Group EMS Manual: Environmental Management System, EMS
Group EMS Manual: Environmental Management System, EMS
Group EMS Manual: Environmental Management System, EMS
No.
Contents Page 2
Documents Hierarchy 3
Organisational Charts & Sites 4-5
1.0 Scope 6 1.0
2.0 Normative references – (not applicable) 6 2.0
3.0 Terms and definitions 6, 22 3.0
4.0 Context of the Organisation 6 4.0
4.1 Understanding the organisation and its context 7 4.1
4.2 Understanding the needs and expectations of interested parties 7-8 4.2
4.3 Determining the scope of the EMS 9 4.3
5.0, 5.1 Leadership, Leadership and commitment 9 5.0, 5.1
5.2 Environmental Policy (Group HSE Sustainability 10 5.2
Policy)
5.3 Leadership and commitment (also see Org Charts) 11 5.3
6.0, 6.1 Planning, Actions to address risks and 12 6.0, 6.1
opportunities
6.1.2 Environmental Aspects 13 6.1.2
6.1.3 Compliance obligations (Legal & other) 13 6.1.3
6.1.4 Planning Action 13 6.1.4
6.2 Environmental objectives 14 6.2
7.0, 7.1 Support, Resources 14 7.0, 7.1
7.2 Competence 14 7.2
7.3 Awareness 14 7.3
7.4 Communication 15 7.4
7.5 Documented Information 16 7.5
8.0, 8.1 Operation, Operational Planning and Control 16, 17 8.0, 8.1
8.2 Emergency Procedures 17, 18 8.2
9.0, 9.1 Performance Evaluation, Monitoring, Measurement, Analysis & Evaluation 18 9.0, 9.1
9.1.2 Evaluation of Compliance 18 9.1.2
9.2 Internal Audit 19 9.2
9.3 Management Review 19, 20 9.3
10.0,10.1 Improvements, Non-Conformity and Corrective 20 10.0, 10.1
Action
10.2 Continual Improvement 20 10.2
Appx. A Sites covered by GEMS Manual & Certification 21 -
Appx. B Sites Linking Document: Held & maintained by sites 21 -
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Appx. C Glossary of terms and definitions 22 -
Document Hierarchy
De La Rue
Group Environmental Management System (GEMS) Manual
Local Site Arrangements to comply
Primary Elements
Supporting Procedures
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Organisational Charts
Executive Leadership Team
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1.0 Scope (ISO 14001:2015 -1.0)
The scope of the Environmental Management System is Design, Holography, Security Printing and
associated systems including passport production and personalisation, finishing and office
functions. For a full listing of the scopes against the individual sites see Appendix A.
Not applicable
In our Annual Report we consider our alignment with United Nations Global Compact Sustainability
Development Goals and see how we can improve our processes to align with these year by year.
Internally, relating primarily to our manufacturing operations, energy use, waste generation and
disposal routes, and water usage are significant environmental issues that are measured and have
focus. Environmental permitting arrangements may also have an impact when they are updated or
any of the controls tightened.
Many of the Company’s customers and stakeholders have an interest in the way our business
operates and we have a Code of Business Principles booklet that we require all employees to read
and comply with, that includes HSE responsibilities.
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4.1 Understanding the organisation and its context (ISO 14001:2015 - 4.1)
Group will establish an EMS to document, implement, maintain and continually improve an
environmental management system in accordance with the requirements as above.
In our Annual Report we consider our alignment with United Nations Global Compact Sustainability
Goals and see how we can improve our processes to align with these year by year.
Internally, relating primarily to our manufacturing operations, energy use, waste generation and
disposal routes, and water usage are significant environmental issues that are measured and have
focus. Environmental permitting arrangements may also have an impact when they are updated or
any of the controls tightened.
4.2 Understanding the needs and expectations of interested parties (ISO 14001:2015
– 4.2)
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Interested Party Needs and Expectations How do we communicate/monitor Priority
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4.3 Determining the scope of the EMS (ISO 14001:2015 – 4.3)
The EMS will cover all main manufacturing sites including Head Office, with relation to
emissions to Land, Air and Water within their functional boundaries.
There is an appointed Board Member for Environmental aspects supported by the Group Director
of Security, HSE & Risk with HSE Advisors at all sites. HSE aspects are integrated into the Group
strategy. An annual Board update is completed to review policy, performance and continual
improvement of the EMS. At ELT level the strategy is reinforced with suitable resources including
capital expenditure. Local site Senior Leadership Teams (SLT) review performance and continual
improvement twice per year.
