Division 1

BAT is to implement and adhere to an environmental management system (EMS) that incorporates all of the following features:

1. I..

   commitment of management, including senior management;

2. II..

   definition of an environmental policy that includes continuous improvement for the installation by the management;

3. III..

   planning and establishing the necessary procedures, objectives and targets, in conjunction with financial planning and investment;

4. IV..

   implementation of the procedures paying particular attention to:

   1. (i)

      structure and responsibility

   2. (ii)

      training, awareness and competence

   3. (iii)

      communication

   4. (iv)

      employee involvement

   5. (v)

      documentation

   6. (vi)

      efficient process control

   7. (vii)

      maintenance programmes

   8. (viii)

      emergency preparedness and response

   9. (ix)

      safeguarding compliance with environmental legislation;

5. V..

   checking performance and taking corrective action, paying particular attention to:

   1. (i)

      monitoring and measurement (see also the Reference Document on the General Principles of Monitoring)

   2. (ii)

      corrective and preventive action

   3. (iii)

      maintenance of records

   4. (iv)

      independent (where practicable) internal and external auditing in order to determine whether or not the EMS conforms to planned arrangements and has been properly implemented and maintained;

6. VI..

   review of the EMS and its continuing suitability, adequacy and effectiveness by senior management;

7. VII..

   following the development of cleaner technologies;

8. VIII..

   consideration for the environmental impacts from the eventual decommissioning of the installation at the stage of designing a new plant, and throughout its operating life;

9. IX..

   application of sectoral benchmarking on a regular basis.