Sustainability Action Plan 2019

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Sustainability Action Plan 2019
Sustainability Action Plan 2019
Sustainability Action Plan 2019

       Contents
1.0    Strategic goal: Engage with our stakeholders                                                    3
	Policy goal A: Engage with advisors, suppliers, tenants and stakeholders to ensure we
  are aware and respond to their expectations                                                          3
	Policy goal B: Engage with advisors, suppliers, tenants and stakeholders to disseminate
  the Group’s corporate responsibility policies and requirements                                       4

2.0 Strategic goal: Invest in our community                                                            5
	Policy goal C: Shaftesbury is committed to investing in its local community                          5

3.0	Strategic goal: Fair and ethical framework for employees
     including supply chain                                                                            6
	Policy goal D: Shaftesbury will conduct its business with integrity and in an open and ethical
  manner and require the same standards throughout its supply chain                                    6
	Policy goal E: Shaftesbury recognises the importance of the welfare of its employees                  7
	Policy goal F: Shaftesbury is committed to supporting the Universal Declaration of Human Rights
  and respects the human rights of its employees through providing equal opportunity for all its
  employees and potential employees and expects its principal advisors and suppliers to do the same    8

4.0	Strategic goal: environmentally sustainable reuse and
     management of buildings                                                                           9
	Policy goal G: Comply with legal requirements                                                        9
	Policy goal H: Before purchase, environmental audits are conducted where appropriate                 9
	Policy goal I: Work with other stakeholders to investigate and promote solutions to reduce
  air pollution in the West End                                                                        9
	Policy goal J: Shaftesbury requires its consultants and contractors to adopt best environmental
  practice in the design and refurbishment of the Group’s property portfolio                           10
	Policy goal K: Shaftesbury requires its managing agents to comply with its sustainability policies   12

	Note: The timeframe of 2018–2019 for implementation of the objectives and targets is consistent
  with the financial year, which is 1st October 2018 to 30th September 2019.

       2
Sustainability Action Plan 2019

1.0 Strategic goal: Engage with our stakeholders
    olicy goal A: Engage with advisors, suppliers, tenants and
   P
   stakeholders to ensure we are aware and respond to their
   expectations

                                           Management Actions                     Key Performance
   Number     Objectives                   2019                                   Indicator                    Responsibility
   A1         Disseminate the Policy       • Ensure Policy continues to be                                     Managing agents
              to all the Company’s           issued to all new commercial
              staff, managing agents,        tenants as part of tenants pack.
              contractors, and tenants     • Ensure Contractors’ Leaflet                                       Shaftesbury/
              and ensure that it is          is issued as part of all                                          Project Managers
              available to the public        refurbishment contracts
   A2         Provide appropriate          • Promote online Building                                           Shaftesbury/
              awareness raising and          Guide for commercial tenants                                      Managing agents
              engagement with tenants        including information on
              within the portfolio           sustainability.
                                           • Include sustainability principles                                 Shaftesbury/
                                             and requirements in letting                                       Managing agents
                                             documentation
              Targets                      • Include SRA fit out guide within     • Number of new              Shaftesbury
                                             tenants letting pack.                  restaurant tenants using
                                                                                    the guide
                                           • Include requirement for              • Number of tenants          Shaftesbury/
                                             data collection of energy              collating data             Managing agents
                                             consumption as part of ’green
                                             lease’ for new commercial
                                             tenants.
   A3         Provide appropriate          • Undertake update awareness                                        RPS/Shaftesbury
              training and awareness         training for all personnel and key
              to staff and principal         suppliers by November 2019.
              suppliers                    • Continue to issue the following                                   RPS/Shaftesbury
                                             checklists to the Principal
                                             Suppliers:
                                           • Contractors Checklist
                                           • Specification Checklist
                                           • Legal Compliance Checklist
              Target                       • Require all contractors working      % of subcontractors          Project Managers
                                             on Shaftesbury refurbishment         with CSCS cards
                                             schemes to record the
                                             number of employees
                                             and subcontractors with
                                             Construction Skills Certification
                                             Scheme (CSCS) Cards
   A4         For projects of capital      • Require all principal contractors                                 • Shaftesbury/
              value over £150,000, and       that work on Shaftesbury                                            Project Managers/RPS
              in excess of three months      schemes to register as a                                          • RPS to audit
              duration, Contractors will     company to CCS.
              sign up to Considerate       • Ensure all eligible schemes are
              Constructors Scheme.           signed up for 2018-2019.
              (NB. Schemes that only
              involve external repair
              and decoration will not
              be included)
              Target                       • Achieve a minimum score              % of schemes above           • Project Managers/RPS
                                             of 30/50 (above satisfactory         30/50                        • RPS to audit
                                             performance)
                                             on 100% of schemes audited.

