Scope 1 Emissions
2022 Communication on Progress
The Star Entertainment Group
Published date
June 29, 2022
No. of questions
66
Supplemental files
Supplier_Code_of_Conduct.pdfCode of Conduct.pdf26-May-2021-Group-Diversity-Inclusion-Policy.pdfTSEG-2021-Sustainability-Report.pdfGroup_Diversity_Policy.pdfBeyond 2020 - The Star Entertainment Group's Sustainability Action Plan A4_20200502.pdfClimate-Related-Disclosures-2021.pdfEnvironmental_Management_Policy.pdfTSEG-2021-Sustainability-Report.pdfSustainable Design and Operational StandardsSustainable Destination Partnership (agreement with City of Sydney)Conflict_Of_Interest_Policy.pdfGifts_Policy.pdfCode of Conduct.pdfPolitical_Donations_Policy.pdfCommunity_and_Charitable_Partnerships_Policy.pdfCEO Statement
Governance
Policies and Responsibilities
1. Does the Board / highest governance body or most senior executive of the company:
Optional commentAnnual Statements relating to sustainability can be found here https://www.starentertainmentgroup.com.au/annual-reports/2. Does the company have a publicly stated commitment regarding the following sustainability topics?
Optional commentCode of Conduct, Supplier Code of Conduct, Diversity and Inclusion Policy and Modern Slavery Statement on our public website at https://www.starentertainmentgroup.com.au/corporate-governance and https://www.starentertainmentgroup.com.au/suppliers3. Does the company have in place a code of conduct regarding each of the following sustainability topics?
Optional commentCode of Conduct, Supplier Code of Conduct, Environmental Management Policy, Equal Opportunity and Employment Policy, Diversity and Inclusion Policy, Anti Corruption Policy4. Has the company appointed an individual or group responsible for each of the following sustainability topics?
Optional commentModern Slavery Working Group, PCSR (People&Performance, Social Responsibility) Board Sub-committee, Sustainability Advisory Board5. Does the company have a formal structure(s) (such as a cross-functional committee) to address each of the following sustainability topics?
Optional commentModern Slavery Working Group, PCSR (People&Performance, Social Responsibility) Board Sub-committee, Sustainability Advisory Committee, Ethics PanelPrevention
6. Does the company have a process or processes to assess risk?
Optional commentModern Slavery Working group and risk-based due diligence process, Employee Relations team and related processes, Sustainability team and related processes involving operations and supply chain, Ethics Panel and Investigations team and processes.6.1. During the assessment of risk, which business relationships are reviewed?
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?
7.1. During the due diligence process, which business relationships are reviewed?
Optional commentWe conduct a risk based due diligence process including a data analysis on 99% of our direct suppliers.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?
Optional commentWe have a Code of Conduct that is supported and re-enforced through training, which refers to our whistleblowing policy and mechanism and is supported by our Ethics Panel which meets at least quarterly. We also have a 'call it out' email address that is supported by an internal communications program to encourage team members to call out behaviors or attitudes that are contrary to our code of conduct and related policies.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.
Optional commentOur values include 'do the right thing' which is supported and re-enforced through internal communications with examples and a call to action to 'call it out' if team members have any concerns. Our supplier code of conduct is on our website and contains information regarding our whistleblowing policy and mechanism for reporting concerns. Whistleblowing is confidential and extends to family members of employees and suppliers.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?
Lessons
10. How does the company capture lessons regarding each of the following sustainability topics?
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:
Optional commentThis is as at April 202213. Do you produce sustainability reporting according to:
Optional commentThe Star produces an Annual Sustainability Report. As an Australian entity, the CSRD is not relevant. Our materiality assessment aligns with SASB. Other reporting includes annual Greenhouse and Energy Reporting Scheme. We report annually to the Workplace Gender Equality Agency and in 2022 were awarded the Employer of Choice for Gender Equality Citation. We report annually to the Australian Workplace Equality Index and in 2021 were awarded Silver for LGBTIQ+ inclusivityData Assurance
14. Is the information disclosed in this questionnaire assured by a third-party?
Human Rights
Materiality / Saliency
1. Which of the following has the company identified as material human rights issues connected with its operations and/or value chain, whether based on their salience (i.e., the most severe potential negative impacts on people) or another basis?
