Victa Lawncare Pty Ltd

Document Sample
Victa Lawncare Pty Ltd Powered By Docstoc
					    Victa Lawncare Pty Ltd

          (PUBLIC REPORT)

           Action Plan

         July 2007 – June 2010

                Page 1

1. Company Profile

2. Company Details

3. Executive Summary and Commitment

4. The Waste Hierarchy

5. Company Requirements under 2005 National Packaging Covenant

   5.1.Previous Environmental Achievements and Proposed Improvements

   5.2.Victa Lawncare Environmental Code of Practice for Packaging

   5.3.Product Stewardship Commitments

   5.4.Roles and Undertakings (including Action Plan)

   5.5.Indicative Baseline Data against Action Plan KPIs (qualifications and assumptions)

   5.6.Indicative individual targets and timelines

                                            Page 2
                                       Company Profile

Victa Lawncare Pty Ltd is an Australian owned company that has been the leading manufacturer,
importer, distributor and marketer of walk behind lawnmowers in Australia for over 50 years. Victa is
also a leading brand in the neighbouring New Zealand market.
Victa had its beginnings in suburban Sydney in 1952 and since that time has manufactured over 7
million mowers. The brand is synonymous with lawn mowing in Australian households and is one of
Australia’s most significant homegrown marketing creations.

The Head Office of Victa Lawncare is situated at a large site at Moorebank in western Sydney with a
staff of approximately 50. Marketing, sales, finance, HR, operations management, manufacturing,
assembly and warehousing are located within this complex.

The company’s product range comprises a range of petrol two and four stroke mowers and mower
and garden maintenance accessories. Victa is also distributor of the Enviromower electric mower.

Victa Lawncare Pty Ltd is a division of GUD Holdings Ltd, which specialises in manufacturing,
offshore sourcing, supply chain and brand management. Other businesses within GUD Holdings
   •   Sunbeam small appliances
   •   Oates cleaning hardware
   •   Ryco, Wesfil and Goss automotive parts
   •   Davey pumps and water pressure systems
   •   Spa-Quip spa controllers, heaters, pumps and filters
   •   Microlene, Steriflo and Filterpure water treatment products
   •   Monarch Pool Systems products for swimming pools
   •   Lock Focus, Locktech and Kiroo security products

                                               Page 3
                                    Company Details

Head Office
Victa Lawncare Pty Ltd

Administration, Assembly, Warehousing and Distribution

1 Moorebank Avenue
Moorebank, NSW 2170

Locked Bag 4096
Milperra BC NSW 1891

61 2 8778 5550 (Phone)
61 2 8778 5505 (Fax)

Company Website

Contact Person

Mark Kleeberg
Supply Chain Manager
Victa Lawncare Pty Ltd
1 Moorebank Avenue
Moorebank, NSW 2170

61 2 8778 5565 (Phone)
0417 285756 (Mobile)

                                         Page 4
                          Executive Summary and Commitment
Victa Lawncare Pty Ltd is a manufacturer, importer, distributor and marketer of lawnmowers and
garden maintenance products.

The company views itself as an environmentally aware member of the community and will ensure
that efforts are made and resources are directed towards being environmentally responsible. Victa
Lawncare is committed to Packaging Covenant process and its objectives, to resource conservation,
product stewardship and the principles of shared responsibility for packaging. Many of Victa
Lawncare’s major customers, as signatories to the NPC, also require demonstrated commitment to it
by their suppliers.

Senior management of Victa Lawncare oversees the responsibilities under the Packaging Covenant
and ensures that relevant resources are available to achieve successful outcomes. Performance related
to these commitments is reviewed regularly and decisions and actions are internally communicated.

A revised and strengthened Packaging Covenant came into force in 2005, under which signatories are
required to produce an Action Plan reporting baseline data and proposing targets. The current report
comprises this undertaking. This report outlines the Victa Lawncare brands, the consumption of
consumer packaging, previous achievements and plans for 2007 - 2010. This document also addresses
issues and makes commitments related to Product Stewardship and the Environmental Code of
Practice for Packaging, a part of the National Packaging Covenant. This plan continues to develop
and implement programs that are informed by The Waste Hierarchy, the overall strategy for waste
management in Australia.

