Action Plan for Valvoline (Australia)

Australian Packaging Covenant Action Plan for Valvoline (Australia) Bridging Action Plan (1 July 2016 30 June 2017) Supersedes version date November 2015 of January 2011 December 2015 Action Plan Valvoline APC Action Plan V4.docx Page 1 of 12

Contents Table 1 Executive Summary... 3 2 Introduction... 4 2.1 General... 4 2.2 Scope... 4 2.3 Time period for the Action Plan... 4 2.4 Relation to Previous Action Plans... 4 3 Environmental Management... 5 3.1 Valvoline Environment Policy... 5 3.2 Potential Environmental Impacts from Used Plastic Oil Bottles... 5 4 Nature of Organisation... 6 4.1 General... 6 4.2 Structure... 6 5 Consumer Packaging... 7 5.1 General... 7 5.2 Oils and Lubricants (Valvoline Lines)... 7 5.3 Disposal of consumer lubricating Oil Bottles... 7 6 APC Action Plan... 8 6.1 General... 8 6.1.1 APC Environmental Performance Goals... 8 6.1.2 APC Key Performance Indicators... 8 6.2 Summary of Intent for Actions in Bridging Period... 9 6.3 Summary of Intent for Actions in beyond Bridging Action Plan... 9 7 Commitment to Implement the Action Plan... 9 8 Contact Details... 10 9 References... 10 Table 1: Valvoline Action Plan (1 July 2016 30 June 2017)... 11 Valvoline APC Action Plan V4.docx Page 2 of 12

1 Executive Summary This Action Plan is a commitment by Valvoline (Australia) Pty Ltd (Valvoline) to the Australian Packaging Covenant (APC). It provides an overview of Valvoline s strategies to address the objectives and outcomes of the APC by minimising the environmental impact from packaging associated with our operations and finished products. The plan identifies Valvoline s brand ownership responsibilities and acknowledges the contribution made by all parts of our business to sustainable packaging design, increased recycling and product stewardship. As a signatory to the Australian Packaging Covenant, Valvoline will endeavour to meet its commitments by completing the following; Submit an Action Plan at a frequency no greater than five (5) years or for the Bridging period; Publish the Action Plan on the company website; Implement and manage actions to achieve the objectives of the three (3) goals and eight (8) KPI s of the Covenant and report on these actions; Submit an annual report to APC Secretariat; and Submit to independent audits when required. Note: This Action Plan released July 2016 supersedes the version issued in November 2015. Amendments to the Action Plan include providing details of the Bridging /Transition period and amendments to the actions in Table 1. Valvoline APC Action Plan V4.docx Page 3 of 12

2 Introduction 2.1 General Valvoline (Australia) has updated this action plan as required for the bridging period to cover calendar 2016. This plan lays out the commitment, responsibilities and reporting structure required to fulfill the Covenant. Valvoline is committed to reducing packaging, providing reuse and recycling solutions, managing waste within the business. This plan addresses the KPI requirements in the new Packaging Covenant including baseline data collection and reporting. 2.2 Scope Valvoline manufactures and sells lubricants for a wide range of applications throughout Australia, New Zealand and South Pacific. Valvoline own brands such as Maxlife, Engine Armour, Durablend, Zerex G05 and NextGen. Valvoline manufactures oils and greases in various forms of packaging, as well as manufacturing (blending) and filling lubes locally in Australia. For the locally filled products, packaging is purchased from 3rd party companies. The portfolio consists of approximately 1400 individual line items and the packaging materials and formats used by the organisation include: plastic bottles, plastic closures, plastic pails, tinplate drums, plastic lined IBC s, cardboard cartons and plastic cartridges. This Action Plan covers the management of consumer packaging from 0.20L to 10L in capacity, used to package lubricating oil products for the retail and light commercial markets. The plastic used for oil bottles packaging is almost exclusively High Density Polyethylene (HDPE). Stretch wrapping is used where required to stabilize pallets for transportation. Packaging used for 20L, 60L, 205L and Intermediate Bulk Containers (1000L) containers for Valvoline commercial and industrial customers is not considered within the scope of the Australian Packaging Covenant. The same principles used in sustainable packaging management are also applied to the commercial and industrial packaging. 2.3 Time period for the Action Plan The time period selected for this Action Plan is one (1) year, from July 2016 to June 2017. A report on progress in the year against the Action Plan will be prepared and submitted for each year of the Action Plan in accordance with timelines specified by the Covenant. 2.4 Relation to Previous Action Plans Valvoline was a signatory of the previous National Packaging Covenant. Under this, Valvoline Action Plans were in place for the following period: January 2016 to December 2016 January 2011 to December 2015 January 2005 to January 2010 Valvoline APC Action Plan V4.docx Page 4 of 12

