a 25.2-corporate policy environmental and energy …...the directive on environmental management is...

Corporate Policy Environmental and Energy Management

Managers of the organizational units affected by this regulation are responsible for ensuring that their employees are aware of this regulation and that they observe itaccordingly. Employees are responsible for familiarizing themselves with the provisions of the regulation and observing them.

Policy Profile

Short Title Corporate Policy Environmental and Energy Management

Policy Number A 25.2

Purpose of Policy / Summary This policy describes the Group's environment-related focus and principles of action. Itincludes environmental and energy guidelines as a statement of Daimler's environmentaland energy policy and the corresponding management handbook as a framework for theDaimler Group.

Scope of Application This policy applies to all companies and employees of the Daimler Group worldwide.

Explanation on Scope of Application

Period of validity of this version 1/1/2014 to 12/31/2018

Last Revision of this version

Approval Dr. Dieter Zetsche5/24/2013

Topic (incl. Subtopic) Core Business: (Environmental Management)

Policy responsible Dr. Udo Hartmann - Daimler AG (0400) (RD/RSE)

Contact Person Dr. Udo Hartmann - Daimler AG (0400) (RD/RSE)

Documentation This policy is documented in "Company/Policies & Guidelines/Enterprise RegulationDatabase (ERD)" in the employee portal at 12/19/2013.

Documents Documents Pages

Corporate Policy Environmental and Energy Management 2

Annex: Corporate Directive on Environmental Management 19

Daimler Group Environmental and Energy Guidelines 4

Further Applicable Regulations - The Environmental Representative at Production, Sales and Logistics Sites of the Daimler Group; Standard-Profile

- The Chief Energy Officer / Energy Manager at Daimler Group Production, Operations, and Logistics Locations;Standard – Job Description

- Daimler Standard “Handling Soil and Groundwater Impacts”- Daimler Standard “Handling Hazardous Substances”- Daimler Standard Environmental Data Acquisition- Daimler AG Standard Abfallwirtschaft

Changes to Previous Version

Note! Printouts of this regulation may already be out of date. Always check on the ERD to ensure you have the latest version.A 25.2; Corporate Policy Environmental and Energy Management Valid from: 1/1/2014 Valid To: 12/31/2018;

of 25 pages (profile + policy + annexes)

Daimler Corporate Policy A 25

Environmental and Energy Management

This policy includes the environmental and energy guidelines as a statement of Daimler's

environmental and energy policy and the corresponding management handbook as a framework for

the Daimler Group.

The environmental and energy guidelines stipulate environmental protection as a major corporate

objective in the Group with a key focus on the responsible handling and efficient use of energy. The

six guidelines require:

• Focusing on the future and continuous improvement

• Developing environmentally friendly and energy-efficient products

• Designing environmentally friendly production with optimized use of energy

• Offering client services aimed at protecting the environment

• Representing a global model for environmental performance

• Providing extensive information on environmental protection and energy use for employees /

the public

Environmental and energy management at Daimler means:

• Compliance with the environmental protection and energy regulations in effect at the

applicable location

• Compliance with Daimler's internal environmental protection and energy efficiency standards

and commitments

• Prevention/minimization of environmental risks

• Ensuring that the organization is legally sound

• Continuous improvement of operational and product-related environmental protection

• Continuous reduction environmental effects and continuous improvement of energy efficiency

at the locations

• Assuming corporate responsibility and improving customer benefit

• Contributing to the company's value creation

Daimler's environmental and energy guidelines and specified standards for environmental and energy

management must be observed and implemented in a binding manner by the company's

organizational units.

Tasks, competencies and responsibilities are specified for:

• Function holders (officers, specialist functions and work groups at the Group / site level)

• Boards and heads of business units

• Management levels L1–L3

• And all employees



Corporate Directive on Environmental Management

Page 1 of 19

This hard copy is not subject to the update service

Corporate Directive on

Environmental Management

in conformity with EN ISO 14001:2004

Daimler AG

70546 Stuttgart




Page 2 of 19


Editorial information

Corporate Directive on Environmental Management ENV-ST-DA-001_ENG, issued

2011/01/01

Replaces:

The Environmental Management Manual of the DaimlerChrysler Group, issued 2003/11/25;

ENV-ST-DC-001_ENG.doc

Editors: Dr. Franz-Josef Ecker, GR/AGE Christof Nagel, TM/MEC

Patrizia Pasquini, TM/MEC

Walter Birnbaum, QSU-UWS

Sandra Carter, TM/MEN

Rolf-Christian Hambrok, VAN/PQD

Roland Hauck, GSP/LS

Christine Kull, TM/TSM-U

Dr. Klaus Ruhland, GR/PZU

Dr. Michael Schwarz, PWT/VUS

John Wu, TM/ERS

Authorization: Professor Herbert Kohler, Chief Environmental Officer Daimler AG

Change requests, suggestions, additions and improvements should be submitted to the

Chief Environmental Officer, who is responsible for the content of this directive.




