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Environmental Management Standard
PURPOSE AND SCOPE
The purpose of this Standard is to specify National Australia Bank Limited’s (NAB Ltd) requirements for
environmental management practices and commitments. It is a supporting standard to the Enterprise
Risk Policy – Environmental Policy Requirements
This Standard sets out how NAB Ltd maintains a focus on environmental sustainability in all its
business activities and operations, including the development of operational environmental
management systems and practices within each geography in which it operates.
The scope of this Standard includes:
• Environmental Management – Assessment
• Environmental Management – Implementation
• Environmental Management – Monitoring and Reporting
• Environmental Management – Roles and Responsibilities (Standard Operating Procedure)
For the purposes of this Standard, the following definition applies:
• NAB Ltd Divisions and entities (Divisions and entities) responsible for geographical environmental
operational performance include: Shared Services (Australia) for Australia, BNZ for New Zealand,
GWB and NY Branch for the USA, CYB for United Kingdom, and Hong Kong Branch (coordinating
with other nabAsia branches and offices).
RESPONSIBILITY FOR IMPLEMENTING
All NAB Ltd Divisions and entities.
EXCEPTIONS
Nil.
EXEMPTIONS
All exemption requests must be submitted to the relevant Policy Owner for consideration. Decisions
will be based on the NAB Ltd’s documented exemptions Standard.
REQUIREMENTS
All requirements for this Standard are linked under Purpose and Scope above.
Note:
No te: All NAB Ltd Divisions and entities must fully comply with the Standard. However, if there is
conflict or inconsistency between this Standard and the laws and regulations of a Division or entity’s
particular country (or countries), those laws and regulations take precedence to the extent of the
conflict or inconsistency, unless this Standard places a higher requirement, or compliance with this
Standard would result in a breach of the local legislation.
In the event of such conflict or inconsistency, the Division or entity must notify Group Credit, who will
inform the Enterprise Risk Leadership team member accountable for Policy and Frameworks.
Classification: External
Environmental Management Standard
Page 2 of 6
Environmental Management – Assessment
Regulatory requirements and voluntary commitments
NAB Ltd Divisions and entities responsible for geographical environmental operational performance
must:
• maintain registers of environmental laws, regulations and voluntary commitments applicable to
their business, with compliance reported annually via the Requisitions on Management (ROMs)
Process
• establish and maintain processes and systems to manage operational environmental compliance
and performance, including obtaining all required environmental licences and permits.
• monitor environmental regulatory change and ensure that environmental regulatory reporting
obligations relevant to the geography are met.
Sustainability, Governance and Risk (SG&R) and Group Regulatory Strategy and Affairs must monitor
the legal landscape to ensure a timely response to any changes in environmental laws and regulations
applicable to the NAB Ltd.
SG&R will act as a delegate for Group Regulatory Strategy and Affairs in managing relationships with
key environmental regulators and maintain a register of voluntary environmental commitments
relevant across the Group.
At a minimum, registers of environmental laws, regulations and voluntary commitments must contain
the following information:
• Applicable jurisdiction (international, national, state, local government)
• Name and type of applicable environmental source document – Act, regulation, Code of Practice,
certification and voluntary commitment
• Name of the regulator/applicable administrator of the Code, certification or voluntary commitment
• High level description of requirements.
Risk assessment
assessme nt
SG&R and Group Risk Inventory (GRI) owners must integrate environmental risk into the NAB Ltd’s risk
appetite with reference to the NAB Ltd’s Environmental, Social and Governance (ESG) Risk Principles.
GRI owners and the NAB Ltd Divisions and entities, particularly those responsible for geographical
environmental operational performance, must identify, consider, control and mitigate environmental
risk inherent in the NAB Ltd’s activities, including both direct risk associated with the NAB Ltd’s
operations and indirect environmental impacts and dependencies that may arise from lending,
investment, customer advisory activities and supply chain management.
For more information, see:
• Operational Risk Profiling Standard
• Group Supplier Sustainability Principles
• Environmental Risk (Credit Risk – banker responsibilities).
Risk analysis and evaluation
Where a significant environment risk is identified (and where appropriate), GRI owners and NAB Ltd
Divisions and entities may proactively engage, in accordance with relevant NAB Ltd’s frameworks,
policies and practices, including the Stakeholder Advocacy and Action Framework, with relevant
stakeholders, which may include customers, suppliers, government, non-government organisations
and local communities, to understand the issue or risk and identify ways to address the issue and/or
reduce or mitigate the risk.
Classification: External
Environmental Management Standard
Page 3 of 6
Environmental Management – Implementation
Key business requirements for environmental management are as follows.
NAB Ltd Divisions and entities, particularly those responsible for geographical environmental
operational performance, must maintain a suitably resourced function to undertake operational
environmental management and reporting, including management of relevant third party service
providers.