3 Environmental Management 3.1 Valvoline Environment Policy Valvoline (Australia) Pty Ltd as a provider of automotive lubricants and car care products will conduct its business in a manner that will protect the environment and health of employees by complying with legal and other requirements, the environmental management system and meeting community expectations. Valvoline understands the nature of the business and therefore will not make or sell any material that cannot be produced, transported or used in a manner protecting the environment. In order to carry out this policy it is the continuing responsibility of Valvoline to maintain an Environmental Management System, consistent with industry standards and legislative requirements. It is committed to ensuring that all requirements of relevant environmental agency regulations and codes of practices are fulfilled. Valvoline will provide where applicable information, instruction, training and supervision to employees, contractors, visitors and customers to ensure environmental compliance. Valvoline is committed to consulting with employees, local community and government authorities. It will also assist, where possible, government agencies and community groups engaged in environmental activities. Valvoline Senior Management is responsible for providing the necessary environmental standards, goals and resources to assure safe and proper operating practices. Line management is responsible for implementing the required standards, training and systems to help assure the safe and proper operating practices, safe handling of products, and for identifying additional needs in these areas. Valvoline will implement systems and programs that promote continual improvement, the prevention of pollution and compliance with legal and other requirements. Valvoline will initiate and review environmental objectives and measurable targets to all appropriate activities. It is the responsibility of employees to correctly use and maintain equipment, carry out their duties in a manner safe to themselves, their fellow workers and the environment. They will also report all environmental issues to their supervisor and actively participate in environmental management. This policy applies to Valvoline in all its operations and functions including situations where Valvoline operates off site. This policy will be reviewed when required by changes in legislation or when company operations require it. Valvoline will communicate this policy to all interested parties including employees, visitors, contractors, customers, and suppliers. Valvoline will adopt the requirements of ISO 14001 Environmental Management system as the basis of its Environmental Management System. Valvoline will also continually reinforce with each of the operating locations the need for continual improvement in environmental management. 3.2 Potential Environmental Impacts from Used Plastic Oil Bottles The environmental issues of the process of collection and recycling of used plastic oil bottles centre on: diversion of this waste stream from landfill; avoidance of pollution from the residual oil contained in the bottles; and management of difficulties in recycling caused by the adsorption of oil into the plastic. Traditionally, used oil bottles have been disposed of through landfill. This is not regarded as sustainable, and the current AIP program is designed in diverting this waste stream to more environmentally sound disposal. Tests have shown that drained bottles can contain residual oil up to 10 per cent of the original volume. Any leakage of this oil may lead to contamination of soil or water, at landfills or elsewhere. The washing out of used oil bottles requires special attention to effluent disposal. The adsorption of oil into the plastic of oil bottles causes difficulties in recycling in regard to: Adsorption of colour bodies from the oil bottles into any broader plastic recycling stream; Valvoline APC Action Plan V4.docx Page 5 of 12