Victa’s products are sold to the public via distributors which include Bunnings, Big W, Harvey
Norman and Retravision. Smaller distributors include independent power equipment suppliers all
around Australia. Approximate sales volumes are as follows:

Australia                    85%

New Zealand                  10%

Global                       5% (UK, Nigeria etc)

Raw materials and manufactured components are received from Australian and overseas suppliers
mainly in stretch wrapped (plastic code 4) cardboard cartons. The majority of cardboard contains
recycled content.

Finished goods are dispatched in recycled content cardboard cartons (or non-recycled content
cardboard where there are packaging strength issues). A small amount of code 6 polystyrene and code
1 polyethylene bubble-wrap is used.

The 2007-2010 Victa Lawncare Action Plan aims to develop and implement improvements across the
organization in areas such as:
       - refining and expanding environmental performance monitoring systems,
       - analysing, reviewing and acting on performance indicators,
       - investigating opportunities for further packaging material reduction,
       - driving improvements in waste minimization and recycling,
       - working with other members of the packaging supply chain in expanding reuse and
           recycled content products and packaging,
       - Furthering education and awareness of staff, suppliers, customers, and consumers in
           packaging re-use, recycling and appropriate disposal.

                                               Page 5
                                   The Waste Hierarchy
Materials should be conserved through more efficient use, the avoidance of unnecessary consumption
and the encouragement of re-use, recycling and energy recovery. The waste hierarchy states that
wastes should be managed in accordance with the following order of preference:

1. Avoidance (source reduction)
2. Re-use
3. Recycling
4. Energy Recovery
5. Disposal

                                             Page 6
        Previous Environmental Achievements and Proposed Improvements
This is the first Action Plan by Victa Lawncare. Previous environmental achievements focussed on
good environmental practice and reduction and reuse of packaging. They have had the effect of
improving business performance whilst reducing our products’ impact on the environment. Victa is
an environmentally responsible global citizen and its products are packaged in recyclable packaging
which contains recycled content.

Existing achievements:-
   • New environmentally friendly products, which are popular and increasing market share, such
       as the Tornado Mulch or Catch, which reduces mowing time (and fuel while engine idles),
       provides nutrients for the lawn, reduces evaporation and reduces garden (possible landfill)
   • Elimination of alkaline (caustic) deck washing material. This alkaline material was used to
       remove oil from pressed metal prior to painting. Instead now the oil is removed without
       caustic and returned to the metal plate pressers. As a result Victa is no longer required to pay
       wastewater discharge fees.
   • The majority of packaging items are printed or embossed with the appropriate recycle
   • Raising the environmental awareness with employees.
   • Identified and separated waste and recycle streams.
   • Re-use of outer cardboard shippers to pack and send goods locally (as pallet edge and flat
   • Re-use of received non-returnable pallets (to send goods).
   • All cardboard, office paper and plastic wrap waste is separated at source and collected by
   • The majority of cardboard shippers used are made from recycled board.
   • Return/reuse of plastic engine nest trays used to transport engines from suppliers in Adelaide
       (replacing single use cardboard packaging).
   • Several powder coating booths designed as clean closed systems permit used waste powder
       to be collected and returned to powder coating supplier. Each of the new booths is dedicated
       to a common Victa colour. Uncommon colours (remaining 30% of volume) still use non-
       recycling systems.

Proposed improvements
   • Use of recycled office paper.
   • Return of cardboard packaging to sender.
   • Reduction of number of waste bins from 3 to 1 replaced by recycle metal bins.
   • Replace waste bins with aluminium and steel recycle bins.
   • Establish aluminium/PET bottle recycling from packaging waste generated on-site in
      canteens etc.
   • Increase recycling and reduce contamination of recyclates by waste stream audits.
   • Reduction of polystyrene packaging, which is used as engine stabilizer. A trial has
      commenced to remove most polystyrene packaging while monitoring transport damage
      reports. Initial results are encouraging.
   • In case of the 25% of production that has polystyrene engine stabiliser packaging; investigate
      alternatives e.g. cardboard.
   • Powder coating of remaining 30% of volume, uncommon colours still use non-recycling
      systems. Investigate economics of establishing more single colour recycling spray booths.
   • Investigation of in-house polypropylene (e.g. grass catcher) recycling.
   • Commence metal (aluminium, steel) recycling.

                                                Page 7
       Victa Lawncare Pty Ltd Environmental Code of Practice for Packaging
The Environmental Code of Practice for Packaging is part of the National Packaging Covenant. The following
specific commitments related to the Environmental Code of Practice for Packaging are made.