Page 3 of 19


Contents

FOREWORD ....................................................................................................................................4

1 OBJECTIVE/PURPOSE ..............................................................................................................5

2 SCOPE OF VALIDITY .................................................................................................................5

3 ENVIRONMENTAL GUIDELINES...............................................................................................5

4 MANAGEMENT BASIC PRINCIPLES.........................................................................................6

4.1 Structure and organization ..................................................................................................... 6

4.2 Process orientation ................................................................................................................. 7

4.3 Legal compliance ..................................................................................................................... 8

4.4 Identification and assessment of environmental relevance ................................................. 8

4.5 Environmental organization .................................................................................................... 9

4.6 Documentation management................................................................................................ 12

5 MANAGEMENT PROCESS ...................................................................................................... 12

5.1 Management responsibility................................................................................................... 13

5.1.1 Environmental control loop: guidelines – strategy – targets .................................... 13 5.1.2 Ensuring legal compliance .......................................................................................... 13 5.1.3 Environmental Representatives.................................................................................. 14

5.1.4 Internal and external communication ........................................................................ 14 5.1.5 Management’s core duties and tasks ......................................................................... 15

5.2 Provision of adequate resources .......................................................................................... 16

5.2.1 Staff .............................................................................................................................. 16 5.2.2 Financial resources...................................................................................................... 17

5.3 Measurement, analysis and improvements ......................................................................... 17

5.3.1 Auditing ........................................................................................................................ 17 5.3.2 Environmental risk analyses ....................................................................................... 18 5.3.3 Environmental review.................................................................................................. 18

6 GROUP ENVIRONMENTAL MANAGEMENT – REQUIREMENTS SUMMARY ...................... 19




Page 5 of 19


1 Objective/Purpose

This directive specifies the key environmental regulations applicable to the Group. It must be imple-

mented for all activities and processes within the organizational units and extended for certain specified

operational areas. Existing documentation shall remain valid if it does not contradict the rules contained

in this directive, and shall continue to apply in addition to the regulations and requirements set out be-

low.

The Board of Management hereby fulfills its corporate obligation of ensuring that the company complies

with the relevant legal provisions. This directive provides a standard mandatory framework for the world-

wide implementation of ISO 14001 certifiable environmental management systems within the Group. It

also provides a framework for the implementation of the EMAS directive (Eco-Management and Audit

Scheme) that applies to the production facilities and sales and service outlets in Germany.

Environmental management at Daimler involves:

• complying with the local environmental regulations applicable at each site;

• complying with Daimler’s internal environmental regulations and self-imposed obligations;

• avoiding/minimizing environmental risks;

• ensuring the organization’s legal compliance;

• continually improving operational and product-related environmental protection;

• continually reducing the environmental impact at the sites;

• accepting our social responsibility and increasing the level of benefits we offer our customers;

• creating value for the company and its stakeholders.

2 Scope of Validity

The Directive on Environmental Management is valid for the entire Daimler Group.

3 Environmental Guidelines

The Group’s environmental policy is delineated in the six core environment-related goals and principles

(the ‘Environmental Guidelines’), and published in a corporate guideline.

The Environmental Guidelines are binding for all employees worldwide.

The Group is committed to the following Environmental principles:

Environmental Protection is one of our fundamental corporate objectives.

1. We face the environmental challenges of the future by working continuously to improve the envi-

ronmental performance of our products and operations.

2. We strive to develop products, which in their respective market segments are highly environmental

responsible.

3. We plan all stages of manufacturing to provide optimal environmental protection.

4. We offer our customers ecologically oriented service and information.

5. We endeavor to achieve exemplary environmental performance worldwide.

6. We provide our employees and the public with comprehensive information on environmental

protection.

(More detailed explanations of the Environmental Guidelines are available on the Daimler Group intranet portal.)




Page 6 of 19


If required, individual organizational units can supplement and refine the Environmental Guidelines with

additional principles and statements of their own.

4 Management Basic Principles

Environmental management contributes directly to the company’s value system. Typical value-added

contributions are shown in figure 4-1.

Fig. 4-1: The contribution of environmental management to value creation

4.1 Structure and organization

Environmental management is an integral part of all business activities and is realized through the com-

mitment for continuous improvement.

Key components include:

• applying the Environmental Guidelines as a basis for environmental management;

• measuring performance based on environmental targets and programs;

• organizing structures and processes to ensure compliance with legal requirements and standards of

environmental performance;

• integrating and recognizing the environmental aspects of all processes that impact the environment;

• monitoring efficiency through the use of management tools and control mechanisms.

These integral elements are to be linked to a system of four interdependent modules. See Figure 4.1-1:

Environmental Management model

Integration

of environmental

aspects into

processes

Contribution to

standardizationTransparency in roles,

responsibilities

and authorities

Prevention or

minimization of riskEfficiency through

lean processes

Stronger brand

image

Conformance

with internal (e.g. Guide-

lines) and external require-

ments (e.g. ISO)

Integrated

harmonized

system

Securing legally

compliant organization

Integration

of environmental

aspects into

processes

Contribution to

standardizationTransparency in roles,

responsibilities

and authorities

Prevention or

minimization of riskEfficiency through

lean processes

Stronger brand

image

Conformance

with internal (e.g. Guide-

lines) and external require-

ments (e.g. ISO)

Integrated

harmonized

system

Securing legally

compliant organization




Page 7 of 19


Figure 4.1.1: Environmental Management model

4.2 Process orientation

Internal and external environmental requirements are to be integrated into Daimler’s business proc-

esses. Daimler’s process model focuses on the core value-creating activities that are supported by ser-

vice processes (support processes), such as Finance & Controlling, Procurement, Human Resources and

Research. The management functions required to oversee the operational model are incorporated into

the overall management process. Daimler’s business processes should be evaluated in terms of their

environmental impact and assessed based on performance data where appropriate. Interfaces with

other management systems (e.g. production and quality management systems) should be taken into ac-

count.

