australian packaging covenant annual report - imperial brands · imperial tobacco australia limited...

Imperial Tobacco Australia Limited

Australian

Packaging Covenant

Annual Report 2014 - 2015

Imperial Tobacco Australia Limited - APC Annual Report 2014-15

Statement of

commitment I am pleased to present Imperial Tobacco Australia’s (ITA) Australian Packaging Covenant (APC) Annual Report for the period July 2014 to June 2015. ITA remains a committed long-term APC signatory, implementing programs to improve the environmental performance of the business and to support APC goals.

During the reporting year we’ve made significant progress implementing our APC Action Plan commitments. Key achievements include:

Implemented a sustainable packaging assessment process to review all new packaging changes against relevant APC strategies

Identified one new packaging project which has the potential to improve the sustainability of primary packaging

Maintained company recycling rates at 50% and recycled 2.2 tonnes of packaging

Reviewed our internal waste and recycling system and recommended a new system for trial in July 2015. At the time of reporting, recycling rates have increased by over 20%

Increased the range of recycled content products purchased via our stationery provider by 34% against the 2011-12 baseline

Implemented a head contract for stationery purchases to standardise the product range. Within this we have made it mandatory to purchase 100% recycled content Australian made A4 paper (in 2014-15, 99% of copy paper purchased contained at least 20% Australian made recycled content materials)

Implemented an Environmental Sustainability section within the Request for Proposal document for all new suppliers to align supplier values with our APC and environment commitment

Designed and implemented sustainability branding in line with APC goals to streamline communications and engage staff to support programs

Donated over 380 items of e-waste to local charities and staff and recycled over 1.7 tonnes of un-usable IT equipment

Continued to work informally with the other tobacco companies to support programs to reduce the prevalence of cigarette butts and packaging in the litter stream

Supported the collection and processing of 3.4 tonnes of cigarette butts for recycling (equating to over 7 million butts) via the TerraCycle program; and

Continued to support Butt Free Australia (Keep South Australia Beautiful) to implement anti-littering communication events and social media communications.

We will continue to work collectively with our stakeholders to support APC objectives to maintain our journey of continual improvement.

For any questions regarding this report or for any other ITA APC related enquiries, please contact Gary Dickson.

Sincerely,

Paul Matthews General Manager Imperial Tobacco Australia March 2016


Introduction This annual report covers the Australian Packaging Covenant (APC) reporting period from 1 July 2014 to 30 June 2015. The purpose of this report is to detail progress made during the period to:

Support APC goals and key performance indicators (KPIs) relevant to brand owners

Meet company performance goals as outlined in the company 2012-2015 APC Action Plan; and

Support our overall commitment to reduce the environmental impact of business operations

APC Team

Implementation of the APC is led by a cross-functional APC Team. The team is responsible for development of the APC Action Plan comes together quarterly at a minimum to discuss implementation and reporting. The team representatives include:

Regulatory and Legal Compliance Manager

Trade Segment Manager

Supply Chain Manager

Country Procurement Buyer

Corporate Services Administrator

Finance Analysist; and

APC Contractor.

Additionally, we have a smaller scale Environment ‘green’ Team, where representatives from each department get together, biannually, to discuss sustainability programs and opportunities. This group goes beyond the scope of the APC to review all company environmental impacts.

For more information about our APC commitment please contact:

Gary Dickson

Regulatory and Legal Compliance Manager

Phone: (02) 9881 0888


Company

Profile Imperial Tobacco Australia Limited (ITA) is a subsidiary of Imperial Brands PLC. As of 30 June 2015, ITA employs 345 people in full time equivalent roles.

As part of a larger international group, ITA has extensive operations in the sale of cigarettes; fine cut tobacco and pipe tobacco, cigars, rolling papers and accessories. In Australia, ITA is a packaging user and brand owner.

Market Share

Table 1 details ITA’s market share of tobacco and tobacco related products sold in the Australian market. ITA is the market leader of fine cut tobacco products in Australia with market share of 60.71%.