    3
Sustainability Action Plan 2019 1.0 Strategic goal: Engage with our stakeholders

Policy goal B: Engage with advisors, suppliers, tenants and
stakeholders to disseminate the Group’s corporate
responsibility policies and requirements

                                          Management Actions
Number     Management Objective           2019                                                Responsibility
B1         The Policy will be reviewed    • Review Policy in August 2019 for                  RPS/Shaftesbury
           on an annual basis and           approval at the Board meeting
           objectives and targets will      in September 2018.
           be set.                        • Monitor use of Supplier
                                            Code of Conduct.
B2         The Company will monitor       • Report performance on                             RPS/Shaftesbury
           and report publicly on its       Company website,
           performance                    • Include summary of
                                            performance
                                            in Annual Report 2018
                                          • Prepare report in accord
                                            with EPRA Sustainability
                                            Best Practice
                                            Recommendations
B3         The Company will maintain      • Engage with key investors and                     Shaftesbury/RPS
           its ongoing engagement           other benchmarking agencies.
           with institutional investors   • Continue membership of Better
           and benchmarking indices         Building Partnership (BBP).
                                          • Remain as signatory to
                                            UN Global Compact
           Targets                        • Remain in FTSE4Good Index        Score in index   Shaftesbury/RPS
                                            for 2018-2019.
                                          • Participate in GRESB             Score in index
                                            survey
                                          • Participate in Carbon Disclosure Score in index
                                            Project and improve score

4
Sustainability Action Plan 2019

2.0 Strategic goal: Invest in our community
	Policy goal C: Shaftesbury is committed to investing in its local
  community

                                            Management Actions                 Key Performance
    Number     Objectives                   2019                               Indicator         Responsibility
    C1         Continue membership of       Ongoing financial support to key Value of support    Shaftesbury
               the London Benchmarking      charities and community support as per LBG
                                            for 2018-2019.
    C2         Support local community      Promote activities of Community                      Shaftesbury
               groups and be proactive      Investment Committee.
               in identifying and working   Continue to work with charity                        Shaftesbury
               with charitable and other    partners in 2019.
               organisations
                                            Continue to work with statutory                      Shaftesbury
                                            bodies through financial support
                                            to improve the local environment
                                            and public realm e.g. lighting
                                            projects, pavement maintenance
                                            etc.

     5
Sustainability Action Plan 2019

3.0	Strategic goal: Fair and ethical framework for
     employees including supply chain
    olicy goal D: Shaftesbury will conduct its business with
   P
   integrity and in an open and ethical manner and require the
   same standards throughout its supply chain

                                           Management Actions                   Key Performance
   Number     Objectives                   2019                                 Indicator             Responsibility
   D1         Provide the standards of     • Continue to maintain existing                            Shaftesbury surveyors/
              accommodation and              regular liaison between tenants,                         Managing agents
              services that have been        managing agents & Shaftesbury.
              agreed
              Target                       • Undertake small bespoke tenant % satisfaction rate       CBRE
                                             surveys at targeted areas
   D2         Comply with the Prompt       • Monitor payment times                                    Shaftesbury
              Payment Code
              Target                       • Suppliers to be paid within        % of suppliers paid   Shaftesbury
                                             30 days                            within time frame
   D3         Promote principles of the    • Monitor implementation of                                Shaftesbury/
              UN Global Compact down         Supplier Code for first tier                             Managing agents/
              the supply chain               suppliers to promote UNGC                                Project managers
                                             principles
   D4         Work against corruption      • Monitor implementation of                                Shaftesbury
              in all its forms in accord     Bribery and Anti- Corruption
              with the anti corruption       Policy and engage with supply
              principle of the UN Global     chain in its implementation
              Compact and ensure
              compliance with anti
              bribery and corruption
              policy.

