resources, flora, fauna, humans, and their interrelations. This definition extends the view from a company focus to the global system. Those aspects of an overall management function (including planning) that determine and lead to implementation of an environmental policy. A systematic evaluation to determine whether an environmental management system and environmental performance comply with planned arrangements, and whether a system is implemented effectively, and is suitable to fulfil an organisation's environmental policy.
Cont. Environmental Management System (EMS) Green Lease Impact Legal Register Management Review The part of an overall management system which includes structure, planning activities, responsibilities, practices, procurements, processes and resources for developing, implementing, achieving, reviewing and maintaining an environmental policy. A Green Lease is a lease of a commercial or public building which incorporates an agreement between the Landlord and the Tenant as to how the building is to be improved, managed and occupied in a sustainable way. Any change to the environment, whether adverse or beneficial, wholly or partially resulting from an organisation's activities, products or services. An environmental impact addresses an environmental problem. A list of regulations regarding environmental aspects of an organisation. A formal evaluation by management of the status and adequacy of systems and procedures in relation to environmental issues, policy and regulations as well as new objectives resulting from changing circumstances. Objectives The overall environmental goal, arising from an environmental policy, that an organisation sets itself to achieve, and which is quantified where practical.
Cont. Policy Pollution Prevention of Pollution Recycling Reuse Stakeholders A statement by an organisation of its intentions and principles in relation to its overall environmental performance. Environmental policy provides a framework for action and for the setting of its environmental objectives and targets. Residual discharges of emissions to the air or water or land. The use of processes, practices, methods or products that avoid, reduce or control pollution. These may include recycling, treatment, process changes, control mechanisms, efficient use of resources and material substitution. The process of re-using material for the production of new goods or services. The additional use of a component, part, or product after it has been removed from a clearly defined service cycle. Individuals or groups concerned with or affected by the environmental performance of an organisation. Interested groups include those exercising statutory environmental control over an organisation, local residents, an organisation's investors, insurers, employees, customers and consumers, environmental interest groups and the general public. Waste An output with no marketable value that is discharged to the environment. Normally the term "waste" refers to solid or liquid materials.
GENERAL LEGISLATION ENVIRONMENTAL LEGISLATION STATUS Environment Protection Act 1990 LEGAL EFFECT An Act to make provision for the improved control of pollution arising from certain industrial and other processes; to re-enact the provisions of the Control of Pollution Act 1974 relating to waste on land with modifications as respects the functions of the regulatory and other authorities concerned in the collection and disposal of waste and to make further provision in relation to such waste; to restate the law defining statutory nuisances and improve the summary procedures for dealing with them Environment Act 1995 Enacts legislation to control environmental impacts of the company. The Environmental Liability (Scotland) Regulations 2009 2009 Brings into force rules to force polluters to prevent and repair damage to water systems, land quality, species and their habitats and protected sites. The polluter does not have to be prosecuted first, so remedying the damage should be faster. Town and Country Act 1990 Control the planning and development of the site with respect to buildings and extensions. Road traffic vehicle emissions regulations 2002 The Road Traffic (Vehicle Emissions) (Fixed Penalty) Regulations 1997 empower certain local authorities in England, Scotland and Wales to issue fixed penalty notices to users of vehicles within their areas who contravene or fail to comply with regulation 61, 61A or 98 of the Road Vehicles (Construction and Use) Regulations 1986. Those regulations are concerned with emissions of smoke, vapour, gases, oily substances, etc.