Table 1: ITA Product Market Share in 2014-15 (Source: AZTEC)

Product market (Australia) Market share

Tailor made cigarettes 29.81%

Fine cut tobacco 60.71%

Pipe tobaccos 44.79%

Rolling papers 70.40%

Cigarette and Loose Tobacco Portfolio

ITA’s Australian brand portfolio for cigarettes and loose tobacco products is detailed in Table 2. All brands are imported:

Table 2: ITA Brand Portfolio in 2014-15

Cigarettes Pipe and Fine Cut Tobacco

Camel Bank

Davidoff Champion

Escort Dr Pat

Horizon Drum

JPS Escort

Peter Stuyvesant Golden Virginia

Horizon

JPS

Peter Stuyvesant

Stockman's

White Ox

Amphora

Log Cabin

Amphora


Company

Profile Business Locations

The Imperial Tobacco Australia Limited head office is located at:

4-8 Inglewood Place

Norwest Business Park

Baulkham Hills NSW 2153

Sales offices are situated in the following locations around Australia:

Mulgrave, VICTORIA

Darra, QUEENSLAND

Adelaide, SOUTH AUSTRALIA

Osborne Park, WESTERN AUSTRALIA


Action Progress

Goal 1: Packaging

KPI 1: Proportion of signatories in the supply chain implementing the SPG for the design or procurement of packaging

ITA supports sustainable packaging design principles as outlined in the APC Sustainable Packaging Guidelines (SPG). Where possible, packaging design aims to:

Avoid or minimise the use of unnecessary materials and other resources

Optimise packaging recyclability and the use of recycled content products; and

Reduce potential litter impacts.

SPG Integration into new packaging design

A new sustainable packaging assessment process was developed by ITA to review all new packaging against the Sustainable Packaging Guidelines. A checklist covering relevant principles of sustainable packaging is completed by the brand team when new packaging concepts are considered for introduction into Australia. The checklist enables local teams to consider the sustainable attributes of the proposed packaging as part of the business case for implementation.

This Sustainable Packaging Assessment process was trialled with the brand team in June 2015, successfully reviewing a proposed new packaging format with the potential to improve the sustainability / recyclability of the cigarette packaging. This project is still in the early research and development phase.

The assessment process will continue to be used to review all new packaging concepts, where applicable, and where it does not conflict with packaging regulations prescribed by the Tobacco Plain Packaging Act 2011.

It should also be noted that the majority of packaging development and procurement processes are controlled by global teams. To capture information about sustainable practices in these areas additional communication has been implemented with global packaging development teams and non-tobacco material procurement. This process has sought to understand current considerations for sustainable packaging and opportunities to align existing processes with the Sustainable Packaging Guidelines.

It was found that global non-tobacco materials procurement teams conduct regular audits of packaging suppliers, which include a review against environmental criteria, accounting for 7% of the total audit score.

Product to packaging ratio

ITA continues to monitor the product to packaging ratio of all cigarette, rolling tobacco and pipe tobacco products to monitor the overall product to packaging trend.

In this reporting period, the company’s overall product to packaging ratio has improved from 3.09:1 in 2013-14, to 3.11:1 in 2014-15, an improvement of 0.6% over 2013-14. The results are attributed to changes in sales volumes of various pack sizes, for example:

The product to packaging ratio for cigarettes improved by 3%, from 3.71:1 in 2013-14 to 3.79:1 in 2014-15 - due to the increased proportion of sales in the more efficient pack sizes. Sales of 40 stick packs have increased by 5%, representing 34% of total cigarette sales, whereas the proportion of smaller 20 and 21 stick packs have decreased by 3%.

The product to packaging ratio for RYO brands decreased by 8% from 6.12:1 in 2013-14 to 5.62:1 in 2014-15. Sales of the smaller RYO pack sizes increased, reducing the efficiency of the product to packaging ratio this year.


Action

Progress Table 3: Summary of Actions and Progress - KPI 1

Action: 2012-2015 Reporting Target Timeframe Progress during 2014-15

1. Establish cross-functional SPG Review Team to participate in all existing packaging reviews

SPG Review Team established

Mar-13 Action completed in 2013-14

2. Develop SPG review template and business integration approach

SPG template and integration approach finalised

May-13 Action completed in 2013-14

3. Review packaging groupings following implementation of the Tobacco Plain Packaging Legislation

Existing packaging grouped for review


4. Develop schedule to review all existing packaging

Review schedule complete


5. Review all existing packaging against the SPG

100% of existing packaging reviewed by 2014

Apr-14 Action completed in 2013-14

6. Liaise with global packaging development teams to identify new sustainable packaging opportunities

New sustainable packaging initiatives researched

Annually Target met:

A new project has been identified with global packaging development teams, which has the potential to improve the sustainability / recyclability of the cigarette packaging.

