Scope 1 Emissions
2022 Communication on Progress
Marshalls plc
Published date
July 29, 2022
No. of questions
72
Supplemental files
CEO Statement
Signed
Governance
Policies and Responsibilities
1. Does the Board / highest governance body or most senior executive of the company:
Optional commentOur Corporate Responsibility Policy sets out our approach as a company and our commitment to the UNGC and SDGs. This is coupled with our Human Rights Policy, Health & Safety Policy, Environmental Policy and our Energy & Climate Change Policy to address impacts on both people and the environment. Our Anti-Bribery Code sets out our stance on anti-corruption. All these policies are reviewed by the Board and are available publicly on our website. Sustainability targets are signed off by the Board or the Executive Team - for example, our approved science-based targets were approved by the Board. Our ESG reporting is conducted by the ESG Team, reporting in to the Chief People & ESG Officer who reports to the CEO. The Executive Team review risks as part of our Risk Register process - more information on this can be found in our Annual Report 2021, which is available on our website.2. Does the company have a publicly stated commitment regarding the following sustainability topics?
Optional commentOur Code of Conduct, Corporate Responsibility Policy, Human Rights Policy, Children's Rights Policy, Diversity & Inclusion Policy, Environmental Policy, and Anti-Bribery Code are all publicly available on our website.3. Does the company have in place a code of conduct regarding each of the following sustainability topics?
Optional commentOur Code of Conduct has been developed for all stakeholders, particularly employees and suppliers. The 54-page document sets out our expectations and covers a range of topics including Health and safety (p16), Procurement (p18), Anti-bribery and corruption (p28), Fraud, deception and dishonesty (p30), Data protection and GDPR (p36), Protecting and respecting human rights (p38), Taking action against modern slavery (p40), Harassment, bullying and discrimination (p42), Diversity, inclusion and social mobility (p46), Protecting the environment (p48) and Raising a concern (p52). Our Code of Conduct is available on our website.4. Has the company appointed an individual or group responsible for each of the following sustainability topics?
Optional commentOur ESG Committee is made up of 17 senior members of staff, who look at broad ESG topics such as materiality and reporting. The ESG Committee process is currently under review though it was fully operational in the reporting year (2021). Our ESG & Human Rights Director leads the ESG Team and our work on human rights and modern slavery. She reports in to the Chief People & ESG Officer who reports to the CEO. Our work on labour rights/decent work is led by our ESG & Human Rights Director and our Talent Director. Our General Counsel & Company Secretary leads on our work on anti-corruption, reporting to the CEO and the Board. Our environment work is led by our Sustainability Improvement Director and Group SHE Director, both of whom report to our Chief Operating Officer.5. Does the company have a formal structure(s) (such as a cross-functional committee) to address each of the following sustainability topics?
Optional commentOur ESG Committee is made up of 17 senior members of staff from different parts of the business including ESG, environment, legal, procurement, logistics and marketing. The group meets quarterly and is led by the ESG Strategy Director. In the reporting year, the ESG Committee discussed a variety of different topics including our materiality assessment and materiality matrix. The ESG Committee process is currently under review though it was fully operational in the reporting year.Prevention
6. Does the company have a process or processes to assess risk?
Optional commentWe have a process to assess risk as outlined in our Annual Report 2021: "The Board establishes the culture of effective risk management and is responsible for maintaining appropriate systems and controls. The Board sets the risk appetite and determines the policies and procedures that are put in place to mitigate exposure to risks. The Board plays a central role in the Group’s risk review process, which covers emerging risks and incorporates scenario planning and detailed stress testing." "There is a formal ongoing process to identify, assess and analyse risks, and those of a potentially significant nature are included in the Group Risk Register. The Group Risk Register is updated by the full Executive Management team at least every six months and the overall process is the subject of regular review by the Board. Risks are recorded with a full analysis, and risk owners are nominated who have authority and responsibility for assessing and managing the risk." We assess environmental risk of all our operations and we have conducted climate analysis on all sites in order to look at climate change risk - see our Climate Action Report 2021 which is available on our website. More information on how we assess risk in the supply chain is detailed in our Modern Slavery Risk Analysis 2021 report - this includes human rights, labour and corruption risks - which is available on our website.6.1. During the assessment of risk, which business relationships are reviewed?
Optional commentThe assessment of risk process is outlined in our Annual Report 2021 (pages 34-43). This is conducted at corporate level and includes all stakeholder relationships.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?
