Environmental Policy

Policy

The Bernard Group is committed to leading the industry in minimizing the impact of its activities on the environment.

The key points of its strategy to achieve this are:

• Maintain a commitment to the protection of the environment, including prevention of pollution 
• Minimize our waste and then reuse or recycle as much of it as is possible to prevent pollution
• Reduce energy consumption and GHG emissions which impacts air pollution
• Minimize water use in order minimize the consumption of natural resources
• Protect biodiversity and excosystems
• As far as is possible, purchase products and services that do the least damage to the environment
• Promote environmental awareness among our employees and encourage them to work in an environmentally responsible manner
• Ensure compliance with all applicable environmental laws and regulations
• Continuously improve the performance of our Environmental Management System (EMS)

Commitment

Our Senior Management Team demonstrates leadership and commitment to achieving the objectives of our Environmental Management System (EMS), by taking accountability for its effectiveness and by providing direction and support ensuring that:

• Our Environmental Policy and Environmental Objectives are compatible with our strategic direction and context
• Our EMS is integrated into our business processes as appropriate
• Our EMS is suitably resourced
• The importance of effective environmental management, and of conforming to the requirements of our EMS, are clearly communicated
• Our EMS achieves its intended outcomes
• Staff are encouraged to contribute to the effectiveness of our EMS
• Continual improvement is actively promoted
• Our environmental policies, objectives and targets are, where appropriate, reflected in individual performance objectives

Policy Scope

Our EMS and Environmental Policy satisfy the requirements of ISO 14001:2015 and, based on our understanding of our business, and the needs and expectations of our stakeholders, address and support our processes for the manufacturing, and distribution of our products.

When determining this scope, we have considered:

• Our organization and its context (both internal and external issues)
• The needs and expectations of interested parties
• Our compliance obligations 
• Our organizational units, functions and physical boundaries
• Our activities, products and services
• Our authority and ability to exercise control and influence

Scope: “The environmental risks associated with the design and manufacturing of both print and fixtures.”

Objectives

The Environmental Management Team has developed our Environmental Objectives.

These objectives take into account our significant environmental aspects, associated compliance obligations and those risks and opportunities that we have identified.

The Environmental Management Team ensures that our Environmental Objectives are:

• consistent with our Environmental Policy
• measurable (if practicable)
• monitored
• communicated
• updated as appropriate

Progress towards achieving each target, and the targets themselves, are reviewed by the Senior Management Team/Rep and Environmental Manager and updated as necessary.

These objectives, and the results of the Environmental Management Teams annual review, are communicated to employees, customers, suppliers, contractors, interested parties and the wider community as applicable.

When planning how to achieve Environmental Objectives, we determine:

• what will be done
• what resources will be required
• who will be responsible
• when it will be completed
• how the results will be evaluated, including indicators for monitoring progress toward achievement of its measurable Environmental Objectives
• wherever practicable, we seek to integrate actions to achieve our Environmental Objectives into our business processes

Energy Consumption and Greenhouse Gases

As an industrial manufacturer, managing energy usage is a critical aspect in achieving our environmental goals.  Comprehensive energy audits are conducted annually to look for energy savings project opportunities. Many projects have been implemented as a result of these audits and the methodology and technology used has been applied on a continuing basis.

Energy Efficient Print Equipment

High transmission efficiency 480V power is specified for all new production equipment wherever possible. LED curing is used on a wide variety of current generation print assets in large format.

Programmable Thermostats

Programmable thermostats continue to be specified for all new HVAC equipment installs as well as on any remedial projects for current installations. TBG continues the practice of installing locking covers on thermostats in controlled areas to prevent tampering.

High Efficiency RTUs

When rooftop HVAC equipment is added or replaced; TBG always specifies an AHRA certified high efficiency unit as this provides numerous benefits. Lower emissions, less fossil fuel consumption, and a rebate incentive are all positive impacts and come at a very small increase to project cost.

Occupancy Sensors

Occupancy sensors continue to be specified for new breakroom, office and conference room build-outs as well as added wherever feasible as a remedial project for our contract electrician.

LED Lamps

TBG uses LED lamps which are more energy efficient and have a longer life than alternatives; and are a critical component of our energy saving efforts.

TBG continues to make energy improvements and holds new installation and construction projects to a high standard of energy efficiency.