This project is still in the early research and development phase and has been reviewed against the Sustainable Packaging Assessment process.

7. Integrate SPG into new product development process (or other opportunity as identified)

SPG criteria considered in all new packaging decisions

Jun-14 Target met:

A new sustainable packaging assessment process has been developed to review all new packaging against the Sustainable Packaging Guidelines.

A checklist covering key principles of sustainable packaging is completed by the brand team when new packaging concepts are considered, and prior to the final decision being made.

A register of all new packaging and the outcomes of the reviews is maintained.

The assessment process has been trialled with the brand team in June 2015, successfully reviewing a potential new packaging format.

The assessment process will continue to be used to review all new packaging concepts, where applicable, and where it does not conflict with packaging regulations prescribed by the Tobacco Plain Packaging Act 2011.


Action

Progress Action: 2012-2015 Reporting Target Timeframe Progress during 2014-15

8. Maintain and improve packaging data management system

Packaging data management system updated and reviewed annually


The data management system for new packaging is maintained.

The system is used to collate detailed packaging data to monitor packaging trends over time and to calculate the product to packaging ratio for all ITA products sold in Australia.

We continue to work closely with our manufacturers to collect accurate packaging and product data to monitor packaging changes and trends.

9. Monitor the company product to packaging ratio for all products sold in Australia

No decrease in product to packaging ratio.


The product to packaging ratio is 3.11 in 2014-15, an improvement of 0.6% over 2013-14.

The product to packaging ratio for cigarettes has increased by 3% from 2.71 in 2013-14 to 3.79 in 2014-15. This is due to the increased proportion of sales in the more efficient pack sizes – sales of 40 stick packs have increased by 5% representing 34% of total cigarette sales, whereas the proportion of smaller 20 and 21 stick packs have decreased by 3%.

The product to packaging ratio for RYO brands has decreased by 8% from 6.12 in 2013-14 to 5.62 in 2014-15. This is attributed to the increase in proportion of sales of the smaller pack sizes, reducing the amount of product for similar packaging formats.


Action

Progress Action Progress

Goal 2: Recycling

KPI 3: Proportion of signatories with on-site recovery systems for recycling used packaging

ITA maintains on-site recovery systems for paper, cardboard and commingled containers at all company sites where feasible. The overall recycling rate for 2014-15 was 50%, with a rate of 49% at head office (accounting for 87% of total company waste) and 61% recycling rate at state offices. Overall 2.2 tonnes of packaging was recycled (1.80 tonnes of commingled containers and 0.44 tonnes of cardboard).

As part of our commitment to on-site recovery systems, we continue to work to improve company recycling rates through three areas:

1. Recycling infrastructure and service

2. Waste and recycling data; and

3. Monitoring and recycling education

1. Recycling Infrastructure and Service

In 2014-15 a review of the recycling system at head office was conducted to identify opportunities to improve recycling rates by:

Installing new centralised bin stations for commingled containers (glass, plastic and metal), paper and cardboard and garbage

Introducing a new food and organics recycling service for inclusion in centralised bin stations

Removing individual desk bins to encourage staff to take ownership of their own waste disposal; and

Developing and installing new signage to help staff recycle correctly.

Therefore a trial of a new colour-coded 4 bin system for commingled containers, paper and cardboard, food and organics and general waste will be conducted in July 2015 to test the system and to understand the potential impact on recycling rates.

At the time of writing this report the trial has been successful, and preliminary results show an increase in recycling rates by over 20%. The new system has now been rolled out to the rest of the business.

2. Waste and Recycling Data

ITA maintains a waste and recycling data management system to record total waste disposed by the business and the amount of packaging and other waste recycled. Waste data is collected via monthly recycling reports from waste contractors (where available) and waste assessments conducted in-house.

In 2014-15, ITA conducted five waste assessments to obtain more accurate weight information for waste disposed from our offices:

Three assessments at head office to understand the weight of garbage disposed

One assessment at state offices to determine the weight of waste sent to landfill versus recycled; and

One assessment at head office to estimate recycling rates prior to implementing the new recycling system trial outlined above.


3. Monitoring and recycling education

ITA regularly engages staff to help improve the company recycling rate and notify of incorrect disposal and contamination. Engagement generally takes place via face-to-face town hall style meetings or email communications.

