Project Type: Compliance & Assurance

Greenhouse Gas and ESG Data Assurance

Compliance & Assurance Project

Greenhouse Gas and ESG Data Assurance

American Multinational Conglomerate • Global

Solution Overview

Client:

American multinational conglomerate

Business Challenge:

  • Assure a wide variety of data across complex manufacturing operations

Solution:

  • Experienced team of professionals with industry-specific technical knowledge

Results:

  • On time delivery of assurance reports and identification of areas for improvement

Challenge

The client has global operations that manufacture a wide variety of products including hydrochlorofluorocarbons (HCFCs), chlorofluorocarbons (CFCs), adhesives, tapes, consumer goods, medical goods, and industrial materials. To meet stakeholder expectations and several international requirements, they pursue assurance for a range of metrics including water, waste, greenhouse gas (GHG) emissions, energy, safety, technical metrics (inclusion of sustainability in new products), and various social metrics (community engagement, etc.) to an AA1000AS Type 2 Moderate level of assurance, utilizing reporting criteria from Global Reporting Initiative (GRI) Standards and the GHG Protocol. Conducting assurance of the organization’s internal environmental, social, and governance (ESG) metrics and GHG emissions requires a good understanding of a wide variety of manufacturing and chemical processes. The company also needs its assurance partner to possess the ability to review and assure data in manufacturing facilities across North America, South America, Europe, and Asia.

Solution

Apex established a team with knowledge of manufacturing systems that consisted of professionals with extensive industry experience as it relates to ESG reporting and assurance. We conducted in-person site reviews at their US locations and remote reviews for non-US locations. Apex ensured that the facilities and client subject matter experts were prepared, developed schedules for site visits and conducted subject matter expert (SME) interviews. Open and consistent communication was key to developing the assurance plan to ensure completion of site visit reviews and completion of metric compilation within client required deadlines.

Results

This assurance is conducted annually and on schedule to meet the client’s various disclosure deadlines. Apex provides the client’s corporate and facility teams with reports that include best practices and opportunities for improvement to encourage more accurate and transparent ESG reporting each year.

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ICMM Sustainability Report Assurance and GHG Emissions Verification

Compliance & Assurance Project

ICMM Sustainability Report Assurance and GHG Emissions Verification

International Mining Company • Multiple International Sites

Solution Overview

Belt conveyors and mining equipment in a quarry of a company where Apex developed a sustainability report and GHG emissions verification.

Client:

Major international mining company

Business Challenge:

  • International mining operations with complex reporting requirements including International Council on Mining and Metals (ICMM) Sustainable Development Framework and the World Gold Council’s (WGC) Responsible Gold Mining Principles (RGMPs).

Solution:

  • Experienced team of assurance professionals that could provide sustainability assurance and commentary on the client’s alignment with ICMM’s 10 Sustainable Development Principles and eight Position Statements.

Results:

  • Assurance report delivered on time and to the standards outlined by our client, resulting in repeat business for five consecutive report cycles.

Challenge

Apex was retained by a major international gold and copper mining company to provide sustainability report assurance as well as third party data verification of various environmental, social, and governance (ESG) metrics. The assurance process included an assessment of performance and progress across a range of sustainability issues to further our understanding of how the client identifies material ESG risks and emerging issues in a changing environment. The sustainability performance required assessment against the ICMM Sustainable Development Framework and progress towards implementation of the WGC RGMPs.

Apex’s role on this project involved performing data reviews and interviews with client personnel and external stakeholders with respect to the client’s sustainability performance at mining sites throughout the world. Additional responsibilities included remote data review and verification of greenhouse gas (GHG) emissions, the review and assurance of the client’s annual sustainability report against the principles of the Global Reporting Initiative (GRI) framework and the assessment of progress towards implementation of the RGMPs.

Among Apex’s challenges on this project were coordinating virtual and in-person meetings and data review with the client’s staff members and stakeholders located around the world.

