2. Overbury & Morgan Lovell
Sustainability
Programme
Neil Pike Steve Smith
3. • What is Sustainability?
• Our sustainability programme
• EUTR Regulations
4.
5. PEOPLE PLANET PROFI
T
SIX TOTAL COMMITMENTS
1.Health & Safety 3.Energy & Carbon 5. Procurement
2.Training & Education 4.Waste 6. Employment
6. What is it?
• “Sustainability” means different things to different people
• The majority of construction personel still associate
sustainability with ‘environmental & energy’ initiatives
• Many of our clients are extremely advanced in their
sustainability programmes which embrace:
Community
Energy Environmental
Procurement Social
Charity
Health & Safety Staff Wellbeing
7. What is our sustainability vision?
100% recommended
Therefore we need to develop a flexible sustainability
framework which enables us to deliver for our
Clients – Staff - Suppliers
8. What are our key sustainability drivers?
1.Provide our clients with new sustainable
alternatives
2.Engage with our suppliers and trade
contractors to develop sustainable
innovations
3.Challenge the status quo of how we
procure and deliver our projects
9. Overbury aspire to developing our Overbury are committed to
environmental management to minimise progressively improving the
waste, enhance energy efficiency and health and safety of our
reduce our environmental impacts in employees and assisting those
everything we do. who work on our sites or interface
with us to do the same
Overbury recognises that talented
people are the key to success. We
are committed to looking after our
staff to create a effective work-life
balance.
Overbury’s office and site activities Overbury have developed a
impact on local communities. We are sustainable supply chain over many
committed to working with years. We are committed to
communities to enhance employment offering ethically sourced products
opportunities and developing a better and services for our clients.
environmental.
10. Sustainable
Integrated education
working
Moving
boundaries
Engaging local
suppliers
Enhanced
communication
Radical problem
solving
Changing Sharing
attitudes Technology
12. Points to be covered
Why is it important to you?
What is the timescale?
What are your obligations?
What is the role of Monitoring Organisations?
Who will enforce the EUTR?
What are the penalties for not complying?
What should you, the buyers be doing?
What information is needed from enquiry to order?
What assurances can Lavers offer?
Q & A’s
13. What is the EUTR?
• This is the European Union Timber Regulation
• It covers the importation of any timber based
product into the EU
• It is primarily focused on Tropical Hardwoods and
Far Eastern/Chinese Plywoods
• Voluntary Partnership Agreements (VPAs) have
been signed between EU and five other countries
• China made no comment on pledge
14. Why is it important to you?
• Prohibition on the first placing of illegal timber
that has been illegally harvested on the EU
market
15. What is the timescale?
• The regulation comes into effect on 3 rd March
2013
16. What are your obligations?
• Your obligations are determined by whether you
are a ‘Trader’ or an ‘Operator’
• The likelihood is that you are a Trader
17. Operators
• This is defined as those who first place timber
and/or timber-based products onto the EU
market.
• Must have a Due Diligence system in place
comprising of:
• Access to Information
• Risk Assessment
• Risk Mitigation
18. What is the role of Monitoring Organisations?
• Maintain and regularly evaluate a due diligence
system and grant operators the right to use it
• Checks that operators are using it’s due
diligence system properly
• Takes appropriate action if an operator is not
using it’s due diligence system properly
• Provide 3rd party credibility to the due diligence
system process
19. Who will enforce the EUTR?
• National Measurement Office
Risk and intelligence-based approach to
enforcement
Carry out checks on operators and
monitoring organisations to verify
compliance
Advise and provide guidance on complying
with the regulation
20. What are the penalties for not
complying?
• Fines proportionate to:
– the environmental damage
– the value of the products
– the tax losses
– economic detriment caused
• Seizure of the goods
• immediate suspension of authorisation to trade
• Imprisonment (for serious violation)
21. Traders
• This is defined as those who sell or buy on the EU
markets any timber and/or timber-based products
that have already been placed onto the EU market
by an operator.
• All ‘Traders’ throughout the supply chain must keep
records of who they have purchased from and (if
applicable) who they have supplied too.
• Records must be kept for a minimum of FIVE years
22. What should you be doing?
• Gain a basic understanding of EUTR and what your
obligations are to comply.
• Establish if you are a ‘Trader’, ‘Operator’ or both
• Carry out a level of Due Diligence even if you are a
‘Trader’. Company image is everything!
• Check delivery notes and invoices for correct
specification
• Add note to purchase documentation along lines of
“All timber supply must comply with EUTR
Regulations”
23. What information is needed from enquiry
to order?
• Ensure that your chosen supplier has FSC and
PEFC accreditation
• Ensure that your chosen supplier adopts a Due
Diligence system such as the TTF Responsible
Purchasing Policy to mitigate risk
• Specify FSC or PEFC certified products at time
of enquiry / order
24. What assurances can Lavers offer?
• We are both ‘Traders’ and ‘Operators’ and
understand the EUTR requirements for both.
