Overview and Policies
CSR’s Health, Safety and Environmental (HS&E) management system promotes the ongoing development of a positive health, safety and environmental culture through development of policies and procedures, and promotion of them on the company’s intranet and via training and monitoring through a designated health and safety officer and a HS&E Committee. These practices are intended to encourage ownership of HS&E matters by all CSR employees as an integral part of our day-to-day operations.
Key aspects of the HS&E policies include:
Health and Safety Policy
- The Company regards the management of health and safety as an integral part of its business and as a management priority.
- It is our policy that all activities will be carried out in a safe manner and we will establish and evaluate, as appropriate, processes and practices to ensure the health, safety and welfare of our employees and of others who may be affected by our activities.
- The hazards associated with our business activities will be identified and mitigated through formal assessment and will be reduced where reasonably practicable.
- The Company will comply with current health and safety legislation, as a minimum, seeking to establish policies and procedures that enable the Company and its employees to meet this commitment and will work to establish and apply best practice to all its activities where this is practicable.
- Employees are expected and encouraged to be proactive on health and safety issues. All employees, contractors and sub-contractors are required to co-operate with the Company and their colleagues in implementing the policy and shall ensure that their own work is without risk to themselves or others as far as is reasonably practicable.
- The Company aims for continual improvement of the environmental management system through employee training, consultation and involvement in identifying environmental impacts; encouraging management commitment; performing regular reviews and conducting internal audits of the environmental management system.
- Analysis is undertaken of the organisation’s significant environmental impacts, including where these involve potential risk of pollution, through a formal assessment process and using these assessments as guidance in setting objectives and targets.
- The Company is committed to co-operation with the applicable local authority and site landlords on relevant environmental issues and due consideration of any environmental complaints relating to CSR sites or operations.
- The Company is committed to compliance with environmental legislation applicable to CSR’s products and operations and maintains a register which identifies applicable environmental legislation and relevant guidance on how to meet these requirements.
- The Company gives due consideration to environmental issues raised by customers and seeks to respond positively to customer-led environmental initiatives.
- The Company works closely with those involved in the manufacturing supply chain, in order to achieve best practice in the environmental aspects of material sourcing, product manufacture, disposal and recycling.
CSR has an Environmental Management System (EMS) which defines the environmental policy of the Group and sets objectives intended to drive continuous improvements in environmental awareness and practices.
More on CSR’s environmental practices associated with products is explained below.
CSR has a HS&E Committee which meets regularly and is chaired by the Facilities Manager. HS&E policies are available to all employees on the CSR intranet, as are the minutes of the HS&E Committee and current HS&E initiatives. An annual report is presented to the Board covering health and safety matters which includes statistics on accidents and incidents, progress against targets from the previous period and objectives for the year ahead.
The Company expects the highest of ethical standards of all its employees and its policies and procedures support its stated aim of acting with integrity in all aspects of its operations. The Board director responsible for health and safety matters is Will Gardiner, Chief Financial Officer. Mr Gardiner met on a number of occasions with those who manage the Company’s health and safety issues including the Chair of the Health, Safety, and Environmental (HSE) Committee. An annual report is presented to the Board covering health and safety matters, which includes statistics on accidents and incidents, progress against targets from the previous period and objectives for the next year. In the UK, we have a Health, Safety and Environmental Committee which meets regularly and is chaired by the Group Facilities Manager, who is also the senior health and safety manager for the Group. Our Health, Safety, and Environmental policies are available to all employees on our intranet site as are the minutes of the HSE Committee and current HSE initiatives.
Current HSE initiatives are explained below.
We are proud to continue to work alongside TSMC, which is reputed to be the “greenest” semiconductor fabricator company in the world. By reducing emissions, recycling water and consuming less water, TSMC is already recognised as the best performer in environmental protection. The Company has also turned its attention to other social responsibility issues, including the establishment of an extensive Education and Culture Foundation which targets resources towards education, sponsoring of art and culture, community building and employee volunteering.
The Company expects the highest of ethical standards of all its employees and its policies and procedures support its stated aim of acting with integrity in all aspects of its operations.
The Board director responsible for health and safety matters is Will Gardiner, Chief Financial Officer. In 2012, Mr. Gardiner met with those who manage the Company’s health and safety issues including the Chair of the Health, Safety, and Environmental (HSE) Committee. Reports are presented to the Board twice each year covering health and safety matters, which includes statistics on accidents and incidents, progress against targets which have been set.
In the UK, we have a Health, Safety and Environmental Committee which meets regularly and is chaired by the Group Facilities Manager, who is also the senior health and safety manager for the Group. Our Health, Safety, and Environmental policies are available to all employees on our intranet site as are the minutes of the HSE Committee and current HSE initiatives. Current HSE initiatives are explained below.
During 2012 work continued in promulgating HSE best practices across the CSR group. Country Leaders and their deputies act as champions at their office location to support various training programmes and initiatives to raise awareness about health and safety activities. Serious and imminent danger policies and procedures have been deployed and we are assisting local groups with their implementation. Newly established offices at Bristol, in the United Kingdom, and Freiburg, in Germany, have also been included within this programme. The Audit Committee received reports on progress against the targets for such matters as part of its routine business at its meetings in February 2012 and July 2012.
As a consequence of the Samsung Transaction, and the necessary diversion of resources in support of that project, and, following its completion in October 2012, the transfer to Samsung of certain employees with day to day involvement in Health, Safety and Environmental matters, some of the planned initiatives have been deferred from 2012 into 2013. However, good progress was made in the first half of the year with a number of sites instituting the undertaking of workplace inspections and risk assessments that are now conducted on a regular basis along with training for First Aid and Fire Marshall representatives.