Solution

Apex provided assurance for the stated content of the sustainability report and commentary on the client’s alignment with ICMM’s 10 Sustainable Development Principles and eight Position Statements. Reasonable assurance was provided for the content of the sustainability report, the client’s Conflict-Free Gold Report, Scope 1 and 2 GHG emissions and total water withdrawal. Apex also provided limited assurance for the Scope 3 GHG emissions and assessed progress towards implementation of the WGC’s RGMPs and ICMM’s mining principles.

Apex completed all project objectives by the client’s due date of late April 2022. Apex kept in close communication with the client’s primary contact throughout the process to ensure we had the necessary data for review and assurance. Details on the assurance process, mine site visits and recommended opportunities for improvement were provided in a management report.

Results

Each year, Apex has completed the project on time and within budget. Apex has helped the client improve ESG related operations and the assurance process by suggesting opportunities for improvement at both the site level and corporate level.

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Sustainability Report Assurance

Compliance & Assurance Project

Sustainability Report Assurance

American Multinational Healthcare Company • Global Manufacturing Operations

Solution Overview

Client:

American multinational healthcare company

Business Challenge:

  • Complete assurance to ISAE 3000, internal standards and greenhouse gas (GHG) protocol across a wide range of data

Solution:

  • Experienced team of assurance professionals
  • Familiarity with regulatory requirements and industry sector nuances

Results:

  • Timely and accurate reporting
  • Progressive improvements to metric tracking and reporting

Challenge

The client, a leading manufacturer of healthcare products and vaccines, has global pharmaceutical and medical equipment manufacturing operations that involve a range of metrics from water, waste, GHG emissions, energy, safety, technical operations, and various social metrics (diversity and inclusion in procurement, etc.) that Apex assures to a limited level of assurance on an annual basis. The client requires assurance to ISAE 3000 and has developed their metrics to meet Global Reporting Initiative (GRI) Standards, internal reporting requirements, and the GHG protocol. A good understanding of the client’s manufacturing processes, water usage needs, and waste knowledge is needed to conduct assurance of environmental, social, and governance (ESG) metrics and GHG emissions. Assurors also must possess the ability to review and assure data in manufacturing facilities in North America, South America, Europe, and Asia.

Solution

Apex established a team of experts with strong assurance and climate change methodology experience who were also familiar with the nuances of the manufacturing sector. In addition to our US-based team, Apex developed a network of internal and contractor resources to conduct global assurance at various non-US locations. Communication was key to developing the assurance plan, ensuring the facilities and client subject matter experts (SMEs) were prepared, and developing schedules for site visits and SME interviews. Logistics and procurement data were also assured as applicable to the ESG reporting. Apex maintained open and consistent communication throughout the project to ensure completion of site visit reviews, and completion of metric compilation within client required deadlines.

Results

These projects are conducted annually, and project deadlines are always met. Assurance is conducted according to the ISAE 3000 assurance standard. Apex works with the client following project completion to identify best practices, opportunities for improvement, and review of proposed changes including increased metrics for assurance for the following year.

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GHG Inventory Management Plan Development

Compliance & Assurance Project

GHG Inventory Management Plan Development

Construction Engineering Company on Behalf of Private Equity Company • Remote

Solution Overview

Graphical depiction of elements involved in developing a GHG inventory management plan

Client:

Construction engineering company on behalf of private equity (PE) company

Business Challenge:

  • Organize energy/greenhouse gas emissions (GHG) data across a wide range of providers and geographies

Solution:

  • Develop a GHG Inventory Management Plan (IMP) to organize the data efficiently and effectively

Results:

  • A sustainable and systematic approach to the quantification of GHG data that can be scaled up in response to the client’s needs

Challenge

The client, a PE firm with a wide array of portfolio companies, engaged with Apex Companies to provide environmental, social, and governance (ESG) support across its holdings. One of these firms, a national engineering firm with over 35 locations and 1,000 employees across the United States, engages in planning, design, and construction oversight to enhance transportation networks and infrastructure. The company decided to measure its GHG emissions to leverage this data when bidding for projects, hiring and retaining talent, and working with investors. Due to the firm’s number of employees, there needed to be extra emphasis on ensuring the continuity of data reporting in the event of management turnover.