Emissions

TBG measures our scope 1, 2 and 3 emissions and reports our emissions publicly to the Carbon Disclosure Project. We purchase renewable energy certificates and verified carbon offset credits to negate 100% of our emissions.

Water Conservation

TBG is a Minnesota based company and we’re especially conscious of protecting our waterways.

Our printing processes are waterless, neither consuming freshwater or producing waste water.

• In fact ALL of our liquid waste is disposed of properly, shipped compliantly to be incinerated
• We do not discharge chemical waste or effluent into the environment or public water system
• We keep all activities indoors, therefore we don’t have outdoor exposure to stormwater or run-off
• We maintain “No exposure” permits

Biodiversity

TBG is committed to biodiversity and abides by the following principles of conduct:

• Identify and assess the impacts and aspects of TBG activities on natural habitat including the protection of wild animals and protected species
• Avoid locating new facilities in spaces that are protected
• Avoid or reduce deforestation associated with our activities and supply chain
• Integrate the management of diversity into the EMS

Air Pollution

TBG is committed to providing a workplace of clean and breathable air. To ensure a high quality of indoor air, periodic measurements are taken of common pollutants in all areas as well as contaminant specific testing in areas of specific known usage or contamination. 

Materials, Chemicals and Waste

TBG handles over 21 different wastes that must be sorted not just for compliant disposal but with the most positive and least negative impacts.

• As much waste as possible is recycled in all areas AND
• Recycling is required even when it isn’t profitable.
• All staff are trained on correct sorting and bin locations of all recycling streams

Product Use and Sustainable Consumption

TBG promotes the use of sustainable materials and packaging to its clients and in all of our facilities. Our aim is to source and test the latest sustainable materials and packaging options that are available on the market. We provide our sales teams and clients with sustainability materials books that allows them to touch and feel sustainable alternatives to conventional non-sustainable options.

Packaging

Sustainable packaging is used wherever possible. Bubble wrap, poly bags and other plastic packaging are replaced with sustainable options.

TBG developed styGreenTM, a proprietary plant based styrene that is made from renewable resources, thus greatly reducing its impact on the environment:

• Reduced greenhouse gases and carbon footprint
• Ocean safe – it is designed to dissolve in water
• Compostable
• Recyclable
• Degradable – will break down in landfills
• Renders colors well, including pastels 

Product Take-Back Program

The product take-back program provides recycling instruction sheets to inform what is recyclable and not recyclable at the store level. Parts that are not recyclable at the store level can be sent back to TBG facilities where they will be sorted and processed through our recycling streams.

Closed Loop Methodology

TBG partners with vendors to buy recycled material that can be sent back to the supplier to be recycled again whenever possible. 

Sheet Utilization

Our production process includes the use of sheet utilization software to optimize the nesting of jobs per sheet to increase efficiency and reduce material waste.

Product End-Of-Life and Circular Design

When possible, projects are eco-designed with the project end-of-life and recyclability in mind with the goal of implementing a closed loop methodology so that our products have a longer life and avoid becoming waste.

TBG teams utilize Eco-Design tools to achieve sustainable design from conception to end-of-life:

Conception

• Optimize the weight of materials used
• When possible, use FSC or PEFC certified materials
• Use recycled materials 
• Use recycled or recyclable packing materials
• When possible, ban batteries, electronic components and magnets – Use only LED

Production

• Use digital print technology
• Avoid lamination

Transportation

• Optimize palletization
• Optimize POS shipments with flat delivery

Use

• Use recycled materials 
• Use recycled or recyclable packing materials

End-Of-Life

• All materials need to be separable for recycling
• Promote recycling with disassembly and recycling instructions
• Promote product take back program

Customer Health and Safety

TBG takes all reasonable steps to ensure the health and safety of our clients while on company premises. In alignment with the EMS, this is achieved by:

• Assessing risks to health, safety and the environment associated with our workplace
• Ensuring instruction and training are timely and appropriate
• Providing suitable and safe facilities for our customers
• Conducting annual environmental audits 
• Reporting incidents through a structured reporting protocol

Environmental Services and Advocacy

TBG supports the Minnesota Nature Conservancy and is signatory of the “Climate Action Now” pledge to call on US leaders to stand strong on climate change and demand climate action. TBG continually strives to reduce our operational impacts on the environment but also believes that we can have an impact on public policy to safeguard our lands and waters from climate’s biggest impacts on a broader scope. 

