Health and Safety: The legal risks of ignoring it on small projects

Despite having been introduced four years ago, there is still limited understanding in the building services sector of the Construction (Design and Management) Regulations (CDM 2015) and the new obligations it has placed on building owners.

The 2015 regulations switched the balance of responsibility for health and safety from a CDM co-ordinator (a role which has now been abolished) to those paying for the works (ie clients). This places direct responsibility on property owners and landlords.

Anyone who has any kind of construction work carried out for them is considered ‘clients’ and are held legally responsible for ensuring every project, undertaken on their behalf, is suitably managed and ensures the health and safety of all those engaged on the project, as well as the members of the public.

CDM 2015 applies in every circumstance, whether it is a category A or B refurbishment or even just the ongoing maintenance of facilities, including remedial repair works.

A refurbishment project doesn’t have to involve any structural changes for CDM to apply. In short, CDM applies to every aspect of works being carried out on a property.

The fines for non-compliance are unlimited and directors can be jailed.

As an example, in 2016 a construction company was removing a roller shutter door on the boundary of a site and in the process, the door fell onto the pavement and badly damaged a market stall. The principal contractor was fined £45K for a CDM breach after the HSE’s investigation found:

  • there was no risk assessment for the task of removing the roller shutter door
  • the site manager was not on site when the incident occurred meaning there was no supervision of the workers
  • the site issues could have been rectified by appropriately planning, managing and monitoring the construction work.

It’s also worth remembering that the obligations apply to the design stage of works as well as actual construction. In fact, the creation of a ‘principal designer’ role in the regulations is supposed to ensure health and safety planning is an integral part of the design stage.


So who is responsible for what under CDM 2015?

Virtually everyone involved in a construction project has legal duties which can be defined as follows:

  • Client– Anyone who has construction work carried out for them. The main duty for clients is to make sure their project is suitably managed, ensuring the health and safety of all who might be affected by the work, including members of the public.
  • Principal designer – A designer appointed by the client to control the pre-construction phase on projects with more than one contractor. The principal designer’s main duty is to plan, manage, monitor and coordinate health and safety during this phase when most design work is carried out.
  • Designer – An organisation or individual whose work involves preparing or modifying designs, drawings, specifications, bills of quantity or design calculations. Designers can be architects, consulting engineers and quantity surveyors, or anyone who specifies and alters designs as part of their work.  They can also include tradespeople if they carry out design work. The designer’s main duty is to eliminate, reduce or control foreseeable risks that may arise during construction work, or in the use and maintenance of the building once built. Designers work under the control of a principal designer on projects with more than one contractor.
  • Principal contractor – A contractor appointed by the client to manage the construction phase on projects with more than one contractor. The principal contractor’s main duty is to plan, manage, monitor and coordinate health and safety during this phase when all construction work takes place.
  • Contractor – An individual or business in charge of carrying out construction work (e.g. building, altering, maintaining or demolishing). Anyone who manages this work or directly employs or engages construction workers is a contractor. Their main duty is to plan, manage and monitor the work under their control in a way that ensures the health and safety of anyone it might affect (including members of the public). Contractors work under the control of the principal contractor on projects with more than one contractor.
  • Worker – An individual who carries out the work involved in building, altering, maintaining or demolishing buildings or structures. Workers include plumbers, electricians, scaffolders, painters, decorators, steel erectors and labourers, as well as supervisors like foremen and chargehands. Their duties include cooperating with their employer and other duty holders, reporting anything they see that might endanger the health and safety of themselves or others. Workers must be consulted on matters affecting their health, safety and welfare.

Architects and engineers are often reluctant to take on the role of principal designer under the regulations because of a lack of expertise in the area of health and safety. At EVORA EDGE we are skilled mechanical, electrical and public health consultants able to take on the principal designer role and ensure health and safety is an integral part of all planned and designed works.

Take a look at our work acting in the principal designer role during the implementation of a large scale photovoltaic installation across multiple buildings in the UK, here.

For more information on how EVORA EDGE might be able to help you please contact Sadie Hopkins (0)1743 341903 or shopkins@evoraglobal.com

London Plan: Generating your own electricity in London just became less attractive

The London Plan, which dictates all planning and development in the capital, is currently undergoing a major rewrite but many in the sector are unaware that some significant changes and adjustments have already come into force.