The engineering firm has a large geographic footprint with locations that utilize a range of energy types and suppliers. Energy data exists in a variety of forms including meter readings, invoices, manifests, and written logs, all of which use different measurement techniques and units.

A key challenge for the organization was a lack of internal structure, which made it difficult to collect, manage, and report data efficiently and at a regular cadence. In addition to helping create a GHG inventory in alignment with the GHG protocol, Apex was also asked to build a strong data management foundation that would allow them to confidently and accurately report their GHG emissions footprint. The engineering firm required written procedures on how data would be collected, compiled, reviewed, and input in a uniform manner.

Solution

To begin the process, Apex helped to create a comprehensive IMP—a dynamic document that companies use to outline their processes on data collection, process management, risk mitigation, and quality control of climate data.

Through a series of questionnaires and interviews, Apex determined gaps in the firm’s current processes, common areas of confusion, and the need for a centralized instructional document to act as a roadmap. The IMP identifies all energy and fuel types being used across the variation in sites. Individual offices and sites use different energy sources depending on their local utility providers. These fuel sources include natural gas, electricity, fuel oil, propane, diesel, gasoline, steam, chilled water, hot water, renewable energy, and refrigerants. The variety of fuels and the variety of energy providers necessitates documentation processes for storing and accessing invoices so that data can be found in an efficient manner and so that no data gets lost. For any estimations or assumptions, methodologies are clearly laid out in the IMP, with detailed estimation calculations, and assumptions such as data conversion factors. An IMP specifically lays out where all the data should be stored and who will be responsible for storage and maintenance.

Results

The detailed IMP Apex created for the engineering firm provides a set road map, clear instructions, and standard operating procedures on data collection, compilation, and review. When it comes time for the company to report its GHG emissions, the data will already be housed in one central location with instructions outlining each data source, with calculations to normalize the units in the data management system, greatly simplifying reporting. Creating and maintaining an IMP helps with process continuity; if the data owners leave, the new owners have a system that details exactly what to do and where to go, as opposed to devising a new system or deciphering an undocumented system.

The IMP that Apex created ultimately provides the firm with guidance on creating climate risk strategies and mitigating reputational risk. It is a dynamic system that can evolve and change as the company grows, develops new policies and procedures, and finds new and improved ways to report GHG emissions.

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Property Acquisition and Demolition

Compliance & Assurance Project

Property Acquisition and Demolition

Electric Utility Company • Center & Blacklick Townships, PA

Solution Overview

Property Acquisition and Demolition

Client:

Electric Utility Company

Business Challenge:

  • Purchase permit and demolition

Solution:

  • Asbestos evaluation and remediation
  • Structure removal and disposal
  • Test pits and artifact classification

Results:

  • Permits obtained
  • Asbestos contained, removed, and disposed
  • Artifacts logged with Pennsylvania Historical Museum Commission (PHMC)
  • All structures have been removed

Challenge

The client’s acquisition of seven neighboring properties included real-estate appraisals and negotiations for final purchase pricing, which ranged from 2-acre residential lots to 200-acre farms. Six of the seven properties contained structures, some of which were over 100 years old. Suspected asbestos required verification, and any found were properly disposed. Asbestos are naturally found in minerals that are impervious to erosion and high temperatures. As such, asbestos are found in various products, such as insulation used for pipes, building constituents, and automobile brakes and clutches. Asbestos includes several mineral fibers, including amosite, chrysotile, tremolite, anthophyllite, crocidolite, and actinolite. The Cultural Resource Notice classified one of these structures as yielding potential historic value. Accordingly, the client acquired these parcels to increase their land holdings for future use, and to minimize risk and liability.

Solution

All evaluation and testing were performed by Apex Companies upon completion of the acquisition. Subsequent to all required procedures, we collaborated with the contractor for proper removal and disposal. Furthermore, we collaborated with the archeologist assigned to this project to perform a series of tasks, including test pits and artifacts classification.

