ENVIRONMENTAL MANAGEMENT SYSTEM MANUAL
1 About this manual
This EMS Policy describes the systematic approach WDP adopts to its environmental management by implementing an environmental management system in order to contribute to the environmental pillar in its ESG strategy.
WDP chooses – on a best effort basis - to align its EMS with the requirements set forth in the international Standard ISO 14001.
The basis for the approach underlying an environmental management system is founded on the concept of Plan-Do-Check-Act (PDCA). Such model provides an iterative process used by organizations to achieve continual improvement.
• Plan: establish environmental objectives and processes necessary to deliver results in accordance with the organization’s environmental policy.
• Do: implement the processes as planned.
• Check: monitor and measure processes against the environmental policy, including its commitments, environmental objectives, and operating criteria, and report the results.
• Act: take actions to continually improve.
The EMS Policy has been drafted under the supervision of WDP’s ESG team, has been verified by Head of Energy and Sustainability and the Compliance Officer, and has been approved by WDP’s Management Committee.
2 Environmental Management System
2.1 Understanding the context
2.1.1 Environmental aspects
As a basis for its Climate Action Plan, WDP determined the main dimensions defining its environmental footprint and impacting WDP group’s operations:
• Land use
• Material use
• Resilient buildings
• Energy use
• Biodiversity
• Air pollution
• Light
• Waste
• Water use
• Noise
• Soil pollution
• Water pollution
On top of this, WDP conducts on a regular basis a “materiality analysis” to define its most important inwards and outwards impacts. This materiality analysis is conducted by the ESG team together with the CEO and covers a broader landscape of Environmental, Social and Governance aspects.
For more information:
• Climate Action Plan: page 11
• Annual Report 2022, page 59-61: ESG Materiality analysis
2.1.2 Interested Parties
As part of the materiality analysis, WDP lists its most important stakeholders to date. These stakeholders include:
• Clients (tenants)
• #TeamWDP (employees)
• Investors, debt providers, shareholders, third-party benchmarks, analysts
• Suppliers
• Policymakers
• Community
For more information:
• Annual Report 2022, page 63: stakeholder engagement
• Annual Report 2022, page 59-61: ESG Materiality analysis
2.1.3 Scope of the EMS
This Environmental Management System applies to all WDP group entities and all WDP group’s operations
For more information:
• Annual Report 2022, page 198-200: boundaries within and outside organisation
• Annual Report 2022, page 9: WDP’s value chain
• Annual Report 2022, page 146: Group structure
2.2 Leadership
2.2.1 Leadership and commitment
The Management Committee takes accountability for the effectiveness of the environmental management system; they ensure that the environmental policy in the form of our Climate Action Plan (CAP) and associated environmental objectives are established and compatible with the strategic growth plan of our Company
They also ensure the integration of the environmental management system requirements into the organization’s business processes through an embedded system where a dedicated Energy & Sustainability team (E&S team) has been engaged. The E&S team brings expertise, innovation, and resources but also relies on other (country) teams within WDP Group according to their expertise and responsibilities
The Management Committee is responsible for communicating the importance of effective environmental management and of conforming to the environmental management system requirements ensuring that all employees are committed to achieve its intended outcomes; each employee (including members of the Management Committee) has one or more ESG objectives set in their personal objectives
This embedded approach will ensure all business lines support the plan and contribute where possible.
For more information:
• www.wdp.eu | Statement by CEO and Chairman of the Board of Directors
• Annual Report 2022, page 35: Team Energy & Sustainability
2.2.2 Environmental policy
WDP published on January 28th 2022 a Climate Action Plan, that was the result of a year-long project executed by the E&S team in collaboration with other teams within WDP group such as finance and legal
This plan sets the general objective of WDP to be fully climate neutral by 2050 for all its operational activities, including the footprint of its portfolio, and having earlier climate neutrality for certain subdomains. The long-term decarbonization goals are to be net-zero in 2030, 2040 and 2050 for Scope 1+2, Scope 3 downstream and Scope 3 upstream respectively.
Furthermore WDP is convinced to take an opportunity in this energy transition and change the way to do business. This is part of what is called our “Sustainable Growth” as part of our 4 value pillars (stated in the Annual Reports)
As such WDP declares goals both on short and medium term: as the roll-out of energy monitoring system, over the setting of goals for energy as a business such as upscaling its green energy production via solar installations The Climate Action Plans sets forth three tracks of actions to realize the plan: WDP Energy, WDP Decarb+, WDP Green.
