Scope 1 Emissions
2022 Communication on Progress
APA Group
Published date
June 29, 2022
No. of questions
64
Supplemental files
CEO Statement
Governance
Policies and Responsibilities
1. Does the Board / highest governance body or most senior executive of the company:
Optional commentFurther information at: https://www.apa.com.au/ APA Sustainability Report 2021 APA Corporate Governance Statement 2021 APA Annual Report 2021 APA Modern Slavery Statement 2021 APA Antibribery and Corruption Policy APA Code of Conduct2. Does the company have a publicly stated commitment regarding the following sustainability topics?
Optional commentFurther information at: https://www.apa.com.au/ APA Code of Conduct APA Sustainability Report 2021 APA Annual Report 2021 APA Modern Slavery Statement 2021 APA Risk Management Policy APA Anti-Bribery and Corruption Policy APA Environment & Heritage Policy APA Health, Safety & Wellbeing Policy APA Whistleblower Policy3. Does the company have in place a code of conduct regarding each of the following sustainability topics?
Optional commentFurther information at: https://www.apa.com.au/ APA Sustainability Report 2021 APA Annual Report 2021 APA Modern Slavery Statement 2021 APA Risk Management Policy APA Anti-Bribery and Corruption Policy APA Environment & Heritage Policy APA Health, Safety & Wellbeing Policy APA Whistleblower Policy4. Has the company appointed an individual or group responsible for each of the following sustainability topics?
Optional commentFurther information at: APA Sustainability Report 2021 APA Corporate Governance Statement 2021 APA Modern Slavery Statement 2021 APA Code of Conduct5. Does the company have a formal structure(s) (such as a cross-functional committee) to address each of the following sustainability topics?
Optional commentFurther information at: https://www.apa.com.au/ APA Sustainability Report 2021 APA Corporate Governance Statement 2021 APA Modern Slavery Statement 2021Prevention
6. Does the company have a process or processes to assess risk?
Optional commentFurther information at: https://www.apa.com.au/ APA Risk Management Policy APA Modern Slavery Statement 20216.1. During the assessment of risk, which business relationships are reviewed?
Optional commentFurther information at: https://www.apa.com.au/ APA Code of Conduct APA Anti-Bribery and Corruption Policy APA Risk Management Policy APA Sustainability Report 2021 APA Corporate Governance Statement 2021 APA Annual Report 2021 APA Modern Slavery Statement 20217. 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 commentFurther information at: https://www.apa.com.au/ APA Code of Conduct APA Anti-Bribery and Corruption Policy APA Risk Management Policy APA Sustainability Report 2021 APA Corporate Governance Statement 2021 APA Annual Report 2021 APA Modern Slavery Statement 20217.1. During the due diligence process, which business relationships are reviewed?
Optional commentFurther information at: https://www.apa.com.au/ APA Code of Conduct APA Anti-Bribery and Corruption Policy APA Risk Management Policy APA Sustainability Report 2021 APA Corporate Governance Statement 2021 APA Annual Report 2021 APA Modern Slavery Statement 2021Concerns 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 commentFurther information at: https://www.apa.com.au/ APA Whistleblower Policy APA Sustainability Report 20218.1. 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.
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 commentAccess enabled through APA's Whistleblower policy. Further information at: https://www.apa.com.au/ APA Sustainability Report 2021 APA Corporate Governance Statement 2021 APA Whistleblower Policy APA Anti-Bribery and Corruption Policy APA Environment & Heritage Policy APA Health, Safety & Wellbeing Policy https://www.apa.com.au/globalassets/about-apa/our-projects/western-outer-ring-mainproject/ western-outer-ring-main-project-consultation-plan.pdfLessons
10. How does the company capture lessons regarding each of the following sustainability topics?
Optional commentFurther information at: https://www.apa.com.au/ APA Sustainability Report 2021 APA Annual Report 2021 APA Whistleblower Policy APA Corporate Governance Statement 2021 APA Anti-Bribery and Corruption Policy APA Environment & Heritage Policy APA Health, Safety & Wellbeing Policy https://www.apa.com.au/globalassets/about-apa/our-projects/western-outer-ring-mainproject/ western-outer-ring-main-project-consultation-plan.pdfExecutive Pay