Optional commentOur Risk Heatmap looks at 12 principal risks: 1 Macro-economic and political, 2 Cyber risks, 3 Security of raw material supply, 4 Long-term impacts of climate change, 5 Human rights consideration, 6 Short-term impacts of weather events, 7 Threat from new technologies and business models/increased pace of digital change, 8 Corporate, legal and regulatory, 9 Competitor activity, 10 Project delivery of major strategic business projects and change management, 11 Health and safety and 12 People risk - see Annual Report 2021 (pages 34-43). Our human rights due diligence approach is thorough and incorporates rigorous analysis via Verisk Maplecroft, enhanced supply chain mapping using the Traffik Analysis Hub platform, and our own country risk analysis using the best available global data. This information is supplemented with knowledge gained from our extensive networks and partners in the UK and overseas. Our risk analysis process has enabled us to identify salient risks. During the reporting year, we introduced a human rights due diligence ‘filter’ within our procurement process based on the Slavery & Trafficking Risk Template (STRT). This has allowed us to further understand and manage our risks. We also utilise the full STRT within our audit process, and in tender processes. A revised and enhanced ten-stage ethical audit process has been put in place and our Business & Human Rights team has been strengthened with the addition of a Business & Human Rights Manager in 2022. We have committed to further human rights programmes in both India and Vietnam to continue our human rights due diligence work and support suppliers. Further information can be found in our Modern Slavery Statement 2021, Modern Slavery Report 2021 and Modern Slavery Risk Analysis 2021 - all are available on our website.7.1. During the due diligence process, which business relationships are reviewed?
Optional commentMost suppliers are reviewed as part of our general due diligence processes - when engaging with us, we ask suppliers to provide information, certificates and other evidence with regards to topics such as legal compliance, insurance, human rights and modern slavery, corruption, health and safety. This is conducted via an online platform.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 commentSafecall is our our independent whistleblowing service which enables any of our people, contractors, suppliers and other stakeholders to raise their concerns.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 commentFrom our Code of Conduct: "We need our colleagues, suppliers, partners and stakeholders to work with us to ensure compliance with the Marshalls Code of Conduct and supporting policies at all times. Where something is in direct conflict with the Marshalls Code of Conduct, we encourage you to let us know." Our Serious Concerns Policy also details how individuals can access Safecall (via phone or website). Safecall is completely independent of Marshalls and allows such matters to be reported at any time, anonymously if preferred, to an experienced individual who may, where appropriate, offer guidance, advice and support. Details on how to contact Safecall are also displayed in our offices and sites. Our Serious Concerns Policy sets out that there will be no reprisals for a concern raised.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?
Optional commentIn the UK, we have a Case and Advice Team as well as a Legal TeamLessons
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?
Optional commentClimate change and health and safety are linked to Annual Incentive Award and Long-term Incentive Plan - see page 33 of our Annual Report 2021Board Composition
12. Percentage of individuals within the company’s Board / highest governance body by:
Optional commentAll statistics are based on 2021. Board ethnic diversity: 86% white, 14% mixed Asian and white - taken from our Annual Report 202113. Do you produce sustainability reporting according to:
Optional commentWe report our sustainability progress as part of the UNGC's Communication on Progress in our Sustainability Report 2021 (available on our website). In the reporting year, we produced a GRI referenced report for the first time. Our materiality matrix which is featured in our Sustainability Report and our Annual Report is based on a variety of factors including the SASB standards for Construction. In the reporting year, we reported on climate-related performance, strategy, risks and opportunities, metrics and targets according to TCFD recommendations (in our Annual Report 2021 and Climate Action Report 2021).Data 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?
Optional commentThis only allows 5 issues to be ticked however the issues that are salient to Marshalls are: freedom of association and the effective recognition of the right to collective bargaining, child labour, forced labour, non-discrimination in respect of employment and occupation, occupational health and safety, working conditions, and rights of women and girls.Commitment
2. Does the company have a policy commitment in relation to the following human rights issues?
Optional commentOur Children's Rights Policy and our WEPS (Women's Empowerment Principles) commitment can both be found on our website.2.1. For each human rights policy, is it:
Optional commentAll our policies can be found on our website.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 commentDue to the collaborative nature of the work we are doing, we continue to work with UN agencies on all salient issues in preventing/mitigating of the risks/impacts in question.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?