Commitment
2. Does the company have a policy commitment in relation to the following human rights issues?
Optional commentThis is referenced in the Diversity and Inclusion Policy2.1. For each human rights policy, is it:
Optional commentThe Supplier Code of Conduct is publicly available and contains expectations of suppliers relating to labour rights and diversity and inclusion. Our corporate website contains our commitments to diversity and including including a focus on gender equality.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?
Optional commentGender Equality issues are regularly addressed within the Diversity and Inclusion SteerCo and the Gender Equality Committed (Balance@TheStar). During the reporting period there was consultation with affected stakeholders in the development of the WGEA Employer of Choice for Gender Equality submission.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?
5. Who receives training for the following human rights issues?
6. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following human rights issues?
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)?
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.
The Star provides an updated gender equality to The Board annually and provides regular updates on targets and progress. We submitted, and was awarded the WGEA Employer of Choice for Gender Equality and launched mandatory training on inclusive leadership that includes information and scenarios related to gender equality and breaking biases. Through it's Gender Equality Committee, "Balance@TheStar", The Star ran an events and communications program to support International Women's Day that included a virtual panel talking about how to 'break the bias'. The Star is a founding member of the Women in Gaming and Hospitality Asia (WGHA) which supports women in the industry.Labour
Commitment
1. Does the company have a policy commitment in relation to the following labour rights principles?
Optional commentEqual opportunity and employment policy (2021). Supplier Code of Conduct (2020)1.1. For each labour rights policy, is it:
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?
Optional commentThe Star operates only in Australia and therefore within a strong legislative framework that prevents child labour. We maintain a strong and pro-active relationship with relevant workers unions.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?
4. Who receives training for the following labour rights issues?
5. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following labour rights issues?
Performance
6. What is the percentage of employees covered under collective bargaining agreements?
7. What is the percentage of employees in a trade union or other workers' organization?
Optional commentWhile this is unkown as participation is directly with the unions, we would assume around 35%8. In the course of the reporting period, what was the percentage of women in:
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?
10. In the course of the reporting period, how frequently were workers injured (injuries per hour worked)?
11. In the course of the reporting period, what was the company’s incident rate?
Optional commentNB: this is based on the Total number of lost days expressed in terms of number of hours / total number of hours worked by workers in the reporting period. The rate is 0.001423 or 1.4 hours lost for each 1000 hours worked. The reporting period is 12 months from 1-4-21 to 31-3-22.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?
Optional commentIn the instance where the answer is no, The Star is not aware of any matters that would require remediation.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.
During the reporting period, The Star Entertainment Group: - Finalised Sydney and Brisbane Enterprise Agreements in line with good faith bargaining principles. - Renegotiated a national approach to the working relationship between The Star and the United Workers Union. - - - Became members of the Cleaning Accountability Framework (CAF). - Created and submitted the Modern Slavery Statement 2021. - Introduced "Star Offer Support (SOS) where team members could apply for grants to support them through Covid. This was implemented with consultation with the Unions. - In addition to Team member consultative committees, as part of the EA consultation, additional working groups have been introduced to focus on additional areas of interest to team members.Environment
Commitment
1. Does the company have a formal policy on the following environmental topics?
1.1. For each environmental policy, is it:
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?
Optional commentThe Star builds and operates on its own land in compliance with local planning requirements. The Star seeks to engage with stakeholders in the communities in which it operates in3. 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?
Optional commentThe Star works with a number of industry groups and local councils to support their sustainability goals. An example is working with Australian green building industry where The Star's requires that all new buildings must achieve a 5 Star Green Star Rating (equivalent to Australian best practice design) from the Green Building Council of Australia.4. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following environmental topics?