      •     All packaging will conform to all government Acts, Regulations and Australian Standards.
      •     The Environmental Code of Practice and the Packaging Covenant are promoted through supply
            chain linkages to customers and end users.
      •     Overall strategies to reduce environmental impacts across packaging supply/recovery chains are
      •     The packaging decision making process will be documented for beneficial and adverse
            environmental impacts by specific reference to the following points 1-7. If any conflict exists The
            Waste Hierarchy (avoidance/source reduction, re-use, recycling, energy recovery, disposal) and the
            requirement for the product to properly and safely perform its primary function will inform
            consideration of the documented best approach.

Victa Lawncare Pty Ltd is committed to these requirements:

1.        Avoidance/Source reduction, (where product efficacy, safety and appeal are not affected)
      •    Production and promotion of environmentally friendly products.
      •    Avoidance of packaging or reduction of packaging mass and dimensions.
      •    Use of non-virgin and re-used raw materials.
      •    Reduction in energy and water use.

2.        Potential for Re-use
      •     If possible favour reuse rather than single use internal packaging (e.g. plastic engine nest trays)
      •     Reuse packaging, (e.g. cardboard) rather than use new materials.

3.        Recovery and recycling
      •    Consideration of product impact on resource recovery and recycling prior to introduction to market.
      •    In house recycling of pre-consumer and post-consumer packaging.
      •    Use of single product material and packaging wherever possible (avoidance of composites).
      •    Provision of disassembly instructions for mixed material products (aluminium/steel)

4.        Incorporating recycled content
      •     Purchase of packaging with recycled content except where packaging strength is compromised
      •     Victa Lawncare Pty Ltd commits to a “Buy recycled” policy in all areas of its business.

5.        Minimising impacts of packaging
      •    Avoidance of hazardous or toxic materials and elimination of trade waste.
      •    Reuse then recycling of process packaging waste wherever possible.

6.        Propensity to become litter
      •     Use of recycling logo.

7.     Consumer information
      • Recycle logo is present in packaging.
      • Information is provided to sales staff and customers on recycling of packaging. This information is
        available at
      • Product packaging used and received by the company is cardboard and plastics codes 1, 4, 6.
        Council facilities for these types are increasingly available. Consumers are advised to check their
        local council’s recycling facilities.

 ..... .....................        (Gregory Goldsmith, Operations Manager) . . . . . . . . .

     EXECUTIVE SIGNATURE                                                                        DATE

                                                        Page 8
                            Product Stewardship Commitments
 Required Action under Covenant                      Victa Lawncare’s Commitment
             (as relevant)                                (with specific examples)
a) Design: consider aspects of        •   Packaging to conform to all government Acts, Regulations
   design of packaging including          and Standards.
   recovery, reuse, recycling and     •   Environmental Code of Practice for Packaging considered
   litter reduction                       in product development.
                                      •   Avoidance of composite products in packaging if possible.
                                      •   Disassembly instructions included for mixed (e.g.
                                          aluminium/steel) products.
                                      •   Packaging artwork will be reviewed for new/revised
                                          product/packaging for size/visibility of recycling logos
b) Packaging: minimisation of         •   Energy use is monitored.
   amount of material used in         •   Reuse/recycling of cardboard packaging received with
   production                             imported company goods.
                                      •   To increase recycled content of packaging and product
                                          inputs Victa Lawncare commits to a policy of “Buy
                                          recycled” in all areas of its business where this is
                                          practicable including office and consumer product
                                          information paper.
                                      •   Most purchased cardboard packaging is 100% recycled
                                      •   Replacement of polystyrene product packaging
                                      •   Recycling of polypropylene (mower catchers etc)
c) Distribution: reduce material and •    Distribution is reviewed for cost and energy efficiency
   energy consumption
d) Disposal: facilitate safe and easy •   Victa provides disassembly instructions for mixed material
   disposal including recovery,           products, such as aluminium engines on steel bases.
   reuse and recycling to minimise •      Victa Lawncare provides information on recycling of
   environmental impact                   consumer packaging to customers through company
e) Research: facilitate research re   •   Will be considered in future Action Plans.
   supply, use and recovery of
   packaging, identification of new
   uses and markets and reduction
   of amount of packaging
f) Education: helping to establish    •   See (d)
   and finance the circulation of
   reliable information for
   consumers to assist their choice
g) Labelling: accurate consumer       •   The recycle logo is present (1x) on most outer cardboard
   information and labelling to           packaging.
   encourage recycling                •   Recycling logos will be included as required and the size
                                          and number of recycle logos will be increased as
                                          packaging artwork is revised for new product packaging.
h) Wholesaling and retailing: Point   •   Recycling Pamphlets are being made available through
   of sale recycling information.         company representatives.
                                               Page 9
                                                      Victa Lawncare Action Plan

                                                        Roles and Undertakings

The Victa Lawncare Action Plan runs from 1 July 2007 – 30 June 2010. Mandatory environmental performance targets will be reported upon by
31 October each year during this period.