11. Is executive pay linked to performance on one or more of the following sustainability topics?
Optional commentFurther information at: https://www.apa.com.au/ APA Annual Report 2021Board Composition
12. Percentage of individuals within the company’s Board / highest governance body by:
Optional commentFurther information at: https://www.apa.com.au/ APA Sustainability Report 2021 APA Corporate Governance Statement 202113. Do you produce sustainability reporting according to:
Optional commentFurther information at: https://www.apa.com.au/ APA Sustainability Report 2021 APA Sustainability Report FY21 Framework IndexData 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 commentFurther information at: https://www.apa.com.au/ APA Sustainability Report 2021Response
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.
At APA we respect all internationally recognised human rights as set out in the Universal Declaration of Human Rights and the International Labour Organisation’s Declaration on Fundamental Principles and Rights at Work. We continue to consider how best to implement the United Nations Guiding Principles on Business and Human Rights (UNGPs). We take steps to ensure that the goods and services we source are procured ethically and responsibly, without harm or exploitation to people of the environment, and require our suppliers and contractors to do likewise and we will not use suppliers that we know supply unsafe or use exploitative or unlawful practices (including modern slavery or violation of human rights standards) to produce their goods or services. Our due diligence processes assess and respond to modern slavery risks. During FY2021, a working group, consisting of Procurement and Accounts Payable, established a new form that was updated to include a human rights declaration for all new suppliers. For all procurement-managed spend >$200k a precedent agreement is considered which requires a decision on whether further due diligence is required based on factors such as the goods or services, country of origin and supplier. Towards the end of FY2021 the Procurement Group rolled out the use of a new supplier on boarding procedure which included a questionnaire that is mandatory for all new suppliers to complete irrespective of size, spend and category of risk. The new form calls for suppliers to declare that they will respect their workers’ fundamental human rights. We will track the number of suppliers that provide the declaration and work with the suppliers who indicate difficulties in providing the declaration. To date the new form has been well received by our suppliers and we are yet to receive any negative feedback or reluctance to commit.Labour
Commitment
1. Does the company have a policy commitment in relation to the following labour rights principles?
Optional commentFurther information at: https://www.apa.com.au/ APA Code of Conduct APA Diversity and Inclusion Policy APA Health, Safety and Wellbeing Policy APA Modern Slavery Statement 2021 APA Sustainability Report 20211.1. For each labour rights policy, is it:
Optional commentFurther information at: https://www.apa.com.au/ APA Modern Slavery Statement 2021 APA Code of Conduct APA Diversity and Inclusion Policy APA Health, Safety and Wellbeing Policy APA Sustainability Report 2021Prevention
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 commentFurther information at: https://www.apa.com.au/ APA Modern Slavery Statement 20213. 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?
Optional commentFurther information at: https://www.apa.com.au/ APA Diversity and Inclusion Policy APA Health, Safety and Wellbeing Policy APA Modern Slavery Statement 2021 APA Sustainability Report 20215. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following labour rights issues?
Optional commentFurther information at: https://www.apa.com.au/ APA Modern Slavery Statement 2021 APA Sustainability Report 2021Performance
6. What is the percentage of employees covered under collective bargaining agreements?
Optional commentFurther information at: https://www.apa.com.au/ APA Sustainability Report 2021 - FY21 figure reported.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 commentFurther information at: https://www.apa.com.au/ APA Sustainability Report 2021 - FY21 figure reported.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)?
Optional commentFurther information at: https://www.apa.com.au/ APA 1H22 Interim Financial Results - 1H22 figure reported11. In the course of the reporting period, what was the company’s incident rate?
Optional commentFurther information at: https://www.apa.com.au/ APA 1H22 Interim Financial Results - 1H22 figure reportedResponse 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.