Feedback is regularly sought from cleaners, and from internal visual inspections to help develop and direct communication and education materials.


4. Table 4: Summary of Actions and Progress - KPI 3


1. Maintain consistent recycling systems to collect used packaging at all company sites

Establish baseline packaging recycling rates

June 2013 Target met:

Recycling systems are maintained at all company sites for paper, cardboard and commingled containers where feasible.

The packaging recycling rate decreased by 2% compared to the baseline of 54%. The new recycling program to be trialled in July 2015 will improve separation and recycling of packaging and other recyclables.

2. Actively research and implement new opportunities to improve packaging recycling rates

70% packaging waste recycled

Increase recycling rates 5% over 2013 baseline per annum

June 2013 Annually

Target partially met:

A review of the recycling system at head office has been conducted to identify opportunities to improve recycling rates by:

Installing new centralised bin stations for commingled containers (glass, plastic and metal), paper and cardboard and garbage

Introducing a new food and organics recycling service for inclusion in centralised bin stations

Removing individual desk bins to encourage staff to take ownership of their own waste disposal

Developing and installing new signage to help staff recycle correctly.

The new system has been approved by senior management and a trial will be conducted in July 2015 to test the system is right for the business and to understand the potential impact on recycling rates.

At the time of writing this report the trial has been successful, and preliminary results show an increase in recycling rates by over 20%. The new system has now been rolled out to the rest of the business.

The 2014-15 packaging recycling rate was 52%, with the overall company recycling rate reaching 50%.



3. Develop and implement waste assessment schedule to maintain continual improvement

Waste assessment schedule developed Waste assessment completed minimum 5 x per annum

June 2013 Annually

Target met:

5 x waste assessments were completed to obtain accurate weight information for waste disposed from our offices:

3 waste assessments were undertaken at head office to understand the weight of garbage disposed

1 waste assessment was undertaken at the state offices to determine the weight of waste sent to landfill versus recycled.

1 waste assessment was conducted at head office to estimate recycling rates prior to implementing the new recycling system trial.

4. Maintain and improve waste data management system across all company sites

Waste and recycling data updated quarterly

Data accuracy reviewed annually

Jun-13 Target met:

The waste and recycling data management system has been maintained.

Waste data is calculated from regular internal waste assessments and monthly waste contractor reports where available.

5. Develop waste and recycling procedure for cleaners and establish communication back to the business for early identification of issues

Waste and recycling procedure implemented for cleaners

Company cleaners adhere to recycling procedures

Cleaner feedback received twice per annum

Cleaner feedback integrated into staff education when relevant

December 2014

Target met:

The cleaners have been engaged to provide input into the new recycling system to be trialled at head office.

Cleaners provide regular feedback to Corporate Services which has been taken into consideration when developing communications and education material on recycling to staff.

The cleaners at state offices have also been engaged to assist with waste assessments to calculate weight of material disposed from each of these sites.

6. Report on percentages of segregated and recycled material (paper, glass and aluminium) at all offices

New baseline for recycling rates established in 2012-13

Annual recycling rates reported against 2013 baseline

June 2013 Annually

Target met:

Company recycling rates have been maintained at 49% at head office which accounts for 87% of total company waste. State offices achieved a 61% recycling rate.

The overall recycling rate for 2014-15 was 50%.

Opportunities have been identified to improve recycling at head office, by implementing a new 4-bin colour coded system which will include food waste recycling. This will be trialled in July 2015 and represents an opportunity to improve the head office recycling rate by 20%.



7. Report estimated quantities of packaging recycled and sent to landfill

Company packaging recycling rates reported in APC Annual Report and to the business

June 2013 Annually

Target met:

Packaging recycled:

2.24 tonnes – comprising of 1.80 tonnes of commingled containers and 0.44 tonnes of cardboard

Packaging disposed to landfill:

8.3 tonnes of waste was disposed to landfill, of which 25% (by volume) was estimated to be packaging (i.e. coffee cups, flexible plastics, take-away containers and drink bottles). The proposed new recycling system aims to recover much of this packaging waste through centralised colour-coded bins allowing easy separation and recycling of packaging waste.

Approximately 50 tonnes of product returns were disposed to landfill locally. It is estimated 30% of this was packaging. The disposal of product returns result from discontinued product being returned from market and are classed as one-off events. They are therefore not included in company business-as-usual recycling rates and are tracked separately.