Goal 1 KPI 1
     General Goal           Goal for individual     Monitoring                                         Comment
                               brand owner          requirement
 Packaging designed,       Total weight of        • Tonnes of          Packaging types - imported
 manufactured,             consumer packaging       packaging by       • Plastics code 1 (bubblewrap).
 distributed and           (domestic and            material type.     • Cardboard
 marketed to minimise      imported) sold per                          Packaging types - locally purchased
 the amount of material    annum into the         •   Tonnes of        • Plastics code 1 (bubblewrap).
 and other resources       Australian market          product          • Plastic types 6 (polystyrene)
 essential to guarantee    and the total weight       packaged         • Cardboard
 the protection, safety,   of products packaged                        • Tonnages provided are to the Australian market only (as required
 hygiene and shelf life                           •   Ratio of product    by the Covenant). Approximately 15% of Victa sales go to export
 of product.                                          to packaging        market, primarily NZ.
                                                      (by weight)

Goal 1 KPI 6
 Packaging designed,       Total weight by type   •   Tonnes, by        •   Victa Lawncare receives or markets its products in cardboard and
 manufactured to           of “non-recyclable”        type.                 plastic codes 1 and 6.
 optimise recoverability   packaging sold per     •   % of total        •   Code 6 is regarded, by Packaging Covenant definition, as “non-
 through collection        annum into the             packaging sold.       recyclable” due to low recycling rates in the marketplace, however
 systems including         Australian market.                               recycling of these plastic types is now more common. Consumers are
 kerbside recycling                                                         advised to check their local council’s recycling facilities.
 schemes.                                                               •   Plastic wrap (type 4) received by Victa is recycled.
                                                                        •   Cardboard packaging is 100% recyclable.

                                                                  Page 10
Goal 2 KPI 16
     General Goal           Goal for individual         Monitoring                                      Comment
                               brand owner              requirement
 Provision of Collection   Percentage of            Recycling               See below
 Services for post         signatories providing    collection facilities
 consumer packaging        recycling collection     for post-consumer
 and paper                 facilities for post-     packaging
                           consumer packaging       generated on-site
                           generated on-site.       provided.

Goal 4 KPI 21
 Increased recycling of    Estimated tonnage of     Tonnes Disposed         •   A significant amount of cardboard outer packaging received from
 used packaging            consumer packaging       and Tonnes                  local and overseas is reused to ship to customers as pallet and
                           recycled and sent to     Recycled                    corner protectors etc. Other cardboard is recycled.
                           landfill respectively,                           •   Received stretch wrap is commercially recycled.
                           from on-site                                     •   Aluminium can and PET bottle recycling is about to commence in
                           collection facilities.                               all workplaces.
                                                                            •   Regular waste and recycle stream audits have commenced to
                                                                                ensure all recyclables are recycled and recycle streams are not

Goal 4 KPI 22
 Adoption of               Adoption of              Victa Lawncare to       See below
 Environmental Code of     Environmental Code       implement the
 Practice for Packaging    of Practice for          Environmental
                           Packaging                Code of Practice for

                                                                      Page 11
Goal 4 KPI 26
     General Goal         Goal for individual         Monitoring                  Comment
                             brand owner             requirement
 Adoption of “Buy        Adoption of “Buy         Victa Lawncare      See below
 Recycled” Purchasing    Recycled”                adopt “Buy
 Policy.                 Purchasing Policy.       Recycled”
                                                  Purchasing Policy

Goal 5 KPI 27, 28, 29
 Continuous              •   Establishment of                         See below
 improvement                 baseline
 demonstrated against        performance data.
 baseline data and all   •   Annual Reporting
 relevant KPIs               against Action
                         •   Demonstrated
                             improvement and
                             against individual
                             targets and

                                                                 Page 12
                  xIndicative Baseline Data against Action Plan KPIs (Qualifications and assumptions)

