Charitable and political donations
WRG made charitable donations amounting to £10,943 during the year ending 31 December 2008. (In 2007, this figure was £26,650.) It also contributed £14,408,606 of its landfill tax liability to Waste Recycling Environment Ltd (WREN), an ENTRUST-registered distributive environmental body – as permitted by Government regulations. (In 2007, this figure was £15,359,241.)
No political donations were made during the year ending 31 December 2008. (In 2007, this figure was also nil.)
WRG does not donate any funds or services in kind to any political organisation.
Suppliers
During late 2008, the central procurement function within WRG re-tendered all Engineering Construction landfill works on the operational sites and appointed new Regional Contractors under standardised Engineering Contracts, at lower schedules of rates. These contracts represent a substantial proportion of the business’s capital expenditure and their success is a key component in having facilities prepared to a high standard for the receipt and safe storage of customers’ waste. The formation of such strategically-important and financially-substantive contracts has provided opportunity for the engineering partners to be bound into environmentally-sound and socially-responsible working arrangements.
Procurement
The central procurement function within WRG has adopted a strategic procurement model and, where appropriate, works towards developing centrally-managed standardising specifications for products and services. Through its central procurement function, WRG is able to specify selection criteria for critical items and services. Whilst general low-value procurement is devolved, as of January 2009 all potential suppliers will be required to complete a pre-qualification process to verify data on their own social, ethical and environmental status in advance of any purchasing arrangements. Attention is now being given to the procurement of electricity and a number of half-hourly supplies are being supplied through non-carbon sources. In line with FCC’s policies and the global compact principles, procurement practice will expand to consider human rights screening.
Product/consumer ethics
Product stewardship has become increasingly relevant to corporate responsibility. In the context of landfills, WRG has a responsibility to demonstrate to customers and other stakeholders that our facilities are a safe repository for waste and that our business has the expertise and resources to responsibly manage the maintenance and aftercare of our landfill sites for decades into the future.
Monitoring continues on closed sites to measure any potential environmental impact, and we review such data to consider or to demonstrate Groundwater Regulations compliance.
The financial means to effect control or to mitigate known impacts into the future are demonstrated via provisions for foreseeable costs, which are assessed for adequacy by external financial audit.
Additionally, it is a requirement of most of our permits and licenses that a separate financial provision is made as part of WRG’s 'fit and proper person' status. The Environment Agency (EA) is a beneficiary of this provision and can draw upon an 'umbrella bond' covering environmental impairment.
WRG has legal agreements with the EA to protect its rights of access to these funds in specified circumstances.
Business ethics
WRG undertakes to pay its suppliers in accordance with transparent terms and conditions and does not knowingly or wilfully withhold payment that might prejudice the cash-flow of SMEs who provide us with critical products or services.
Bribery and corruption
A number of investigations into allegations of fraud and corruption were carried out in 2008, in response to complaints and other intelligence. The company uses internal staff or external professional investigators, depending on the nature of the allegation. In addition, FCC’s governance procedures require that they take a direct and participative role in auditing WRG’s activities, and a permanent audit staff member is based at Northampton, reporting directly to Internal Audit in FCC Group, Madrid.
The Company continues to operate a confidential and independent “whistleblower’s hotline” for employees, in order to allow reporting of any aspect of business malpractice.
Anti-competitive behaviours
In 2008, there were no examples of legal action taken for anti-competitive behaviour, anti-trust or monopoly practices. All high value tenders issued include non-collusion certificates, and receipt of signed copies is a pre-condition for tender consideration.