A residual oily odour in the recycled material; and Weeping of oil from recycled material. These issues mean that, while small volumes of used plastic oil bottles can be fed into general HDPE recycling streams, any significant volumes need special attention and separate facilities. 1 4 Nature of Organisation 4.1 General Valvoline (Australia) is a leading supplier of automotive lubricants to the Australian market for over 100 years. Since the 1960 s, Valvoline has been manufacturing a large range of quality lubricants in Australia. Products are distributed across the country to thousands of workshops, dealerships and industrial customers as well as sold through numerous supermarket and mass merchant chains. Valvoline markets its products to the DIY (Do It Yourself), DIFM (Do It For Me) and commercial and Industrial customers. Valvoline is a globally recognised lubricant brand trusted by many as having high performing quality products. Valvoline s manufacturing site at Wetherill Park has been ISO 9001 certified since the early 1990 s with its laboratory separately NATA accredited for lubricant testing against ISO 17025. Valvoline first appeared in 1901, distributed by Carrigan brothers. In 1961 saw Valvoline Oil Inc., U.S.A. open a branch in Australia. On January 16th, 1964, Valvoline (Australia) Pty Limited was incorporated, being jointly owned by Total, Boral and Ashland Oil Inc - based in the U.S.A. In 1980 Valvoline Australia became a full affiliate of Valvoline International, a wholly owned Company of Ashland Oil Inc, based in U.S.A. In September 2016, Valvoline has split from Ashland to become an individually listed company on the New York stock exchange Valvoline Inc. Valvoline as a brand owner produces and sells a complete and comprehensive range of quality products in Australia which are tailored for Australian conditions. They include; 4.2 Structure Engine Oils Gear Oils Coolants Transmission Oils Racing Oils Brake Fluids Greases Degreasers Industrial Oils Rust Preventatives Oil Filters Agriculture Products Car Care Products Valvoline has one (1) blending and packaging plant as well as six (6) direct market warehouses. Valvoline has a total of 240 employees deployed across all states and most territories in all areas of product stewardship. Valvoline APC Action Plan V4.docx Page 6 of 12

5 Consumer Packaging 5.1 General The sale of Valvoline branded products, in consumer packaging (0.20L to 10L) can be broadly separated into two groups lubes and grease & appearance and engine additive products. In addition, Valvoline manufactures on behalf of third parties private label consumer lubes. 5.2 Oils and Lubricants (Valvoline Lines) Packaging of Valvoline brand lines is associated primarily with the range of lubricating oils and other automotive and industrial products including: automotive oils (i.e. passenger car engine oils, diesel engine oils, gas engine oils, automotive gear oils and heavy duty gear oils); coolants; detergents and degreasers; grease; hydraulic oils; industrial oils; marine engine oils; metal working oils; speciality products (i.e. anti-wet and penetrating fluid, chain and bar oil, mould oils and transformer oil); engine performance additives; and 2 and 4 stroke engine oils. 5.3 Disposal of consumer lubricating Oil Bottles An understanding where used lubricant consumer packaging is disposed of will help develop recycling strategies to divert valuable material from landfill. The Australian Institute of Petroleum (AIP) and its contract partner VIP Packaging (VIP) have undertaken research to establish the current pattern of disposal of plastic retail lubricating oil bottles. Their research has shown that approximately 50 per cent of the bottles are disposed of by households through waste transfer stations with oil collection units. Disposal by households through other means accounts for a further 16 per cent, as follows: Kerbside recycling: 6 per cent General household waste: 8 per cent Household de-tox programs: 2 per cent The balance is considered to originate from non-household channels, particularly small and medium size enterprises (SMEs). Disposal patterns from this sector will tend to follow general waste disposal patterns. Audits of the waste stream from kerbside recycling show that plastic HDPE bottles of all kinds are collected, extracted and usually recycled in an environmentally sound manner. AIP considers therefore that, in addition to the oil bottles collected under the AIP program, a further 5 per cent of the waste stream can be regarded as recycled and so counted towards meeting overall recycling targets for plastic HDPE oil bottles. Waste disposal and collection of used bottled packaging at Valvoline operated facilities is separately managed. Waste is normally disposed of on-site through a number of bins located through the facility. 1 Valvoline APC Action Plan V4.docx Page 7 of 12

