CR management

We require all businesses to implement the requisite level of risk management control to ensure compliance with our safety and environmental policies, taking into account business needs and local circumstances. Managers, operators, contractors and safety and environmental specialists work together to identify the main hazards and assess the risk of harm. Appropriate operational procedures and controls are put in place and all employees are provided with relevant information, training and supervision to reduce and manage those risks. Strong emphasis is placed on preventing accidents and incidents, but should they happen we have appropriate emergency plans which are rehearsed routinely.

47 manufacturing sites have an environmental management system externally certified to ISO 14001 standard or equivalent national standard. The remaining sites and Primark stores have internal environmental management systems which are broadly in line with ISO 14001. Similarly, 41 of our manufacturing sites are certified to nationally recognised health and safety management systems. This equates to 18% of our non-retail sites having externally certified management systems. Our safety specialists meet every year as a group to update themselves on developments and exchange examples of good practice.

The safety performance of our businesses is reported monthly and forms part of formal quarterly reviews with group management. Our environmental performance is reported and analysed annually. Due to the group’s considerable diversity we do not impose standard improvement targets on businesses. Instead, each business sets itself targets appropriate to the nature of its operations and risks, which are reviewed by the Group Human Resources Director and the Group Safety and Environment Manager, to ensure that they address the principal risks.

The risk management section, and selected data and case studies marked Δ within this report are subject to independent assurance under ISAE 3000 by KPMG; see here for their full assurance report.

For the eighth successive year we employed Environmental Resources Management Ltd (ERM) to continue a rolling programme of internal audits of the management of health, safety and environmental risks at a representative sample of our businesses. To date ERM has carried out 136 independent audits. The 27 sites visited in 2010 were selected on both a risk and sample basis according to geographical location, previous audit findings and their contribution to the health, safety and environmental performance of the group as a whole. 16 sites were audited for the first time in 2010, located in 15 countries across the continents in which we operate. 11 sites audited in 2009 were revisited to confirm resolution of outstanding issues. During these site visits, ERM also carried out internal data assurance over specified health, safety and environmental data. This included interviews at each of the 27 sites with relevant Company personnel and reviews and sample-tests of data, and of procedures and associated documents used for data collection, aggregation and reporting. Interviews and reviews of supporting documentation were also conducted at seven businesses (with combined responsibility for more than 75% of the total number of Company sites and over 80% of its total headcount). ERM tested the effectiveness of the data reporting processes and quality of aggregated data at Company level, and reviewed the presentation of the selected health, safety and environmental data in the draft report to ensure consistency with its findings.

In addition, Ernst & Young has verified Primark’s reporting on labour standards in its supply chain. For more information, please see www.primark.co.uk

The safety and environmental data in this report covers our 255 principal manufacturing sites and 200 Primark stores. Where possible, we also included safety and environmental data for some of the many depots, offices and distribution centres within the group. We do not include data from those joint ventures in which we have a 50% interest or less and do not report on the impact of agricultural operations in our businesses. (This differs from prior year health, safety and environmental data where certain joint ventures were included; hence the comparative data in this report differs slightly from previously reported heath, safety and environmental data.) Through the application of the PAS 2050 carbon footprinting standard we have begun to consider the impact of the transport activities within our supply chain and the disposal/recycling of our finished products, but these are not included in our performance data. We have not made any acquisitions during the year and we have not included the data from those sites which we sold or closed during the year. The reporting period for this data is from the end of August 2009 to the end of August 2010.