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Group HSSE Public Page 9 of 28
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5.2 Environmental Policy (ISO 14001:2015 – 5.2)
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5.3 Leadership and commitment (ISO 14001:2015 – 5.3) see Organisational charts
Chief Executive Officer – Overall environmental strategic direction
Chief Finance Officer - Environmental responsibility for providing financial resources for
projects, managing the EMS system, ensuring environmental levies are met.
General Counsel & Company Secretary - Environmental responsibility for business statutory
compliance.
Group Director of Security, HSE & Risk – Responsibility for ensuring Group Environmental
compliance and audit and links to the risk programme.
Group Director of Risk – Responsibility for Site Facility Environmental surveys and
highlighting business risk
Plant and operational managers – Ensure conformity of all compliance obligations and
promote continual improvement.
Site HSSER Manager – ensures day to day compliance, monitoring, review, reporting and
coordination of the EMS and ensures adequate local HSE resource is available.
All other persons working under the organizations control or on behalf of the organisation –
conform to EMS requirements.
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6.0 Planning (ISO 14001:2015 – 6.0)
SITES
Environmental
Objectives &
Targets
Group
Environmental Management
Procedures & Review
Instructions
Environmental
Performance
Monitoring
Site
Environmental
Management
Review
Group has an established business planning cycle which is reviewed annually by the
Executive Leadership Team. The plan identifies objectives and targets and provides an
indication of the timescale for achievement for the same. The Executive Leadership team
meets monthly to review progress
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6.1.2 Environmental Aspects (ISO 14001:2015 – 6.1.2)
De La Rue has conducted an assessment of the environmental aspects of its activities, end product,
services and have logged all aspects which pose a significant impact on the environment.
The Global HSE Manager/Site EHS Advisors are responsible for assessing the significance of
environmental impacts, using external expertise when required. They are also responsible for
ensuring the site log of aspects and impacts is maintained and updated. The significance of aspects
and impacts is to be evaluated using a scoring methodology.
Identified significant environmental impacts shall be taken into account when setting annual
environmental objectives and targets and in the prioritization of action plans.
Key legislation that could affect Group activities and operations are detailed in the Register of
Environmental Legislation and other requirements held at each site. Each site’s log will contain
variations dependent on local activities performed on their specific site.
The register is reviewed and updated following the introduction of new environmental legislation
or other requirements, at regular periods and no less than annually.
The organisation has a Business Continuity system which continually identifies threats and risks,
relating to significant environmental aspects and compliance obligations.
The organisation subscribes to relevant bodies in order to identify opportunities at an early stage in
development in order to enhance its technical or commercial solutions. For example: Polymer
substrates, chemical substitution, fibre recovery, digital/3d printing etc..
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6.2 Environmental objectives (ISO 1400:2015 – 6.2)
Group has established implemented and documented environmental objectives and targets
at functional and organisation levels within the Group. Local sites can go over and above
these.
These objectives and targets are SMART and consistent with our Policy and include
commitments to prevention of pollution, compliance to legislation and continual
improvement
Environmental objectives and targets are established and reviewed on an annual basis and
the process of setting those takes into account:
• Group Policy
• Legislative requirements
De La Rue has established and implemented a system for achieving, sustaining and
monitoring the environmental objectives and targets, to which the site specific targets and
objectives will be added.
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7.4 Communication (ISO 1400:2015 – 7.4)
The Group communications structure provides a basis for two-way communication on
environmental matters throughout all the sites. It enables management and other
employees to monitor performance and discuss ways to improve operational practices. It
provides direct feedback to senior management on issues requiring attention and ensures
the executive and senior leadership teams are informed of material issues that require
monitoring and for enhancing the EMS. Environmental reviews operate as an integral part
of other management meetings (e.g. HSE) with a wider focus.
De La Rue have made a conscious decision to publicise environmental data and information
to their external stakeholders this is carried out through the Company’s Annual Report,
through the website and through the Carbon Disclosure Project and Group will occasionally
provide environmental information upon request. The Policy statement document is a
classed as a public document. De La Rue actively works with other stakeholders to promote
sustainability.
ELT
• ELT team meet on a monthly basis to discuss all functional areas and any ‘material’
matters
SLT
• Teams meet on a regular basis to discuss all functional areas at an operational level
• HSSER Manager updates these teams on environmental issues through the Site
Environmental Contact
• Key material issues are to be escalated to the Manufacturing Director, COO & Global
HSE Manager
• Site Management Reviews are led by Senior Site Managers and are minuted.
HSE Committee
• Site HSE Committee’s meet on a periodic basis (usually monthly or bi-monthly) and
review environmental matters affecting the site. Legislation updates and their
impact are reviewed here.