Goal 1 KPI 1
      Goal for              Monitoring                   Aim                           Baseline Data (April 2006 – April 2007)
 individual brand           requirement
Total weight of        •   Tonnes of             Increase ratio of               Packaging Type            Imported (T/yr)   Domestic (T/yr)
consumer                   packaging by          product to              Plain Cardboard                        xxx              xxx
packaging                  material type.        packaging.              Plastics - Type 1 (bubblewrap)         xxx              xxx
(domestic and                                                            Plastics - Type 6 (polystyrene)         0               xxx
imported) sold per
annum into the                                                          Tonnes of product packaged xxx T/y
Australian market
and the total weight                                                             Packaging Type            Packaging Ratio
of products            •   Tonnes of product                             Plain Cardboard                        11.5
packaged                   packaged                                      Plastics - Type 1 (bubblewrap)         3218
                                                                         Plastics - Type 6 (polystyrene)       11350
                       •   Ratio of product to
                           packaging (by

Goal 1 KPI 6
Total weight by        •   Tonnes, by type.      Reduce non-            Packaging types (kg/yr)
type of “non-                                    recyclable             • Plastic Type 6: xxx Tonne/yr
recyclable”            •   % of total            packaging in           • % of Total packaging: 0.1%
packaging sold per         packaging sold.       product range.
annum into the
Australian market.

                                                                     Page 13
Goal 2 KPI 16
Signatories             Recycling collection   Provide recycling       •   Established for office paper, cardboard, plastic wrap, aluminium
providing recycling     facilities for post-   collection facilities       cans, PET bottles and hazardous (printer cartridges).
collection facilities   consumer packaging     for post-consumer       •   Aluminium can recycle collection bins in lunchrooms and other
for post-consumer       generated on-site      packaging                   employee areas. Collected cans recycled.
packaging               provided.              generated on-site.      •   All unusable cardboard is commercially recycled.
generated on-site.                                                     •   Periodic audits are conducted to ensure correct separation of landfill
                                                                           waste and recyclables.
                                                                       •   Waste paper from office is separated at source by user, collected by
                                                                           cleaner and recycled.
                                                                       •   Hazardous recyclable materials are separately recycled (printer
                                                                       •   In-process plastic waste (Type 4) is commercially recycled.

Goal 4 KPI 21
Estimated tonnage       Tonnes Disposed and    Tonnes Recycled         The company is monitoring mass of recyclates and material to landfill.
of consumer             Tonnes Recycled
packaging recycled                                                     Amount to landfill (T/y)                 Estimate %
and sent to landfill                           Tonnes Disposed to      Steel                              2.0         1.3%
respectively, from                             landfill                Aluminium                         0.26         0.2%
on-site collection                                                     plastic type 1                     0.0         0.0%
facilities.                                                            plastic type 4                    0.40         0.3%
                                                                       plastic type 6                    0.05         0.0%
                                                                       Cardboard                          xxx        13.3%
                                                                       Total                             22.7          15%

                                                                       Amount to recycle (T/y)                  Estimate %
                                                                       Steel                              5.0         3.3%
                                                                       Aluminium                          0.0         0.0%
                                                                       plastic type 1                     0.0         0.0%
                                                                       plastic type 4                     2.9         1.9%
                                                                       plastic type 6                     0.0         0.0%
                                                                       Cardboard                          xxx        79.7%
                                                                       Total                              xxx          85%

                                                                   Page 14
 Goal 4 KPI 22
 Adoption of          Adoption of                 Victa Lawncare to    •     Victa Lawncare has committed to the Australian Environmental
 Environmental        Environmental Code of       implement use of           Code of Practice for Packaging.
 Code of Practice for Practice for Packaging      Environmental        •     Victa will use documentation to ensure best environmental practice
 Packaging                                        Code of Practice for       in design of new products.
                                                  Packaging            •     As new product lines are introduced or packaging updated, if absent
                                                                             the recycle logo is being included on packaging.

