THE THINKING BEHIND OUR INDICATORS

We have a range of policies and guidelines in place to govern our sustainability practices. These include our Environmental Management System which establishes the procedures that must be followed on all our projects, our Occupation Health & Safety (OH&S) program that promotes and ensures the safety of employees and contractors, and our performance management system that monitors staff performance and facilitates career development across the organisation.

We include requirements in all our contracts relating to this governance framework, and expect those who work with Landcom to meet these contract conditions through self audits. Since we do not directly manage all of the projects on our sites, we opted to take this approach to promote appropriate behaviour and transfer risk to those who are actually managing the risk.

A non compliance target of zero (or 0%) has been set for many of these indicators. We acknowledge that this represents an aspiration that may never be achieved, but in our efforts to be a responsible developer, a target which contemplated even a small degree of non compliance did not seem appropriate.

Our Environmental Management System was recertified to AS/NZS ISO 14001:2004. This gives us the confidence that the systems and processes we have in place are working successfully and environmental risks are being managed effectively. However, inconsistent levels of reporting and compliance against some of these indicators are of concern. Sub-optimal results against some of the indicators can be explained by the need to iron out difficulties in the new business practices and processes associated with our second generation indicators. We will also continue to educate our staff on the importance of this indicator set.

HOW WE PERFORMED

Only eight out of 24 contractors (or 33% of contracts let) carried out environmental and OH&S audits in accordance with contract conditions. The self-auditing requirement is relatively new and because it is a new indicator, internal audits carried out by the contractors themselves were accepted for this reporting period. However, now that both contractors and Landcom staff are familiar with this contract requirement, we will take steps to enforce it rigorously in 2010/2011.

No builder contracts carried out environmental or OH&S audits during the reporting period. Our active projects include only two builder contracts (i.e. for our Redgum and Waterford projects). Waterford’s contract was signed in 2003 and Redgum’s was signed in 2006, which means neither contained the requirement for environmental audits when they were originally executed.

The remaining contracts we have with builders are for the Ageing, Disability and Home Care group homes. The requirement for an Environmental Management Plan audit was not included in the contracts let so far. As previously mentioned, this is a new and evolving relationship, and we spent the year developing management protocols. The requirement for an Environmental Management Plan self-audit has now been included in future contracts. OH&S selfaudits were included in the contracts, but none were completed by an external auditor. However, Landcom has weekly safety notes and inspections from each of the group home builders.

For those projects with display villages during the reporting period (Oran Park), Landcom was only involved in the sale of land, and not construction of the homes.

For our other projects with built form being reported this year, the builder contract is with the Project Delivery Agreement partner (e.g. Australand for The Ponds Stage 1, Lend Lease for The New Rouse Hill) and we do not have the ability to ensure that Environmental Management Plan or OH&S self-audits are received. While we can request them, we cannot require the builder to provide them to us.

Our overall objective here is to influence the behaviour of our supply chain and make improvements in supply chain practices. However, we are having difficulty in collecting data and obtaining results for this indicator set. This is complicated by the fact that there are already a number of other authorities monitoring the industry. Our current methodology may not be the most appropriate approach, and we will review the indicator and consider how to improve compliance when reporting for 2010/2011.

Through the environmental and OH&S self-auditing process, eight of 16 civil contractors received immediate action rectification requests. Of these 8, there were 64 instances where the civil contractors were given immediate action rectifications based on findings from either the environmental or the OH&S audit. The actions identified mainly related to erosion and sediment management and environmental procedures and records. Landcom’s internal auditors also audited contracts that have been in place prior to this new indicator, and all results were above Landcom’s minimum required performance of 75%, with one project (Parkbridge) receiving a 100% result for the second year in a row.

Because no data were available, we were unable to record a result for the number of builder contractors issued with an immediate action rectification based on findings of either environmental or OH&S audits.

One penalty notice was received by a civil works contractor from a regulatory authority (Department of Environment, Climate Change and Water). This followed an incident where a Landcom civil works contractor tracked mud onto residential roads. Corrective action was taken by installing a truck washing and pressure cleaning system and laying a bitumen surface from the truck-wash to the boundary of the site. This incident occurred in late June 2009, which is outside the reporting period. However, it wasn’t resolved before the last year’s (2008/2009) sustainability report went to print, so is being reported this year. In future, we will reinstate Landcom’s original indicator, being ‘Projects that achieved full regulatory compliance with Protection of Environment Operation Act 1997 & environment, OH&S and planning legislation’ to ensure reporting of any authority notifications we receive.

No repeat offences or repeat non-compliances with immediate rectification requests were received from a regulatory authority in this reporting period.