Optional commentThe Star has a commitment to conduct energy and water audits every two years. The Star has a commitments to align with the TCFD framework and conduct physical climate risk audits every two years.The Star has an ongoing program to audit waste streams and has Operational Environmental Management Plans in place at its assets.4.1. For each environmental topic in which the company sets timebound goals / targets, what kind of targets has the company set?
Optional commentFurther targets and actions around resource use and material issues can be found in the company's Beyond 2020 Sustainability Action Plan and within the Group's 2021 Sustainability Report4.2. For each environmental topic in which the company sets timebound goals / targets, how is progress against target / goal tracked?
Optional commentRefer to attachments provided above. Quarterly resource performance scorecards are prepared by an independent third party based on invoiced consumption data. All resource use is reported annually in the Sustainability Report and received Limited Assurance5. 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)?
Optional commentImpacts outside of The Star's business are not known. The Star builds and operates on its own land. The Star has Operational Environmental Management Plans in place at each of its assets.Climate Action
6. What were the company’s gross global greenhouse gas emissions for the reporting period?
Scope 2 Emissions
Scope 3 Emissions
Optional commentScope 3 emissions were quantified based on financial ledger. The Star is conducting a further Scope 3 materiality review to include sources both operational and financial in FY227. What percentage of the company's revenue was invested in R&D of low-carbon products/services during this reporting period?
Optional commentThe Star is moving to prefer more carbon neutral suppliers in its supply chain however has not engaged in direct R&D8. Has the organization acted to support climate change adaptation and resilience?
Optional commentCase studies on climate resilience can be found within the company's Climate-related Disclosure ReportsEnergy / Resource Use
9. Please report the company's renewable energy consumption as a percentage of total energy consumption in the reporting period.
Optional commentThe company has a target to achieve 85%-100% renewable energy by 2030, if not beforeTechnology
10. What percent of the company's revenue came from environmentally friendly products / services during this reporting period?
Sector-specific Questions
11. Which sector(s) does the company operate in? If diversified, choose top 3 by revenue.
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):
Water consumption (volume of water in megaliters):
Optional commentThe Star's potable water consumption for the reporting period is provided in the 2021 Sustainability Report and receives Limited Assurance13. Please provide details about the company’s water intensity of products in regions with high or extremely high water stress.
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.
The Star has a sustainability strategy called Our Bright Future. All targets, actions and objectives can be found in the Group's Beyond 2020 Sustainability Management Plan. The Star conducts an annual materiality assessment which forms the basis of reporting in its Sustainability Report. The Star is committed to managing its carbon emissions in line with its net zero 2030 target and reducing the expected impacts of climate change which includes implementing mitigation and adaptation actions which can be found in the company's annual Climate-related Disclosure Reports on the company website.Anti-corruption
Commitment
1. Does the company have an anti-corruption compliance programme?
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?
Optional commentWe have several policies that cover conflict of interest, attached: Gifts Policy, Code of Conduct, Political Donations Policy, Conflict of Interest Policy, Community Giving and Partnerships PolicyPrevention
3. Who receives training on anti-corruption and integrity?
Optional commentWe have mandatory Code of Conduct training, and 'Do the Right Thing" training that is required of all employees and contractors, every two years.3.1. How often is such training provided?
Optional commentThis training is virtual. We also have elements of this training in our induction (welcome day) for all employees, and re-enforced through internal communications of 'do the right thing'4. Does the company monitor its anti-corruption compliance programme?
Response and Reporting
5. Please report the company's total number and nature of incidents of corruption during the reporting year.
Optional commentIncidence of corruption as defined by the Anti Corruption policy6. 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?
Optional commentThere is currently an independent review underway.7. Does your company engage in Collective Action against corruption?
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.
The Ethics panel meets monthly to oversee the Code of Conduct at a Group Level. The use of probity advisors in the case of high risk or high-value procurement.