    6
Sustainability Action Plan 2019 3.0 Strategic goal: Fair and ethical framework for employees including supply chain

Policy goal E: Shaftesbury recognises the importance of the
welfare of its employees

                                          Management Actions                    Key Performance
Number     Objectives                     2019                                  Indicator                   Responsibility
E1         Fully comply with all the      • Review Health and Safety Policy                                 • Shaftesbury
           requirements of the Health       for Head Office and portfolio.
           & Safety at Work Act           • Ensure health & safety induction                                • Project Managers
           1974 etc. for employees          training is being undertaken by
           and those that may be                                                                            • RPS to audit
                                            contractors for 100% site staff
           affected by its activities       including use of contractor
           and minimise risk of             induction leaflets.
           reportable health and
           safety accidents/incidents
           throughout the portfolio
           Targets                        • Achieve zero reportable             Number of prohibition/      Project managers
                                            accident/incidents on               enforcement notices
                                            refurbishment sites throughout      received
                                            100% of the portfolio.
                                          • Achieve zero reportable             Number of prohibition/      Managing agents
                                            accident/incidents throughout       enforcement notices
                                            100% of the managed portfolio.      received
                                          • Record absenteeism within           Number of days absent/      Shaftesbury
                                            Shaftesbury Head Office.            employee
                                          • Continue to improve                 % score at next review      Shaftesbury
                                            performance for next
                                            assessment against
                                            Fairplace Award in 2020.
                                          • Ensure all contractors on
                                            refurbishment projects hold
                                                                                % of site staff with
                                            Construction Skills Certification
                                                                                CSCS cards
                                            Scheme (CSCS) Card

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Sustainability Action Plan 2019 3.0 Strategic goal: Fair and ethical framework for employees including supply chain

Policy goal F: Shaftesbury is committed to supporting the
Universal Declaration of Human Rights and respects the
human rights of its employees through providing equal
opportunity for all its employees and potential employees and
expects its principal advisors and suppliers to do the same

                                          Management Actions                  Key Performance
Number     Objective                      2019                                Indicator                     Responsibility
F1         Comply with employment         • Ensure approach to internal
           legislation and best             staff management & recruitment
           practice including diversity     to ensure compliance with
                                            equal opportunities policy
                                            and diversity complies with
                                            Principles of the RICS Quality
                                            Mark and Real Estate Balance.
           Targets                        • Monitor staff turnover.           % of leavers as part of       Shaftesbury
                                                                              total staff number per year
                                          • Monitor average length of         Number of years of            Shaftesbury
                                            service                           service per employee
                                          • Monitor relevant diversity        % of women in board/          Shaftesbury
                                            metrics including % of women      senior/ management
                                            in key positions                  positions
                                          • Record number of staff with       % of staff                    Shaftesbury
                                            flexible working/part time
                                            arrangements.
F2         Invest in training and         • Ensure approach to internal
           development of our               staff management & recruitment
           employees.                       to ensure compliance with
                                            equal opportunities policy
                                            and diversity complies with
                                            Principles of the
                                            RICS Quality Mark and Real
                                            Estate Balance.
                                          • Undertake Personal             Days training                    Shaftesbury
                                            Development Reviews for all
                                            personnel and
                                            record training.
F3         Ensure London Living Wage • Work with managing agents and                                        Shaftesbury/
           is paid through the supply   project managers to monitor                                         Managing agents/
           chain where within our       scale of remuneration for all full                                  Project managers
           control.                     time personnel working within
                                        the portfolio
                                      • Work with managing agents and
                                        project managers to monitor
                                        scale of remuneration for
                                        contractors working on the
                                        portfolio.
           Target                         • All new contracts agreed within % of contracts                  Shaftesbury/
                                            the managed portfolio to pay                                    Managing agents
                                            London Living wage
                                          • Maintain accreditation from                                     Shaftesbury
                                            London Living Wage Foundation
F4         Principal suppliers to     • Continue to work with                                               Shaftesbury/
           ensure compliance with the tier 1 suppliers in ensuring                                          All Tier 1 suppliers
           Modern Slavery Act within    compliance with the Modern
           the supply chain             Slavery Act.
           Target                     • Increase awareness of site                                          Shaftesbury
                                        management teams through use
                                        of leaflets and posters at sites
                                        e.g. Stronger2gether

8
Sustainability Action Plan 2019

4.0	Strategic goal: environmentally sustainable
     reuse and management of buildings
   Policy goal G: Comply with legal requirements

                                            Management Actions                   Key Performance
   Number     Objectives                    2019                                 Indicator                Responsibility
   G1         Comply with all legal and     • Review legislation checklists                               RPS to liaise with:
              regulatory requirements         to ensure are current.                                      • Shaftesbury
                                            • Monitor environmental
                                                                                                          • Project Managers
                                              compliance on refurbishment
                                              and construction projects for                               • Managing agents
                                              2018-2019 using checklist
              Target                        • Achieve zero environmental         No. of non-compliances   All above
                                              non- compliance for 2018-19