Fig. 4.2-1: Environmental management in Daimler’s process model


flow of information

Requirements pursuant to :

Environmental Guidelines, statutory provisions,

internal and external standards

Documentation of :

Tasks, authorities, responsibilities and

respective delegation

Integration in:

Process descriptions

Driving and controlling

- legal compliance

- organization

- environmental performance

- risk minimization

by measurements, audits

and visual inspections


flow of information

Requirements pursuant to :

Environmental Guidelines, statutory provisions,

internal and external standards

Documentation of :

Tasks, authorities, responsibilities and

respective delegation

Integration in:

Process descriptions

Driving and controlling

- legal compliance

- organization

- environmental performance

- risk minimization

by measurements, audits

and visual inspections

Resource

Management

Measurement

Analysis

Improvement

Daimler Environmental Management

Management

Process

Management

Responsibility

Core Prozesses

Supporting Processes

Financial

Services

Customers

Authorities

Interested

Parties

Expectations

DemandsProduc-tionProcess

SalesProcess

ProductCreationProcess

Satisfaction

Information

Customers

Authorities

Interested

Parties

Loyalty

Human

Resources

Group

Research

Resource

Management

Measurement

Analysis

Improvement

Daimler Environmental Management

Management

Process

Management

Responsibility

Core Prozesses

Supporting Processes

Financial

Services

Customers

Authorities

Interested

Parties

Expectations

DemandsProduc-tionProcess

SalesProcess

ProductCreationProcess

Satisfaction

Information

Customers

Authorities

Interested

Parties

Loyalty

Human

Resources

Group

Research




Page 8 of 19


4.3 Legal compliance

The Board of Management is responsible for ensuring that Daimler’s systems of corporate governance

are legally compliant. This responsibility extends to all the Group’s managers through the delegation of

tasks, which specifies who (responsibility) must perform which legally required tasks (duties) and who is

liable (liability) for any dereliction of duty.

All organizational units are responsible for identifying, analyzing and ensuring their own compliance with

the environmental regulations that apply to them. In most cases, the local point of contact is the envi-

ronmental representative at the site concerned. In Germany, local contacts are supported by the Corpo-

rate Environmental Department, which assesses laws passed at EU and German federal government

level.

Fig. 4.3-1: Monitoring environmental regulation

4.4 Identification and assessment of environmental relevance

All responsible parties, including executive managers and general employees need to assess how their

areas of responsibility contribute to the environmental impact of a particular division, its organizational

units and sites. They should assess the impact of their processes, activities, products and services and

identify any need for action or further regulation. Results of these environmental assessments should be

taken into consideration when formulating business strategies.

For example, the findings of such an analysis and positioning can be recognized within a risk portfolio.

Monitoring and Implementation of Environmental Legislation

Mandate: Timely monitoring, evaluation and communication of trends and changes in

environmental legislation, respectively initiation of implementation processes

Target: Legal compliance & risk minimization

Monitoring of

specific legal,

governmental

publications,

respectively

screening of

web-sites, and

online-data-

bases

analysis,

evaluation,

elaboration of

comments

on relevant

legislation and

norms

lobbying in

industrial and

governmental

bodies

Communi-

cation, i.e.

forwarding

of

evaluation

and /or

comments

Deduction

of strate-

gies and

measures

for imple-

mentation

of require-

ments

Implemen-

tation at

the site

Environmental Representative Business unit, sites

Monitoring and Implementation of Environmental Legislation

Mandate: Timely monitoring, evaluation and communication of trends and changes in

environmental legislation, respectively initiation of implementation processes

Target: Legal compliance & risk minimization

Monitoring of

specific legal,

governmental

publications,

respectively

screening of

web-sites, and

online-data-

bases

analysis,

evaluation,

elaboration of

comments

on relevant

legislation and

norms

lobbying in

industrial and

governmental

bodies

Communi-

cation, i.e.

forwarding

of

evaluation

and /or

comments

Deduction

of strate-

gies and

measures

for imple-

mentation

of require-

ments

Implemen-

tation at

the site

Implemen-

tation at

the site

Environmental Representative Business unit, sites




Page 9 of 19


4.5 Environmental organization

The environmental concerns of the Daimler Group are represented at the board level by the member re-

sponsible for corporate research and MBC development.

A Chief Environmental Officer is appointed to oversee the Group-wide management of environmental

concerns and is supported in this role by the Corporate Environmental Department.

Each division appoints environmental management representatives who perform division-specific tasks

on behalf of the respective boards of management and act in coordination/consultation with the Chief

Environmental Officer.

Cross-divisional committees have been set up to oversee further interlinking.

• The Corporate Environmental Council comprises decision-makers responsible for environmentally

sound product design, environmental management representatives of the divisions and representa-

tives from the corporate strategy and communications departments.