• Site HSE Committee’s are attended and normal led by a Site Senior Manager or
appointed deputy
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7.5 Documented Information (ISO 1400:2015 – 7.4)
The EMS documentation requirements include:
Inputs
All company operations are controlled from the planning stage through to operational procedures
and training. When or if process controls vary or when unexpected variability in output results are
noted then formal problem-solving processes are followed to identify the causes and to prevent
recurrence by carrying out corrective actions.
Outsourced processes are controlled and under contracts set up by Procurement with support
from the technical and quality teams. Environmental Management System standards of outsourced
partners or suppliers are reviewed by the Procurement team. If an aspect is identified and the
impact is likely to be significant relative to the ‘volume of supply’ these may require a formal
review.
Change Management, both in planning and with regard to processes is controlled and
documented. There is a documented Change Management procedure relating to EHS aspects that
is based on EEM principles and checklists.
Within the business, aside from, but relating to Operational Controls the company has two formal
process considering EMS and environmental impacts, these are:
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a) Relating to Expenditure Authorities (EA) and capital projects there is an EHS review and sign
off process early in the financial approval process.
b) Relating to R&D and product development a technical checklist is used to identify EHS
aspects and potential impacts alongside identifying any statutory requirements.
Aside from these two processes and overall there is a stand-alone EHS Changes checklist that can
be used for other general changes used to review EHS requirements post or prior any planned or
even unplanned changes.
Inductions are provided to new employees and contractors and these cover EMS and any
significant Environmental aspects, such as waste disposal etc.
Some detailed lifecycle studies have been carried out relating to our main product streams and we
have also worked with customers to assist them regarding lifecycle comparisons.
Overall, there are three main environmental aspects relating to Operational Planning and Control
that may have significant impact in direct correlation to the products produced:
a) Adding security features may have a significant impact for example printing double sided
intaglio as opposed to single sided intaglio is known to have a significant impact. Adding
other additional security features may also add additional machine processes. Thus using
more energy and perhaps generating more waste. Combining processes within one
machine may have a beneficial effect, this is being developed within the industry, for
example letterpress and varnishing processes.
b) Quality defects or customer complaints that have been missed during production
operations may have a significant effect by creating both rework and increasing spoilage,
waste or transport costs.
c) Finally, shipping from different locations around the world to our customers can have an
environmental impact depending where the products are manufactured and this may be
connected with planning constraints or required delivery timelines. This area is particularly
sensitive with regards to customers and DLR and the processes used for transport e.g.
flying, shipping or road transport. This area is not publically disclosed under normal
circumstances.
With regards to Environmental Management Systems and environmental impacts the company has
a number of environmental aspects which it considers and has emergency plans and controls for,
already in place. These are primarily fire risk, floods, chemical/oil spillages and other potential
pollution incidents. These are all considered within our Business Continuity Plans and employee
training provision. Sites have emergency spill training and spill kits in place where required and
sites test these emergency procedures periodically.
The Business Continuity Plan process also considers environmental aspects and reviews these
controls as appropriate.
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Procedures have been established as appropriate, to prevent and mitigate the
environmental impacts that may arise from emergency situations
The procedures specify responsibilities and actions to be taken and include contact and
communication details within the company and with external organisations.
Emergency procedures will be subjected to review and revision usually annually, and after
an occurrence of an emergency situation. Procedures are tested periodically by simulation
of incidents as part of training exercises or drills.
• Fires
• Spills
• Floods
This information will be reported and reviewed monthly for analysis and evaluation to
support continual improvement of the EMS system. Key annual performance will be
published in the Annual report.
Any monitoring and measuring equipment used in this function will be calibrated or
verified and maintained with records retained as proof.
Periodic evaluation of compliance with environmental legislation and other requirements is carried
out annually and outputs are reviewed during environmental management reviews. Site
management reviews feed into Group management review.
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9.2 Internal Audit (ISO 1400:2015 – 9.2)
All Sites shall ensure internal audits of the EMS are conducted at planned intervals to
determine whether the Environmental Management System conforms to planned
arrangements for environmental management including the requirements of ISO
14001:2015 and has been properly implemented and is maintained.
Audit programs will be planned, established implemented and maintained taking into
consideration the environmental importance of the operation(s) concerned and the
results of previous audits.
Selection of competent auditors will ensure impartiality and objectivity of the audit
process.