   Policy goal H: Before purchase, environmental audits are
   conducted where appropriate

                                            Management Actions                   Key Performance
   Number     Objectives                    2019                                 Indicator                Responsibility
   H1         Undertake environmental/ • Ensure environmental/building                                    Shaftesbury/RPS
              building health surveys       health surveys are used to
              of properties prior to        screen properties before
              purchase if appropriate and purchase of all properties,
              continue to invest only in    including risks from climate
              ‘brownfield’ sites            change, rising water tables and
                                            localised flooding.
                                          • Review acquisition checklist
                                            in line with GRESB and BBP as
                                            appropriate to portfolio.
              Target                        • Continue to achieve 100% use     % of brownfield            Shaftesbury
                                              and regeneration of ‘brownfield’
                                              land during expansion and
                                              refurbishment
                                              of portfolio.

   Policy goal I: Work with other stakeholders to investigate and
   promote solutions to reduce air pollution in the West End

                                            Management Actions                   Key Performance
   Number     Objectives                    2019                                 Indicator                Responsibility
   I1         Work with other local         • Implement Air Quality Strategy                              Shaftesbury/
              land owners, occupiers,       • Continue to work with tenants in                            Managing agents
              local authorities and the       Carnaby to coordinate deliveries
              Mayor’s office to investigate to the managed portfolio
              and promote solutions to        through partnership with
              reducing air pollution in       suppliers and expand initiative
              central London                  to Soho and Seven Dials.

    9
Sustainability Action Plan 2019 4.0 Strategic goal: environmentally sustainable reuse and management of buildings

Policy goal J: Shaftesbury requires its consultants and
contractors to adopt best environmental practice in the
design and refurbishment of the Group’s property portfolio

                                         Management Actions                    Key Performance
Number    Objectives                     2019                                  Indicator                   Responsibility
J1        To operate in an            • Continue to refurbish existing                                     Shaftesbury
          environmentally sustainable buildings and promote the re-
          manner throughout its         use of materials to reduce the
          activities and minimise the   need to introduce additional
          impact on climate change      ‘embodied’ carbon.
          through use of BREEAM       • Continue to assess on project                                      Shaftesbury/
          and increasing the EPC        by project basis whether                                           Project Managers
          rating of properties being    renewable energy technologies
          refurbished                   can be economically
                                        incorporated into future
                                        projects, including heat
                                        recovery technology.
                                      • Encourage tenants to use the                                       Shaftesbury/RPS
                                        Better Building Partnership best
                                        practice fit out guide.
          Targets                        • Achieve BREEAM Very Good            BREEAM Score                Shaftesbury/SPPM
                                           for all new commercial
                                           developments.
                                         • Achieve BREEAM Very Good            BREEAM Score                Shaftesbury/
                                           for domestic and non domestic                                   Project Managers
                                           refurbishment schemes of a
                                           capital value above £1 million
                                         • Aim for an EPC Grade B EPC          EPC rating                  Shaftesbury/SPPM
                                           rating on new build
                                         • In all structural refurbishments    EPC rating of C for         Shaftesbury/
                                           of non listed buildings over        structural refurbishments   Project Managers
                                           £150,000 (excluding retail shell)
                                           that the existing EPC rating is
                                           improved to
                                           a C rating.
J2        Efficient use of energy        • Project managers to use revised                                 • RPS/Project Managers
          and water                        Specification and Contractor’s
                                           checklists for all projects over
                                           £150,000 and in excess of 3
                                           months duration.
J3        Source timber from well      • Continue to maximise                                              • Project managers
          managed sources, certified     proportion of timber that is                                      • RPS to audit
          by third party certification   reused within projects and
          schemes                        monitor for reporting purposes.
                                       • Contractors to retain all timber                                  • Project Managers to
                                         supply invoices and ensure that                                     ensure contractors retain
                                         full chain of custody details are                                   invoices
                                         recorded.
                                       • RPS to collate information to                                     • RPS to collate
                                         identify proportion sourced
                                         from certified timber
          Targets                        • Ensure that 100% of hardwood    % of hardwood timber         • Shaftesbury /
                                           timber is sourced from a        from a certified sustainable   Project Managers
                                           certified sustainable source.   source                       • RPS to audit
                                         • Ensure that preferred suppliers % of other timber sourced • Shaftesbury /
                                           demonstrate sourcing of a       from a certified sustainable   Project Managers
                                           minimum of 90% of other types source                         • RPS to audit
                                           of timber from a certified
                                           sustainable source.
                                         • Aim for suppliers to source a   % of FSC timber sourced      Project managers
                                           minimum of 70% timber from                                   RPS to audit
                                           an FSC certified source.