Results

Via county demolition permits, utility cut-offs were coordinated and obtained. Prior to full demolition, all structures were investigated for asbestos. Upon confirmation of any asbestos, they were properly contained, removed, and disposed. Deemed historical, artifacts that were uncovered during the process were logged and now reside within the PHMC. In closing, construction and demolition waste were disposed in a local municipal landfill, whereas the sites were re-graded and seeded.

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Oil and Gas Compliance and Assurance Services

Compliance & Assurance Project

Oil and Gas Compliance and Assurance Services

Confidential Oil and Gas Client • Eagle Ford Basin

Solution Overview

Compliance and assurance

Client:

Confidential oil and gas client

Business Challenge:

  • Our client needed help addressing air permitting and compliance needs for over 300 sites

Solution:

  • Conducted process modeling
  • Calculated site-wide emissions
  • Identified the permitting mechanism under the Texas Commission on Environmental Quality (TCEQ) New Source Review Program
  • Conducted National Ambient Air Quality Standard (NAAQS) impacts assessment
  • Prepared air permitting packages
  • Addressed TCEQ’s follow-up questions

Results:

  • With Apex’s help, our client aspires to be 100 percent compliant with applicable laws, regulations, and internal procedures

Challenge

Since 2011, Apex Companies has been helping this oil and gas client address their air permitting and compliance needs for over 300 sites including well sites, compressor stations, dehydration plants, and stabilizers in the Eagle Ford Basin.

Specifically, their challenges include the following:

  • Identifying aggregation issues in accordance with the TCEQ’s Senate Bill (SB) 1134
  • Identifying the fugitive counts for their operations
  • Conducting hydrogen sulfide (H2S) and sulfur dioxide (SO2) impacts evaluations for sour sites
  • Conducting impacts evaluations using advanced air dispersion modeling (AERMOD) for stabilization plants.

Solution

Our services include conducting process modeling using ProMax, calculating sitewide emissions, identifying the permitting mechanism under the TCEQ’s New Source Review Program, conducting NAAQS impacts assessment using SCREEN3 or AERMOD modeling, preparing air permitting packages, and addressing TCEQ’s follow-up questions. TCEQ’s air permitting mechanisms used for permitting these facilities include permit by rule (PBR) and non‑rule standard permit (NRSP) for oil and gas facilities. Over the years, Apex has prepared over 1,000 PBR and NRSP registration and revision packages for this client.

During the course of our project work, we have also helped the client evaluate the permitting mechanism for over 150 audit privilege sites in Texas and implement the corrective actions by submitting the air permit applications for all sites within the specified timeframe.

Results

Across all assets, our client aspires to be 100 percent compliant with applicable laws, regulations, and internal procedures. As we continue to work directly with their operational divisions and help them protect our natural resources, Apex is consistently praised by their management and associates for our quick response time and our understanding of their assets and objectives.

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Compliance and Assurance Services

Compliance & Assurance Project

Compliance and Assurance Services

Confidential Client • Permian and Eagle Ford Basins

Solution Overview

Client:

Confidential client

Business Challenge:

  • Our client needed to gather and track data from over 300 sites for New Source Performance Standards (NSPS) OOOO and OOOOa reporting

Solution:

  • Gathered operational data from over 300 sites
  • Evaluated regulatory applicability for each piece of equipment
  • Generated compliance reports
  • Assisted with air permitting and compliance needs in the Permian Basin

Results:

  • Apex continues to provide regulatory updates and address the client’s air permitting and compliance needs

Challenge

With the release of the NSPS OOOOa for oil and natural gas facilities in 2016, our client needed to gather operational data for their equipment needs including well completion, compressors, pneumatic devices, storage tanks, control devices, and fugitive leak detection surveys from over 300 sites including tank battery, compressor station, salt water disposal, and produced water recycling facilities. To track the data, they requested a single spreadsheet for reporting the facilities subject to NSPS OOOO as well as NSPS OOOOa regulations.

