environmental disclosures of two different companies

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Amcor Limited ABN 62 000 017 372
679 Victoria Street Abbotsford Victoria 3067 Australia
Tel: 61 3 9226 9000 Fax: 61 3 9226 9050
www.amcor.com

Amcor is committed to managing its operations in an environmentally responsible manner. Through continued research into the resources and procedures used to produce Amcor's products, the Group is dedicated to achieving sustainable environmental management across its operations. This commitment permeates all aspects of Amcor's business and is supported by extensive environmental support systems.
This statement is only 53 words and does not give any meaningful information to the public
Its current statement on the website reads:
Amcor embraces its responsibilities as a leading Australasian packaging manufacturer to our people, community and the environment. The company is committed to product stewardship, managing its operations and designing its products in an environmentally responsible manner. To ensure environmentally responsible behaviour is embraced as an integral part of our operations, we specifically undertake to:
· conduct operations in compliance with relevant local environmental legislation, regulations, licences and other requirements;
· prevent pollution and achieve continual improvement in environmental performance through economically viable practices;
· reduce the environmental impact of the products we make through consideration of resource inputs and production methods while meeting consumer quality expectations;
· set environmental objectives and targets and review our performance annually;
· improve energy, water and waste efficiency per unit of product;
· communicate openly and constructively with our people, suppliers, customers, government and the wider community about our environmental practices;
· educate our people and contractors, ensuring that environmental responsibility is integrated into work practices, training, decision-making and is included in performance assessment.

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The inclusion of the qualifiers "particular and significant" in the reporting require-ment has created endless opportunities for reporters to qualify, narrow, and gen-erally render meaningless their disclosures. It is conceptually unclear what a "particular" environmental regulation is. Many environmental regulations are rules of general applicability - for example, a rule that persons and entities must not cause serious environmental harm, or a rule that licence holders must comply with the terms of their licences. Are such rules not "particular" within the meaning of the law because they apply to everybody? If so, the disclosure requirement applies only to an exceedingly narrow class of regulations - those specific to uranium mines or logging, perhaps. Reporters frequently interpret the legislation in this way, which effectively eviscerates it.
Example: "During the period from 28 July 2003 to the date of this report no par-ticular and significant environmental regulation under a law of the Commonwealth or of a State or Territory has applied to the CML Group or its operations."
Source: Coles-Myer, 2003-2004 Annual Report
Here we see an example of one of Australia's top 10 companies, with 1900 stores across Australia, including in environmentally sensitive sectors such as service stations and auto repair shops, maintaining that 299(1)(f) does not apply to it at all.
Example: "In making this report, the directors note that the Group's operations frequently involve the use or development of land, the transport of goods and the storage, transport and disposal of waste. Some of these activities require a licence, consent or approval from Common-wealth or State regulatory bodies. This regulation of the Group's ac-tivities is typically of a general nature, applying to all persons carrying out such activities, and does not in the directors' view comprise par-ticular and significant environmental regulation."
What the Coles-Myer website now says:
While we believe our key responsibility is to look after the interests of our shareholders, we also acknowledge our responsibilities to other stakeholders - customers, team members, suppliers and communities. Corporate responsibility is integral to how we do business and how we treat people, local communities, suppliers and the environment.
At Coles Myer we see corporate social responsibility as having four important areas of focus: corporate governance, the workplace and our people, the community and the environment.
Because we take pride in aiming for the highest standards of corporate governance, we have established a Board sub-committee to oversee development of a ...