audit ready guide
DESCRIPTION
APCTRANSCRIPT
Audit Ready Guide
ANNUAL REPORTING
Audit Ready Guide
AUDIT READY GUIDE 1
Getting ‘audit ready’
Signatories to the Australian Packaging Covenant (APC) are required to report by March 31 annually. As in the past, the APC will be initiating an assessment and audit process (outlined in Figure 1) as part of annual reporting this year, with the primary intention of helping all signatories to remain compliant with the Covenant.
Annual reports submitted by signatories will be reviewed and accepted by the APC. All reports are then externally assessed in greater detail, cross-referenced against action plans and provided with a rating out of five. Signatories have the option of making this rating publicly available if they choose. Further to this assessment, a selection of signatories will be randomly chosen for independent audit. In 2014, 28 signatories were audited, with 100 per cent compliance.
Those being audited this year will be required to provide evidence supporting the claims made in their annual reports. Auditors will also review the content of signatory’s action plans and progress in implementation. It is important that all signatories are ‘audit ready’.
Figure 1: APC annual reporting assessment and audit process
What does being ‘audit ready’ mean?
Being ‘audit ready' involves exercising sound document control procedures to ensure you can substantiate any claims made in your annual report. Put simply, it requires you to keep documented evidence of all activities undertaken in line with your APC commitments, and to have this documentation readily available for an external auditor. You will have one month to respond to the auditors and provide credible evidence for all claims made.
What is acceptable evidence?
Acceptable evidence could include records of any policies and procedures that have been developed and implemented to assess and review packaging, and the results of any reviews committed to within the reporting period. Some other sound examples could include:
Minutes of internal and external meetings;
Copies of emails with suppliers regarding packaging sustainability, linked to action
plan items;
INITIAL REVIEW & ACCEPTANCE BY APC OPPORTUNITY TO ADDRESS ISSUES
ANNUAL REPORTS SUBMITTED BY SIGNATORIES
ASSESSMENT & RATING OPPORTUNITY TO ADDRESS ISSUES
NOTIFICATION OF SIGNATORIES TO BE AUDITED
INDEPENDENT AUDIT
TIMING OF AUDIT FINALISED
RESULTS OF AUDIT PROVIDED OPPORTUNITY TO ADDRESS ISSUES
STAGE 1
STAGE 2
Audit Ready Guide
AUDIT READY GUIDE 2
Policies supported by senior management;
Documents detailing implementation of procedures;
Evidence of procurement and design practices influenced by APC-related actions;
Checklists used when performing packaging reviews;
Collection data from recovery/ recycling companies;
Tender documents detailing sustainable packaging criteria;
Photos of onsite activities including waste management systems and plant
modifications; and
Tracking of litter management actions.
What is an acceptable way to store and present evidence?
Your organisation may already have a records management system with a central document storage process. If appropriate, you can use this system to store APC and packaging sustainability-related data. Having in place a central document storage system may also improve the efficiency of your APC process by allowing team members to access assessment and supplier data.
If a system is not in place or not appropriate then each activity/ target in your action plan should identify what records you will need to maintain in order to be ‘audit-ready’. You will need to ensure this data is available and easily accessible.
To assist signatories with the data collation required for annual reporting the APC has developed an Annual Report Data Collection Template. This template is designed to improve efficiency, distribute accountability and establish a sound reference for auditing purposes.
What happens if I am selected for audit?
Organisations selected for audit will be contacted via a formal letter and email, addressed to their APC contact officer. The letter will provide specific details regarding the audit process, including timelines, what data will be required, and more specifics regarding how the data should be presented.
Organisations selected will be audited based on the following criteria:
1. That the action plan and annual report meet the minimum obligations outlined by the APC (as detailed in Schedule 1).
2. That the company has attempted to undertake the actions described in their action plan or is able to provide a reasonable argument as to why not.
3. That the outcomes reported in the annual report have actually been achieved and evidence exists which substantiates those achievements.
If a signatory does not comply with the audit requirements and/or is found to be non-compliant, the compliance procedures as set out in Schedule 3 of the Covenant will apply.
EXAMPLE 1: If you have reported under KPI 4 that “a ‘Buy Recycled policy’ and relevant procedures were developed and implemented by June 2014”, then you should have a copy of the policy and evidence it has been implemented and has influenced the consideration of recycled content in the products procured by your organisation.
Audit Ready Guide
AUDIT READY GUIDE 3
Who do I contact for support and further information?
As stated above, the intention of the audit process is to ensure signatories remain compliant. If you have any questions regarding your approach to annual reporting and document control please contact the APC.
For support in understanding how to be ‘audit ready’ please email Member Services at: [email protected].
For more information regarding the compliance process please contact Signatory Services: [email protected].