• ‘Production-related Environmental Panels’ are working groups who address production-related envi-

ronmental issues.

The Chief Environmental Officer also acts as representative for environmental issues in the Corporate

Sustainability Board.

Figure 4.5.1 shows how these functional units, the divisions’ environmental management representatives

and site-specific environmental management are integrated into Daimler’s corporate environmental

management structures.

Corporate Environmental Department

Figure 4.5-1: Corporate environmental management

The Group’s current environmental management structures are described and updated on the Corporate

Environmental Department’s intranet site.

Corporate Environ-

mental Department Chief

Environmental Officer

Chairman Board of Management

Corporate Research & MBC development

direct reporting lines

communication/coordination




Page 10 of 19


A brief description of the duties of the key officers and organizational bodies:

Officer/ organ-

izational unit

Tasks, authority and responsibilities

Chief Environ-

mental Officer

• ensures effective and coordinated environmental management across the

Group;

• advises senior management on environmental matters and reports on the

current status of the Group’s environmental management to the Board of

Management;

• ensures the implementation of environmental risk prevention measures and

checks legal compliance with production-related environmental require-

ments, thereby providing legal protection to the members of the Board of

Management concerning their respective responsibilities;

• ensures the Group’s public representation is consistent in relation to envi-

ronmental issues;

• ensures adequate environmental reporting (internal and external);

• analyzes environmental and energy legislation and influences decision-

making by representing the Group on committees and in trade associations

(on product-related, production-related and overarching topics);

• collaborates on establishing/defining the objectives for research projects

and core research activities concerning product-related and production-

related environmental issues;

• ensures rights to information and duties to provide information are upheld

in relation to all environment-related issues, particularly in dealing with the

official environmental representatives;

• coordinates and ensures the correct management of hazardous materials

across the Group;

• ensures legally compliant and coordinated CO2 emissions trading (only ap-

plies within Germany);

• ensures adequate internal energy and CO2 reporting;

• initiates the establishment of Group-wide environmental standards (techni-

cal and organizational) and projects – relates to a duty to suggest environ-

mental objectives for product and production-related areas (realization to

be approved by the Board of Management);

• directs environmental reporting.




Page 11 of 19


Officer/ organ-

izational unit


Corporate Envi-

ronmental De-

partment

• monitors the effectiveness of the Group’s environmental management;

• checks for legal compliance with production-related environmental re-

quirements to contribute to the exculpation/exoneration of the relevant

board members from their respective responsibilities;

• ensures adequate environmental reporting (internal and external);

• analyzes European and German environmental and energy-related legisla-

tion that relates to overarching and production-related issues and informs

the site-based environmental representatives;

• ensures the quality of data and its subsequent analysis for the environ-

mental reporting (internal and external) and advises senior management on

environmental issues;

• manages the development of environmental targets and monitors the effi-

ciency of implementation;

• initiates projects for environmental pollution mitigation and defines and up-

grades internal environmental standards;

• represents the company’s position in internal and external committees, e.g.

the German Automotive Industry Association, the European Automobile

Manufacturers’ Association, etc.;

• oversees the management of hazardous materials across the Group;

• coordinates CO2 emission trading (only applies within Germany);

• collaborates on environmental and climate-change-related energy manage-

ment projects.

Corporate

Environmental

Council

• analyzes product and production-related environmental issues on a techni-

cal/scientific basis and ensures the coordination of public statements con-

cerning the Group’s impact on the environment;

• sets environmental targets for the Group and develops cross-functional and

cross-divisional environmental programs;

• coordinates cross-functional and cross-divisional environmental tasks (clari-

fies technical issues and represents the company’s position in the public

and political domains);

• initiates cross-functional and cross-divisional environmental projects, in-

cluding preventive measures.

Production-

related Environ-

mental Panels

DA-ERG Daimler Americas Environmental Representatives Group

F-ERG Daimler-Fuso Environmental Representatives Group

AKU Environmental Representatives Working Group Germany/Europe

AKA Process Materials Working Group

• coordinate regional and global environmental related production activities

and ensure no duplication of efforts arise;

• promote the exchange of best practice in production-related environmental

management;

• highlight any cross-plant need for action;

• initiate and conduct joint projects;

• develop and approve standard processes within the company’s environ-

mental management.




Page 12 of 19


Officer/ organ-

izational unit


Environmental

(expert) represen-

tatives

act as the environmental representatives for the sites of Daimler Trucks,

Daimler Buses, Mercedes-Benz Cars and Mercedes-Benz Vans.

See standard ENV-ST-CVD-MCG-001 for a description of the environment repre-

sentatives’ tasks.

Environmental

management rep-

resentatives for

the divisions and

their subordinate

organizational

units (OU)

• manage the initiation, development, implementation and enhancement of

environmental strategies and environmentally relevant activities of the divi-

sion/OUs;

• ensure and review effective environmental management systems in the di-

vision/OUs;

• monitor, assess and record environmental risks, legal compliance and envi-

ronmental performance of the division/OUs;

• regularly report on the status of the environmental management systems to

their respective senior management;

• liaise/communicate with the Chief Environmental Officer and other relevant

environmental committees across the Group;

• promote and ensure the exchange of best practice and environmental

knowledge

• initiate environmental projects in the division/OUs;

• collaborate on cross-divisional environmental initiatives.

