
Our approach
Governance
Who oversees our sustainability requirements, and where the accountability for each of them sits.
The board's duty
Oversight of sustainability sits with our board as part of its core duty to direct the company and supervise its management. Our board considers sustainability within strategy, risk and performance oversight rather than as a separate agenda.
Key facts
Board oversight of sustainability is part of the board's core duties, not a voluntary committee mandate.
Responsibility for climate matters rests with executive management.
Sustainability risk sits in our single enterprise risk register.
Our governing policy for each subject names the escalation route.
Who is accountable for what
Sustainability risk
Sustainability risks are managed within our enterprise risk management framework rather than in a separate register. Environmental, social, human rights, supply chain and climate risks are assessed and recorded in the risk register, and treated on the same basis as financial, legal and operational risks. Risk assessment is built into project planning, procurement, permitting, project appraisal and operational decisions.
We structure our Enterprise Risk Management Policy against ISO 31000 and the COSO enterprise risk management framework, neither of which provides a basis for certification.
Escalation
The accountable function escalates systemic or unresolved issues to executive management and, where the matter warrants it, to our board. Where the law so requires, or where the issue concerns a matter within their remit, we escalate to the competent authorities, to providers of finance and to affected communities. The policy governing each subject names the escalation route, so that the route is settled before it is needed rather than determined during an incident.
Review
Each policy states the review cycle that applies to it, and is reviewed again after a significant incident or a change in regulation. Stakeholder feedback is taken into account in the review. The Climate Action Transition Plan is reviewed on the cycle stated in it, and where a review changes the methodology, a boundary or a target, the change and the reason for it are recorded and disclosed in the next issue of the plan.