Environmental Agenda and Management Framework
SG&R must coordinate the development of, and maintain, NAB Ltd’s Environmental Agenda and
Management Framework, including policies, related standards and standard operating procedures.
This must be reviewed at least bi-annually.
Shared Services (Australia) must:
• coordinate the development and aggregation of Group-level environmental operational
performance targets in accordance with relevant NAB Ltd Standards and Operating Procedures
• coordinate the development of enterprise-wide operational strategies to execute the operational
environmental performance aspects of the NAB Ltd’s Environmental Agenda and Management
Framework.
NAB Ltd Divisions and entities responsible for geographical environmental operational performance,
must set geographical environmental operational objectives and performance targets and develop
regional operational strategies for implementing the NAB Ltd’s Environmental Agenda and
Management Framework and achieving operational environmental targets.
NAB Ltd and geographical environmental reduction targets must be set for a three year period to allow
for budget allocation delivery of initiatives, such as capital works, which may be required to meet the
targets.
Risk treatment and mitigation
NAB Ltd Divisions and entities responsible for geographical environmental operational performance
must establish, implement and maintain Standards and Standard Operating Procedures (SOPs) to
identify and mitigate risks caused by the Group's business operations that may impact the
environment, including the NAB Ltd’s environmental objectives documented in the Environmental
Agenda and Management Framework.
Management systems
NAB Ltd Divisions and entities responsible for geographical environmental operational performance
must ensure that operational environmental management systems and practices are in place
consistent with, and aligned to, the requirements of:
• the International Organization for Standardization (ISO) 14001 Environmental Management System
Standard (ISO 14001)
• relevant laws, regulations and voluntary commitments
Standards and SOPs may be incorporated into existing management systems.
NAB Ltd Divisions and entities responsible for geographical environmental operational performance
must also:
• manage relevant contractors undertaking environmental management on behalf of a Division or
entity
• maintain third party accreditation related to environmental management practices, where relevant
to the geography (e.g. Australia – Government National Carbon Offset Standard, NABERS and
GreenStar; UK – Carbon Trust Standard; and Asia – where NAB Limited entities have a small
operational footprint, we will implement our environmental policy requirements and objectives
through expanding our occupancy of green buildings for which we seek recognised environmental
accreditation (e.g. LEED and Greenmark)
• ensure that the potential effects of significant environmental events and disasters are considered in
business continuity and disaster management planning within the geography.
Classification: External
Environmental Management Standard
Page 4 of 6
Shared Services (Australia) must maintain an environmental data management system on behalf of the
Group.
Where applicable, SG&R must maintain relevant independent third party environmental accreditation
at the NAB Ltd level.
Use of external property services providers to implement environmental management
Where an external property services provider is engaged to assist in the management of operational
environmental performance, NAB Ltd Divisions and entities responsible for geographical
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environmental operational performance must, at the time of contracting and/or renewing , require
the property services provider to hold ISO 14001 certification covering the activities conducted on
behalf of NAB.
NAB Ltd Divisions and entities responsible for geographical environmental operational performance
must review and/or audit the external property services provider to ensure they are satisfactorily
contributing to the management of the NAB Ltd’s environmental performance, regulatory performance
and voluntary commitments. This should occur within the first year of any new services agreement and
every 12 months thereafter.
The external property services provider must provide the geography with evidence of their current ISO
14001 certification and a summary of audit findings and recommendations relevant to the activities
undertaken on behalf of the NAB Ltd following each external ISO 14001 surveillance and certification
audit.
Impacts
Accidents and emergencies
NAB Ltd Divisions and entities responsible for geographical environmental operational performance
must:
• establish, implement and maintain SOPs to identify potential accidents, spills and emergency
situations caused by NAB Ltd business operations that may impact the environment and develop
response plans to prevent or mitigate any associated adverse environmental impacts (e.g. improper
storage, handling and transportation of hazardous wastes or management of diesel spills).
• Where an external property services provider is contracted to perform these activities on behalf of a
NAB Ltd Division or entity responsible for geographical environmental operational performance,
the responsible Division or entity must ensure that they are notified of any significant accidents,
spills and emergency situations by the external property services provider in a timely manner
following the accident, spill or emergency situation.
Business continuity planning
NAB Ltd Divisions and entities responsible for geographical environmental operational performance
must ensure that business continuity planning considers the impact of significant environmental
events and disasters, such as extreme weather and geophysical events, on NAB Ltd’s business
operations.
Impact minimisation
NAB Ltd Divisions and entities responsible for geographical environmental operational performance
must act to:
• prevent pollution
• minimise greenhouse gas (GHG) emissions and use of natural resources
• improve resource efficiency (e.g. water, paper and energy)
• increase waste diversion from landfill
• transition to lower emissions energy sources (where practicable).
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This requirement may be included in a contract sooner if it can be negotiated within a current contract term.