4.6 Documentation management

Documentation includes paper documents, electronic files and data that contain product-related, proc-

ess-related, procedural, official and legal information. Documentation is broken down into:

• directives (management documents) setting out specifications and implementation guidelines;

• audit documentation (environment-related records) that provide evidence of compliance, i.e. proof

of compliance with product, process and legal requirements.

The Corporate Environmental Department is responsible for the management of documentation at Group

level. Responsibility at divisional, business unit and site levels falls to the respective entity and its envi-

ronmental management representative. Documentation processes are regulated by the Group’s existing

current guidelines, e.g. the rules governing layout, access by external parties and those governing the

categorization of information, which need to be taken into consideration. Conformity with other existing

management systems (for example quality management) is desirable.

5 Management Process

The management process includes the following aspects.

• Managerial responsibility, with a focus on the implementation of the Environmental Guidelines, envi-

ronmental targets and programs and the delegation of tasks.

• The provision of adequate resources.

• Measurement, analysis and improvement, with a focus on environmental related company processes

that are monitored for effectiveness and efficiency through audits, environmental risk analyses and

reviews. In addition to the internal audit findings, measured values and performance data are also

taken into consideration in the decision-making processes, together with feedback from customers,

the authorities and shareholders.




Page 13 of 19


5.1 Management responsibility

5.1.1 Environmental control loop: environmental guidelines – strategy – targets

The Corporate Environmental Guidelines serve as a basis for drawing up strategic environmental objec-

tives, targets and programs at all management levels. The Environmental Guidelines are reviewed and

updated every five years by the Group’s Chief Environmental Officer. The strategies and targets devel-

oped based on the Guidelines serve as management tools and are reviewed and updated annually. Im-

plementation is carried out in accordance with the delegation of tasks.

Fig. 5.1.1-1 Environmental control loop: environmental guidelines – strategy – targets

5.1.2 Ensuring legal compliance

All levels of management must ensure the following for their area of responsibility: employees must be

sufficiently aware of the relevant environmental regulations; legislative trends and changes to environ-

mental laws need to be identified early, analyzed and communicated; all the required measures must be

taken to ensure legal compliance. Fig. 4.3-1 provides guidance regarding the necessary procedures.

Managers are supported by the environmental functions at Group, division, business unit and site level.

Review of status and environmental

performance at divisional level

Indication of need of action

Regular verification of

- Environmental Guidelines

- Environmental Strategy

- Objectives and programs

at corporate level

Approval /Adjustment


- Environmental strategy

- Environmental objectives

Communication /

Implementation

Communication /

ImplementationIssuing of business unit specific

strategies, objectives and programs

In consideration of corporate re-

quirements and standards

Environmental Management Representative of division/site

Site Environmental Representative

Chief Environmental Officer

Supported by Corporate Environmental Department

Board of Management

Review of status and environmental

performance at divisional level

Indication of need of action

Regular verification of


- Environmental Strategy

- Objectives and programs

at corporate level

Approval /Adjustment


- Environmental strategy

- Environmental objectives

Communication /

Implementation

Communication /

ImplementationIssuing of business unit specific

strategies, objectives and programs

In consideration of corporate re-

quirements and standards

Environmental Management Representative of division/site

Site Environmental Representative

Chief Environmental Officer

Supported by Corporate Environmental Department

Board of Management




Page 14 of 19


5.1.3 Environmental Representatives

Across the Group, environmental representatives oversee the implementation of new and extended regu-

latory, standard and internal environmental management requirements. The following environmental

functions must be incorporated within the organizational structures:

• Environmental management representatives are to be nominated in writing (for divisions, business

units and sites).

• Environmental (expert) representatives are to be appointed in writing (“environmental representa-

tive” is an internal umbrella term for the country-specific and legally required company representa-

tives – who in Germany, for example, represent a site on issues of water protection, air emissions

and waste)

The tasks and responsibilities of the environmental management representatives and the environmental

representatives are described in Chapter 4.5.

Depending on the national laws, additional representatives/specialist functions need to be appointed/

nominated.

5.1.4 Internal and external communication

All employees must be informed of the Group and divisional environmental strategies and incorporated

into activities where required. Managers should ensure that all employees are provided with the informa-

tion required to carry out their individual roles. This should be communicated via the regular reporting

and instruction processes.

Fig. 5.1.4-1: Internal communication of environmental information

Flow of Information

Interaction

Flow of Information

Staff Member

Contribution to

• Legal compliance

• Compliant Organization

• Environmental Performance

• Risk minimization

Environmental Information of

• Environmental Experts

• Business divisions, -units, sites

• Corporate Communication

Analysis and initiation of activities within

respective scope of specific responsibility

• specific communication

• delegation of tasks, duties, authorities

• instruction/qualification

• planning of resources (human power, finances)

• activities / projects

Management

Flow of Information

Interaction

Flow of Information

Staff Member

Contribution to

• Legal compliance

• Compliant Organization

• Environmental Performance

• Risk minimization

Environmental Information of

• Environmental Experts

• Business divisions, -units, sites

• Corporate Communication

Analysis and initiation of activities within

respective scope of specific responsibility

• specific communication

• delegation of tasks, duties, authorities

• instruction/qualification

• planning of resources (human power, finances)

• activities / projects

Management




Page 15 of 19


Replies to external inquiries about Group-related environmental issues must be coordinated with the

Corporate Environmental Department and Corporate Communications. External inquiries about environ-

mental issues that relate to organizational units and sites must be managed according to the corporate

communications guidelines that apply. The organizational units and environmental departments are re-

sponsible for the factual accuracy of replies and documents provided to external parties.