• We have representation on various trade federation
committees including Board level and the EUTR is
on the agenda
• We hold FSC and PEFC Chain of Custody
• We operate a robust Due Diligence system that is 3rd
party verified on an annual basis
• We have introduced a Supplier Charter
27. Our mission
‘To be the first choice supplier of certified timber and
timber based products in the UK, by making it easy for
our customers to trade with us’
28. Who are we?
• A timber importer and merchant
• Established 1920
• Turnover approx. £100m
• A family business
• 13 branches / multi-regional
• 550 personnel
• Unique position within the marketplace
• Expansive product range - held
in stock
• Highly trained and experienced personnel
38. Why are we different?
Service
• Staff : trained experts - “the best in the business”
Supply Chain Management
• Robust supply chain
• Partnership approach
• Product innovation
• Market evolution
39. Partnerships - we develop genuine long term
partnerships with our suppliers ..
Just some of our leading supply partners
40. Why are we different?
Logistics
• Strategically located very large depots
• Significant quantities of stock
• Local services - machining / treatment / bespoke
• National production centre
• Rapid response delivery - 24/48hrs
• Vehicle tracking
41. Why are we different?
Corporate systems
• Progressive approach
to IT solutions
• Mobile data
• Electronic trading
– EDI / COINS / TRADEX
• Extranet
• E-trading
42. Environmental Policy
Our commitment;
‘to help preserve the world’s forests and promote
effective forestry management’.
• Over 96% of the material we supply is certified
• Full Chain of Custody
• CPET (Central Point of Expertise for Timber)
• FSC, PEFC, CSA, MTCC, MTCS & SFI
• RPP
43. Chain of Custody
• Chain of Custody certification provides evidence
of an unbroken chain from the forest to product.
• Chain of Custody certification is required within
every link in the Supply Chain.
• The Chain of Custody is broken when legal
ownership of the product is taken by any party
which is not accredited.
• Chain of Custody certification requires 3rd Party
accreditation by a recognised certification
organisation (BM Trada Certification Ltd).
44. TTF Responsible Purchasing Policy
The Responsible Purchasing Policy requires a Company
Policy with environmental commitments towards
procurement activities.
This involves:
• a Risk Assessment procedure to evaluate a suppliers
ability to support Company Policy.
• a Management Report to summarise the achievements
made.
• an annual 3rd Party audit to ensure compliant to the policy
and continuous improvement is being achieved.
45. Our service promise
By working in conjunction with our customers we
endeavour to ensure that;
• We provide a professional, helpful and friendly service
• All materials are delivered correct, in full and on time
•Materials supplied are fit for purpose – we will ensure
that the right material is provided for each application
•We look to provide product and service innovation where
possible
• Any problems are dealt with quickly and effectively
• We listen to our customers
46. London 2012
Gold medal for timber supply
• Over 50% of all timber used
• Four times more than next supplier
• Collaborative approach
• Making it ‘easy’ for the customer
• Legacy for our company
VPAs once agreed then will have FLEGT (Forest Law Enforcement Governance and Trade) licence. Cameroon Congo Gabon Liberia Ghana Indonesia/Vietnam/Malaysia have pledged but not yet signed.
Access to Information Description of product bought Country of harvest Quantity of material procured Name and address of Supplier Documents proving compliance with local legislation Risk Assessment Compliance with applicable legislation which may include Chain of Custody certification or Verified Legal Schemes (VLS) that are 3 rd party verified. No illegal harvesting of specific tree species. No illegal harvesting or practices in country of harvest. Complexity of supply chain Risk Mitigation Measures and procedures to minimise effectively the risk of illegality including: 3 rd party verification, additional documentation or changing supplier.
DEFRA are drafting and adoption of additional legislation covering detail on monitoring organisations and due diligence systems – to be finalised by June 2012. In short no MO’s have been authorised!
A competent authority has now been appointed – it is National Measurement Office (formerly weights and measures) Defra’s Animal Health & Veterinary Laboratories Agency (AHVLA) will be the designated Competent Authority for implementing the FLEGT licensing system in the UK. The UK Border Agency will be the enforcement authority for the regulations at the border . Away from the border AHVLA Wildlife Inspectors will have a role in checking compliance with the domestic regulations, with the police being responsible for investigating breaches and taking forward charges and prosecutions.
If you are a 'Trader' only, the EUTR requires that due diligence is carried out. If a small sub-contractor supplies you with timber and it was proven that the timber was in fact illegally sourced, because of their failing to carry out their own due diligence, your company would be at risk and be caught up in any investigation. Although it would be highly unlikely that a fine would be imposed, your industry reputation will be at risk.
By using ALTW you can be assured that a robust Due Diligence process has taken place. We are signatories to the Timber Trade Federations Responsible Purchasing Policy that is aligned to meet the EUTR obligations for ‘Operators’ (First placers). We hold FSC and PEFC Chain of Custody across all our Timberworld’s. Not all suppliers will have a Due Diligence system in place. On all timber contracts or purchase orders stipulate that “ All timber supply must comply with EUTR regulations ”
Who bought product from? I.e. Purchase orders – description of product. Who sold it to? i.e. Sales invoices
In terms of the 'who goes to jail'...if a due diligence system was in place and it failed to identify illegal timber being brought into the EU.....then it is more likely that a fine would be imposed that is proportionate to the 'crime'.....hence the industry reputational risk is higher...also beware of the ‘interested party’ brigade that will no doubt follow an illegal shipment to its end user!