Report - COP Prototype

2022 Communication on Progress

The GPT Group

Published date

June 8, 2022

No. of questions

Supplemental files

CEO Statement

Signed

Governance

Policies and Responsibilities

1. Does the Board / highest governance body or most senior executive of the company:

Issue an annual statement about the relevance of sustainable development to the company

Issue an annual statement that addresses impacts on both people and the environment

Issue an annual statement highlighting a zero tolerance for corruption

Sign off on organizational sustainability targets

Supervise Environmental, Social, and Governance reporting

Regularly review potential risks related to the business model

None of the above

2. Does the company have a publicly stated commitment regarding the following sustainability topics?

	No, this is not a current priority	No, but we plan to have a commitment within 2 years	Yes, and the commitment is focused on our own operations	Yes, and the commitment includes our own operations and the value chain	Yes, and the commitment includes our own operations and the value chain along with communities and society
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Optional comment

Refer to the following policies, publicly available on GPT's website: Human Rights Statement: https://www.gpt.com.au/sustainability/community/Human-Rights Sustainability Policy: https://www.gpt.com.au/sites/default/files/inline-files/Sustainability%20Policy%20202011_0.pdf Supplier Code of Conduct: https://www.gpt.com.au/sites/default/files/inline-files/Supplier%20Code%20of%20Conduct_0.pdf Climate Change and Energy policy: https://www.gpt.com.au/sites/default/files/inline-files/Climate%20Change%20and%20Energy%20Policy%20202011_0.pdf Biodiversity policy: https://www.gpt.com.au/sites/default/files/inline-files/Biodiversity%20Policy%20202011.pdf Anti-bribery, fraud and corruption prevention policy: https://www.gpt.com.au/sites/default/files/inline-files/GPT%20Anti-Bribery%2C%20Fraud%20and%20Corruption%20Prevention%20Policy.pdf

3. Does the company have in place a code of conduct regarding each of the following sustainability topics?

	No, this is not a current priority	No, but we plan to have a code of conduct within two years	Yes, focused on employee conduct	Yes, focused on employees and suppliers	Yes, focused on employees, suppliers, and other business relationships
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

4. Has the company appointed an individual or group responsible for each of the following sustainability topics?

	No one is specifically responsible for this topic	Yes, with limited influence on outcomes (e.g., limited access to internal information, limited decision-making authority)	Yes, with moderate influence on outcomes (e.g., has access to relevant information, reports to senior manager)	Yes, with direct influence of some outcomes (e.g., has access to relevant information, includes one or more senior manager with decision making rights	Yes, with direct influence at the highest levels of the organization (e.g., has access to relevant information, includes most senior members of organization)
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

5. Does the company have a formal structure(s) (such as a cross-functional committee) to address each of the following sustainability topics?

	No formal structure	Yes, and with limited influence on outcomes (e.g., limited access to internal information necessary to understand risks, poor representation from relevant departments or functions)	Yes, with moderate influence on outcomes (e.g., it includes representatives of some functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, reports to senior manager)	Yes, with direct influence on some outcomes (e.g., it includes representatives of functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, it involves one or more members of senior management)	Yes, and with direct influence at the highest level of the organization (e.g., full access to relevant information, it involves members at highest level of organization)
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Prevention

6. Does the company have a process or processes to assess risk?

	No, this is not a current priority	No, but we are planning to develop one in the next two years	Yes, related to our own operations	Yes, related to our own operations and entire value chain and other business relationships
Human rights risks
Labour rights risks
Environmental risks
Corruption risks

6.1. During the assessment of risk, which business relationships are reviewed?

	A few suppliers or business relationships [approximately less than 25 %]	Several suppliers / business relationships (i.e., first tier or other high priority) [approx. 25 - 50 %]	Most suppliers / relevant business relationships [approx. 51 - 99 %]	All suppliers / relevant business relationships outside the supply chain
Human rights risks
Labour rights risks
Environmental risks
Corruption risks

7. Does the company have a due diligence process through which it identifies, prevents, mitigates, and accounts for actual and potential negative impacts on sustainability topics?

	No, this is not a current priority	No, but we are planning to develop one in the next two years	Yes, related to our own operations	Yes, related to our own operations and entire value chain and other business relationships
Human rights risks
Labour rights risks
Environmental risks
Corruption risks

7.1. During the due diligence process, which business relationships are reviewed?

	A few suppliers or business relationships [approximately less than 25 %]	Several suppliers / business relationships (i.e., first tier or other high priority) [approx. 25 - 50 %]	Most suppliers / relevant business relationships [approx. 51 - 99 %]	All suppliers / relevant business relationships outside the supply chain
Human rights risks
Labour rights risks
Environmental risks
Corruption risks

Concerns and grievance mechanisms

8. Are there any processes through which members of the company’s workforce can raise concerns about the company’s conduct related to human rights, labour rights, environment, or anti-corruption?