5.1.5 Management’s core duties and tasks

The divisions, business units and sites must provide descriptions of their environment-related tasks,

powers of authority and responsibilities.

The core duties and tasks of the following are illustrated below:

• The Board of Management and heads of business units (levels A to C)

• Management levels E1 to E3.

Board of Management and heads of business units (levels A to C)

The Board of Management guides, coordinates and controls the business of the Daimler Group in accor-

dance with the relevant legal requirements, standards, statutory regulation, Supervisory Board resolu-

tions and the Board’s own procedural rules.

Environmental strategy

• Ensure the provision of future-oriented and demand-based updates and the further development of

the Corporate Environmental Guidelines

• Ensure the implementation of the Environmental Guidelines in terms of strategic objectives at

Group, division and business unit level

• Set quantitative and qualitative environmental targets and standards

• Approve capital expenditure required to achieve compliance with the Environmental Guidelines

Environmental performance

• Analyze environmental performance based on environmental indicators

Legal compliance and environmental liability

• Ensure compliance with all environmental related legal and standard obligations and requirements

• Ensure the provision of organizational structures, financial and human resources

Risk prevention

• Ensure the identification and analysis of environment-related risks for all company activities and

processes (e.g. supply management, product development, mergers & acquisitions activities)

Communication of environmental issues

• Strengthen the public profile of the company’s environmental management

• Promote the involvement of employees in matters relating to environmental issues




Page 16 of 19


Management levels E1 to E3

E1 to E3 managers are responsible for the management of environmental issues in their respective or-

ganizational units.

Environmental Strategy

• Establish business-unit-specific strategies, objectives and programs that also take the Group-wide

directives into account

Environmental performance

• Measure and analyze environmental performance in their own areas of responsibility based on envi-

ronmental indicators and audit findings

Legally compliant management and environmental liability

• Fulfill all environmental related legal and regulatory requirements, e.g.

• identify, delegate and oversee the management of environmental related tasks, responsibilities

and powers of authorization for all levels of management and employees

• ensure the written appointment/nomination of the environmental representatives

• check the technical suitability of employees and oversee the delegation of tasks, task instruction

and training of employees

• ensure that adequate and qualified resources are in place to support environmental manage-

ment

Risk prevention

• Pursue environmental risk minimization for all activities and processes

• Actively source and check the environmental suitability of technologies, materials and processes

Communication of environmental issues

• Ensure that all employees are provided with the information required to carry out their individual

roles – communicated via the regular reporting and instruction processes

• Promote the involvement of employees in matters relating to environmental issues

5.2 Provision of adequate resources

Adequate resourcing is required in order to minimize risks, ensure legal compliance and achieve contin-

ual improvement in the environmental performance of the business processes. Management ensures re-

sourcing levels are set in advance, regularly checked for relevance and effectiveness and adapted to suit

requirements.

5.2.1 Staff

Environmental related training needs must be ascertained for all activities, included in role descriptions

and taken into consideration in the placement process.

The internal and legal requirements profiles of the environmental functions are mandatory and must be

implemented.

As part of environmental management practice, new employees, employees moving to new places of

work and employees who are required to carry out new types of operation must be informed of the busi-




Page 17 of 19


ness unit’s general regulations and the specific environmental implications of their place of

work/activity before they commence their new role.

The requirements of environmental related activities include:

• Environmental conscious and responsible behavior at the workplace (activity and site-specific).

• Knowledge of the environmental implications and specific environmental targets of the OU in rela-

tion to their own activities and in reference to the Corporate Environmental Guidelines.

• Ensuring environmental representatives and employees tasked with particular environmental-related

responsibilities acquire specific environmental knowledge through internal or external professional

training events/courses. These employees include environmental management representatives, en-

vironmental representatives and other representatives (e.g. specialists in the areas of emissions

control, water protection, waste disposal, etc.).

• Compliance with the site-specific environmental regulations and the environmental laws that apply

to the site and knowledge of the potential impact (regulatory/criminal offense) that would result

from a failure to comply.

5.2.2 Financial resources

The following environmental related requirements and aspects are to be taken into account when plan-

ning and preparing budgets:

• compliance with legal, official and standard requirements

• elimination of existing environmental damage

• provision of the required, trained personnel

• avoidance/minimization of environmental risks/impacts

• continuous improvement of the company’s environmental performance.

5.3 Measurement, analysis and improvements

All processes and activities are to be checked regularly for legal compliance and compliance with other

internal and external environmental related requirements.

The achievement of environmental targets and program objectives also needs to be monitored, together

with the suitability of the measurement parameters and measurement procedures selected for the pur-

pose of monitoring.

5.3.1 Auditing

Internal audits need to be planned, carried out and their findings documented in order to ensure the or-

ganization’s legal compliance and the effectiveness of its environmental management practices. The en-

vironmental audits can be conducted as part of an integrated audit process, e.g. together with quality

auditing and occupational health and safety auditing.

