2013 Registration document and annual financial report - page 136

Registration Document 2013
Corporate Governance
Risk Management
Environmental risks
In its risk identification process, Accor considers that potential
environmental risks in the hotels business mainly concern the
storage of gas and fuel oil in or near hotels, the malfunction of
transformers containing polychlorinated biphenyls (PCBs), spillage
of cleaning products and contamination from cooling towers.
In general, the risk of causing environmental damage remains
low in the hotels business. In Europe, however, these risks are
assessed with environmental inspections performed during on-site
visits by insurance company experts.
More particularly, given that Accor uses very few toxic or hazardous
products, there is little risk of accidental pollution likely to have an
impact beyond the hotels. In seawater spas, however, procedures
have been introduced to alert public authorities in the event of
non-compliant wastewater analyses.
Moreover, asbestos was used in the construction of certain
hotels at a time when asbestos was not yet prohibited. The use of
asbestos in our buildings is now, however, completely forbidden.
When hotel buildings containing asbestos are renovated, very strict
protocols are implemented to protect workers, in compliance with
the applicable local regulations.
Most Accor hotels are located in Europe and are subject to EU
directives in the following main areas:
environmental responsibility;
energy efficiency of buildings;
waste management, including non-hazardous waste (particularly
packaging), electrical and electronic equipment, and hazardous
waste (particularly batteries and compact fluorescent light bulbs);
management of cooling fluids;
management of chemical substances (compliance with the
REACH directive).
In France, certain installations are covered by regulations relating
to facilities listed for environmental protection purposes and must
therefore be registered in accordance with the relevant procedures.
To mitigate the possibility of the above environmental risks
occurring in any hotel worldwide, prevention policies have been
put into place, based on:
the proprietary SET software program, which measures
compliance with Safety, Environmental and Technical regulations,
as described in the corporate responsibility section, page 68;
sustained deployment of the ISO 14001 certification program,
as described in the corporate responsibility section, page 67;
specific procedures implemented by the country organizations.
Exogenous risks, which mainly arise when hotels are located near
industrial sites or airports, are identified and taken into account
during on-site visits by insurers.
The risk mapping exercise conducted by the Risk Management
Department, which covered all of the Group’s operations, did not
report any major information concerning the environment. As a
result, no material provisions were set aside for environmental
risks in 2013.
Lastly, Accor was not the subject of a court ruling in connection
with any environmental claims during the year.
Regulatory and legal risks
Regulatory risks
The Group is not subject to any specific regulations that could
have a major impact on its operations.
In addition, as Accor operates on a global scale, no specific
regulations are applicable across all of its businesses. Accor SA and
its subsidiaries are subject to local legislation and regulations, in
particular, national regulations applicable to public access buildings.
Like all hotel operators, Accor is required to comply with the
applicable disabled access regulations. This issue has long been
addressed and most Accor hotels already have wheelchair-friendly
rooms, but further expenditure may be required in the coming
years to enhance hotel accessibility.
Risks relating to changes in tax legislation
In response to the difficult economic environment, some governments
may be tempted to introduce new taxes or increase existing ones
carbon tax, VAT etc.). Changes in tax legislation are regularly
monitored by our teams, who work with trade associations to
effectively foresee these decisions and assess their impact.
Risks relating to legal and arbitration
In general, the Group is exposed to the risk of liability in proceedings
that may be brought against it before the courts or administrative
authorities. Information concerning claims, litigation and arbitration
proceedings that could have – or in 2013 had – a material effect
on the Group’s financial position, business or results of operations
is provided in note 39, page 271 to the consolidated financial
statements. Management considers that apart from the cases
described in said note, there are no governmental, legal or
arbitration proceedings (including any threatened proceedings
of which the Group was aware as of the date of filing) that could
have – or in 2013 had – a material effect on the Group’s financial
position, business or results of operations.
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