KPI 4 – Proportion of signatories with a policy to buy products made from recycled packaging

ITA remains committed to purchasing products made from recycled packaging, with our Environment Policy stating we will "seek to purchase products with more sustainable attributes, including items manufactured from recycled or low impact materials, where quality and cost are comparable."

A head contract for stationery purchases was implemented across all company offices to streamline purchasing of recycled content products, and generate cost savings for the business. In 2014-15, the recycled content product range from our stationery contractor included 31 different products, an overall increase of 34% compared to the baseline of 23 in 2011-12.

In 2014-15, 99% of A3 and A4 office paper purchased contained at least 20% Australian made post-consumer recycled material - an increase of 5% compared to 2013-14. Furthermore, the quantity of recycled content office paper purchased (containing a minimum 20% recycled material) increased from 94% in 2013-14 to 99% in 2014-15, equating to 2.77 tonnes of recyclate. The business has recently made a decision that all copy paper should be 100% recycled content, therefore we have now made it mandatory to only purchase 100% recycled content Australian made A4 paper.

Coupled with this increase in recycled content, office paper consumption was reduced by 26% in 2014-2015 against 2013-14 levels.

Other recycled content purchases in 2014-15 included:

25kg of other general recycled content stationery products (across 16 categories)

3.6 tonnes of recycled content paper stock used to produce trade marketing materials (representing 52% of trade marketing jobs - up from 41% in 2013-14)

3 editions of the company magazine were published on 100% recycled content material

All ‘Recall’ archive boxes purchased are manufactured from 100% recycled material; and

All company stationery - including letterhead, invoices, business cards and envelopes - is on recycled content stock.

The total weight of recycled content material purchased in 2014-15 was approximately 6.4 tonnes.

The APC team continues to seek further opportunities for the business to buy recycled content products.


Table 5: Summary of Actions and Progress - KPI 4


1. Integrate buy-recycled commitment into company Environment Policy

Environment Policy updated annually and signed by the General Manager

Environment Policy publicly communicated

December 2012 Annually

Target met:

The company Environment Policy states our commitment to "seek to purchase products with more sustainable attributes, including items manufactured from recycled or low impact materials, where quality and cost are comparable."

The policy was last updated and signed by the General Manager in August 2014.

The policy is reviewed annually.

2. Increase the number of recycled content stationery products purchased annually

10% increase in product range of recycled content products purchased per annum

June 2013 Annually

Target partially met:

The recycled content stationery product range in 2014-15 included 31 different types of products. This represents an overall increase in the product range of 34% compared to the baseline of 23 in 2011-12.

Further work will be conducted in the next reporting period to standardise the contracted product range with our stationery provider and improve the recycled content product range.

Other recycled content products purchased by the business include:

Company magazine (printed on 100% recycled stock)

‘Recall’ archive boxes (100% recycled content)

Company branded letterheads and envelopes (100% recycled content stock)

Business cards (100% recycled content stock)

Additionally, a new process has been implemented whereby a request for quote for trade marketing materials includes a request for recycled content stock in addition to other recommended stock. Quotes are then assessed comparing cost and quality. 52% of trade marketing jobs were completed on recycled content stock in 2014-15, an increase of 11% compared to 2013-14

Work is ongoing to determine other material purchases and identify opportunities ‘buy recycled’.



3. Investigate opportunities for head contract for stationery purchasing

Head contract for stationery investigated

Mar-13 Target met:

A head contract for stationery purchases has been implemented across all company offices.

This provides both cost savings to the business but also streamlines purchasing of preferred products which align with ITA's commitment to buy-recycled.

4. Purchase of recycled content office paper rolled out across all company sites

90% company office paper purchased contains Australian sourced recycled content

Mar-14 Target exceeded:

99% of A3 and A4 office paper purchased contained at least 20% Australian made post-consumer recycled material (an increase of 5% compared to 2013-14).

A commitment has now been made to only purchase 100% recycled content Australian made copy paper. This is now mandatory.

5. Maintain and improve data management system for recycled content purchases

Recycled content purchasing data updated quarterly

Jun-13 Target met:

The data management system to monitor recycled content purchases has been maintained.

Head office data is collected and reviewed monthly.



