Governance
The Board takes direct responsibility for determining policy and strategic direction on CR matters. Our broad strategic direction is disseminated through the CR Board Committee and progress against our operational objectives is delegated to the CR Management Committee. Delivery of the agreed action plans, targets and objectives is the responsibility of executive management reporting to the CR Management Committee, as appropriate. We continue to refine CR risks that impact on our business, benchmarking against best practice, including GRI, FTSE4Good, Dow Jones SI, Defra and the BiTC Corporate Responsibility Index.
CR Risks
The CR Management Committee has undertaken its annual review of the Group’s risk register and has identified those that have a potential effect from a CR perspective. The Group assessment is a comprehensive review of the full spectrum of corporate risks, undertaken as a part of the company’s annual report. Responsibility for the executive management of the processes involved in each area of risk is assigned to the appropriate individual member, or group of members, of the board. The identified CR risks and the board members designated to manage them are set out below.| Stakeholder Groups / CR Risks | Management Processes | Liberty International Board Responsibility |
|---|---|---|
| Corporate Governance, Business Code of Practice compliance & verification | Policies, systems and audit | Entire Board |
| Shareholders and analysts | Investor relations programme | Chairman, Chief Executive and Finance Director |
| Staff | HR management | Chief Executive |
| Local Communities – support | Community engagement initiatives | Chairman |
| Central Government | Engagement | Chairman and Chief Executive |
| Planning process – Local Authorities, Regional Government Departments, NGOs | Engagement | Managing Directors – CSC, C&C |
| Suppliers, contractors and consultants | Procurement | Managing Directors – CSC, C&C |
| Health & Safety | Policies, training, systems and audits | Chief Executive – Liberty International, Managing Directors – CSC, C&C |
| Environment – energy, waste and transport | Policies, training, systems and audits | Managing Directors – CSC, C&C |
| Retailers and occupiers | Direct engagement and benchmarking against peer group | Managing Directors – CSC, C&C |
| Shopping public | Range of feedback mechanisms including surveys and focus groups | Managing Directors – CSC, C&C |
Committee Training and Learning
The Management and Board Committees are continually involved in activities to ensure members are kept abreast of best practice in the field of CR. Training has included in-house presentations on CR-related best practice from specialist organisations such as the Carbon Trust, Bureau Veritas and many of our community programme partners. Committee members have furthered their involvement and learning through attendance at seminars, conferences and visits to a variety of community projects. CSC H&S Executive Committee members attended a Health & Safety training course in April 2008, as part of an ongoing programme.
Corporate Policies
Our comprehensive set of policies supporting our Business Code of Practice is listed throughout this document and can be viewed in full on our website. The CR policies, Business Code of Practice and Environmental Guide were reviewed and amended as necessary in late 2007. The review was conducted to take account of best practice and feedback from stakeholders. Reviewed policies were approved by the Board in January 2008 and published thereafter. The Environmental Policy & Guide is subject to continual monitoring as it is included within consultants’ appointments and construction contracts. New legislation, such as the Site Waste Management Plans Regulations 2008 and Energy Performance of Buildings (Certificates and Inspections) Regulations 2007, was enacted during the year. It was necessary, therefore, to amend the Policy & Guide to ensure that our consultants and contractors comply with these new regulations. The amendments were approved by the Board in November 2008 and the revised policy published.
CR Management Systems and Data Collection
We have operated an environmental management system (EMS), equivalent to ISO14001, at all our directly managed UK shopping centres for several years. The management systems form part of the consistent mechanism for the delivery of CR objectives in the UK shopping centres. We also have a well-established system to allow utilities, waste, transport and community activities to be monitored at all shopping centres and office properties on a quarterly basis. This data is now used to establish our carbon footprint and to benchmark and normalise our data with more accuracy, as detailed in the Environment section. All performance indicator data is subject to both internal and external audit.
Audit
The internal audit programme continues to cover verification of CR data, which is also independently verified, on a sample basis, by Bureau Veritas. The scope of verification includes adherence to stated policies as well as reviewing the procedures involved in collating the figures and the accuracy of the data itself. This process covers both internally generated data and that provided by our service partners.
Health & Safety
The responsibility for health & safety in respect of our staff, contractors, occupiers and visitors to our shopping centres and other properties lies with the Liberty International Board which has delegated responsibility for Health & Safety policy to three separate Health & Safety Committees – Liberty International, Capital Shopping Centres and Capital & Counties. Each committee is responsible for establishing safety procedures for its part of the overall business. The Committees are advised by specialist external consultants to ensure that high standards and levels of performance are maintained throughout the group. Operational responsibility remains with line management. View the Health & Safety section
Compliance
The company has complied with all applicable legislation and has been subject to no sanctions or fines for environmental, health & safety or any other infringements.