6 APC Action Plan 6.1 General 6.1.1 APC Environmental Performance Goals The APC s clearly stated objective is to minimise the overall environmental impacts of packaging. In order to achieve this, the APC has established three performance goals: Goal 1 Design: Optimise packaging to use resources efficiently and reduce environmental impact without compromising product quality and safety. Goal 2 Recycling: Efficiently collect and recycle packaging. Goal 3 Product Stewardship: Demonstrate commitment by all signatories. Valvoline supports the principle of product stewardship and accepts that all members of the packaging supply chain share responsibility for adverse environmental impacts of packaging associated with their activities. Under this Action Plan Valvoline will continue its ongoing liaison with Valvoline branded product suppliers focusing on design and Sustainable Packaging Guidelines. 6.1.2 APC Key Performance Indicators The APC has outlined an appropriate Key Performance Indicator(s) (KPI s) against each goal. Of the eight KPI's, outlined within the APC documentation as follows: KPI #1 (Goal 1): Proportion of signatories in the supply chain implementing the Sustainable Packaging Guidelines for design or procurement of packaging; KPI #2 (Goal 2): National recycling rate for recyclable packaging recovery; KPI #3 (Goal 2): Proportion of signatories with on-site recovery systems for recycling used packaging; KPI #4 (Goal 2): Proportion of signatories with a policy to buy products made from recycled packaging; KPI #5 (Goal 2): Additional tonnes of material reprocessed in primary and secondary markets as a result of Covenant funded projects; KPI #6 (Goal 3): Proportion of signatories that have formal processes for working with others to improve design and recycling of packaging; KPI #7 (Goal 3): Proportion of signatories demonstrating other product stewardship outcomes; and KPI #8 (Goal 3): Reduction in the number of packaging items in the litter stream. Each KPI has associated reporting requirements relating to the APC Annual Report that is to be submitted annually by March 31. Valvoline APC Action Plan V4.docx Page 8 of 12

6.2 Summary of Intent for Actions in Bridging Period The full Valvoline APC Action Plan for the period - 1 July 2016 30 June 2017 is presented in Table 1, within the Tables section of this document. In summary, this Action Plan covers the bridging/transition period of the Covenant until it is reissued by the APC, scheduled July 2017. This Action Plan includes the majority of the maintenance actions of the 2011-2015 Action Plan. Valvoline branded product suppliers are to become signatories of the Australian Packaging Covenant, to establish baselines into the position of Valvoline in relation to generation and management of packaging wastes, and to begin to identify specific actions to address areas where improved management of packaging wastes is required. This may also include the establishment of changes (if any) to operations and/or procedures that may be required to ensure compliance against the APC Goals and KPIs. 6.3 Summary of Intent for Actions in beyond Bridging Action Plan In summary, all subsequent years beyond this Action Plan will be covered by the new action plan developed after the new Covenant is released by the Australian Packaging to implement any programs and/or changes to procedure that have been identified during Year 1 and to monitor and evaluate progress against the Action Plan, with the aim of continuous improvement. 7 Commitment to Implement the Action Plan As Managing Director of Valvoline (Australia), I hereby confirm our commitment to the Action Plan outlined in Section 6. Signed: Date: Peter J Besgrove Managing Director Valvoline (Australia) Pty Ltd Valvoline APC Action Plan V4.docx Page 9 of 12

8 Contact Details Valvoline (Australia) Pty Ltd Head Office Level 6, Suite 603 2 Burbank Place Baulkham Hills, NSW 2153 Phone: 02 9609 7999 Fax: 02 9604 5127 Email: ddejean@valvoline.com Web site: www.valvoline.com.au Contact persons: Mr. Peter Besgrove Managing Director Primary Contact: Secondary Contact: Mr. David Pye Operations Director Mr. Didier Déjean EHSQ Manager 9 References 1. Australian Institute of Petroleum Australian Packaging Covenant, Action Plan for Lubricant Oil Bottles, July 2010 June 2013 Valvoline APC Action Plan V4.docx Page 10 of 12