6. Report annually on number of recycled content / sustainable products purchased

Recycled content products purchased reported in APC Annual Report and to the business annually

Total weight of recyclate in in recycled products purchased estimated and reported annually

Annual Target met:

Office paper consumption was reduced by 26% in 2014-2015 against 2013-14 levels.

Furthermore, the quantity of recycled content office paper purchased (containing a minimum 20% recycled material) increased from 94% in 2013-14 to 99% in 2014-15, equating to 2.77 tonnes of recyclate.

Other recycled content purchases in 2014-15 included:

25kg of other general recycled content stationery products (across 16 categories)

3.6 tonnes of recycled content paper stock used to produce trade marketing materials (representing 52% of trade marketing jobs - up from 41% in 2013-14)

3 editions of the company magazine were published on 100% recycled content material

All Recall archive boxes purchased are manufactured from 100% recycled material

All company stationery including letterhead, invoices business cards and envelopes

The total weight of recycled content material purchased in 2014-15

was approximately 6.4 tonnes.


Action Progress

Goal 3: Product Stewardship

KPI 6 – Proportion of signatories that have formal processes for working with others to improve design and recycling of packaging

We continue to work with our suppliers to improve the design and recycling of packaging, including:

Communication with company cleaners to uphold correct disposal of recyclable materials;

Regular contact with our waste contractors to ensure continuity of service to maximise recycling rates

Annual communication with our global parent company regarding meeting our APC commitments, with APC Annual Reports, Action Plans and case studies publicly available on our global website.

In addition, a new process has been introduced this year, to review potential new suppliers at the Request for Proposal stage. All new suppliers are requested to complete questions about their environment and sustainability programs – for example, implementation of an Environmental Management System, or development of an Environment Policy, and identify programs which could assist us to achieve our environmental commitments

KPI 7 – Proportion of signatories demonstrating other product stewardship outcomes

We acknowledge the impact of our product and packaging on the environment at the end of its life and seek to implement programs which address this.

We continued to work with the other major Australian tobacco companies, British American Tobacco Australia and Philip Morris Limited, to implement a recycling program for cigarette butts and some cigarette packaging waste in partnership with TerraCycle. The program commenced in March 2014, with the program collecting over 3.4 tonnes of cigarette butts for recycling (equating to over 7 million butts).

However at the time of writing this report, the three companies made the decision to discontinue the trial at the end of 2015 on the basis it didn’t meet the industry objectives. Regardless, we continue to work together as an industry to implement the informal Tobacco Product Stewardship program

Internally, we continue to support other product stewardship activities to further minimise the environmental impacts of business operations, including:

Continued support for the Australian Battery Recycling Initiative (ABRI) at ITA head office, collecting around 66kg of batteries (from home and office use by staff) for recycling.

A mobile phone recycling drive at head office during National Recycling Week, for staff to recycle old personal and company mobile phones. 177 phones were collected for re-use or recycling through the Aussie Recycling Program (ARP) which refurbishes and on-sells working mobile phones to less developed countries (phones not in working order are recycled)

Donation of 44 computer monitors to Work Ventures, a company that provide computer equipment to low income families (165 company laptops were sold to staff for reuse); and

Recycling of 1.7 tonnes of un-useable IT equipment, for example cables and servers, via IT E-waste.


Action

Progress KPI 8 – Reduction in the number of packaging items in litter

Litter is a problem in Australia and cigarette packaging and butts do contribute to the litter stream. To help mitigate this problem, we continued to:

Conduct annual reviews of litter reports and data, such as the KAB National Litter Index Reports, to better understand the extent and location of tobacco related litter. Recent reports show a 34% reduction butt litter items per 1000m2 since 2006-07. Analysis of these results against the decrease in filtered cigarette sales during this time indicates a 12% actual decrease in butt litter.

Conduct research into cigarette butt littering behaviour to understand where and why smokers are likely to discard their butts inappropriately. This information is used to inform company anti-litter strategies for cigarette butts. The 3 tobacco companies have now implemented this research individually, which allows us to gain a larger sample range and broader picture of littering behaviour.

Provide a $25,000 (exc. GST) financial contribution to Butt Free Australia (KESAB) to support implementation of an anti-littering communication event for National Butt Free Day in October 2014

Maintain litter disposal infrastructure to prevent litter at all company sites.




1. Work with waste management contractors to improve waste and recycling data

Waste and recycling data to include accurate volumes and weight estimates

Business has confidence in data presented

June 2013 Annually

Target met:

Head office recycling contractors continued to supply monthly reports which provide an estimate of commingled containers and secure documents recycled each month.