Suitable audit procedures should be implemented in the business units; tools and working materials

should be made available for the documentation management and for the reporting processes. Each or-

ganization’s environmental management representative is responsible for managing and coordinating the

audit procedures.




Page 18 of 19


5.3.2 Environmental risk analyses

Stock corporations are legally obliged to have early warning monitoring systems in place for risk-related

activities – pursuant to the German Business Transparency Act (KonTraG) and Section 91 of the German

Stock Corporation Act (AktG). This is why environmental risk analyses (environmental due diligence) are

carried out at the sites on behalf of the divisional management boards.

The findings are made available to the responsible managers and environmental representatives of the

divisions and sites in the form of business-unit-specific and site-specific risk analyses. These flag any

need for action and recommend measures to reduce risks. An assessment of implementation status of

the recommended measures is conducted annually and made available to the environmental manage-

ment representatives for their own reporting to the divisions’ boards of management.

5.3.3 Environmental review

In order to ensure that the Board of Management fulfills its executive obligations (see Chapter 5.1.1, Fig.

5.1.1-1) the Chief Environmental Officer regularly reports on the status of environmental management

practice in the Group and provides updates on any need for action. The divisions’ environmental man-

agement representatives support the Chief Environmental Officer in this task.

The reporting process has the following objectives:

• to review the suitability, efficacy and continual improvement of the environmental management ac-

tivities of the Group and divisions;

• to assess the need for the Environmental Guidelines and environmental targets to be updated;

• to check and verify the company’s legal compliance and minimization of risk.

Based on this review, the Board of Management decides on the further strategic focus of the company’s

environmental management. The Chief Environmental Officer communicates the decisions to the divi-

sions’ environmental management representatives and environmental related Group committees.




Page 19 of 19


6 Group Environmental Management – Requirements Summary

Daimler’s environmental management requirements described in this document must be taken into ac-

count and implemented by the Group’s organizational units. This requires, in particular:

• communicating the Environmental Guidelines and ensuring that these are taken into consideration in

the strategies of the divisions and business units;

• ascertaining and ensuring compliance with all relevant legal provisions, regulations, official require-

ments (e.g. court orders) and internal and external standards;

• ascertaining and assessing the significance and consequences of environmental aspects and envi-

ronmental impact of processes, activities, products and services;

• defining environmental targets and programs based on the significance of the environmental aspects

and environmental impact, as well as the possibility for potential action to be taken;

• identifying, delegating and documenting environmental tasks, powers of authority and responsibili-

ties;

• integrating the environmental functions early on into the checking of new developments, plans,

changes to processes, products, facilities, services and sites;

• identifying the training needs and delivering the required training and instruction;

• regularly measuring and analyzing environmental performance;

• providing the information required for the Group-level review.



Daimler Environmental and Energy Guidelines

We invented the car and the truck – and are passionate about their future

These words epitomize a duality highly characteristic of Daimler: tradition and innovation. The two

concepts are closely interlinked, since it is above all from the inventor of the automobile that

groundbreaking solutions for its future are to be expected. “Innovation for Sustainability” – this

claim extends to all our business activities and actions. We are determined to continue our tradition

as automotive pioneers, and with our premium brand Mercedes-Benz we are striving for a leading

role in environmental technology and energy efficiency as well. The present “Environmental and

Energy Guidelines” are a binding standard for our actions; they apply to environment-friendly

products as well as to their manufacture in processes that help preserve natural resources as far as

possible. At the same time, they are intended to promote and reinforce awareness in general.

Clean, efficient and safe – this is our vision for tomorrow’s mobility.

Dr. Dieter Zetsche

Chairman of the Board of Management,

Head of Mercedes-Benz Cars

Preamble

Environmental protection is one of our fundamental corporate objectives; special focus is

directed to manage the production factor responsibly.

Integral component

Daimler is committed to enhancing the quality of life and the environment in the communities and

societies in which we serve. Environmental protection and responsible usage of energy resources is

one of the fundamental corporate objectives of the Daimler Group. In this context, environmental

protection and energetic optimization1 are integral components of our corporate strategy, which is

designed to ensure long-term value creation. Daimler’s goal of maximum product quality includes

compliance with stringent environmental and energetic standards and careful treatment of the

natural foundations of life. Accordingly, our approach to environmentally and energetically

acceptable product design requires careful consideration of the entire product life cycle from

design, production, and use to disposal or recycling.

Holistic approach

The Environmental and Energy Guidelines approved by the Board of Management define the

environmental and energy policy of the Daimler Group and describe the commitment to integrated

environmental protection and the responsible usage of energy which addresses environmental

impacts at their roots and also the target of the holistic energetically optimization1, assesses in

advance the ecological implications of production processes and products, and incorporates these

findings in corporate decision-making. Appropriate control and monitoring procedures and

measures have been implemented. Responsibility for the implementation of and adherence to

environmental protection measures and energy efficiency requirements have been assigned to

1 includes the measureable result of the energy management system according to ISO 50001



specific employees in all functional areas, ranging from development and production to sales and

service, and at all corporate staffs.

Active process

The Environmental and Energy Guidelines are binding for all employees at all corporate locations.