AIR LEGISLATION ENVIRONMENTAL LEGISLATION STATUS LEGAL EFFECT Clean Air Act 1993 Enacts legislation to control emissions to air from site Air Quality Standards Regulations 2010 To improve air quality by reducing the impact of air pollution on human health and ecosystems through assessment and management. Ozone Depleting Substances (Qualifications) Regulations 2009 These revoke and replace the Ozone Depleting Substances (Qualifications) Regulations 2006 and continues to give effect to provisions of Regulation (EC) No 2037/2000 on substances that deplete the ozone layer, which relate to minimum qualifications for those working on the recovery, recycling, reclamation or destruction of controlled substances and the prevention and minimising of leakages of controlled substances. Fluorinated Greenhouse Gases Regulations 2009 Places new requirements for companies working with certain F Gases including qualifications of personnel working with refrigeration and air conditioning equipment requires testing for leakage and keeping records of equipment and substances. Environmental Protection (Controls on Ozone-Depleting Substances) Regulations 2011 2011 These Regulations enforce Regulation (EC) No 1005/2009 of the European Parliament and of the Council on substances that deplete the ozone layer
CONSERVATION LEGISLATION ENVIRONMENTAL LEGISLATION STATUS Wildlife and Countryside Act 1981 1981 LEGAL EFFECT The Act makes it an offence to disturb, injure or recklessly harm any habitat of wild birds, animals or plants. It also identifies prohibited means of removing or controlling animal, bird and plant habitats. It also highlights obligations with regards to introducing new species into a habitat and how these introductions can impact on native species Environment Act 1995 1995 Countryside and Rights of Way Act 2000 2000 Establishment of a body (Environment Agency) to enforce environmental legislation and their powers of enforcement The Act enforces public access on certain rights of way on registered common land, which can be on private land. The Act also identifies increased protective measures on Sites of Specific Scientific Interest (SSSIs) and Areas of Outstanding Natural Beauty (AONB) Natural Environment and Rural Communities Act 2006 2006 The Act s general purpose is to ensure that the natural environment is conserved, enhanced and managed for the benefit of present and future generations. It incorporates the promotion and protection of biodiversity and landscapes as well as promoting social and economic well-being of the environment within local and wider communities The Conservation of Habitats & Species Regulations 2010 2010 Securing the conservation of areas that have been designated as protected natural habitats or areas. These sites will have been designated as Special Areas if Conservation (SACs), Special Protection Areas (SPAs) or Sites of Community Importance (SCIs) by Natural England and the Regulations control any potentially damaging activities within these areas
ENERGY LEGISLATION ENVIRONMENTAL LEGISLATION CRC Energy Efficiency Scheme Order 2010 STATUS 2010 The CRC Energy Efficiency Scheme (Amendment) Order 2011 2011 The CRC Energy Efficiency Scheme Order 2013 2013 LEGAL EFFECT Qualifying businesses must register with the Environment Agency, submit and annual energy report and purchase carbon credits. The aim is to improve energy efficiency in public and private sector organisations and to help UK meet GHG emission reduction targets. Amends 2010/768 by extending phase one of the trading scheme to 1 April 2014. Reduces the second and sixth phases from seven to six years. The second phase will start on 1 April 2013. Each phase will overlap the previous phase by one year instead of two. Introduces a simplified version of the Carbon Reduction Commitment (CRC) that will apply following the end of the introductory phase established under the CRC Energy Efficiency Scheme Order 2010. It provides for revocations, continuing effect and amendments to the CRC Energy Efficiency Scheme Order 2010 and the CRC Energy Efficiency Scheme (Amendment) Order 2011. Climate Change Act 2008 2009 Act to set a target for the year 2050 for the reduction of targeted greenhouse gas emissions; The Energy Performance of Buildings (Scotland) Regulations 2008 2008 Requires building owners to make an energy performance certificate available for buyers or tenants and sets out the requirements for the certificate. Also requires public buildings to clearly display an energy performance certificate within the building.
ENERGY LEGISLATION CONT ENVIRONMENTAL LEGISLATION STATUS LEGAL EFFECT The Energy Performance of Buildings (Scotland) Amendment Regulations 2012 2012 Amends the 2008 Regulations by requiring the Energy Performance certificate to provide an indication as to where the owner or tenant can receive more detailed information on the cost effectiveness of the energy performance certificate. The Energy Performance of Buildings (Scotland) Amendment (No. 2) Regulations 2012 2012 Requires Energy Performance Certificates to be show to prospective tenants or buyers and requires further information to be included in certificates The Building (Scotland) Amendment Regulations 2006 2006 Replaces the six schedules up to 2004/406 that set out functional standards for buildings. Requires building owners to inspect air conditioning systems regularly and give advice to building occupants on reducing their energy consumption. Energy Act 2011 2011 The Energy Act 2011 has three principal objectives: 1. Tackling barriers to investment in energy efficiency (Green Deal and Energy Company Obligation ECO) 2. Enhancing energy security 3. Enabling investment in low carbon energy supplies The key significant provision is that from April 2018 it will be unlawful to rent out commercial property which does not reach a minimum energy efficiency standard. The current intention is a minimum EPC rating of E. Landlords would have fulfilled their obligations if the property is E rated or carried out the maximum package of measures funded under the Green Deal and/or ECO.
POLLUTION LEGISLATION ENVIRONMENTAL LEGISLATION STATUS Control of pollution Act 1974 The Environmental Liability (Scotland) Regulations 2009 2009 Control of Pollution (Amendment) Act 1989 LEGAL EFFECT Controls emission of noise from the site. The act also relates to the collection and disposal of waste and the providing of receptacles for waste Brings into force rules to force polluters to prevent and repair damage to water systems, land quality, species and their habitats and protected sites. The polluter does not have to be prosecuted first, so remedying the damage should be faster. The Water Environment (Oil Storage) (Scotland) Regulations 2006 2006 Sets out standards for the design and installation of oil storage containers, and timescales for businesses to comply with the rules.