This reporting is complimented by internal waste assessments to check data accuracy.

2. Work with cleaning contractors to maximise recycling rates at all company sites

Cleaners actively supporting company waste and recycling systems

No bin contamination caused by cleaner activities

June 2013 Annually

Target met:

Communication is maintained with the company cleaners to uphold correct disposal of recyclable materials.

Feedback is also regularly provided by the cleaners to notify the business if contamination levels rise in the recycling bins of if too many recyclable items end up in general waste bins.

3. Communicate APC requirements to parent company

Two APC communications to parent company per annum

Parent company aware of and supportive of local APC requirements

March 2013 Annually

Target met:

Annual communication of the company's progress in meeting our APC commitments is maintained with our global parent company.

Our APC Annual Reports, Action Plans, and a case study highlighting our achievements are publicly available on our global website.

Given many packaging development and procurement processes are made globally, additional communication has been implemented with global packaging development teams and non-tobacco material procurement to understand current considerations for sustainable packaging and opportunities to align already embedded processes with the requirements of the SPG.

4. Review suppliers to assess APC signatory status, where relevant

Supplier survey completed

June 2014 Action completed in 2013-14




1. Cross functional APC team maintained to oversee APC Commitments

4 APC Team meetings per annum

June 2013 Annually

Target exceeded:

A proactive and enthusiastic cross-functional APC Team has been maintained with representatives from brand marketing, corporate and regulatory affairs, corporate services, supply chain and finance.

The APC Team is governed by a charter which outlines the team scope to oversee ITA’s APC commitments inclusive of Action Plan redrafting, action implementation, business engagement and communication and annual report development and submission.

4 meetings were convened in 2014-15.



2. Develop and implement an APC communications and stakeholder engagement plan

2 x communications to internal stakeholders and parent company per annum

1 x sustainability event per annum

1 x communication to suppliers per annum

June 2013 Annually

Target exceeded:

An APC communications plan was developed to engage staff and communicate key activities and promote APC commitments. Additionally, communication is maintained with global counterparts to align local and global sustainable packaging processes.

In 2014-15 we implemented the following communications to internal stakeholders and parent company:

Email communications to global Head of Non-tobacco Material Procurement and Packaging Innovation and Development Teams

Engaged local staff in the development of sustainability branding for the company via a poll to vote for the favourite design through email communication and the internal social media platform

Published 3 articles in the company magazine to showcase APC commitments and achievements

Held 2 green team meetings with staff to discuss environmental programs and identify new ideas to improve our environmental performance

Conducted desk-drop and other communications to engage staff and promote the new recycling trial (to commence in July 2015)

Developed a case study to promote APC activities on the Imperial Tobacco Group website

We convened 2 sustainability events:

Conducted a mobile phone recycling drive at head office during National Recycling Week, to provide staff an opportunity to recycle old personal and company mobile phones - 177 phones were collected for re-use or recycling through the Aussie Recycling Program (ARP)

Communication event to engage staff in the design of sustainability branding

We communicated with our suppliers:

Regular communications are maintained with suppliers relevant to the APC including distribution suppliers, stationery and other material suppliers and service provider’s manufacturers to collect information to support our commitment to the APC.



3. Develop company sustainability branding and implement APC communication under the banner of broader company commitments

Sustainability / APC branding complete

4 x sustainability communications to the business per annum

December 2014

Target met:

New sustainability branding has been developed to provide consistency for all environment and sustainability communications. The new branding "Respect IT" is used on all communications, with a series of sub-messages which centre on key focus areas including recycling, buy recycled, sustainable packaging, reducing consumption, and reducing litter.

4. APC information to be included in company induction sessions

APC information presented at induction sessions

Dec-12 Action completed in 2013-14

5. Develop and publish APC action plans and annual reports on company website

APC annual reports submitted by 31 March annually

Branded APC report published by May each year

APC action plan and Annual Reports available on company website

June 2013 Annually

Target met:

The 2013-14 Annual Report was prepared and submitted to the APC in January 2015.

In addition to the standard reporting format prescribed by the APC, ITA developed a branded APC report for internal communication and public distribution via the company website.

The most recent Action Plan and Annual Report are publicly displayed on the global company website. There is no local company website at this time.