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Sustainability Action Plan 2019 4.0 Strategic goal: environmentally sustainable reuse and management of buildings

Policy goal J continued

                                         Management Actions                     Key Performance
Number    Objectives                     2019                                   Indicator                 Responsibility
J4        Management and disposal        • Continue to monitor                                            • Project managers
          of construction waste            construction waste generated                                   • RPS to audit
                                           data for all projects above
                                           £150,000 and in excess of 3
                                           months duration.
                                         • Project managers to ensure
                                           waste transfer notes retained as
                                           part of contract documentation.
          Target                         • Aim to reuse or recycle 90% of       % of reused or recycled   Project managers
                                           non-hazardous demolition and         waste for projects
                                           construction waste by weight
J5        Improve biodiversity           • Continue membership of                                         • Shaftesbury
          appropriate to the Group’s       Wild West End                                                  • Managing agents/Project
          urban location                 • Implement five year Biodiversity                                 managers to implement
                                           Strategy.
                                         • Continue to research
                                           opportunities of supporting
                                           bees in the capital with
                                           appropriate use of planters and
                                           window boxes.
          Target                         • Increase area of biodiversity        Area of biodiversity      • Shaftesbury
                                           features                             features                  • Managing agents/Project
                                           by 10% throughout portfolio.                                     managers to implement
                                         • Implement green roof
                                           installation
                                           at a minimum of two locations
                                         • Investigate opportunity for
                                           parklet
J6        During construction the        • Continue to provide all                                        Project managers
          Company through its              contractors with a copy of the
          Project Managers will            Company Policy & Specification
          endeavour to minimise            questionnaires etc. in tender
          adverse impacts on the           documentation
          environment                    • Continue to issue Induction                                    Project managers
                                           Leaflet to all contractors
                                           working on portfolio.
                                         • Continue to ensure that there                                  Project managers
                                           are minimal emissions to air
                                           and water given small scale and
                                           location of schemes in central
                                           London
                                         • Monitor energy and water use                                   Project managers
                                           on site throughout the life of the
                                           project.
          Targets                        • Achieve zero reportable              % schemes with zero       Project managers
                                           environmental incidents              incidents
                                         • Ensure that a minimum of 80%         % of water based          Project managers
                                           water based paints are used to       paints specified
                                           minimise pollution.

11
Sustainability Action Plan 2019 4.0 Strategic goal: environmentally sustainable reuse and management of buildings

Policy goal K: Shaftesbury requires its managing agents to
comply with its sustainability policies