WASTE LEGISLATION ENVIRONMENTAL LEGISLATION The Environmental Protection (Duty of Care) (Scotland) Regulations 2014 STATUS 2014 The Special Waste Regulations 1996 1996 The Special Waste (Amendment) Regulations 1996 1996 LEGAL EFFECT Requires a transfer note to be signed by the transferor and transferee of waste, specifies information to be included and requires copies to be kept for two years. Includes the use of SIC codes. Enables the use of electronic waste transfer notes. These regulations revoke the Environmental Protection (Duty of Care) Regulations 1991. Provides a definition of 'special waste' in Scotland, to cover all hazardous waste, and regulates waste carriers by requiring them to complete and keep consignment notes. Amends 1996/972 by defining special waste in Scotland, to cover all hazardous waste, and regulates waste carriers by requiring them to complete and keep consignment notes. The Special Waste (Amendment) Regulations 1997 1997 The Special Waste (Scotland) Regulations 1997 1997 Amends 1996/972 to revise the qualifications and experience required to deal with special waste Establishes that managers of specified waste facilities operated by local councils who meet certain criteria should be treated as technically competent for special waste facilities. The Special Waste Amendment (Scotland) Regulations 2004 2004 Amends the 2004 regulations, defines special waste and sets out controls on labelling, packaging and separating it. Requires consignment notes to be used when special waste is transferred and producers to keep registers of documents for at least 3 years.
WASTE LEGISLATION CONT... ENVIRONMENTAL LEGISLATION The Waste (Scotland) Regulations 2012 STATUS 2012 LEGAL EFFECT Controlled Waste Regulations 1992 Control of disposal of controlled waste The regulations introduce a number of important new requirements including the segregation of materials such as glass, metal, plastics, paper and card for recycling. It also introduces the requirement for food businesses to present food waste for collection and a ban on sending segregated materials for incineration or to landfill. Waste contractors must provide services that enable high quality recycling. The Waste Management Licensing (Scotland) Regulations 2011 2011 Waste Electrical and Electronic Equipment 2006 Adds new exemptions. Consolidates the Waste Management Licensing Regulations 1994 and amendments. Removes need for licence holders to have a certificate of technical competence. Requires businesses carrying their own waste to register as Professional Carriers and Transporters of Waste. For the prevention of WEEE and the reuse, recycling and recovery of such wastes in order to reduce the adverse impacts of disposal of electrical and electronic waste The Waste Electrical and Electronic Equipment Regulations 2013 2013 Aim to combat the rapid growth of waste electronic and electrical equipment (WEEE) and its impact on the environment due to its hazardous content. Measures are established for its treatment, reuse, recovery and recycling. From 1 January 2019, the scope of EEE covered by the Regulations changes, incorporating a wider range of products.
WATER LEGISLATION ENVIRONMENTAL LEGISLATION STATUS LEGAL EFFECT Water Industry Act Chapter 3 1991 Control the discharge of water to foul sewers The Groundwater Regulations 1998 1998 The Water Environment (Oil Storage) (Scotland) Regulations 2006 2006 Empowers SEPA to prevent direct or indirect discharge of certain dangerous substances to groundwater and control pollution resulting from the discharge of those and other substances. Sets out standards for the design and installation of oil storage containers, and timescales for businesses to comply with the rules. NOISE AND STATUTORY NUISANCE LEGISLATION ENVIRONMENTAL LEGISLATION STATUS LEGAL EFFECT Noise Act 1996 An Act to make provision about noise emitted from dwellings at night; about the forfeiture and confiscation of equipment used to make noise unlawfully; and for connected purposes Noise and Statutory Nuisance Act 1993 An Act to make provision for noise in a street to be a statutory nuisance; to make provision with respect to the operation of loudspeakers in a street; to make provision with respect to audible intruder alarms; to make provision for expenses incurred by local authorities in abating, or preventing the recurrence of, a statutory nuisance to be a charge on the premises to which they relate; and for connected purposes Clean Neighbourhoods and Environment Act 2005 An Act to make provision for Clean neighbourhoods covering litter, parked cars, noise, graffiti etc..
Savills Environmental Sustainability Policy This document was produced in conjunction with: The S 2 Partnership Ltd., 14-17 Avenue Business Park, Elsworth, Cambridge, CB23 4EY Tel: +44 (0)1954 267788 info@s2partnership.co.uk S 2 Partnership Ltd. Version 1.0 June 2014