No, this is not a current priority

No, but we plan to within two years

Yes, we have an informal process (e.g., through supervisors, others)

Yes, we have a formal process

8.1. Please provide additional detail regarding the process(es) the company has through which members of the company’s workforce can raise concerns about the company’s conduct.

	No	Yes
Is the process communicated to all employees/workers in local languages?
Is the process available to non-employees (e.g., contractors, vendors, suppliers)?
Is the process confidential (e.g., whistleblowing process)?
Are there processes in place to avoid retaliation?
Can concerns be raised about suppliers or other business relationships (e.g., clients, partners, etc.)
Other (Please provide additional information)

9. Does the company provide or enable access to effective remedy to right holders / stakeholders where it has caused or contributed to the adverse impact?

	No process to enable remedy to stakeholders	Remedy available to some stakeholders (i.e., some geographies, employees only)	Remedy is available to all affected stakeholders	Remedy is available to all stakeholders, and suppliers are expected to have similar policies
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Lessons

10. How does the company capture lessons regarding each of the following sustainability topics?

	No lessons are regularly captured	Conducts root cause analyses/investigation of major incidents	Conducts root cause analyses/investigation and changes organizational policies, processes, and practices accordingly	Systematically conducts root cause analyses/investigation and leverages learnings to influence both internal and external affairs
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Executive Pay

11. Is executive pay linked to performance on one or more of the following sustainability topics?

Board Composition

12. Percentage of individuals within the company’s Board / highest governance body by:

	Number/Percentage	Not applicable (Please provide additional information)
Total number of board members (#)	7
Male (%)	57
Female (%)	43
Non-binary (%)	0
Under 30 years old (%)	0
30-50 years old (%)	0
Above 50 years old (%)	100
From minority or vulnerable groups (%)	0
Executive (%)
Independent (%)	86

Data Assurance

14. Is the information disclosed in this questionnaire assured by a third-party?

No assurance for any metrics

Limited assurance for minority of metrics (e.g., GHG emissions only)

Limited assurance for majority of metrics

Reasonable assurance for minority of metrics

Reasonable assurance for majority of metrics

See

Other (Please provide additional information)

Human Rights

Commitment

2. Does the company have a policy commitment in relation to the following human rights issues?

	No, and we have no plans to develop a policy	No, but we plan to in the next two years	Yes, included within a broader policy	Yes, articulated as a stand-alone policy
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
2020
Access to culture
Free, prior and informed consent
Access to water and sanitation

Optional comment

The rights of indigenous peoples is referenced in GPT's Human Rights Statement (https://www.gpt.com.au/sustainability/community/Human-Rights) and also in GPT's Reconciliation Action Plan (see https://www.gpt.com.au/sustainability/community/rap).

2.1. For each human rights policy, is it:

	Aligned with international human rights standards?	Publicly available?	Approved at most senior level of the company?	Applied to the company’s own operations?	Applied to the company’s supply chain and/or other business relationships?	Developed involving human rights expertise from inside and outside the company?	Other (Please provide additional information)
Freedom of expression
Digital security / privacy
Rights of women and/or girls
Access to culture
Rights of indigenous peoples
Informed by engagement with Australia's First Peoples.
Free, prior and informed consent
Rights of refugees and migrants
Access to water and sanitation

Prevention

3. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following human rights issues?

	No engagement on this topic	To better understand the risks/ impacts in question	To discuss potential ways to prevent or mitigate the risks/ impacts in question	To agree on a way to prevent/ mitigate the risks/ impacts in question	To assess progress in preventing /mitigating the risks/impacts in question	To collaborate in the prevention/ mitigation of the risks/ impacts in question
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

4. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this human rights issue?

	Provided internal training/ capacity building for the direct workforce	Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)	Conducting an audit process and/or corrective action plan	Collective Action with peers or other stakeholders to address the issue	Collaboration with governmental or regulatory bodies	Other (Please provide additional information)	No action within reporting period
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Direct engagement with First Nations Australians, including Traditional Owner group representatives.
Access to culture
Free, prior and informed consent
Access to water and sanitation

5. Who receives training for the following human rights issues?

	No training provided	Select employees	All employees	Contractors	Direct suppliers of the organization	Indirect suppliers of the organization	Other – such as partners, clients, etc.
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

Optional comment

GPT also collaborates with its supply chain to support their engagement and training regarding First Nations cultural awareness and reconciliation.

6. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following human rights issues?

