Environmental and Social Assessment and Management System (ESMS)
Due to the nature of retailing businesses which typically have facilities within urban settings and limited environmental issues (e.g., L&FS, emergency response plans, waste management, effluents, and energy consumption), regulatory agencies usually do not require an environmental impact assessment (EIA). The company must comply with Colombian requirements (NSR-10 and NTC for construction, Decree 1076/2015 Decreto Único Reglamentario del Sector Ambiente y Desarrollo Sostenible, Resolution 0631/2015 for effluents discharge, Resolution 0627/2006 for noise, besides the regional and/or local requirements) to obtain the necessary permits and authorizations at local and/or regional levels as part of commercial developments. In the main cities (such as Bogota, Barranquilla, Santa Marta, and Cartagena), environmental agencies issue permits after a site inspection. In addition, since 2016, a national legal framework requires approval of effluents discharges (from environmental agencies or public service companies, depending on the city). An excel matrix is used to control the requests to the public authorities. An environmental database system is used to manage Key Performance Indicators results per store for aspects and impacts such as waste, water, wastewater, energy, and GHG emissions among others. E&S KPIs results are shared with the executive level / corporate level on a monthly basis. The Occupational Health and Safety Management System includes policies and procedures covering H&S at work and surveillance programs.
Ara Tiendas started pre-operational activities in 2012. Different matters are dealt by different people using different platforms/systems. Ara’s environmental objectives for 2018 are: (i) Assurance of environmental legal compliance, carrying out the plans documented in the matrix of environmental legal requirements identified in 2017, focused on highest risk issues; (ii) Strengthening of the E&S management system, also attending the program Environmental business management of the Secretary of Environment of Bogota, that seeks to align environmental management with ISO 14001; (iii) Creation of the company’s environmental standards to be adopted by the whole company.
Going forward, as per ESAP #1, the company will consolidate an integrated Environmental and Social Management System (ESMS), following corporate policies and procedures, and PSs provisions, and develop all necessary policies, management procedures and programs to deal with identified gaps. The ESMS will ensure ongoing review of issues in a continuous improvement context.
Policy
Ara’s Environmental Policy is based on three pillars: (i) Reduction of energy consumption and greenhouse gases emissions, (ii) Biodiversity preservation through an active contribution to the protection of biological diversity and ecosystem services, and (iii) Responsible waste management, through a commitment to the prevention, reduction and recovery of generated waste.
Identification of Risks and Impacts
The company developed a tool: Identification of Environmental Aspects and Impacts Matrix, considering three criteria: legal requirements, communications from external stakeholders, and assessment of the environmental impacts (frequency, relevance and scope of the impact). Each criterion is qualified in terms of its level or magnitude (1, 5, or 10). Qualifications of each identified environmental aspect are added, and the significance is classified as being high, medium, or low. The main aspects are: Energy consumption, organic wastes, wastewater, and emission of offensive odors. Key Performance Indicators (KPIs) arising from these are: electricity consumption, generation of plastic bags, water consumption, and wastes. Tools and mechanisms to track the KPIs are selected from the risks & impacts analysis. Ara is currently focused on energy consumption and carbon footprint reduction.
In addition, a risk matrix is used to the site selection decision-making process, including risk identification, assessment, and mitigation plan. The Director of Security reports to the CEO and is supported by managers and analysts for each region. The Insurance and Risk Management area of the company follows the Group´s Risk Management Policy, which is set according to the ISO 31000 standard.
Management Programs
With the objectives of continually improving the environmental performance of its activities, products and services, as well as to prevent pollution, minimize the environmental impacts and, as a minimum, ensure compliance with the applicable legislation, Ara develops management programs to promote resource efficiency, to mitigate water and energy consumption, to manage waste, to reduce the volume to be sent to landfills, to reduce the organic load of the effluents, to engage with workers and external stakeholders, to improve occupational health and safety, amongst other aspects.
Organizational Capacity and Competency
JM Group has a Committee on Corporate Governance and Corporate Responsibility, which is appointed by the Board of Directors and works closely with it, and an Ethics Committee, which monitors the disclosure and compliance with the Code of Conduct in all Group’s companies.
At the company level, an Environmental Specialist based in Bogota HQ reports to the Corporate Environmental Director. An environmental analyst is to be hired in 2018 to support him. In 2018, the company will outsource the licensing/permitting processes.