Australian Packaging Covenant Valvoline (Australia) Pty Ltd Table 1: Valvoline Action Plan (1 July 2016 30 June 2017) Goal/KPI Objectives KPI # Action Responsibility Timeframe Baseline data Target Evidence Goal 1 Design optimise packaging to achieve resource efficiency and reduce environmental impact KPI # 1 1 Maintain Team (VPT) Sustainability Committee formed Proportion of internally within the Coordinator signatories in the business to deliver Annual supply chain Report and Action Plan implementing the SPG s aligned to the SPG & APC Target: 70% of Covenant signatories with documented policies and procedures for evaluating and procuring packaging using the SPG or equivalent Target: 70% of Covenant signatories assessing 100 of new packaging against the guidelines 2 Review new packaging in line with APC Sustainable Packaging Guidelines 3 Percentage (%) of suppliers of Valvoline branded products who comply with the Sustainable Packaging Guidelines Procurement Manager EHS Manager Procurement Manager EHS Manager July 2017 When required 100% of new packaging to be assessed July 2017 80% comply with SPG 100% of the main packaging suppliers to comply with the SPG Meeting minutes to be logged into Qudos VPT comprises of; Procurement Manager EHS Manager Operations Director Production Manager Review assessment in Qudos Suppliers confirmed on the APC register Goal 2 Recycling the efficient collection and recycling of packaging KPI #3, 4 Increase onsite recovery Production Manager July 2017 Current levels at 83% 90% of used Proportion of systems to capture 100% packaging to be signatories with of recyclable materials recycled onsite recovery systems for recycling used packaging Waste data tracking matrix KPI #4 - Proportion of signatories with a policy to buy products made from recycled packaging. 5 100% Waste Diversion site 6 Review existing Valvoline Procurement Policy Production Manager July 2017 No baseline data 95% of used packaging to be recycled Procurement Manager EHS Manager July 2017 Procurement/ Purchasing in place Review procedure Waste data tracking matrix Copy of procedure All APC signatories will have a formal documented policy of buying recycled products or materials. Valvoline APC Action Plan V4.docx Page 11 of 12

Australian Packaging Covenant Valvoline (Australia) Pty Ltd Goal/KPI Objectives KPI # Action Responsibility Timeframe Baseline data Target Evidence Goal 3 Product Stewardship demonstrate commitment to product stewardship KPI s # 6 Proportion of signatories that have formal processes for working with others to improve design and recycling of packaging. 7 To work with main packaging suppliers at product development process the need to include recognizable recycling symbols to all packaging Procurement Manager Target: 70% of Covenant signatories implementing formal policies and procedures in working with other to improve design, procurement and recovery of packaging 8 Develop procurement procedure with our suppliers to towards packaging sustainability Procurement Manager & EHS Manager July 2017 Confirm 100% of new products to have symbols on packaging from July 2017 July 2017 Completed To have procedure drafted, published and implemented by July 2017 Review product containers to ensure markings are embossed on them Actual procedure KPI #7 Proportion of signatories demonstrating other product stewardship outcomes 9 Valvoline to upgrade ISO 14001 Environmental Management certification to 2015 standard EHSQ Manager July 2017 No baseline data Successfully certified to new standard ISO certificate KPI #8 Reduction in the number of packaging items in litter 10 To ensure all new product labels are clearly marked with consumer advice as to proper disposal method. Product Manager July 2017 No baseline data 50% of new labels to be clearly marked from July 2017 Sample of product labels to review disposal marking instructions. 11 To ensure existing labels are clearly marked with consumer advice as to proper disposal method. Product Manager July 2017 No baseline data 50% of existing products by July 2017 Sample of product labels to review disposal marking instructions. Valvoline APC Action Plan V4.docx Page 12 of 12