	No monitoring of progress	Review issues on ad-hoc basis	Set annual targets/ goals, track progress over time (internal programs only)	Set annual targets/ goals, track progress over time (internal and external programs)	Other (Please provide additional information)
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

Response

7. During the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to adverse impact associated with the following human rights issue(s)?

	Yes	No	Choose to not disclose	Not applicable (Please provide additional information)
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
There have not been any matters requiring action during calendar year 2021.
Access to culture
Free, prior and informed consent
Access to water and sanitation

8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the human rights principles, including any challenges faced and actions taken towards prevention and/or remediation.

GPT understands and takes seriously its responsibility to all stakeholders to uphold high ethical standards in our business practices and decision making. Critical to this is respecting the human rights of everyone we deal with, whether indirectly or directly. GPT's commitment to human rights applies to our operations and our engagement with third parties and is embedded in our policies, systems and processes. This commitment is relevant to all areas of our business, in particular our people, our supply chain and procurement practices, compliance and risk management, and our community engagement and philanthropic activities (see GPT’s corporate governance principles and policies). Any material breaches or issues of significance are escalated to the GPT Board. GPT published its second Modern Slavery Statement in 2021 and continued a program of work to identify, address and mitigate modern slavery in GPT’s supply chain and operations (see GPT 2021 Modern Slavery Statement). We have also continued an audit of our supply chain's respect and support of human rights, and reviewed and actioned GPT’s Social Risk Register. During 2021, various employee training and engagement activities were delivered relating to human rights, including cultural awareness training, inclusion training and modern slavery training. This included training and communications relating to GPT’s Code of Conduct, safety and workplace relations and 100% of employees completed these learning modules. GPT maintains registers tracking breaches of its Code of Conduct, Equal Employment Opportunity and Workplace Behaviour Policy, and Diversity and Inclusion Policy. During the reporting period, breaches relevant of these policies have resulted in a range of actions in line with GPT’s Consequences Framework, including amendments to policies, internal audits being undertaken, changes to practices and procedures and disciplinary action. There have not been any breaches of the Supplier Code of Conduct during the reporting period. GPT also took action in 2021 through its contributions to communities of practice and industry networks including the Property Council of Australia's Modern Slavery, Sustainability, Social Sustainability and Diversity and Inclusion committees; the Supply Chain Sustainability School; Reconciliation Australia; the Property Champions of Change; and Pride in Diversity. Detailed goals and outcomes are further outlined in GPT's 2021 Sustainability Report (https://www.gpt.com.au/sites/default/files/inline-files/GPT%20Sustainability%20Report%202021_0.pdf) and GPT's 2021 Modern Slavery Statement (https://www.gpt.com.au/sites/default/files/data_fund/GWOF-GWSCF/GPT-Modern-Slavery-Statement-2021.pdf).

Labour

Commitment

1. Does the company have a policy commitment in relation to the following labour rights principles?

	No, and we have no plans to develop a policy	No, but we plan to in the next two years	Yes, included within a broader policy	Yes, articulated as a stand-alone policy	Not applicable (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
GPT recognises our employees’ right to freedom of association with others, including forming and joining trade unions. GPT does not have any employees represented by an independent trade union or covered under a collective bargaining agreement, as at 31 December 2021. Three main Australian industrial instruments exist to define the employment standards applicable to an individual, enterprise or industry: » The National Employment Standards (NES) are set out in the Fair Work Act 2009 and detail the minimum employment standards applicable to an individual. » Enterprises may also elect to establish collective bargaining agreements; however, these are not compulsory given the existence of the NES and Modern Awards (which cover over 100 industries and occupations). » Individual contracts can also be established, as is the case for GPT employees, so long as the terms and conditions meet or exceed the minimum entitlements set out in the NES and Modern Awards (where these apply). See also GPT's 2021 Sustainability Report, page 58:https://www.gpt.com.au/sites/default/files/inline-files/GPT%20Sustainability%20Report%202021_0.pdf
Forced labour
2021
Child labour
2021
Non-discrimination in respect of employment and occupation
2020
Occupational safety and health
2022
Working conditions (wages, working hours)
2020

1.1. For each labour rights policy, is it:

	Aligned with international labour standards?	Publicly available?	Approved at most senior level of the company?	Applied to the company’s own operations?	Applied to the company’s supply chain and/or other business relationships?	Developed involving labour rights expertise from inside and outside the company?	Other (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

Prevention

2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following labour rights issues?