• Review of Minutes of previous meeting, actions & matters arising from previous
Group Mgt Reviews
• Review of relevant external and internal issues relating the Group EMS & GHSES
Policy
• Review of the needs and expectations of interested parties & new compliance
obligations
• Risks & Opportunities that may be ‘material’ for the Group including Group
developments
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• Review group environmental legal and other compliance and any concerns or
breaches
Outputs
• Actions to take regarding EMS objectives & targets that were not achieved
• Implications for our EMS factors for our strategic direction as a business
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Appendix A - Sites covered by Manual
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Appendix B – Refer to Linking Document at Sites linking GEMS to site processes &
procedures
Group
Director of Security,
HSE & Risk
Global HSE
Manager
Logan
HSSE
Tech Centre
HSSE
Kenya
Sri Lanka Malta Westhoughton Debden Gateshead Head Office
HSSER
HSSER HSSER HSSER HSSER HSSER HSSE
Manager
Manager Manager Manager Manager Manager Manager
HSE Advisor HSE Advisor HSE Advisor HSE Advisor HSE Advisor HSE Advisor HSE Advisor
Kenya Sri Lanka Malta Westhoughton Debden Gateshead Head Office
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Appendix C - Glossary of Terms and Definitions
Abatement
Acid
Air pollution
Air is made up of a number of gases, mostly nitrogen and oxygen and, in smaller amounts, water vapour, carbon dioxide and argon
and other trace gases. Air pollution occurs when harmful chemicals and particles are emitted to the air – due to human activity or
natural forces – at a concentration that interferes with human health or welfare or that harms the environment in other ways.
Air quality
Amenities
Benefits of a property, such as nearby playgrounds, swimming pools, community centre’s or parks.
Biodegradable waste
Organic waste, typically coming from plant or animal sources (for example food scraps and paper), which other living organisms can
break down.
Biodiversity
A short form of the phrase ‘biological diversity’, which means the variety of life on this planet and how it interacts within habitats
and ecosystems. Biodiversity covers all plants, animals and micro-organisms on land and in water. See also ecosystem, habitat and
organism.
A colourless gas that is naturally produced from animals and people in exhaled air and the decay of plants. It is removed from the
atmosphere by photosynthesis in plants and by dissolving in water, especially on the surface of oceans. The use of fossil fuels for
energy is increasing the concentration of carbon dioxide in the atmosphere, which is believed to contribute to global warming. See
also greenhouse gases and photosynthesis.
Carbon footprint
A measure of the impact our activities have on the environment, especially climate change, often reported as the units of tonnes (or
kg) of carbon dioxide each of us produces over a given period of time.
Carbon monoxide
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A highly poisonous, odourless, tasteless and colourless gas that is formed when carbon material burns without enough oxygen.
Carbon monoxide is toxic when inhaled because it combines with your blood and prevents oxygen from getting to your organs. If a
person is exposed to carbon monoxide over a period, it can cause illness and even death. Carbon Monoxide has no smell, taste or
colour. This is why it is sometimes called the “Silent Killer”. The most common causes of carbon monoxide poisoning in the home are
house fires, faulty heating appliances such as boilers, blocked chimney or flues, and rooms not properly ventilated. Carbon
Monoxide alarms can be used as a backup to provide a warning to householders in the event of a dangerous buildup of carbon
monoxide.
Carbon neutral
A situation that arises when the amount of carbon dioxide released into the air equals the amount of carbon dioxide removed from
the air, for example by planting trees, or the amount saved by using renewable energy sources to produce the same amount of
energy. See also renewable energy.
Carbon offset
A unit, equal to one ton of carbon dioxide, that individuals, companies or governments buy to reduce short-term and long-term
emissions of greenhouse gases. The payment usually funds projects that generate energy from renewable sources such as wind or
flowing water. Individuals can choose whether to buy an offset (for example to compensate for air travel), but governments and
large industries are sometimes required to buy them to meet international targets aimed at reducing greenhouse gases.
CFCs
Short for ‘chloroflurocarbons’, which are chemicals used in manufacturing and, in the past, in aerosol cans and refrigerators, which
can damage the ozone layer.
Climate change
A change in the climate of a region over time due to natural forces or human activity. In the context of the UN Framework
Convention on Climate Change, it is the change in climate caused by higher levels of greenhouse gases in the atmosphere due to
human activities as well as natural climate changes. See also global warming, and UN Framework Convention on Climate Change.
Deforestation
The reduction of trees in a wood or forest due to natural forces or human activity such as burning or logging.
Development plan
A public plan that sets out the development objectives and policies of a local authority for its area. It covers a six-year period and
states the local authority’s goals for a range of areas such as maintaining and improving roads and parks, preserving and enhancing
amenities (such as playgrounds or swimming pools), zoning land for homes, businesses, factories and farming and providing services
and facilities such as waste disposal and sewerage. Members of the public have opportunities to make submissions on the plan
before it is agreed.
