Environmental Policy
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Statement of Policy
GKN is committed to safeguarding the environment and contributing positively to the
communities in which it operates by acting with integrity at all times in compliance with
the regulatory framework and by good corporate governance.
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General Principles
1. The aim of environmental management is to minimise the impact of the Group’s
activities in areas such as pollution of water, emissions to atmosphere, noise and the
creation of excessive or harmful waste, and to encourage the conservation of natural
resources.
2. Each company must identify and evaluate risks associated with its operations through
a continuing programme of environmental risk assessment.
3. Companies must work closely with other stakeholders, for example, the enforcement
authorities, trade associations and the local community, in the implementation of this
Policy.
4. Procedures must also be established whereby employees can make a positive
contribution to the achievement of high standards of environmental management.
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Practice
All companies are expected to be certified to ISO 14001, the International Environmental
Management System.
All companies must adopt documented environmental procedures which are appropriate
to the nature, scale and environmental impacts of their activities, products and services
and which include:
• a commitment to continuous improvement and the prevention of pollution
• a commitment to implement GKN’s Energy Policy, which is attached as an Appendix
to this Policy
• a commitment to comply with applicable legal requirements, including local reporting
requirements, and with this Policy
• provision for a framework for setting and reviewing environmental targets
• appropriate consideration of the environmental impacts of new products and
processes during the initial stages of their development
• safeguarding the environment during the manufacture, use, handling, storage,
distribution and final disposal of existing products
• safeguarding the environment during the use, handling, storage, distribution and final
disposal of products supplied by third parties.
A formal review of the procedures must be undertaken by each company annually.
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All companies must put in place a formal system, which will be capable of generating
accurate data, for the collection of the following environmental data:
• energy consumption
• the generation of waste
• the consumption of water
• the emission of carbon dioxide from the use of energy.
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Guidelines
From time to time the Group may produce guidelines on environmental management
matters. Such guidelines will be incorporated into the GKN Group Environmental
Manual. Although these guidelines will not be mandatory, the arrangements in a
company should ensure that any alternative procedures which are implemented will
achieve equivalent results.
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Measures and Metrics
Companies shall, wherever possible, refer environmental data to metrics agreed at
Divisional level, in order to enable valid year on year comparisons to be made taking into
account year on year changes in production. Typically the measure of production shall
be the weight of product produced in the relevant year. Where this is inappropriate
another appropriate measure must be found, failing which the sales value should be
used.
Where possible companies must benchmark with other Group companies with similar
production patterns in order to establish and share best practice.
Where appropriate, companies may develop their own additional metrics to enable
internal year on year comparisons to be made.
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Assurance
Companies must set up internal review procedures, in accordance with the requirements
of ISO 14001, to provide assurance that their internal environmental management system
is operating as intended and that all environmental data collected is accurate and reliable.
Companies must require external organisations certifying compliance with ISO 14001 to
include compliance with this Policy as part of their audit.
This Policy must be read in conjunction with the GKN Code, any written guidelines, the
other GKN Policies and the requirements regarding their implementation.
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Appendix to Environmental Policy
Energy Policy
As part of our stated principles for delivering outstanding products and services to our
customers, for maintaining the well being of our employees and for delivering superior
returns to our shareholders, GKN is committed to long-term sustainability. Optimising the
Group’s consumption of energy is an essential element of this. Our Policy is:
1. to improve progressively energy efficiency at all levels in the Group;
2. to have clearly defined energy management roles, responsibilities and plans within an
environmental management systems (EMS) framework based on the ISO 14001
standard;
3. to set achievable targets for reducing energy consumption per unit of production in all
our operations;
4. to purchase energy at the most competitive rates, to leverage energy purchases
across the Group to obtain maximum commitment from suppliers and to develop
supply side hedging strategies to minimise exposure to market fluctuations;
5. to ensure that energy consumption is taken into account when specifying new plant
and equipment and that significant consumers of energy have energy meters with an
output compatible with modern energy management systems;
6. to ensure that energy efficiency receives adequate resources and investment in order
to meet the Policy objectives and targets;
7. to include energy awareness and management in employee training programmes;
8. to minimise the environmental impact of our energy consumption by exploring ways of
using low carbon technologies, by maximising the use of renewable energy sources
where economically feasible, by seeking to reduce progressively emissions of carbon
dioxide relative to production and by abiding by international agreements and
protocols;
9. to communicate the achievements with external bodies and stakeholders; and
10. to influence our supply chain to pursue improvements in energy efficiency and to
adopt low carbon technology.
As a broad strategy for achieving these Policy objectives, we will continually monitor and
review our performance in energy management and target achievements throughout all
our operations.
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