This Climate Action Plan is currently being implemented and will be maintained, evaluated and updated in the next coming years.
For more information:
• www.wdp.eu | Climate Action Plan
• www.wdp.eu | Annual Report 2021
• www.wdp.eu | Annual Report 2022
2.2.3 Organizational roles, responsibilities and authorities
Within WDP, the execution and implementation of the CAP is embedded within the organization through the ESG team which ensures complete coordination and necessary interaction between the environmental, social and governance tasks.
2.2.3.1 Energy & Sustainability Team
To execute the 3 groups of actions defined in the CAP, WDP can count on the Energy & Sustainability team (E&S team) to coordinate all actions and ensure timely & qualitative roll-out in the organization. WDP believes in an integrated approach where the E&S team steers, supports and coordinates the actions, but workload is distributed in the operational Business Lines of each country, supported by different corporate divisions such as finance, legal and data & IT
The team is organized under the CFO who also represents the team in the Management Committee. This ensures a good strategic fit with the WDP overall strategy and financial support to achieve the beforementioned goals.
The E&S team is responsible for setting up new business models rooted in the energy & sustainability domains, as well as for reporting on environmental goals, providing technical support and defining and organizing the execution of the decarbonization roadmap.
For more information:
• Annual Report 2022, page 64: Decision-making process
• See 2.4 Resources in this document for a more detailed description of our E&S team.
2.2.3.2 Reporting
As a regulated real estate company (RREC), WDP reports yearly on its emissions & energy data through EPRA SBPR and the GHG Protocol. This is done in the Sustainability Reporting section of the Annual Report. Here you can find the progress on our emissions for Scope 1, 2 and 3 (downstream). WDP also calculates its GHG footprint for upstream activities which can also be found in the GHG Protocol section.
The Energy & Sustainability team, together with the ESG team is responsible for proper reporting according to EU and EPRA guidelines.
For more information:
• Annual Report 2022, page 170-185: EPRA & GHG Environmental Performance indicators
2.3 Planning
2.3.1 Actions to address risks and opportunities
2.3.1.1 General
WDP’s operations are exposed to a number of internal and external risks, or uncertainty factors that could impact the Group’s ability to achieve its overall strategic objectives. The Group's risk management focusses on risk awareness and on control and/or mitigation of real risks or threats whilst allowing controllable risks (combined with opportunities) in pursuit of generating and protecting value for its shareholders, clients and other stakeholders. This implies the Group has a rather low to medium appetite for risk, which is integrated in its decision-making processes in the execution of its strategic objectives.
The Group is convinced that risk management should be an integral part of the culture of the organization to foster an environment in which people are motivated to identify and cope with risks and ensuring the necessary transparency with regard to any possible risks.
From a governance perspective, our integrated approach combines a top-down strategic view with a complementary bottom-up operation process.
In 2021, the Group’s enterprise risk management policy was reviewed, enhanced and brought into line with the current complexity, dimension and strategic goals of WDP, as well as changing contexts, such as regulations, ESG, and climate change.
For more information:
• Enterprise Risk Management Policy
• Annual Report 2022, page 137-143: Risk Management
2.3.1.2 Environmental aspects
In the road to our Climate Action Plan, WDP and an external consultant have initiated the development of an environmental framework by workshops, desk research, challenge and work sessions, guided by the relevant WDP team. Such environmental framework enables WDP to structure, organize, identify and quantify environmental related developments. Long term main dimensions and sub dimensions have been created, from energy use to climate resilience, taking the stakeholder and value chain landscape into account. The environmental framework, its dimensions and way-of-working contributed to the Climate Action Plan.
For more information:
• See 2.2.1 Environmental aspect in this document for further details.
• See 2.2.2 Environmental policy for further details on the Climate Action Plan
• Annual Report 2022, page 188: Climate Action Plan Results
• Annual Report 2022, page 189-192: TCFD
2.3.1.3 Compliance obligations
As for other aspects impacting WDP, the operational teams with WDP determine and consider the respective compliance obligations related to the environmental aspects. There is a continuous monitoring of requirements and compliance, assisted by specialists and external consultants.