At APA we respect all internationally recognised human rights as set out in the Universal Declaration of Human Rights and the International Labour Organisation’s Declaration on Fundamental Principles and Rights at Work. Our employees and contingent workforce operate mostly in mainland Australia and the majority of our employees are employed on a direct and permanent basis. The risks of modern slavery such as child labour, forced labour, or other modern slavery practices occurring in our operations is low, having regard to our compliance with all applicable legislative requirements in Australia regulating workplace relations and our internal policies and processes in place to mitigate risks. These include: ― Our Health, Safety and Wellbeing policy and practices, which commits to providing workplaces that support good health, wellbeing, respect and inclusion for our employees, contractors and visitors ― Our recruitment and on-boarding processes including undertaking visa and health checks ― Our ongoing commitment to build a diverse and inclusive culture so all of our people, feel safe, valued and trusted to do their best every day ― Providing benefit entitlements in excess of statutory requirements and encouraging employees to enjoy the right to family, recreation, and work-life balance through flexibility initiatives ― Providing regular and ongoing training, including modern slavery awareness training, to our employees in their obligations regarding lawful, appropriate behaviour, discrimination and complaints and investigation processes. Our employees are free to associate and enter into employment agreements that meet the requirements of the National Employment Standards (NES), including requests for flexible working arrangements, parental leave and long service leave. APA uses a documented risk management approach to fulfil the principles of and our obligations under the Commonwealth Modern Slavery Act 2018 (MSA). APA will not intentionally use suppliers and contractors that engage in modern slavery practices, such as child labour, debt bondage, inhumane treatment of employees and forced or compulsory labour. In December 2020, APA submitted our first Modern Slavery Statement to the Australian Border Force for publication ahead of the reporting timetable of March 2021. APA’s focus for FY2021 was on Tier 1 suppliers in our supply chain – those with whom APA has a direct contractual agreement – who are largely based in Australia. By mapping line item spend information to international product codes, potential very high and high-risk suppliers were identified in Central Africa, India and Malaysia, across our product and service categories and other supplier industries. APA is now in the process of subjecting these high-risk suppliers to more detailed reviews to assess and appropriately manage the risk of modern slavery. Supplier onboarding procedures are also being updated to better capture potential modern slavery risk and continuing to review and monitor all our existing suppliers. Finally, a new modern slavery awareness training module was rolled out, which is mandatory for all procurement staff. In future years, our focus will expand to Tier 2 suppliers.Environment
Commitment
1. Does the company have a formal policy on the following environmental topics?
Optional commentFurther information at: https://www.apa.com.au/ APA Climate Change Policy APA Environment and Heritage Policy1.1. For each environmental policy, is it:
Optional commentFurther information at: https://www.apa.com.au/ APA Environment and Heritage Policy APA Climate Change Policy APA Sustainability Report 2021Prevention
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 commentFurther information at: https://www.apa.com.au/ APA Climate Change Resilience Report 2020 APA NGI Cultural Heritage Management Plan APA NGI Pipeline EPA Environmental Referral APA ECGX Construction Environmental Management Plan APA ECGX Aboriginal Cultural Heritage Management Plan APA ECGX Soil & Water Management Plan APA ECGX Erosion & Sediment Control Plan APA Western Slopes Pipeline environmental assessment update APA Climate Change Resilience Report 20203. 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 commentFurther information at: https://www.apa.com.au/ APA Climate Change Resilience Report 2020 APA NGI Cultural Heritage Management Plan APA NGI Pipeline EPA Environmental Referral APA ECGX Construction Environmental Management Plan APA ECGX Aboriginal Cultural Heritage Management Plan APA ECGX Soil & Water Management Plan APA ECGX Erosion & Sediment Control Plan APA Western Slopes Pipeline environmental assessment update APA Climate Change Resilience Report 2020 APA Environment and Heritage Policy APA Sustainability Report 20214. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following environmental topics?
Optional commentFurther information at: https://www.apa.com.au/ APA Sustainability Report 2021 APA Climate Change Resilience Report 20205. 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 commentNot disclosedClimate Action
6. What were the company’s gross global greenhouse gas emissions for the reporting period?
Scope 2 Emissions
Scope 3 Emissions
Optional commentFurther information at: https://www.apa.com.au/ APA 1H22 Interim Financial Results - FY21 figure reported7. What percentage of the company's revenue was invested in R&D of low-carbon products/services during this reporting period?