6. Implement battery recycling at all company sites

Battery recycling implemented at all company sites

Quantity of batteries recycled reported per annum

Jun-14 Target met:

The battery recycling program at head office was maintained to keep used batteries out of landfill. The battery recycling program is available to staff to recycle batteries from the workplace and from home.

In 2014-15, 66kg of batteries were recycled.



7. Implement e-waste recycling service at all company sites

E-waste recycling implemented at all company sites

Quantity of e-waste recycled reported per annum

Jun-14 Target met:

ITA supports the waste hierarchy of reduce, reuse, recycle, and seeks opportunities to re-use computer equipment before recycling.

In 2014-15, we:

Donated 44 computer monitors to Work Ventures, a company that provide computer equipment to low income families

Donated 177 old company and non-company mobile phones to the Aussie Recycling Program which seeks to refurbish and on sell working mobile phones to less developed countries (phones not in working order are recycled)

165 company laptops were sold to staff for reuse

In addition, we recycled 1.7 tonnes of un-useable IT equipment, for example cables and servers, via IT E-waste.

8. Conduct consumer research to help gain further insight on butt littering behaviour

Consumer research conducted and outcomes summarised

June 2013 Annually

Target met:

Littering behaviour questions have been included in the ITA consumer insights questionnaire, as part of a tobacco industry initiative to better understand:

The number of smokers that are likely to litter

What drives them to litter; and

Where they are most commonly likely to litter.

The survey commenced in June 2015 for 3 months. The results will be collated and outcomes used to consider how ITA and the industry can best assist to reduce butt litter.



9. Work with other tobacco companies to investigate opportunities for an industry product stewardship response

2 industry meetings held per annum

Proportion of cigarette product and packaging in the litter stream understood and documented

Opportunities for tobacco industry involvement in product stewardship initiatives identified

June 2013 Annually

Target exceeded:

6 tobacco industry product stewardship meetings were convened with British American Tobacco Australia and Philip Morris Limited during 2014-15, to progress an informal industry product stewardship response.

The industry is continuing to trial a TerraCycle program to recycle cigarette butts. The aim is to understand if recycling cigarette butts is viable and can help reduce cigarette butt litter.

As at end June 2015, over 7 million butts were collected representing 3.4 tonnes of butts and packaging diverted from landfill.

Whilst this trial was ongoing during the reporting period, at the time of writing the report an industry decision had been made to discontinue the trial in Dec 2015. Further information will be reported in our 2015-2016 Annual Report.

ITA continues to work together with the other tobacco companies to identify and progress other opportunities to reduce cigarette butt and packaging litter.




1. Monitor litter research to track cigarette packaging as % of litter stream

NLI results reviewed annually and reported to the business


Target met:

2013-14 NLI results were reviewed by the company APC Team to monitor the number of cigarette butts found in the litter stream and how butts are represented in the litter stream.

Whilst butts still remain the highest littered item at 23 items per 1000m2, there has been a 34% reduction butts per 1000m2 since 2006-07. Analysis of these results against the decrease in filtered cigarette sales during this time indicates a 12% decrease in butt litter.

The tobacco industry has developed an informal product stewardship response to seek ways to further reduce butt littering.

2. Provide sponsorship for research and/or anti-littering campaigns as relevant to ITA objectives

Annual financial contribution to anti littering initiatives supported and reported


Target met:

A $25,000 (exc. GST) financial contribution was provided to Butt Free Australia (KESAB) to support implementation of an anti-littering communication event for National Butt Free Day in October 2014.

3. Action: Develop and implement campaign to retailers and consumers to raise awareness of appropriate disposal of tobacco product packaging

Campaign implemented

June 2014 Target progressed:

The tobacco industry, as part of their informal product stewardship response, has committed to implement an anti-butt littering campaign via tobacco retailers. The campaign will be displayed at the point of sale for tobacco products to directly impact smokers.

The campaign is currently under development for implementation in the next reporting period.

4. Maintain appropriate infrastructure to avoid littering at company sites

Bins and ashtrays installed and maintained at all company sites

No littering on company premises

December 2013

Target met:

Ashtrays are provided in all smoking areas at all company sites to provide facilities which support the correct disposal of cigarette butts and to collect butts for the TerraCycle butt recycling trial.

To date ITA has collected over 38,000 cigarette butts for recycling.

4-8 Inglewood Place

Baulkham Hills NSW 2153

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