In this regard, the Compliance Officer - performed as an independent function within the Company – also investigates and promotes compliance by the Company with the laws and regulations with respect to the environmental aspects.
For more information:
• Corporate Governance Charter, page 47-48
2.3.1.4 Planning action
Reference is made to the 2.2.2 Environmental policy in this EMS Manual, as well as to the risk management of the company. Both topics provide for actions to address the significant environmental aspects, the compliance obligations and the environmental risks and opportunities. The WDP’s risk management approach guarantees a continual review and evaluation of risks and opportunities.
For more information:
• Enterprise Risk Management Policy
• See 2.2.2 Environmental policy for further details on the Climate Action Plan
• Annual Report 2021, page 189-192: TCFD
2.3.2 Environmental objectives and planning to achieve them 2.3.2.1 Environmental objectives
Reference is made to 2.2.2. Environmental policy of this EMS manual.
Publication of the CAP
Scope 1+2 Offices net zero
Scope 1+2 Car fleet net zero
Scope 3 downstream net zero
Scope 3 upstream net zero
2.3.2.2 Planning actions to achieve environmental objectives
Reference is made to 2.2.2 Environmental policy and 2.4.2.1 Embedded organization of this EMS manual.
A list of relevant topics to develop was defined in accordance with the CAP objectives. They will be conducted through company-wide embedded task forces (see 2.4.1.2 Embedded organization) and are scheduled as follows.
Publication of the CAP
Scope 1+2 Offices net zero
Sustainable WDP Offices
Green Energy Procurement
Scope 1+2 Car fleet net zero
Sustainable Mobility
Scope 3 downstream net zero
Batteries
BREEAM cert. of existing Portfolio
BREEAM cert. of New Builds
Green Lease
PV Roll-out
Sustainable Heat
e-mobility
Micro grid development
LED Lighting
Decarb Energy Use
Scope 3 upstream net zero
Sustainable Materials (new build) Carbon Removal
This list is a living document that will be subject to yearly review based on the measured progress and state-of-the-art developments.
2.4 Support
2.4.1 Resources
2.4.1.1 The E&S team
The E&S team refines, coordinates and partly executes the actions set in the Climate Action Plan (deadlines from 2025 2050):
• the decarbonization of Scope 1, 2 and 3 (Track DECARB+);
• the roll-out of PV, EMS, LED and Green Energy procurement over the complete relevant portfolio (Track ENERGY);
• the roll-out of the energy as a business strategy (pilot projects on the energy markets, purchase and sales contracts re. energy, ancillary services for the grid, energy communities with both WDP tenants as other 3rd companies etc) (track ENERGY);
• the certification of all relevant buildings as at least BREEAM Very Good or EDGE (Track GREEN);
• WDP set forth some company certifications and indexes it wants to be listed in as to promote its green ambitions and facilitate green finance (Track GREEN)
Aside the coordination, the E&S team will provide the necessary skills and competences in Sustainability matters to support the other teams. For example (but not limited to)
• Expertise in Sustainable Building materials to support Project Developers
• Expertise in Sustainable Maintenance Strategy & techniques to support Property Managers
• Expertise in Sustainable Lighting (Smart and LED), Green Heat (heat pumps, heat storage…), e-mobility (EV charge capacity for both cars and trucks)
• Data & smart analysis of the water and energy consumption of our sites, the production of our solar energy installations and the use of our batteries and other large energy consumers as EV chargers.
2.4.1.2 Embedded organization
In order to execute (DO) the projects and programs defined under the CAP, the E&S team will rely on a deeply embedded collaboration with the other teams.
Each of these teams have a critical role to play in the development of these new energy installations (PV, electric vehicle chargers, batteries, heat pumps etc.), upgrade of existing buildings (insulation, water recuperation etc.), or the establishment of more stringent requirements for new builds.
WDP believes for all its ESG goals an embedded approach will be the best solution. All managers and other employees get at least one ESG objective in their annual goals. ESG focus domains are defined to be worked on in multi-disciplinary teams, with a review from the ESG-team & management to boost knowledge & progress in a shortlist of ‘E’, ‘S’ and ‘G’ domains. For the ‘E’oriented task forces, the goals are distilled from the CAP objectives.