The executive director with responsibility for the Group’s Environmental Management System (EMS) throughout 2012 was Mr. Chris Ladas, Operations Director. The EMS, which has the support of the Board, has been developed reflecting our existing low eco-footprint, with all employees working in office based environments, whilst recognising that high standards should be established and maintained across all aspects of our operations. The ongoing management of EMS is overseen by a team incorporating managers responsible for Facilities, Business Management Systems and Quality Assurance.
The team establishes a programme of action for each year and monitors progress against targets. Progress in carrying out the action plans is monitored by the Company’s internal Quality Assurance department, which reports regularly to the Internal Auditor and to the Audit Committee. In 2013, the Company underwent a certificate renewal assessment for both ISO 14001 and OHSAS 18001 which was completed by Lloyds Register Quality Assurance Limited, an internationally recognised independent assessor. The assessment confirmed that the Company’s Management System continues to satisfy the requirements of ISO 14001:2004 and BS OHSAS 18001:2007, with no nonconformities being raised during this visit, and continued certification to these standards was awarded.
Certification requires that we have an EMS which defines the environmental policy of the Group and sets objectives intended to drive continuous improvements in environmental awareness and practices.
Our environmental policy includes commitments to:
- employee consultation and training;
- assessment of our activities and product related environmental impacts to identify targets for continuous improvement; and
- legal compliance and due consideration of other stakeholder environmental requirements.
We believe that we are taking considerable steps to contribute to sound environmental practices, covering not only the manufacture and supply of our products but also positive measures to establish and build on good working practices within our various office locations.
We have registered and fulfilled requirements pursuant to the Carbon Reduction Commitment (CRC) and reported the energy consumption of our UK premises. We continue to take steps to monitor and minimise our Co2 emissions through on-going energy efficiencies.
Organisations that participate in CRC are required to purchase allowances for each tonne of Co2e, based on energy consumed. The first Co2e allowance sales for 2011-12 emissions took take place in 2012. This is intended to provide a direct incentive for businesses to reduce energy use emissions, since the lower the emissions, the lower the levy paid to the Government. For 2012, the appropriate number of allowances were surrendered in accordance with the scheme.
Good progress was made in the first half of 2012 on monitoring and evaluating any energy efficiencies that had arisen from the continued operation of the new chiller system at our Cambridge HQ. We believe that there is the opportunity for additional efficiencies which will be considered under a cost/benefit analysis during 2013 as part of our consideration of continuous improvements.
In Cambridge, we remain committed to continuous improvement in the recycling of spent materials. The total amount of all waste types recycled during 2012 was 115,014 kgs which is equivalent to 70% of all the waste that we produce, and was 5% ahead of our target for the year. Over the same period, landfill waste reduced from 38.5% to 30%. Staff are actively encouraged to support such initiatives. Waste bins are segregated into categories of recyclable materials and no offices have waste bins. In addition, part of the selection criteria for waste removal contractors considers their environmental credentials.
CSR has long been committed to optimising the use of “greener” materials in our end products. We continue to work with customers and suppliers as well as our own in-house teams in developing and supplying products which meet the highest standards as regards minimising the use of hazardous substances.
CSR’s products are manufactured and packaged in a variety of forms. All new products released by CSR in recent years are manufactured according to CSR’s own “green” standards. The green standards have been developed by CSR as part of continual engagement with leading global companies who are customers of CSR and also with the support of our suppliers. CSR’s green standards therefore reflect not only internationally recognised guidelines but also the feedback of our customers, whose requirements frequently exceed the minimum conditions set by governments and regulators.
We have dedicated staff who assist in the development of all new products and the review of existing product lines targeting the use of greener materials. Part of their role is to monitor established and pending legislation and standards published by national and supranational governments and agencies and to ensure that we are proactive in going beyond the minimum requirements in our compliance with the types and quantities of materials used.
In this respect we work closely with both customers and suppliers in developing products to reduce the use of hazardous materials, and through testing and certification, ensuring ongoing compliance.
Our standard integrated circuits are fully compliant with all existing European legislation, including RoHS and REACH, as well as in other territories where equivalent legislation has been introduced.
In addition to procedures that establish and monitor compliance, we have processes in place to make sure that customers are supported with up to date materials information and laboratory analysis to validate the environmental compliance of our products.
In August 2012, requirements for reporting on the utilisation of certain so-called "conflict minerals" were adopted by the US Securities and Exchange Commission ( the "SEC") pursuant to provisions of the Dodd Frank Wall Street Reform and Consumer Protection Act, (the "Dodd Frank Act"). As a result of this decision, companies registered with the SEC must prepare for making certain disclosures commencing from May 2014 on their use of specific conflict minerals (Tantalum, Tin, Tungsten and Gold). Whilst CSR is not a direct buyer of the conflict minerals from source, we recognise that we will need to report on our supply chain and the extent to which such conflict minerals may be used in our products. To that end, we are taking steps which will continue through 2013, to gather responses from our suppliers that will support us in our endeavours to conform to the requirements of the Dodd Frank Act in respect of conflict minerals disclosure.
We recognise the importance of ensuring that our key suppliers have appropriate policies and practices on Social, Environmental and Ethical matters. Key manufacturing partners are selected and assessed based on certification to appropriate globally recognised standards such as ISO 14001, OHSAS 18001 and SA 8000. Audits of their operations are undertaken regularly to ensure that appropriate standards and certification exists.
During 2012, reviews of product environmental compliance were conducted by our Supplier Audit Team at ASE in Taiwan and China. Through these reviews, we obtained assurances on certain practices and supporting certifications.
Based on the extent of our ongoing engagement described above, the Board believes that steps are being taken to mitigate against the risks relating to health, safety and environmental responsibilities and there is no present expectation that prevailing practices would materially affect our strategic objectives.
Chief Financial Officer
28 March 2013