                                         Management Actions                      Key Performance
Number    Objectives                     2018-2019                               Indicator                   Responsibility
K1        Maximise use of landlord       • Continue to monitor energy                                        Managing agents to collect
          procured renewable               consumption in Shaftesbury                                        data
          energy and reduce energy         Head Office and common parts
                                                                                                             RPS to collate for reporting
          consumption in common            of portfolio
                                                                                                             baseline
          parts                          • Increase proportion of
                                           definitive floor areas that are
                                           being assessed against energy
                                           consumption.
                                         • Implement step change findings
                                           from ESOS audits
                                         • Obtain tenants consumption
                                           figures and collate for reporting
                                           purposes for whole buildings for
                                           REEB 2019.
          Targets                        • Aim for wholly owned common           Carbon per m2 not to        Managing agents/
                                           parts normalised data to not          exceed target               Shaftesbury
                                           exceed 0.05tonne C02e/m2
                                         • Aim for 3% absolute reduction         % absolute reduction        Managing agents/
                                           in landlord controlled energy         across portfolio            Shaftesbury
                                           consumption against 2018.
                                         • Aim for 5% like for like reduction    % like for like reduction   Managing agents/
                                           in landlord controlled energy         across portfolio            Shaftesbury
                                           consumption against 2018.
                                         • When renewing energy                  % new contracts placed on Managing agents/
                                           contracts throughout the              green energy tariffs      Shaftesbury
                                           portfolio purchase ‘green tariff’
                                           electricity when costs are within
                                           5% of brown energy.
                                         • Increase proportion of LED            % of LED bulbs within       Managing agents
                                           bulbs within common parts             portfolio
                                           of managed portfolio and
                                           specifically for external lighting.
K2        Reduce Greenhouse Gas          • Continue to monitor and report                                    RPS/Shaftesbury
          emissions within managed         greenhouse gas emissions for
          portfolio                        landlord controlled portfolio
                                           including the Head Office.
          Targets                        • Reduce Greenhouse Gas
                                           emissions by a rolling target of
                                           5% from the baseline of 2015
                                           by 2020.
K3        Monitor and, where             • Continue to investigate                                           Managing agents
          possible, minimise water         opportunities for including
          consumption                      water meters in properties
                                           where Shaftesbury is
                                           responsible for water purchase.
          Targets                        • Monitor water use in Carnaby/ % of coverage                       CBRE to collect data
                                           Seven dials common parts – aim                                    RPS to collate for reporting
                                           for 75% reporting of readings.                                    baseline
                                         • Increase coverage of water            % of coverage               Managing agents
                                           data collection in remainder of                                   to collect data
                                           wholly owned portfolio
                                         • Aim to reduce like for like water     % reduction                 CBRE and MJ Mapp
                                           consumption by 5% from 2018                                       to collect data
                                                                                                             RPS to collate for reporting
                                                                                                             baseline
                                         • Aim for usage at maximum              Water use does not          CBRE and MJ Mapp
                                           of 0.5m3/m2                           exceed 0.5m3/m2             to collect data
                                                                                                             RPS to collate for reporting
                                                                                                             baseline
                                         • Monitor water use for South           Water use does not          MJ Mapp
                                           Service yard in Chinatown –           exceed 2017-2018 usage
                                           maintain constant usage

12
Sustainability Action Plan 2019 4.0 Strategic goal: environmentally sustainable reuse and management of buildings

Policy goal K continued

                                         Management Actions                    Key Performance
Number    Objectives                     2018-2019                             Indicator                 Responsibility
K4        Monitor and reduce             • Work with tenants to abolish                                  Shaftesbury
          waste from its managed           single use plastics throughout
          properties including the         the portfolio.
          Head Office                    • Maintain discussions with
                                           Westminster CC to identify                                    Shaftesbury/
                                           residential waste management                                  MJ Mapp
                                           centre within Chinatown.
          Targets                        • Divert from landfill minimum of     % of tenants’ waste       Shaftesbury/CBRE
                                           90% of tenant generated waste       diverted from landfill
                                           from Carnaby and Seven Dials.
                                         • Recycle a minimum of 50%            % of waste recycled       CBRE
                                           tenants waste at Carnaby and
                                           Seven Dials
                                         • Aim for 20% compostable waste       % of waste composted      Shaftesbury/CBRE
                                           at Carnaby and Seven Dials
                                         • Maintain high rate of recycling     % of waste recycled       Shaftesbury/RPS
                                           at above 95% in Head Office
K5        Ensure that contractors        • Issue updated induction Leaflet                               • Shaftesbury
          (including cleaners,             to all contractors working on                                 • Managing agents
          maintenance personnel            portfolio throughout 2018-2019.
          etc) comply with the policy    • Maintain documented audit                                     • Managing agents
          with respect to the use          trail of contractors that have                                  to keep records
          of hazardous materials           received leaflet.
          and materials from non-                                                                        • RPS to audit
          renewable resources;
K6        Remove and dispose of          • Ensure up to date asbestos                                    • Managing agents to
          hazardous materials e.g.         register is held for managed                                    maintain asbestos register
          asbestos in accordance           portfolio.                                                    • Managing agents to
          with relevant legislation      • Retain copies of waste transfer                                 collate hazardous waste
                                           notes and record volume of                                      data
                                           hazardous waste disposed to                                   • RPS to audit
                                           landfill
K7        Minimise emissions to          • Continue rolling programme                                    • Managing agents to keep
          air through appropriate          throughout the portfolio of                                     records
          management of buildings          maintenance of extractor ducts.
                                         • Progress boiler upgrades
                                           where viable following ESOS
                                           recommendations.
                                         • Commission survey of
                                           remainder of portfolio to
                                           identify boilers that could be
                                           updated.
K8        Minimise emissions to          • Undertake discussions with                                    • MJ Mapp
          water through appropriate        tenants re. findings of review of
          management of buildings          effectiveness of grease traps for
                                           restaurants in Chinatown

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