Occupational Health and Safety (OHS) is handled by an Employment Relations Manager in Bogotá, who reports to the HR Director, and Health Coordinators and Safety Coordinators for each region, who are in charge of managing drills and track Health and Safety (H&S) KPIs, supported by H&S analysists for each region. The company leverages the services and support provided by the professional risks insurance company (ARP). In 2018, Ara will hire an OHS Manager, who will report to the Employment Relations Manager.
Supply Chain Managers for each region receive support from four analysts, and report to the IT&Supply Director.
Security matters are handled by a Security’s Director, who reports to the CEO, with the support of two analysts, one Security Coordinator per region, and selected contractors for the whole country.
Going forward, as per the ESAP #2, Ara will review its internal environmental capacity to include at least one qualified environmental professional per each zone; and review responsibilities for stores’ managers on implementation of E&S management system and monitoring key E&S indicator. The company will submit a formal review of the internal capacity (personnel) to manage environmental, OHS and social elements in the operations, once expansion has been implemented. The company will review the need to have permanent staff covering these functions per each zone, as per ESAP #3.
Monitoring and Review
The company sets targets and KPIs results are compared to those targets and shared internally. Action plans are developed to improve the indicators, and in some cases, follow up audits are conducted. One of the main issues is related to stores’ construction. The company has different mechanisms to verify the compliance of the construction of stores with the legal requirements and the internal procedures, such as: Pre-opening, and post-opening inspections, annual H&S and HR audits, Ticketing Tool (Store Managers or Area Managers can report insecure conditions within the store through an internal system). The Fire Department’s authority does yearly inspections in each store.
Reporting to Carbon Disclosure Project - CDP is audited by an external independent consultancy.
Supply Chain:
The JM Group has advanced standards and imposes high requirements on its suppliers in terms of production, storage and food quality. In the case of suppliers of Private Brand and Perishables, Ara has an Evaluation Audit process in place which comprehends food safety, quality, infrastructure, product, process, personnel, and environmental legal requirements. The audit ranks suppliers according to defined criteria. In 2017, 116 Private Brands suppliers were audited in Colombia, the company conducted additional 37 evaluation audits, and 113 follow-up audits. 40 Perishables providers were audited in 2017.
Since 2014, and as part of the Carbon Disclose Project – CDP, the JM Group conducts an annual comprehensive survey of suppliers of products identified as containing deforestation risk commodities and requests the identification of the respective points of origin, up to country level. In 2017, in Portugal, Poland and Colombia, a total of 16,415 food and non-food products (SKU’s) were scoped and a survey was conducted on over 800 suppliers of products and packaging found to contain deforestation commodities.
Commodities assessed include: palm oil, soy, paper, wood and beef. JM is prioritizing engagement with suppliers heavily dependent on such origins, encouraging the use of certified commodities, alongside with product reformulation. The JM Group is part of The Consumer Goods Forum and has committed to this organization's ambition of ending 2020 with zero net deforestation in the supply chain. The first step of the JM deforestation risk management strategy is the substitution of deforestation-related commodities in Private Brand and Perishable products portfolio for certified ones or substitutes, and avoidance of countries of origin with high deforestation risk. In 2017, and comparing with the baseline year (2014), there was a 38% decrease of palm oil used in Private Brand products and Perishables. There was also a 41% reduction in paper and wood products from countries at risk of deforestation.
JM Group engages in a number of multi-stakeholder initiatives, both within the industry and with other organizations, in projects targeted at reducing deforestation from agricultural commodities production. Besides the already mentioned The Consumer Goods Forum (commitment to 2020 Zero Net Deforestation target, use of industry focused guidelines for the sustainable sourcing of timber, palm and soy and active participation in forest-related Working Groups), examples include Roundtable on Sustainable Palm Oil (the Group became a member in 2017) and the Soy Buyers Coalition, with whom the Group also started to cooperate with in 2017.
The assessments of Private Brand and Perishables suppliers for Quality covers waste management practices as well as a comprehensive set of environmental aspects, such as criteria associated with the management of water, effluents, atmospheric emissions, noise and hazardous substances. The company also assesses Health & Safety in the workplace and training conditions, comprehending criteria such as the existence and use of appropriate clothing, equipment for hand wash, rules of conduct, personal hygiene, the existence and conditions of social areas for employees, changing rooms and bathrooms for employees.
As per ESAP #4, the company will review the Private Brand Supplier’s Quality audits to include the screening of child labor, forced labor and significant occupational health and safety risks. As needed, Ara will train auditors and will amend supply contracts and Terms of Agreement to address these aspects.