8. Has the organization acted to support climate change adaptation and resilience?
Optional commentFurther information at: https://www.apa.com.au/ APA Sustainability Report 2021 APA Climate Change Resilience Report 2020Energy / 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?
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.
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: Air pollution
17. Where applicable, please report the company's emissions of the following pollutants during the reporting period.
Optional commentFurther information at: https://www.apa.com.au/ APA Sustainability Report 2021 - Sustainability Data Tables, Air Emissions FY20 figure reportedSector-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.
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.
To help protect the environment and preserve cultural heritage, APA continually works to keep our environmental governance and systems up to date. In FY2021, APA developed and published a new Environment & Heritage Policy, recognising Environment & Heritage as a separate management area distinct from the Health and Safety components under our previous Health Safety Environment (HSE) Policy. The new policy is underpinned by APA’s existing Environment Framework, which includes procedures and state-based guidelines for all assets and activities under APA’s operational control. The Environment Framework is being brought to life with awareness programs and Environment Management Plans for each asset. During FY2021, APA developed and rolled out seven new Environment Standards to help us take a consistent approach to environmental protection. This is a core initiative within the Environment & Heritage Pillar of the three-year Health, Safety, Environment and Heritage (HSEH) Strategy. The Standards set minimum mandatory requirements for each environmental area in the Framework, raising the standard of environmental management practices across the business. In FY2021, APA completed our four-year Environment Management Plan (EMP) Improvement Program (FY2018-FY2021) having refreshed 32 EMPs for individual assets across our networks, transmission and power divisions. As well as creating site-specific plans, the Program has streamlined and standardised our local management structures for environment risk at APA by: ― Improving asset-specific environmental risk management ― Creating greater awareness of environmental risks, associated responsibilities and control measures ― Refining environment risk assessment processes and templates ― Standardising EMP templates for our Networks and Transmission/Power divisions to drive consistency ― Conducting an environment risk assessment workshop with operations and environment personnel for each EMP.Anti-corruption
Commitment
1. Does the company have an anti-corruption compliance programme?
Optional commentFurther information at: https://www.apa.com.au/ APA Anti-Bribery and Corruption Policy APA Sustainability Report 2021 APA Code of Conduct2. 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 commentFurther information at: https://www.apa.com.au/ APA Anti-Bribery and Corruption Policy APA Sustainability Report 2021 APA Code of ConductPrevention
3. Who receives training on anti-corruption and integrity?
Optional commentFurther information at: https://www.apa.com.au/3.1. How often is such training provided?
4. Does the company monitor its anti-corruption compliance programme?
Optional commentFurther information at: https://www.apa.com.au/ APA Anti-Bribery and Corruption PolicyResponse and Reporting
5. Please report the company's total number and nature of incidents of corruption during the reporting year.
Optional commentAPA Sustainability Report 20216. 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?
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.
APA’s (Our) Anti-Bribery and Corruption Policy strictly prohibits bribery and corruption in any form. The Policy mandates our anti-bribery and corruption program and covers approvals for gifts, sponsorships, donations and entertainment, record keeping, third-party due diligence, and monitoring and reporting. APA maintains a Whistleblower Line via an externally managed disclosure service as an independent, impartial and confidential means of reporting potential incidents. Through the Whistleblower Line and our internal reporting channels, we record material breaches of our Code of Conduct and potential or actual fraud, bribery and corruption. During the year (FY2021) management continued to raise awareness of the whistleblower process via various communication approaches however there were low levels of reporting to the independent APA Whistleblower hotline. In response, additional communication approaches will be completed as part of APA’s culture program of work for FY2022. In the reporting period (FY2021), APA recorded zero incidents of fraud, bribery or corruption and received no fines for noncompliance with any laws or regulations related to bribery or corruption. APA recorded seven material breaches of our Code of Conduct. The breaches related to unacceptable behaviour, breach of key policies or sexual harassment. Each incident was fully investigated and performance management actions put in place with the Board fully informed of all incidents and outcomes.