	No engagement on this topic	To better understand the risks/ impacts in question	To discuss potential ways to prevent or mitigate the risks/ impacts in question	To agree on a way to prevent/ mitigate the risks/ impacts in question	To assess progress in preventing/ mitigating the risks /impacts in question	To collaborate in the prevention/ mitigation of the risks/ impacts in question	Other (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
GPT recognises our employees right to freedom of association with others, including forming and joining trade unions. GPT does not have any employees represented by an independent trade union or covered under a collective bargaining agreement, as at 31 December 2021. See also GPT's 2021 Sustainability Report, page 58: https://www.gpt.com.au/sites/default/files/inline-files/GPT%20Sustainability%20Report%202021_0.pdf
Forced labour
GPT has engaged with stakeholders who have expert knowledge and experience relating to modern slavery, and directly with workers in high risk industries (cleaning and security).
Child labour
GPT has engaged with stakeholders who have expert knowledge and experience relating to modern slavery.
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this labour rights issue?

	Provided internal training/ capacity building for the direct workforce	Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)	Conducting an audit process and/or corrective action plan	Collective Action with peers or other stakeholders, in particular workers' organizations, to address the issue	Collaboration with governmental or regulatory bodies	Other (Please provide additional information)	No action within reporting period
Freedom of association and the effective recognition of the right to collective bargaining
GPT recognises our employees right to freedom of association with others, including forming and joining trade unions. GPT does not have any employees represented by an independent trade union or covered under a collective bargaining agreement, as at 31 December 2021. See also GPT's 2021 Sustainability Report, page 58: https://www.gpt.com.au/sites/default/files/inline-files/GPT%20Sustainability%20Report%202021_0.pdf
Forced labour
GPT has engaged with stakeholders who have expert knowledge and experience relating to modern slavery, and directly with workers in high risk industries through audits and assessments (cleaning and security).
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

4. Who receives training for the following labour rights issues?

	No training provided	Select employees	All employees	Contractors	Direct suppliers of the organization	Indirect suppliers of the organization	Other – such as partners, clients, etc.
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

5. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following labour rights issues?

	No monitoring of progress	Review issues on ad-hoc basis	Set annual targets/ goals, track progress over time (internal programs only)	Set annual targets/ goals, track progress over time (internal and external programs)	Other (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

Performance

6. What is the percentage of employees covered under collective bargaining agreements?

	Percent of employees (%)	Unknown
Employees covered under collective bargaining (%)	0

7. What is the percentage of employees in a trade union or other workers' organization?

	Percent of employees (%)	Unknown	Not applicable (Please provide additional information)
Employees in a trade union or on a worker committee (%)
GPT recognises our employees right to freedom of association with others, including forming and joining trade unions. GPT does not have any employees represented by an independent trade union or covered under a collective bargaining agreement, as at 31 December 2021. See also GPT's 2021 Sustainability Report, page 58: https://www.gpt.com.au/sites/default/files/inline-files/GPT%20Sustainability%20Report%202021_0.pdf

8. In the course of the reporting period, what was the percentage of women in:

	Percent of women (%)	Unknown
Senior leadership level position	46
Non-executive board	50

9. What was the average ratio of the basic salary and remuneration of women to men (comparing jobs of equal value) during the reporting period?

	Salary ratio (%)	Unknown	Choose to not disclose
Women / Men (%)	79

Optional comment

GPT takes a multi-facted approach to examining pay equity and analyse our performance in several ways, including average remuneration by seniority, like-for-like role comparison, and industry comparison. This is outlined further in GPT's 2021 Sustainability Report (see page 48).

10. In the course of the reporting period, how frequently were workers injured (injuries per hour worked)?

	Frequency of injury	Unknown	Choose to not disclose
Frequency of injury	0

Optional comment

Based on the guidance provided (number of hours / total number of hours worked by workers in the reporting period), the frequency of direct employees injured at GPT during 2021 was 0.00000207. GPT's LTIFR rate for employees in 2021 was 2.07, based on Australian standards (number of hours / total number of hours worked by workers in the reporting period x 1,000,000 hours). LTIFR measures the number of lost time injuries per million hours worked during an accounting period. Both calculations are based on scheduled work days and the day immediately after the accident.

11. In the course of the reporting period, what was the company’s incident rate?

	Incident rate	Unknown	Choose to not disclose
Incident rate	0

Optional comment

Based on the guidance provided (number of hrs lost/total hrs worked), GPT's incident rate during 2021 was 0.00069056. At GPT this calculation is based on scheduled work days and the day immediately after the accident.

Response and Reporting

12. In the course of the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to the adverse impact associated with the following labour rights issues?

	Yes	No	Choose to not disclose	Not applicable (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
GPT recognises our employees right to freedom of association with others, including forming and joining trade unions. GPT does not have any employees represented by an independent trade union or covered under a collective bargaining agreement, as at 31 December 2021 and no action was required during the reporting period relating to freedom of association. See also GPT's 2021 Sustainability Report, page 58: https://www.gpt.com.au/sites/default/files/inline-files/GPT%20Sustainability%20Report%202021_0.pdf
Forced labour
No matters have been identified or raised during the reporting period.
Child labour
No matters have been identified or raised during the reporting period.
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)
No matters have been identified or raised during the reporting period.

13. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the labour rights principles, including any challenges faced and actions taken towards prevention and/or remediation.

GPT is committed to creating a diverse and inclusive workplace by providing equal opportunity in all aspects of employment and this is articulated in GPT's Equal Employment Opportunities Policy and Diversity Policy. GPT encourages and supports the right to freedom of association and collective bargaining, and the elimination of all forms of forced and compulsory labour; and this extends to relationships with our suppliers. In 2021, GPT refreshed its Diversity and Inclusion Strategy which drives the Group’s diversity objectives and initiatives. GPT has also been endorsed by Reconciliation Australia to develop its second Stretch Reconciliation Action Plan, contributes annually to the AWEI and Workplace Gender Equality Agency assessments, and actively participates on the Property Champions of Change and the Property Council of Australia's Diversity & Inclusion Committees. In 2022, GPT was recognised as a certified Family Friendly Workplace. Employee health and safety is a key risk category for GPT, and GPT's Risk Appetite Statement includes metrics relating to workplace behaviour and discrimination in respect to employment and occupation. GPT actively supports efforts to drive more transparency in global supply chains and ensure the production of goods and services in Australia has not been exposed to modern slavery. Since 2019, a cross-functional program of work continues to identify potential exposure to modern slavery within our operations and supply chain; map existing and mitigating actions and plan future actions to address modern slavery risk. GPT also contributes to the Property Council of Australia’s Modern Slavery Committee and Supplier Assessment Platform, and is a member of the Supply Chain Sustainability School, the Cleaning Accountability Framework and the UN Global Compact Australia Modern Slavery Community of Practice. GPT’s Supplier Code of Conduct outlines our expectations of our suppliers. It is each supplier’s responsibility to achieve and maintain the standards as set out in the Supplier Code of Conduct and GPT monitors supplier compliance through a range of activities including regular meetings, audits and our Supplier Pre-qualification Survey. Detailed goals and outcomes are further outlined in GPT's 2021 Sustainability Report (https://www.gpt.com.au/sites/default/files/inline-files/GPT%20Sustainability%20Report%202021_0.pdf) and GPT's 2021 Modern Slavery Statement (https://www.gpt.com.au/sites/default/files/data_fund/GWOF-GWSCF/GPT-Modern-Slavery-Statement-2021.pdf).

Environment

Commitment

1. Does the company have a formal policy on the following environmental topics?

	No, and we have no plans to develop a policy	No, but we plan to in the next two years	Yes, included within a broader policy	Yes, articulated as a stand-alone policy	Not applicable (Please provide additional information)
Climate Action
2020
Water
2020
Oceans
2020
Forests / Biodiversity / Land Use
2020
Air Pollution
2020
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
2020
Energy & Resource Use
2020

Optional comment

Refer to the following GPT policies, publicly available on GPT's website: - Sustainability Policy: https://www.gpt.com.au/sites/default/files/inline-files/Sustainability%20Policy%20202011_0.pdf - Climate Change and Energy Policy: https://www.gpt.com.au/sites/default/files/inline-files/Climate%20Change%20and%20Energy%20Policy%20202011_0.pdf - Water Policy: https://www.gpt.com.au/sites/default/files/inline-files/Water%20Policy%20202011_0.pdf - Biodiversity Policy: https://www.gpt.com.au/sites/default/files/inline-files/Biodiversity%20Policy%20202011.pdf - Materials and Waste Management Policy: https://www.gpt.com.au/sites/default/files/inline-files/Materials%20and%20Waste%20Management%20Policy%20202011.pdf

1.1. For each environmental policy, is it:

	Aligned with international environmental standards?	Publicly available?	Approved at most senior level of the company?	Applied to the company’s own operations?	Applied to the company’s supply chain and/or other business relationships?	Developed involving environmental expertise from inside and outside the company?	Other (Please provide additional information)
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

Prevention

2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following environmental issues?

	No engagement on this topic	To better understand the risks/ impacts in question	To discuss potential ways to prevent or mitigate the risks/ impacts in question	To agree on a way to prevent/ mitigate the risks/ impacts in question	To assess progress in preventing/ mitigating the risks/ impacts in question	To collaborate in the prevention/ mitigation of the risks/ impacts in question	Other (Please provide additional information)
Climate Action
Water
Oceans
Oceans is recognised a subset of water.
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with these environmental topics?

	Provided internal training/ capacity building for the direct workforce	Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)	Conducting an audit process and/or corrective action plan	Collective Action with peers or other stakeholders to address the issue	Collaboration with governmental or regulatory bodies	Other (Please provide additional information)	No action within reporting period
Climate Action
Water
Oceans
Oceans is recognised a subset of water.
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

4. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following environmental topics?