Solution

Apex Companies developed an Excel-based tracking spreadsheet. We gathered operational data from over the sites, evaluated the regulatory applicability for each equipment, and generated compliance reports. We worked diligently to identify the subtle differences between NSPS OOOO and NSPS OOOOa regulations to ensure reporting accuracy.

Impressed with our quality of work, attention to detail, and in-depth understanding of state and federal regulations, our client asked us to assist with their air permitting and compliance needs in the Permian Basin.

We provided specific air permitting services including process modeling using ProMax, calculated sitewide emissions, identified the permitting mechanism under the Texas Commission on Environmental Quality’s (TCEQ’s) New Source Review Program, conducted National Ambient Air Quality Standard (NAAQS) impacts assessment using SCREEN3 modeling, prepared air permitting packages, and addressed TCEQ’s follow-up questions. TCEQ’s air permitting mechanisms primarily used for permitting these facilities include permit by rule (PBR) and standard permit (SP) for oil and gas facilities.

Additionally, we helped our client develop a detailed equipment fugitive count by coordinating the data collection with their engineering and field teams. Over the last couple years, the client has started relying on Apex’s team for preparing air permit applications for their produced water treatment and recycling plants in addition to their typical tank battery and salt water disposal facilities.

Results

The Apex air team is consistently praised by the client for our response time and attention to detail as they continue to rely on us to provide regulatory updates and address their air permitting and compliance needs in the Permian Basin.

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Assurance Services for Corporate Reporting

Compliance & Assurance Project

Assurance Services for Corporate Reporting

Louisville, KY and Various US Locations

Solution Overview

Client:

A for-profit health insurance company which employs 46,000+ personnel with $64.9B in revenue in 2019.

Business Challenge:

  • Ensure transparency, data quality, and standards-aligned public disclosure of the 2019 CSR report.

Solution:

  • Apex professionals with comprehensive understanding of the GRI reporting standard conducted an independent third-party assurance review of data and content.
  • This was performed through remote interviews with data owners and detailed examination of data sources and report language.
  • We used AA1000 Assurance Standard (AA1000AS, 2008) as the reference assurance standard, at a limit assurance level, to assess data collection, management and reporting procedures.

Results:

  • Achieve transparency demanded by stakeholders.
  • Proactively understand material topics that impact business operations; allowing better risk management; new growth opportunities; and insight into how to provide value to your employees, customers, and investors.
  • Improved reporting systems, data quality, and management processes.

Challenge

Apex Companies was retained to conduct a limited-level assurance of the client’s 2019 Corporate Social Responsibility (CSR) report prepared in accordance with the Global Reporting Initiative (GRI) Standards Core option.

Solution

Apex helped to ensure select GRI content data and information related to social and governance included in the GRI Content Index of the CSR report. The review included an assessment of the appropriateness and robustness of underlying reporting systems and processes, used to collect, analyze and review the information reported. The Apex team also evaluated the GRI content against the principles of Completeness and Accuracy as defined in the related GRI Standards.

The assurance process was conducted in line with the requirements of AccountAbility’s AA1000 Assurance Standard (AA1000AS, 2008) Type 2 assurance. The work was planned and carried out to provide moderate (also known as limited), rather than absolute assurance and we believe it provides a reasonable basis for our conclusions.

As part of its independent assurance, Apex provided:

  1. Interviews with relevant personnel of the client;
  2. Review of documentary evidence produced by the client;
  3. Audit of performance data and a sample of which was traced back to the source data;
  4. Review of the client’s data and information systems for collection, aggregation, analysis and review;
  5. Review of stakeholder engagement activities by reviewing news articles, event agendas, and other documentation.

Results

Apex’s assurance services conclusions were summarized in a detailed management report and assurance statement to accompany the public disclosure of the 2019 CSR report. These deliverables provide client’s stakeholders with confidence that the report was prepared in a credible and transparent manner.

The assurance process also resulted in discovery of key areas of ongoing development and improvement observed by Apex that were communicated to the client. These recommendations provide valuable opportunities for improvement for the client and will inform future assurance activities in assessing effectiveness of implementation and new opportunities to continue the cycle of continuous improvement.

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