In October last year, the Greater London Authority (GLA) published updated Energy Assessment Guidance which applies from January this year and directly impacts on developers. All new planning submissions in London are now ‘encouraged’ to use the new emissions factors detailed in the government’s latest Standard Assessment Procedure for Building Regulations (known as SAP10) alongside PART L 2013.

This is a highly unusual step for GLA to have taken, given SAP10 has yet to be incorporated into official building regulations. The government is not due to consult on new Part L regulations until Spring this year so the new emissions factors are unlikely to be made law until the latter part of the year at the earliest.

However, the GLA guidance states that any energy assessments which do not use SAP10 will be expected to provide a justification as to why not and presumably this will be a consideration in planning approval.


The reason behind this policy change is England’s rapid decarbonisation of the National Grid which has seen the amount of electricity sourced from wind and solar technologies increase year on year, while at the same time there is a move away from coal fired generation to gas fired generation.

The GLA believe the new SAP10 factors more accurately reflect actual carbon emissions as the electricity emissions factor in SAP10 is now 55% lower than that specified in PART L 2013. As a result, generating electricity onsite, by using combined heat and power engines (CHP) and/or photovoltaic solar energy systems, are no longer as attractive to London planners as previously.

Additionally, district heat networks using gas-engine CHPs are unlikely to be favoured because of concerns about the impact on air quality, which has become a high-profile issue in London.

The guidance makes it clear that applicants will be expected to use other low carbon technologies such as heat pumps. Ground source heat pumps are generally deemed more efficient than air source heat pumps, depending on ground conditions.

In practical terms, any PART L 2013 compliance should be accompanied by a separate spreadsheet document, supplied by the Greater London Authority (GLA), that translates energy consumption to SAP10 carbon emissions.


The changes, detailed in the GLA’s Energy Assessment Guidance, affect both residential and non-residential applications referred to the Mayor of London from January this year including:

  • Developments of 150 residential units or more
  • Development over 30 metres in height (outside the City of London)
  • Development on Green Belt or Metropolitan Open Land

Applications for commercial developments also need to show at least a further 35% reduction in carbon emissions on top of those specified in PART L of Building Regulations 2013. However, the Mayor has already said that he intends to introduce zero carbon emissions for commercial developments in the final version of the London Plan which will be published later this year.

Domestic residential developments are already required to achieve zero carbon emissions. However, if this is not feasible or viable then developers must show how they will reduce emissions on-site by a minimum of 35% on top of those specified in Part L. The remainder of the target needs to be met via carbon-offsetting either elsewhere in London (for example photovoltaic panels on a local school) or by contributing a carbon offset payment.


EVORA EDGE can help the success of planning submissions in London by modelling and testing how such ambitious targets could be achieved using sophisticated, dynamic simulation software both for passive design (such as fabric improvements and shading strategies) and active design (mechanical systems and lighting).

If you would like to discuss further please email Erieta Dimitriou edimitriou@evoraglobal.com or call on 07538141399 for further information.

Streamlined Energy & Carbon Reporting – What does it mean for you?

Since its initial announcement in 2016, the Department for Business, Energy, and Industrial Strategy (BEIS) has been working on a new framework to simplify the complicated environmental reporting landscape that exists currently. What they came up with is known as the “Streamlined Energy & Carbon Reporting Framework” (SECR).

Following an extensive consultation process, which EVORA took part in, the Government recently confirmed the details of how the framework will look. Under the new legislation:

  • All quoted companies will be required to report their UK energy use, associated Scope 1 & 2 emissions (in simple terms, covering electricity and gas use), an intensity metric and, where applicable, global energy use in their Annual Reports.
  • All “large” unquoted companies will be required to report their UK energy use, associated scope 1 & 2 emissions, and an intensity metric in their Annual Reports.
  • All “large” LLPs will be required to report similar to Unquoted Companies in their Annual Reports.
  • Unregistered companies required to prepare a Directors’ Report will also need to include similar information to unquoted companies.

The framework will be applied through Companies House, which means there are no requirements for non-UK registered companies. Meanwhile, the Companies House definition of “large” will be applied (i.e. when two or more of the following are true: 250 employees or more, annual turnover of £36mil or more, annual balance sheet of £18mil or more).

The Timescale:

The legislation takes effect on April 1st 2019 and applies to any financial reporting years starting on or after this date. This means the first SECR reports will need to be filed in 2020.

How we can help:

Here at EVORA, we have significant experience in the collation, management, and analysis of ESG data.