Optional commentInternal training was provided via Code of Conduct training, Modern Slavery training, health, safety and environmental training on Marshalls Learning Zone and Toolbox Talks. More information on our due diligence process can be found in our Modern Slavery 2021 reports. We publish our Gender Pay Gap report as well as our Modern Slavery Statement (both available on our website). During the reporting year, we collected diversity data from our existing employees and new starters. Around 40% of our employee base voluntarily shared details about their gender identity, sexual orientation, ethnicity, religious beliefs, generation, caring responsibilities and disabilities. More information on our collaborations with NGOs, government and other bodies can be found in our Sustainability Report 2021.5. Who receives training for the following human rights issues?
Optional commentEmployee training is provided via our Code of Conduct training, Toolbox Talks, Marshalls Learning Zone and Modern Slavery training, and our Female Network Group.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.
More information can be found in our Modern Slavery Statement 2021, Modern Slavery Report 2021, Modern Slavery Risk Analysis 2021 and Sustainability Report 2021 - all are available on our website.Labour
Commitment
1. Does the company have a policy commitment in relation to the following labour rights principles?
Optional commentOur Human Rights Policy, Children's Rights Policy, Diversity and Inclusion Policy, and Health and Safety Policy can all be found on our website.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?
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?
8. In the course of the reporting period, what was the percentage of women in:
Optional commentTaken from Annual Report 2021, pages 70-71 (2 out of 4 non-executive directors) and page 109 (senior managers)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?
Optional comment10. In the course of the reporting period, how frequently were workers injured (injuries per hour worked)?
Optional commentThis has been calculated by the number of LTIs x 1,000,000/hours worked11. In the course of the reporting period, what was the company’s incident rate?
Optional commentThis has been calculated by all incidents x 1,000,000/hours workedResponse 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?
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.
More information can be found in our Modern Slavery Statement 2021, Modern Slavery Report 2021, Modern Slavery Risk Analysis 2021 and Sustainability Report 2021 - all are available on our website.Environment
Commitment
1. Does the company have a formal policy on the following environmental topics?
Optional commentAll environmental topics are covered by our Environmental Policy (Water, Biodiversity/Land Use, Air Pollution, Waste) and our Energy & Climate Change Policy (Climate Action, Energy & Resource Use).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?
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?
Optional commentClimate action - in the reporting year, we applied to the Science Based Targets initiative to review our science-based targets to 1.5ºC. This target was approved in July 2022. Water - in the reporting year, we started a water risk matrix based on site locations, looking at drought areas in the UK and prioritising working on the locations for water reduction by risk score. We are currently working with a project at two of our sites in the south of England. Forest/Biodiversity/Land use - in the reporting year, we identified land that was used for the planting of 2,800 trees in 2022. We have also identified land with third parties that can be used for development for potential solar arrays/wind farms. Waste - We have been liaising with customers to reduce packaging, which includes eliminating plastic where possible and working with the LOOP forum on re-using pallets. We have now started to review waste generated from packaging from suppliers and will be working with them on reducing packaging or ensuring packaging is made of recycled content so reducing potential waste to landfill. Energy and resource use - we have a plan to install solar arrays at manufacturing sites which would reduce our mains grid usage by circa 30%. We are also working with other businesses and councils to use solar power.4. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following environmental topics?
Optional commentThere are key metrics and goals that are measured and reported annually. We have signed up to science-based targets to 1.5ºC. The metric used is C0²/tonne of production. We have agreed to a target to reduce mains water usage and the metric used is m³/tonne of concrete. Waste has set a target of zero waste to landfill by 2030 which is measured in % of waste to landfill. For energy, the reduction is to less than 28 Kwh/tonne of concrete produced by 2030. Key risks are identified and they form part of the business risk register that is reviewed by the Executive Team twice a year.4.1. For each environmental topic in which the company sets timebound goals / targets, what kind of targets has the company set?
4.2. For each environmental topic in which the company sets timebound goals / targets, how is progress against target / goal tracked?
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)?
Climate Action
6. What were the company’s gross global greenhouse gas emissions for the reporting period?
Scope 2 Emissions
Scope 3 Emissions
Optional commentThis is partial and only represents business travel, which is a very small part of our Scope 3 emissions and does not provide the full picture. We don't currently publicly report our Scope 3 emissions. We will continue to work on Scope 3 disclosures with a view to external reporting in the future.7. What percentage of the company's revenue was invested in R&D of low-carbon products/services during this reporting period?