Ecosystem
A community of organisms that depend on each other and the environment they inhabit.
Effluent
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Emissions
In the context of the atmosphere, gases or particles released into the air that can contribute to global warming or poor air quality.
Energy efficiency
Actions to save fuels, for example better building design, changing production processes, developing better transport policies, using
better road vehicles and using insulation and double glazing in homes.
A statement about the expected effects on the environment of a proposed project or development such as a new road or waste
water treatment plant, including how any severe effects on the environment will be addressed.
Greenhouse gases
Gases such as carbon dioxide and methane, which tend to trap heat radiating from the Earth’s surface, so causing warming in the
lower atmosphere. The major greenhouse gases that cause climate change are carbon dioxide (CO2), methane (CH4) and nitrous
oxide (NO2). See also greenhouse effect and global warming.
Ground water
Water that collects or flows underground in the small spaces in soil and rock. It might be a source of water for springs and wells and
then used for drinking water.
Hazardous waste
Waste that poses a risk to human health or the environment and needs to be handled and disposed of carefully. Examples include
oil-based paints, car batteries, weed killers, bleach and waste electrical and electronic devices.
Insulation
In this guide, material such as foam or glass wool that is used in homes and other buildings to prevent heat loss, reduce noise and
improve comfort.
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Landfill
A site that is specially designed to dispose of waste and operates with a license granted by the Environmental Agency (EA). The EA
reviews licenses and, with local authorities, monitors landfills around the country for emissions.
Noise pollution
Noises that disturb the environment and people’s ability to enjoy it, for example continually sounding house alarms, loud music, air
conditioning or other electrical units and aircraft or motor engines.
Oil spill
The harmful release of oil into the environment, usually through water, which is very difficult to clean up and often kills birds, fish
and other wildlife.
Ozone layer
The thin protective layer of gas 10 to 50km above the Earth that acts as a filter for ultraviolet (UV) radiation from the sun. High UV
levels can lead to skin cancer and cataracts and affect the growth of plants.
Particulate matter
Fine solid or liquid particles that pollute the air and are added to the atmosphere by natural and man-made processes at the Earth’s
surface. Examples of particulate matter include dust, smoke, soot, pollen and soil particles.
Pesticides
A general term for any chemicals that are used to kill weeds, fungi, insects or other pests.
Permits
In the context of waste, certificates or other documents granted by local authorities to private companies to collect and manage
waste or to operate waste management facilities such as recycling centers.
Planning permission
Permission granted by a local authority for new buildings or for extensions, once nobody objects to the plans.
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Radiation
A form of energy that is transmitted in waves, rays or particles from a natural source, such as the sun and the ground, or an artificial
source, such as an x-ray machine. Radiation can be ionising or non-ionising. Ionising radiation includes ultraviolet rays, radon gas and
X-rays. Too much exposure to ionising radiation can be harmful, leading to increased risk of cancer. Non-ionising radiation includes
visible light, radio waves and microwaves. This type of radiation is less risky to health because it contains less energy, but it can still
be harmful at high levels for a long time.
Recycle
To break waste items down into their raw materials, which are then used to re-make the original item or make new items.
Sewage
Liquid wastes from communities, which may be a mixture of domestic effluent from homes and liquid waste from industry.
Smog
Air pollution consisting of smoke and fog, which occurs in large urban and industrial areas and is mainly caused by the action of
sunlight on burned fuels, mostly from car exhausts. Smog can cause eye irritations and breathing problems and damage plant life.
Toxic
V - Ventilation
In this guide, the movement of air between the inside and outside of a building usually through windows, doors and air vents built
into the building’s walls or ceilings.
W - Waste management
The management of waste collection, handling, processing, storage and transport from where it is produced to where it is finally
disposed. See waste prevention.
Waste prevention
An aspect of waste management that involves reducing the amount of waste we produce and minimising the potential harm to
human health or the environment from packaging or ingredients in products.
WEEE
Short for Waste Electrical and Electronic Equipment (WEEE), which are any unwanted devices with a plug or battery – from a remote
control or digital camera to a vacuum cleaner or fridge freezer. These devices must be disposed of carefully to avoid damage to the
environment. To get rid of an unwanted device, you can bring it to a civic amenity site or leave it with a retailer when you are buying
a new device. All WEEE left in retail outlets and civic amenity sites are collected for recycling.
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X/Y/Z - There are no terms starting with the letters X, Y or Z.
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