Goal 4 KPI 26
   General Goal        Goal for individual            Monitoring                                          Comment
                           brand owner               requirement
 Adoption of “Buy     Adoption of “Buy            Victa Lawncare         •   Purchasing Procedures state that the company will consider products
 Recycled”            Recycled” Purchasing        adopt “Buy                 with highest recycled content in purchasing decisions and
 Purchasing Policy.   Policy.                     Recycled”                  implement where product efficacy, safety and appeal is not
                                                  Purchasing Policy          compromised.
                                                                         •   Purchasing staff are encouraged to purchase products with the
                                                                             highest level of recycled content.
                                                                         •   Locally purchased cardboard is composed of 100% recycled

Goal 5 KPI 27, 28, 29
 Continuous            •   Establishment of                              •   Baseline data established.
 improvement               baseline
 demonstrated              performance data.
 against baseline      •   Annual Reporting
 data and all relevant     against Action Plan.
 KPIs                  •   Demonstrated
                           against individual

                                                                      Page 15
                                             Indicative individual targets and timelines
Goal 1 KPI 1
 Goal for individual                                 Targets                                                    Comment
    brand owner
Total weight of                                  Targets                                    •   Cardboard wall thickness will be downsized
consumer packaging                             Baseline 2007-08 2008-09 2009-10                 where possible without affecting box strength.
(domestic and            Cardboard                    11.5  11.8    12.2    12.5            •   Lighter gauge plastics and replacement of
imported) sold per                                                                              polystyrene are regularly reviewed.
                         Plastic code 1
annum into the
                         (bubblewrap)                 3218     3540     3862     4183
Australian market
                         Plastic code 6
and the total weight
                         (polystyrene)               11350     12485   13620    14755
of products packaged.

Aim: Increase ratio of
product to packaging.

Goal 1 KPI 6
Total weight by type                                                                        Use of non-recyclable polystyrene and any possible
of “non-recyclable”      Polystyrene (T/y) Targets                                          recyclable replacement is regularly reviewed.
packaging sold per       Baseline 2007-08 2008-09 2009-10                                   Polystyrene has been eliminated from 75% of
annum into the                                                                              production lines in recent years. Its replacement is
                                0.34      0.31     0.27 0.24
Australian market.                                                                          constrained by efficacy and appeal requirements.
Aim: Reduce non-         •
recyclable packaging
in product range.
Goal 2 KPI 16
Signatories providing    Established for office paper, cardboard, plastic wrap, aluminium   •   Complied.
recycling collection     cans and PET botles.
facilities for post-
consumer packaging
generated on-site.

                                                                   Page 16
Goal 4 KPI 21
Estimated tonnage of     Amount to landfill (T/y)                                          Regular waste audits are being conducted to ensure
consumer packaging                               Baseline 2007-08 2008-09 2009-10          all recyclables are recycled and that recycle streams
recycled and sent to     Steel                         2.0      1.6     1.2     0.8        are not polluted with landfill waste materials.
landfill respectively,   Aluminium                     0.3      0.2     0.2     0.1
from on-site             plastic type 1                  0        0       0       0
collection facilities.   plastic type 4              0.40       0.3     0.2     0.2
Aim: Increase Tonnes     plastic type 6              0.05     0.04    0.03    0.02
Recycled                 cardboard                      20       16     12        8
                         Total                          23       18     14        9

                         Amount to recycle (T/y)
                                                Baseline 2007-08 2008-09 2009-10
                         Steel                        5.0      5.5     6.0     6.5
                         Aluminium                    0.0      0.1     0.1     0.2
                         plastic type 1               0.0        0       0       0
                         plastic type 4               2.9      3.0     3.2     3.3
                         plastic type 6               0.0      0.0     0.0     0.0
                         cardboard                   xxx      xxx     xxx     xxx
                         Total                      Xxx       xxx     xxx     xxx

Goal 4 KPI 22
Adoption of              Victa Lawncare to continue use of Environmental Code of           •   Complied.
Environmental Code       Practice for Packaging
of Practice for

Goal 4 KPI 26
Adoption of “Buy         Victa Lawncare will identify products it purchases that contain   •   Complied.
Recycled”                no or low recycled content to see if any effective alternatives
Purchasing Policy.       exist that have recycled content.

                                                                   Page 17
Goal 5 KPI 27, 28, 29
 Establishment of         Baseline data established                                           •   Baseline data established and targets set.
 baseline performance                                                                             Annual Report due 31/10/07

 Annual Reporting         First Action plan (no report as yet)                                •   Reporting of improvements to 30/6/07 on
 against Action Plan.                                                                             31/10/07 and each year thereafter.

 Demonstrated             First Action plan (no report as yet)
 improvement and
 achievements against
 individual targets and

Victa Lawncare is happy with the quality and robustness of the baseline data provided in this report and will report annually against this baseline
data by 31 October for preceding year 1 July to 30 June.

                                                                     Page 18