Accordingly, Daimler supports and encourages all employees to put environmental protection into

practice at the workplace at their own initiative, for example to use energy more efficient.

Measures implemented at the various corporate locations are regularly assessed and subjected to

a process of continual improvement. In order to comply with its self-imposed environmental

protection standards and energetically optimization1, Daimler draws up its own environmental and

energy goals. The ecological programs required to meet these goals are monitored through a

comprehensive auditing process aimed at measuring compliance with procedures and regulations;

and when necessary, corrective action is taken to improve performance. The underlying Energy and

Environmental Management System is coordinated by the Chief Environmental Officer and the

Chief Energy Management Officer, who report to the Board of Management on these matters at

regular intervals. A verifiable Sustainability Report, published annually, documents the Group’s

activities and achievements. We also will endeavor to ensure that our Environmental and Energy

Guidelines are accepted in joint venture partnerships.

Global challenge

Our responsibility to the environment and to the energy consumption does not stop at our doors.

Accordingly, in addition to our own environmental protection and efficient energy activities, Daimler

will promote the development of intelligent solutions shared by the entire industry and encourage

the international development of environmental and energy efficient technology. Our objective is to

retain and further develop transportation products and systems which cater equally to the

requirements of the individual, society, and the environment.

Environmental and Energy Guideline 1:

We address the challenges of the future referring to environmental and energy aspects.

Compliance with environmental legislation, regulations and other requirements are a matter of

course for Daimler. To ensure sustainable development, the Group is also committed to the active

and ongoing development of environmental protection and efficient energy consumption, both in

production and in the products themselves, in order to further reduce the burden on the

environment. Therefore Daimler develops strategic and operative goals and ensures that

information and resources for the verifications are available.

Daimler also contributes its expertise to non-corporate scientific, technical, and governmental

activities. The Environmental and Energy Guidelines of the Daimler Group are binding for all

employees and at all corporate locations. Particular responsibility rests with managerial staff at all

hierarchical levels: Through their example, they make an active contribution to the further

development of our environmental and energy policy and of the general awareness among the

Group’s employees, as well as helping to anchor environmental protection in our corporate culture.




We strive to develop products which are highly responsible to the environment and are

energy efficient in their respective market segments.

Our approach to environmentally and energetically acceptable design covers the entire product

spectrum of the Daimler Group, taking into account the product life cycle from design through

disposal or recycling. Continuously improving the environmental and energy performance of our

products is a major point of emphasis in our research and development activities. Daimler is

committed to the ongoing pursuit of this objective.


We plan all stages of manufacturing to provide optimal environmental protection and

efficient energy utilization.

Daimler sees itself as leader in the ongoing development of environmentally and energy efficient

responsible production technology. This includes proactive behavior to prevent or minimize the

impact of incidents which may adversely affect the environment. Particular emphasis is given to the

application and continuing development of technologies which save energy and water, and which

are characterized by minimal emission and waste levels. This includes the development of effective

environmental assessments, emission controls, as well as reuse and recycling strategies. Daimler

aims to achieve closed-loop material cycles. For Daimler particularly relevant are the procurement

of resources, the planning and operation of production plants and buildings, the economic

efficiency, the security of supply and the quality of energy.

Our ultimate goal is waste-free, resource-optimized, and CO2-neutral production.

Daimler requires its suppliers and contractual partners to comply with all applicable laws and

regulations and encourages them to pursue proactive environmentally and energy efficient

responsible practices. Contractors working on Daimler premises also must comply with the

location’s own standards and requirements.


We offer our customers ecologically and energy efficient oriented service and information.

Our customers should be able to use the Daimler Group’s products in an environmentally

acceptable manner. Daimler therefore provides its customers with products with a long service life

in order to conserve natural resources. Our service outlets work to provide optimal information and

expert service on environmental matters. Customers also receive comprehensive and competent

advice on the eco-friendly and energy efficient use of our products.


We endeavor to achieve exemplary environmental and energy performance worldwide.

Daimler manufactures and markets its products internationally. The Daimler Group endeavors to

behave in an exemplary manner in environmental protection and energy usage at all of its plants

and service outlets and to continually enhance environmental protection and energy usage through

the application of progressive environmental and energy management. For a global player,

however, taking responsibility seriously also means looking beyond our boundaries. At its locations,

Daimler thus supports and encourages the cooperative development of environmentally and

energetically superior technology and management methods throughout industry and the public



sector. In addition we cooperate with authorities to develop technically and financially sound,

environmentally and energetically responsible laws and regulations.


We provide our employees and the public with comprehensive information on

environmental protection and energy utilization.

Only a policy of openly providing information and illustration on environmental protection

measures, energy policy and reporting on achievements and problems in their implementation can

motivate employees and create credibility in the general public. The Group employs the available

personnel development, employee training, and information measures to transform a general

environmental awareness into specific employee behavior. As a corporate member of the

community, Daimler actively seeks dialogue with the public and welcomes constructive cooperation

with all groups of society. In addition to its own activities for environmental protection and energy

efficiency, Daimler promotes initiatives in society to protect and conserve the environment.

Employees, customers, and the general public are provided with the information they need to

understand the ecological impact of Daimler’s products and corporate activities.