Optional commentThis is unknown as we do not split our R&D budget8. Has the organization acted to support climate change adaptation and resilience?
Optional commentOur mitigation and adaptation strategy focuses on our products and our processes. We continue to invest into research and development – and this includes sustainable product development. Where our mitigation strategy focuses on delivering our science-based targets for carbon emissions reduction and efficiency in our manufacturing processes, our adaptation strategy focuses on flood protection and urban heat island effect.Energy / Resource Use
9. Please report the company's renewable energy consumption as a percentage of total energy consumption in the reporting period.
Technology
10. What percent of the company's revenue came from environmentally friendly products / services during this reporting period?
Optional commentWe have a range of different products which offer a lower carbon alternative to other building materials.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):
13. Please provide details about the company’s water intensity of products in regions with high or extremely high water stress.
Optional commentWe do not currently calculate or report on this specifically but will look to do so in future reporting.Sector-specific: Forest, biodiversity, and land use
14. Please report the number and area (in hectares) of sites owned, leased, or managed by the company in or adjacent to protected areas and/or key biodiversity areas (KBA).
15. What area (in hectares) of natural ecosystems was converted during the reporting period in areas owned, leased, or managed by the company?
16. Is the company supporting or implementing project(s) focused on ecosystem restoration and protection?
Sector-specific: Waste
18. Please report the company's total weight of waste generated in metric tonnes during the reporting period.
19. Please report the percentage of the company's waste that was hazardous waste (i.e., hazardous waste ratio) during the reporting period.
Optional comment597 tonnes of hazardous waste in the reporting period.20. Please report the company's estimated metric tonnes of single-use plastic consumed wherever material along the value chain during the reporting period.
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.
More details on our activity can be found in our Sustainability Report 2021 - available on our websiteAnti-corruption
Commitment
1. Does the company have an anti-corruption compliance programme?
Optional commentOur core programme of compliance training is available on our Marshalls Learning Zone. The training modules comprehensively cover modern slavery, anti-bribery and corruption, and GDPR. In total, our colleagues engaged in 2,018 hours of compliance training and refresher training is planned for 2022. During the reporting year, we put in place Corporate Criminal Offence (CCO) training for all colleagues involved in financial transactions in order to raise awareness of tax fraud. This will be further developed in 2022.2. 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 commentOur Serious Concerns Policy outlines procedures for employees to report a concern via our independent whistleblowing hotline, Safecall. As part of our Anti Bribery Code, our Gifts and Hospitality Guidance is issued to help employees of Marshalls plc and/or its subsidiary companies, and also other people who are working on Marshalls’ behalf to comply with the principles of the Marshalls Anti-Bribery Code. It applies to gifts and hospitality given to or received by employees in their capacity as an employee, consultant or agent of Marshalls. This guidance can also be shared with suppliers, contractors and other business partners, to inform them of the standards that we apply.Prevention
3. Who receives training on anti-corruption and integrity?
Optional commentEmployees who deal with procurement (buying and selling) receive training every year. All employees have access to training via our Code of Conduct training and the Marshalls Learning Zone.3.1. How often is such training provided?
Optional commentContractors and suppliers are expected to sign up to mandatory policies (health and safety, modern slavery, anti-bribery etc).4. Does the company monitor its anti-corruption compliance programme?
Optional commentRefresher training is available for employees on the Marshalls Learning Zone. There is a time limit for completion and users are emailed reminders. Managers also support this as they receive completion reports for their areas.Response and Reporting
5. Please report the company's total number and nature of incidents of corruption during the reporting year.
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?
7. Does your company engage in Collective Action against corruption?
Optional commentThis is not an area of priority for Marshalls as we have our own controls in place, compliance training programme, and policies and procedures.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.
We have our own controls, compliance training programme, and policies and procedures. According to our Gifts and Hospitality guidance, our employees should keep a record of all offers of gifts and hospitality (a) that they have made, (b) that they have received, and (c) that they have declined, whether or not they are of Negligible Value in each case. Details of this record are returned on a quarterly basis for entry into the Marshalls Gifts and Hospitality Register. The reporting of gifts and/or hospitality that do not qualify as being of Negligible Value should be immediate and the report should be countersigned by the line manager or director who has given approval, with a short explanation of the grounds for approval.