	No monitoring of progress	Review issues on ad-hoc basis	Set annual targets/ goals, track progress over time (internal programs only)	Set annual targets/ goals, track progress over time (internal and external programs)	Other (Please provide additional information)
Climate Action
Water
Oceans
Oceans is recognised a subset of water.
Forests / Biodiversity / Land Use
Air Pollution
Air pollution is a subset of climate and biodiversity targets and actions.
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

4.1. For each environmental topic in which the company sets timebound goals / targets, what kind of targets has the company set?

	Description of targets (e.g., what is the target, absolute vs. intensity, externally verified, on track, etc.)
Climate Action	Emissions intensity kg of Co2 per square meter; performance data assured; target achieved; target was 38kg of Co2/m2.
Energy & Resource Use	Emissions intensity MJ/m2; performance data assured; target achieved; target was 300MJ/m2.
Water	Emissions intensity L/m2; performance data assured; target achieved; target was 852L/m2.
Forests / Biodiversity / Land Use	Deliver net positive biodiversity impacts at all certified carbon neutral assets; target achieved. No environmental incidents that cause significant breach of Australian environmental regulations or incur significant liabilities; no incidents.
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)	Refer to biodiversity; also closed-loop materials recovery target of 34.5%; not achieved, result was 34.4%.
Oceans

Optional comment

This reflects GPT's assured reporting period of calendar year 2021.

4.2. For each environmental topic in which the company sets timebound goals / targets, how is progress against target / goal tracked?

	Progress is reviewed against goals annually or more frequently	Progress is reported internally to the most senior level	Progress is reported externally	Other (Please provide additional information)
Climate Action
Energy & Resource Use
Water
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Oceans

5. In the course of the reporting period, has the company been involved in providing or enabling remedy for any actual impacts associated with the following environmental issue(s)?

	Yes	No	Choose to not disclose	Not applicable (Please provide additional information)
Climate Action
During the reporting period, GPT is not aware of any significant breaches of any environmental regulations under the laws of the Commonwealth of Australia or of a State or Territory of Australia and has not incurred any significant liabilities under any such environmental legislation.
Water
During the reporting period, GPT is not aware of any significant breaches of any environmental regulations under the laws of the Commonwealth of Australia or of a State or Territory of Australia and has not incurred any significant liabilities under any such environmental legislation.
Oceans
During the reporting period, GPT is not aware of any significant breaches of any environmental regulations under the laws of the Commonwealth of Australia or of a State or Territory of Australia and has not incurred any significant liabilities under any such environmental legislation.
Forests / Biodiversity / Land Use
During the reporting period, GPT is not aware of any significant breaches of any environmental regulations under the laws of the Commonwealth of Australia or of a State or Territory of Australia and has not incurred any significant liabilities under any such environmental legislation.
Air Pollution
During the reporting period, GPT is not aware of any significant breaches of any environmental regulations under the laws of the Commonwealth of Australia or of a State or Territory of Australia and has not incurred any significant liabilities under any such environmental legislation.
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
During the reporting period, GPT is not aware of any significant breaches of any environmental regulations under the laws of the Commonwealth of Australia or of a State or Territory of Australia and has not incurred any significant liabilities under any such environmental legislation.
Energy & Resource Use

Climate Action

6. What were the company’s gross global greenhouse gas emissions for the reporting period?

Scope 1 Emissions

Full

None

Emissions (tCO2e)

7799

Scope 2 Emissions

Full

None

Emissions (tCO2e)

48907

Scope 3 Emissions

Full

Partial

None

Emissions (tCO2e)

23135

Optional comment

This reflects GPT's assured reporting period of calendar year 2021 as disclosed in the GPT environmental data dashboard. Scope 2 emissions are market based.

7. What percentage of the company's revenue was invested in R&D of low-carbon products/services during this reporting period?

Percent of revenue (%)

100

Unknown

Not applicable (Please provide additional information)

Optional comment

GPT invests in high performing real estate assets with low carbon or carbon neutral performance.

8. Has the organization acted to support climate change adaptation and resilience?

We have taken action to increase organization-wide resilience to climate change

We have taken action to increase resilience in our supply chains

We have taken action to increase resilience in the communities in which we operate

We have provided funding for climate change adaptation and resilience initiatives and projects

We have not taken actions to build climate change resilience in the reporting period

Other (Please provide additional information)

Unknown

Energy / Resource Use

9. Please report the company's renewable energy consumption as a percentage of total energy consumption in the reporting period.

% of total energy consumption

Unknown

Optional comment

This reflects GPT's assured reporting period of calendar year 2021.