Classification: External
Environmental Management Standard
Page 5 of 6
Carbon inventory and offset
Shared Services (Australia) must:
• manage the Group’s carbon offset portfolio in accordance with the forward purchase model
(including purchase, retirement, recording in registers and reporting). Carbon offsets must meet
defined carbon offset criteria. For more information, see the NAB Ltd’s Environmental Operational
Reporting and Offset Management Standard.
• prepare annual public reporting on the Group’s operational environmental performance and
practices. This must include both aggregate Group performance and regional performance
summaries, with commentary that explains key elements of performance, key assumptions and
restatements in accordance with the Environmental Operational Reporting and Offset Management
Standard.
SG&R must publish a summary of NAB Ltd’s Environmental Agenda and Management Framework and
approach to environmental performance and reporting, including carbon inventory and carbon offset
portfolio management in the public domain.
Procurement and outsourcing
Shared Services (Australia) must coordinate the development and implementation of the NAB Ltd’s
Supplier Sustainability Program to improve the environmental (and other sustainability) performance
of the NAB Ltd’s supply chain.
NAB Ltd Divisions and entities responsible for geographical environmental operational performance
must:
• integrate environmental and social considerations into procurement and outsourcing activities and
ensure all critical or material suppliers meet the requirements of the Group's Supplier Sustainability
Principles (GSSP).
• inform suppliers about the environmental (and other sustainability) requirements of the Group
Supplier Sustainability Principles and monitor adoption and implementation by suppliers.
Customers
Where appropriate and financially viable, NAB Ltd Divisions and entities must provide financing which
supports the adoption of clean technologies and processes that reduce environmental impacts.
Employees
NAB Ltd Divisions and entities responsible for geographical environmental operational performance
must develop operational environmental programs and communication to engage employees in
meeting the NAB Ltd’s Environmental Agenda and relevant targets. In particular, NAB Ltd Divisions and
entities responsible for geographical environmental operational performance must provide employees
with:
• training to enable them to understand environmental risks and integrate environmental
considerations into their work practices
• opportunities to participate in community volunteer programs which have environmental
objectives and outcomes
• information regarding relevant environmental targets and performance (this may be via the
intranet).
Shared Services (Australia) must maintain up to date enterprise-wide environmental operational
performance information on the NAB Ltd’s internet site.
NAB Ltd Divisions and entities responsible for geographical environmental operational performance
may provide geographical environmental operational performance information on applicable entity
internet sites.
SG&R must integrate consideration of environmental risk into risk awareness training and other
training as appropriate.
Classification: External
Environmental Management Standard
Page 6 of 6
Environmental Management – Monitoring and Reporting
Reporting
SG&R, Shared Services (Australia) and the NAB Ltd Divisions and entities responsible for geographical
environmental operational performance must meet the operational environmental reporting
requirements, roles and responsibilities set out in the Environmental Operational Reporting and Offset
Management Standard.
SG&R must prepare internal and external reporting on ESG risks and risk management as required for
the NAB Ltd Governance and Risk Committees.
SG&R must maintain enterprise-wide ESG information on internet and intranet sites, including
information on the Environmental Agenda and Environmental Management Framework.
Shared Services (Australia) must coordinate Group SSP performance reporting for both internal and
external reporting purposes.
External reporting and information
NAB Ltd Divisions and entities responsible for geographical environmental operational performance
must update environmental information on their internet sites at least annually. Shared Services
(Australia) and the NAB Ltd Divisions and entities responsible for geographical environmental
operational performance must on an annual basis, or as required for regulatory purposes, report
publicly on Group and geographic environmental performance and practices.
Monitoring
SG&R, with Group Risk Inventory Owners, Divisional and entity risk teams and Procurement functions
(Shared Services in Australia), must regularly monitor emerging and sensitive environmental issues of
concern to stakeholders to enable appropriate proactive actions to be taken to mitigate risks. This
must, at least, involve the consideration of the NAB Ltd’s sensitive industry and activity list.
Oversight and assurance
SG&R must:
• incorporate oversight of the implementation of the NAB Ltd’s Environment Policy requirements and
Standards within their periodic oversight program (see Enterprise Risk Policy)
• provide oversight related to environmental performance (including performance targets),
environmental risk management and reporting.
Where applicable, NAB Ltd Divisions and entities must participate in risk oversight and external
assurance processes related to environmental risk management and operational performance
reporting.
SG&R must:
• provide risk oversight and review of voluntary and regulatory reporting
• as a minimum, obtain independent assurance over regulatory reporting (reasonable assurance)
• where appropriate, obtain independent assurance over voluntary reporting (limited assurance or a
higher level where specifically required for accreditation or certification purposes or voluntary
commitments).
Administration Schedule
Approval date
1 April 2015
Next review date
22 April 2016
Document Owner
Group Credit Risk
Issuing Division / Performance Unit
Enterprise Risk
Highest approval authority
Group Regulatory,
Committee
Compliance
and
Operational
Risk