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GRC Professional : GRC Winter 2012
13 to pass it through or to identify if companies have existing contractual obligations in place that don’t provide for that.” Detailed modelling in all areas is a must, taking into account all inputs of products and costs that are passed on through suppliers, such as electricity and gas. Ensuring carbon pricing claims are truthful is also necessary or companies could face fines of up to $1 million through action by the ACCC. “Companies also have to recalculate their emissions number each year, and obviously have to relook at all inputs in their models to see if they have changed,” she says. Incident response As Australia’s leading fuel supplier, Caltex Australia has to be at the top of its game when it comes to environmental compliance from its refineries, terminals and depots right through to its retail network. Caltex’s operations are subject to requirements across local, state and federal jurisdictions, and there are about 1800 Caltex-branded sites around Australia including refineries, terminals, depots and service stations. Sa m Collyer, senior media adviser for Caltex, says ongoing mon itor i ng and a com m itment to continuou s improvement is crucial. “We have teams of environmental experts positioned across each part of our business. Their role is to monitor and analyse our environmental performance and, wherever the need is identified, adjust our practices.” A well-developed incident response procedure is vital for any company engaged in transport and handling of hazardous materials. “Caltex engages with response agencies and conducts training exercises regularly. Bonuses are ava ilable to Caltex employee s a nd executives, depend ing on reaching environmental performance goals. We also have a The introduction of the carbon tax is set to bring environmental compliance into the mainstream of big business. c omprehen s ive oper ationa l gover n a nce process to monitor the health and performance of environmental controls and the emergency management system.” Transparency Caltex’s experience shows that community eng ag ement and approaching the regulatory env ironment in a spirit of collaboration is fundamental to competent environmental compliance. “We work closely with regulatory bodies and believe in maintaining open communication with regulators and our neighbours. We have dedicated community relations managers at both ou r refi ner ies,” rema rk s Collyer. Tomago Aluminium in NSW is Austra lia’s second -l a rg est aluminium s melter. Neil Roser, env iron ment al services team leader, says the Orica incidents were a wake-up call for businesses in heavy industry and manufacturing, and saw Tomago review its own compliance to the NSW State Gover n ment’s Protection of the Env iron ment Operations Act 1997. He points to the i mpor tance of independent review and reporting, and constant attention to the regulatory environment. “Every 12 months we do an external legal review using a third party company to coordinate it so X
GRC Autumn 2012
GRC Spring 2012