Technology

10. What percent of the company's revenue came from environmentally friendly products / services during this reporting period?

Percent of total revenue (%)

100

All of GPT's assets are high performing, market leading assets.

Unknown

Not applicable (Please provide additional information)

Sector-specific: Water

12. Please provide details regarding the company's water withdrawal and consumption (own operations) during the reporting period.

Water withdrawal (volume of water in megaliters):

	Mega-liters	Unknown	Not applicable (Please provide additional information)
Total	1013.785
Groundwater:
GPT draws from water networks.
Surface water:
GPT draws from water networks.
Rainwater:	6.062
Wastewater:
GPT draws from water networks.
Percentage of water withdrawn in regions with high or extremely high water stress (%)
From a climate risk perspective, GPT recognises drought as one of our major risks, however our assets are located in urban areas where day to day risk of water stress is limited.

Water consumption (volume of water in megaliters):

	Mega-liters	Unknown	Not applicable (Please provide additional information)
Total	1059.784
Groundwater:
GPT draws from water networks.
Surface water:
GPT draws from water networks.
Rainwater:	6.062
Wastewater:	39.937
Percentage of water consumed in regions with high or extremely high water stress (%)
From a climate risk perspective, GPT recognises drought as one of our major risks, however our assets are located in urban areas where day to day risk of water stress is limited.

Optional comment

GPT consumes the majority of its water from third party suppliers, both of potable water and non-potable, quality. We have classified the non-potable third party supply as waste water by source under water consumption and have provided no source attribution for the third party potable water since third party, as defined by GRI is not provided as an option.

13. Please provide details about the company’s water intensity of products in regions with high or extremely high water stress.

Water intensity of products (cubic meter/$):

562

Unknown

Not applicable (Please provide additional information)

Optional comment

The appropriate industry standard for real estate is per square m of lettable space.

Overall Environment

21. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the environment principles, including any challenges faced and actions taken towards prevention and/or remediation.

Climate change is a global challenge. GPT recognises that changes to the environment influence the operation of our business and our assets, and we are committed to identifying and managing climate change risks across our business. Environmental sustainability and climate is therefore recognised as a key risk category for GPT. Environmental sustainability is integrated into the management of the GPT portfolio operations and development projects. Working with site teams and other key stakeholders, performance is reviewed and targets set to improve GPT’s environmental sustainability performance each year. GPT's Sustainability Policy supports the development and adoption of practices and actions in relation to: - Resource use and waste minimisation - Biodiversity - Water management - Climate change - Energy and emissions - Community engagement and development. GPT’s ISO14001 certifiable Environmental Management System is a key pillar in implementing our Sustainability Policy. During 2021, the Group reduced its emissions intensity by 82 per cent and energy intensity by 55 per cent respectively against our 2005 baseline. We maintained the Climate Active Certification of the GWOF portfolio, and continued to make progress on our Carbon Neutral 2024 target with a further two office assets certified during 2021. Four assets commenced operating on a carbon neutral basis during the year, including our first two retail assets. We also reduced our water intensity by 64 per cent against our 2005 baseline, and increased our closed loop waste recovery to 34.4 per cent in 2021. GPT also contributes to technical working groups and sharing through industry networks, for example through the Property Council of Australia Sustainability Roundtable and the Better Buildings Partnership. Detailed goals and outcomes are further outlined in GPT's 2021 Sustainability Report (https://www.gpt.com.au/sites/default/files/inline-files/GPT%20Sustainability%20Report%202021_0.pdf) and GPT's 2021 Climate Disclosure Statement (https://www.gpt.com.au/sites/default/files/2022-02/GPT%202021%20Climate%20Disclosure%20Statement.pdf).

Anti-corruption

Commitment

1. Does the company have an anti-corruption compliance programme?

No, it is not an immediate business priority

No, but we plan to in the next two years

Yes

November 2020

2. Does your company have policies and recommendations for employees on how to act in case of doubt and/or in situations that may represent a conflict of interest, e.g. with regard to gifts and hospitality, donations, sponsorship, or interactions with public officials?