Performance Monitoring

Data drives all of our environmental action at TBG; so performance monitoring is a major component of our programs. Performance is continually monitored for waste, recycling, emissions, and numerous other categories

Implementation

To ensure this policy is successfully implemented The Bernard Group will develop an environmental management program that will:

• Ensure this environmental policy is communicated to The Bernard Group staff, it’s customers, Suppliers, Sub-Contractors, and the community;
• Ensure compliance with all applicable environmental laws and regulations;
• Ensure environmental considerations are included in planning, property, financial, developmental, and operational decisions, including feasible and cost-effective options for applicable regulatory requirements;
• Define and establish environmental objectives, targets, and best management practices and monitor performance

Accountability and Employee Responsibilities

Our Senior Management Team has assigned and communicated responsibilities and authorities for all roles relevant to the full and proper implementation, operation and maintenance of this management system. 

The Senior Management Team has assigned responsibility and authority for:

• Ensuring that the EMS conforms to applicable standards
• Ensuring that EMS processes are delivering their intended outputs
• Reporting on the performance of the EMS
• Ensuring the promotion of a focus on environmental matters throughout the organization
• Ensuring that the integrity of the EMS is maintained when changes are planned and implemented

All managers are expected to demonstrate their commitment to the implementation and improvement of the EMS through:

• The provision of necessary resources 
• Their involvement in the internal audit process 
• Their proactive involvement in continual improvement activities
• Focusing on the improvement of key system processes

All managers are responsible for the implementation of the policies, processes and systems described in this manual and for planning, controlling and suitably resourcing the EMS processes within their area of responsibility.

All staff are responsible for the implementation of the environmental policies and procedures applicable to processes they perform and are encouraged to identify and report any known or potential problems and to recommend related solutions. 

All staff responsible for environmental outcomes have the authority to stop activities to address environmental problems. 

Raise a Concern

If you witness or experience any activities negatively affecting The Bernard Group’s environment, you are encouraged to raise your concerns at as early a stage as possible. If you’re uncertain about whether a certain action or behavior will have a negative environmental impact, you should speak to your manager, Human Resources or the General Manager.

The Bernard Group will familiarize all employees with its whistleblowing procedures so employees can vocalize their concerns swiftly and confidentially. 

All employees have access to has access to our 24-hour Helpline to report work-related problems confidentially and without fear of retaliation. The Company will investigate, address and respond to the concerns of employees and will take appropriate corrective action in response to any violation. 

Training and Communication 

The Bernard Group will provide training on this policy as part of the induction process for all new employees. Employees will also receive regular, relevant training on how to adhere to this policy, and will be asked annually to formally accept that they will comply with this policy. 

The Bernard Group’s environmental policy will be clearly communicated to all suppliers, contractors, business partners, and any third-parties at the outset of business relations, and as appropriate thereafter. 

The Bernard Group will provide relevant training to employees etc. on this policy and environmental aspects and impacts.

Review Mechanisms

We operate and maintain arrangements for evaluation of compliance as set out in our EMS Fulfillment of Environmental Compliance Obligations Procedure. 

By means of this procedure we:

• Determine the frequency of compliance evaluation
• Evaluate compliance and take action as necessary
• Maintain knowledge and understanding of our compliance status

1. Environmental Monitoring Plan

We have identified the key characteristics of processes and activities that should be measured and included them in our Environmental Monitoring Plan which clearly identifies what will be measured, where and when it should be measured, and what methods should be used.

The Environmental Manager periodically analyses the results of measurement and monitoring and:

• communicates relevant environmental performance information both internally to the Environmental Team and appropriate managers and supervisors
• reports results to the environmental management review meeting, which evaluates and uses these results, to identify both successes and areas requiring correction or improvement

2. Internal audit

We operate and maintain arrangements for internal auditing at planned intervals as set out in our Control of Internal Auditing Procedure.

By means of these audits, we provide information to management and determine whether our EMS:

• conforms to our own requirements
• conforms to the requirements of ISO 14001
• is effectively implemented and maintained
• is effective in achieving our management system’s policies and objectives

3. Management review

We operate and maintain arrangements for reviewing the suitability, adequacy and effectiveness of our EMS, at planned intervals, as set out in our EMS Management Reviews Procedure.

These reviews include assessing the continuing suitability, adequacy and effectiveness of our EMS, opportunities for improvement, and the need for changes.