Through use of our bespoke ESG data management software, SIERA, and the support of our team of expert consultants we can fully manage the delivery of your annual SECR Report from start to finish, and help you use this information as the basis for a broader ESG strategy that will maximise value from the SECR process and deliver transformative change for your Company.

If you have further questions or are seeking assistance with your environmental reporting, get in touch and our team of experts will be happy to help.

Speak to EVORA today about SECR reporting and an accompanying ESG strategy that will help maximise value from the process

GRESB 2019 pre-release: a review of the tweaks and refinements

GRESB has broadly taken a “don’t fix what ain’t broke” approach to the 2019 survey, with the pre-release revealing that only minor changes to the reporting framework have been made from last year.

This is perhaps a sign that, after ten years of development, GRESB are settling on a long-term formula for the majority of the questionnaire. This consistency will enable real estate funds and sustainability professionals to focus more on delivering improvement programmes and less on dealing with shifting reporting expectations, thereby maximising the benefit that GRESB participation will bring about.

Steps have also been taken to reduce reporting burden, with evidence requirements removed from ME2 (data management system) and SE8.1 (tenant satisfaction surveys) where past evidence acceptance rates were high. While EVORA generally supports attempts to reduce reporting burden, removing evidence requirements is potentially an integrity risk, particularly in this instance regarding SE8.1. Open text boxes removed from RO5/6/7 (implemented measures), PI1.2/2.2/3.2 (intensity calculations) and NC7.2 (net zero buildings) where the information was not considered to be adding sufficient value for the effort required.

While EVORA generally supports attempts to reduce reporting burden, removing evidence requirements is potentially an integrity risk

Despite the pursuit of consistency, GRESB is still recognising the real estate industry’s shifting goalposts by introducing two two-part questions to the stakeholder engagement section (SE12 and SE13) on the implementation of programmes for the promotion and improvement of health & wellbeing. These are at organisation (i.e. your employees) and asset level respectively. A selection of other references to health & wellbeing has also been introduced throughout the survey, acknowledging the growing importance of this theme in real estate.

The Resilience Module is also entering its second year, and we await further details of this with intrigue. This topic continues to gain significant momentum amongst our clients and in the industry as a whole, and we expect GRESB will acknowledge this through its updates to the Module and the subsequent introduction to the main survey in the coming years.

If anything, I would argue that it’s the “checked” and “verified” categories that could be merged

Perhaps the most controversial change to the Survey is that “verification” and “assurance” of data will be scored equally. Having been through the assurance process with clients in the past, I can vouch that it is extremely thorough and, in my view, warrants the additional points it receives. If anything, I would argue that it’s the “checked” and “verified” categories that could be merged, as the lines of definition between these two are generally more blurred.

Overall, EVORA supports GRESB’s approach of striving for consistency whilst acknowledging new industry themes, and we look forward to continuing to drive innovation and transformation through its delivery in 2019.


EVORA Global GRESB Premier PartnerWe are perfectly positioned to provide GRESB support. View our official Premier Partner profile.

We can work with you to complete the submission and understand your scoring, as well as develop a sustainability plan that will improve your future GRESB performance and align with your organisation’s key environmental objectives.

Contact us to see how we can help you.

GRESB 2019: What are your limiting factors?

It feels like not too long ago, the GRESB reporting season reached its climax and our consultants breathed a sigh of relief, dubbing last year as one of our busiest GRESB periods yet.

Ironically, it’s set to get even busier for us this year with our team expected to support close to 90 submissions, quite a leap from the 70 submissions we supported on last year.

But how do we manage to accurately support all these submissions you may ask?


EVORA has had a close working relationship with GRESB over the last six years and has been supporting clients with the survey ever since. The depth of experience we’ve gained over this time enables us to support first-class submissions for our clients. To a large extent, our efforts are powered by our proprietary sustainability software, SIERA, which seamlessly transfers data into the GRESB portal reducing what we well know is a time-intensive process.

Getting outstanding results (where targeted), which is the much coveted five-star rating, comes with being recognised as an industry leader and speaks highly of you to investors and stakeholders. However, to achieve GRESB success we often find that there are limiting factors that can hold participants back from reaching their end goal.

With our experience in supporting clients right from the early stages through to market leadership, we seek to address common limiting factors that get in the way of achieving high GRESB ratings.

Have you identified areas where you can improve scoring opportunities?