These topics are led by a company wide group of employees of all departments, countries and expertise
Today these task forces are led by a diversity of people for all country teams and all expertise
2.4.2 Competence
Thanks to the embedded projects, an identification of needs for training in the environmental subjects will take place. Where needed, WDP will engage in either inhouse or outhouse training to fulfill these requirements. This accounts for all employees of WDP, not only those in the environmental-linked positions.
2.4.3 Awareness
WDP ensures that its employees (internal stakeholders) are aware of the environmental policy (Climate Action Plan); the significant environmental aspects and related actual or potential environmental impacts associated with their work; their contribution to the effectiveness of the environmental management system, including the benefits of enhanced environmental performance; the implications of not conforming with the environmental management system requirements, including not fulfilling the organization’s compliance obligations.
Next, WDP takes measures to raise external stakeholder awareness of the environmental policy and environmental impacts. Examples include involvement in materiality assessments, newsletter to stakeholders, making the EMS policy publicly available.
Our hands-on and efficient approach is reflected in:
• publication of the Climate Action plan in January 2022 at the occasion of the publication of the annual results 2021;
• making the Climate Action Plan publicly available on our website;
• regular news posts on specific environmental topics on WDPConnect!, the group-wide internal communication platform;
• the target-setting within the Climate Action Plan support the realization of the WDP’s growth plan 2022- 25 and are therefore fully incorporated in the Company’s business strategy and value pillars;
• one or more ESG objectives set in the personal objectives of each employee (including members of the Management Committee);
• stakeholders are involved in the (regular) refresh of the materiality matrix and the dedicate materiality assessments;
• newsletters and white-papers on environmental aspects and performance of our buildings.
• Annual update on the progress of the targets set in our Climate Action Plan through our Annual Report
For more information:
• Annual Report 2022, page 59: ESG Materiality matrix
• Annual Report 2022, page 64: decision process
• Annual Report, page 63: stakeholder engagement
• Annual Report 2022, page 188: CAP (Climate Action Plan) Performance Indicators
• See 2.4.2.2 embedded organization in this document for further details on dedicated focus domains
• www.wdp.eu | Statement by CEO and Chairman of the Board of Directors
2.4.4 Communication
2.4.4.1 General
Communication with respect to the environmental management system is fully embedded in the general communication processes related to ESG. This process takes into account current and future legal reporting requirements (such as the Belgian Code of Companies and Associations, EU Prospectus regulation, EU CSRD,…) and is aligned to the defined stakeholder groups.
For more information:
• Annual Report 2022, page 64: Decision process
• Annual Report 2022, page 282-283: Declarations
2.4.4.2 Internal communication
ESG-team together with the E&S team is responsible for regular communication on the progress made in all ESG focus domains towards #Team WDP. Therefore, regular internal meetings are set in place encouraging the teams to share knowledge, align on approach and targets and to prepare reporting towards the management.
Such reporting to the Management Committee is done on a quarterly basis and on a (at least) biannual basis to the ESG Committee within WDP’s Board of Directors.
This interaction is reflected in the ESG decision-making process which is fully embedded in the day-to-day organization and governance structure of the Company combining a top-down and bottom-up approach.
For more information:
• Annual Report 2022, page 64: Decision process
• Annual Report 2022, page 48 (Diversity of thoughts)
2.4.4.3 External communication
Since 2017, WDP reports in accordance with the EPRA Best Practice Recommendations for Sustainability Reporting (EPRA sBPR). The EPRA sBPR guidelines are based on the recommendations and methodology of the internationally used Greenhouse Gas Protocol (GHG Protocol). This provides a consistent manner in which listed real estate companies can measure sustainability performance, which contributes to transparency in sustainability reporting.
Following the implementation of our Climate Action Plan, WDP will report on its progress through the Annual Report
In principle, our external communication is done by means of the Annual Report and the interim reports, as well as through ad hoc press releases. All information is available on our website.
For more information:
• Annual Report 2022, page 170-175: EPRA & GHG Environmental Performance indicators
• Annual Report 2022, page 176-187: EPRA & GHG Environmental Performance indicators
• Annual Report 2022, page 188: CAP (Climate Action Plan) Performance indicators
2.4.5 Documented information
Our Document Management System (DMS) is the platform to manage all our asset and contract related documents, as documentation is a building block of the WDP business.