No, and we have no plans to develop a policy

No, but we plan to in the next two years

Yes, included within a broader policy

Yes, articulated as a stand-alone policy

Optional comment

Refer to the following policies, publicly available on GPT's website: - Anti-bribery, fraud and corruption prevention policy: https://www.gpt.com.au/sites/default/files/inline-files/GPT%20Anti-Bribery%2C%20Fraud%20and%20Corruption%20Prevention%20Policy.pdf - Code of Conduct Policy: https://www.gpt.com.au/sites/default/files/inline-files/Code%20of%20Conduct%20November%202021.pdf - Supplier Code of Conduct: https://www.gpt.com.au/sites/default/files/inline-files/Supplier%20Code%20of%20Conduct_0.pdf - Personal Dealing Policy: https://www.gpt.com.au/sites/default/files/inline-files/Personal%20Dealing%20Policy_2.pdf

Prevention

3. Who receives training on anti-corruption and integrity?

3.1. How often is such training provided?

	One time only	Every year	Every two or more years	We do not collect this data
All employees
Select employees
Contractors
Direct suppliers of the organization
Other – such as partners, clients, etc.
Indirect suppliers of the organization

4. Does the company monitor its anti-corruption compliance programme?

No, we do not monitor the anti-corruption compliance programme

Review issues on ad-hoc basis

Yes, through internal employee self-evaluations

Yes, through automated controls monitoring

Yes, through external independent monitoring

Yes, through other mechanisms

Response and Reporting

5. Please report the company's total number and nature of incidents of corruption during the reporting year.

	Number of incident(s)	Unknown	Choose to not disclose
Confirmed during the current year, but related to previous years	0
GPT's takes seriously its responsibility to uphold high ethical standards in its business operations and supply chain, and during the reporting period there were no known instances of corruption or bribery by GPT employees. During the reporting period there was one breach of the Code of Conduct amounting to misconduct, which was non-disclosure of a personal relationship that was perceived as a conflict of interest. A full investigation substantiated the breach and disciplinary action was initiated. There was no link to corrupt activity of bribery in this instance. This is also outlined in GPT's 2021 Sustainability Report, page 58 and page 65: https://www.gpt.com.au/sites/default/files/inline-files/GPT%20Sustainability%20Report%202021_0.pdf
Confirmed during the current year, and related to this year	0
GPT's takes seriously its responsibility to uphold high ethical standards in its business operations and supply chain, and during the reporting period there were no known instances of corruption or bribery by GPT employees. During the reporting period there was one breach of the Code of Conduct amounting to misconduct, which was non-disclosure of a personal relationship that was perceived as a conflict of interest. A full investigation substantiated the breach and disciplinary action was initiated. There was no link to corrupt activity of bribery in this instance. This is also outlined in GPT's 2021 Sustainability Report, page 58 and page 65: https://www.gpt.com.au/sites/default/files/inline-files/GPT%20Sustainability%20Report%202021_0.pdf

6. Within the reporting period, what measures has the company taken to address suspected incidents of corruption independently or in response to a dispute or investigation by a government regulator?

Initial case assessment

Internal investigation

Review by risk / ethics committee

Review by board of directors

External audit / review

Other (please provide additional information)

Not applicable/no incidents in the reporting period

7. Does your company engage in Collective Action against corruption?

No, it is not an immediate business priority

No, but we plan to in the next two years

Yes (please explain)

8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the anti-corruption principle, including any challenges faced and actions taken towards prevention and/or remediation.

GPT is committed to creating and maintaining a culture of corporate compliance and ethical behaviour in which employees are responsible and accountable, behave with honesty and integrity and are able to raise concerns regarding unethical, unlawful or undesirable conduct, without fear of reprisal. Fraud and/or corruption in all forms, including bribery, are behaviours that are contrary to GPT’s values and culture. GPT is actively committed to preventing fraud and corrupt conduct throughout the organisation. We expect all of our people to do the right thing and comply with applicable laws, codes and policies. GPT has zero tolerance for and strictly prohibits bribery, corruption and fraudulent or dishonest conduct. GPT's policies and corporate governance support and underpin our commitment to work against all forms of corruption, including extortion and bribery. GPT expects its suppliers to achieve and maintain the standards as set out in the Supplier Policy and to train their employees and contracted parties on their consequential rights and responsibilities. GPT enacts policies relating to its suppliers through the Supplier Management Framework, and monitors supplier compliance through a range of activities including regular meetings and audits. GPT's risk appetite metrics include measures relating to People and Culture, and Compliance and Regulation; and GPT's risk culture scorecard includes monitoring breaches of workplace behaviour policies. During the reporting period, there were no known instances of corruption or bribery by GPT employees. During the reporting period there was one breach of the Code of Conduct amounting to misconduct, which was non-disclosure of a personal relationship which was perceived as a conflict of interest. A full investigation substantiated the breach and disciplinary action was initiated. In line with GPT’s Anti-bribery, Fraud and Corruption Prevention Policy and GPT’s Code of Conduct which prohibit political donations, no political donations were made by GPT during the reporting period. All charitable contributions made during the reporting period were to Australian Registered Charities. During the reporting period, GPT employees completed mandatory compliance training, see Appendix B of GPT's 2021 Sustainability Report (https://www.gpt.com.au/sites/default/files/inline-files/GPT%20Sustainability%20Report%202021_0.pdf).