Here WDP stores its certificates for example for BREEAM and EDGE certification; as well as all (critical) information related to the reporting on the level of E (such as sBPR, GHG Protocol reporting)
• Centralise and standardize documentation for all WDP stakeholders (both internal as external)
• Manage in a process driven way in order to facilitate the flow of critical information across the organization
• A system to track, maintain and store documentation
2.5 Operation
2.5.1 Operational planning and control
The environmental objectives stated under 2.3.2.1 are monitored by the ESG team.
Through the embedded organization, a periodic coordination is scheduled among the project managers of the different focus domains to exchange on progress, potential difficulties and changes to planning. ESG members will take the shared information, gather feedback and report back to the members of the Management Committee in case of need for extra resources or important changes to the planning and/or objectives.
On a quarterly basis, a reporting flow is foreseen to the Management Committee and (at least biannual) to the Board of Directors (see 2.4.4.2 and 2.6).
2.5.2 Emergency preparedness and response
For more information:
• Enterprise Risk Management Policy
• Annual Report 2022, page 137-143: Risk Management
• See 2.2.1 Environmental aspect in this document for further details.
• See 2.2.2 Environmental policy for further details on the Climate Action Plan
• Annual Report 2022, page 189-192: TCFD
2.6 Performance evaluation
2.6.1
Monitoring,
measurement, analysis and evaluation
2.6.1.1 NanoGrid utility metering
As a central part in the WDP Climate Action Plan there is the roll-out of an energy monitoring system on all our buildings. This system will serve as an independent proof of our progress in reducing carbon emission in our portfolio.
Metrics measured today:
• Electricity consumption on-site (both total consumption and grid consumption)
• Electricity production on-site (both total production and consumption onsite)
• Gas consumption
• Other fuel consumption
• Water use
• Any other useful electricity flows on-site (multitenant submetering, solar auto-consumption, EV Hub consumption etc.)
Data is available in 15-minute-values per site via the nanoGrid system. This serves as a base for environmental reporting.
2.6.1.2 Material footprint database
Furthermore, a system will be put in place to gather information about the embedded carbon in our new build, renovation, and energy projects. This will allow for accurate calculations regarding upstream emissions (scope 3) This information comes from contractors, material manufacturers, complemented with emission factor from independent & reliable sources such as EcoInvent, EXIOBASE or IEA.
For more information:
• Annual Report 2022, page 173-175: EPRA & GHG Environmental Performance indicators
2.6.1.3 Building Certificate DMS
All information on the BREEAM and EDGE certifications is stored in our DMS (see 2.4.5 Documented information).
2.6.1.4 EPRA sBPR
Yearly as part of the annual report (typically taking place in January-February), these values are treated according to both EPRA SBPR and GHG Protocol calculation methods to allow for reliable and repeatable scores on energy consumption and carbon footprint.
2.6.1.5 Annual report
Complementary to these quantitative metrics, the performance of our biodiversity, land-use and other objectives is reported in this report, providing as such a complete reporting on our environmental performance.
The results for each calendar year are published as part of the Annual Report which is published around the end of March of the next year.
For more information:
• Annual Report 2022, page 31-44: Future Logistics
2.6.2 Internal audit
For more information:
• Annual Report 2022, page 137: internal control
• Corporate Governance Charter, page 50-51
2.6.3 Management review
Yearly a set of indicators are defined that will follow the progress made in each of the focus domains in action (see 2.3.2.2). These indicators are reported on a quarterly basis to the Management Committee and (at least bi-annually) to the Board of Directors.
The list of focus domains (see 2.3.2.2 and 2.4.1.2) is reviewed by the Management Committee and Board of Directors upon compliance with the set goals for environmental performance. Both in effectiveness and timing, including the allocation of appropriate resources to execute the program.
2.7 Improvement
The Climate Action Plan breaks down in three core areas with clear objectives set in January 2022. The E&S team continuously monitors the progress in order to ensure its consistent relevance in the changing context If relevant, the E&S team will propose an update on the CAP objectives, based on actual business results, changes in regulation or technology availability. This will be discussed within the ESG team, the Management Committee and the Board of Directors who will decide on the targets to be set.