“It’s the little things that matter!”

To bridge the gap between where you are and where you want to be, spend some time reviewing/analysing last year’s scores and define an action plan for this year’s survey aligned with your fund’s sustainability strategy and objectives. If this is your first GRESB assessment, consider each of the sustainability aspects within the survey and review the availability of sustainability performance data such as utility data, technical audits, and stakeholder engagement programmes. Allocate roles and responsibilities within the business, a timeline for completion and track progress.

Don’t forget to review changes to the survey questions within the pre-release document, which is available now!

Is there a coordinated approach within the organisation for submitting supporting evidence?

As we well know, a lot of supporting evidence that broadly covers ESG (Environmental Social & Governance) topics is required throughout the survey. It gets even trickier if you have an international portfolio and you work with multiple stakeholders.

Put a structure in place for collating and preparing evidence required early! Engage with internal and external stakeholders to ensure they understand what is required of them to ensure a smooth submission process.

Are there efficient processes in place for collating and submitting PI (performance indicators) data?

Collating asset level data can be quite a challenge for organisations with large portfolios, however, the PI aspect of GRESB accounts for 25.6% of the overall marks; the highest weighting of all seven aspects.

As we always say, focus on transparency, quality, and automation as much as possible. For example, with our software SIERA, we support clients to collate asset level data, provide verification, analyse and support submissions.

To provide an even more streamlined process to the GRESB survey we are set to release exciting updates to our SIERA software prior to April 2019 – keep your eyes peeled.

How would you respond to new ESG trends included within the survey this year?

The GRESB 2019 survey includes select questions from the previously optional Health & Wellbeing module. Prepare in advance by studying the pre-release document which sets out the key changes and will let you draw up an approach your organisation may take in responding to these. Keeping an eye on the weighting will help you to take a strategic view when identifying key focus areas for GRESB 2019.

Health and wellbeing is a broad topic and as such we recommend you engage with a variety of key stakeholders (considering internal programmes and what’s happening within your portfolio) to draw out key considerations. This could be across health, safety, crime, wellbeing, accessibility and inclusivity.

Implement a monitoring procedure which you can easily report on, that reflects these activities such as tenant satisfaction surveys, IEQ (Indoor Environmental Quality) assessments etc.

Final thoughts

With each limiting factor that you eliminate, you accelerate the rate at which you progress towards enhanced fund performance and GRESB success. EVORA can offer advice on overcoming any of these factors that are limiting your potential.

Read our GRESB eBook here for a comprehensive guide on how to prepare your assets and portfolio for success in the GRESB 2019 reporting cycle.

To make it easy on yourself and others, get in touch and our team of experts will be happy to help.

ESOS Phase 2 compliance: Have you got a plan in place?

With the compliance deadline for ESOS Phase 2 just a year away – 5 December 2019 – proactive organisations have started to prepare by planning and carrying out energy audits as part of the compliance process.

With only a few exemptions for public bodies, your organisation qualifies if on the 31st December 2018, it meets the ESOS definition of a large undertaking:

  • You employ 250 staff or more
  • You have an annual turnover exceeding €50m and a balance sheet exceeding €43m

Qualifying organisations that fail to undertake an ESOS assessment will be liable for a penalty of up to £50,000 and details of non-compliance would be published.


To avoid this action, organisations are required to complete the following compliance procedures;

  1. Measure and report energy use for a continuous 12-month period (overlapping the qualification date of 31 December 2018), to include energy consumed by buildings, industrial processes and transportation activities
  2. Identify your areas of significant energy consumption. ESOS assessments must be completed to cover at least 90% of an organisation’s total energy consumption
  3. Appoint a Lead Assessor to carry out, oversee or review your energy audits and overall ESOS assessment
  4. Undertake energy assessments for your areas of significant energy consumption using one or more of the following approved routes:
    • ESOS Energy audits
    • Display energy certificates
    • An ISO 50001 Energy Management System
  5. Report compliance to the National Scheme administrator – the environmental agency in England, SEPA in Scotland, NIEA in Northern Ireland and NRW in Wales and store your records of assessment.

Don’t forget to take advantage of the energy saving opportunities identified – EVORA identified £2.8M of energy savings in Phase 1 of ESOS.

With our expertise and data management solution SIERA, we can implement energy efficiency programmes, leading to substantial reductions in energy usage and associated costs. Our energy management team typically find quick win energy savings with payback in less than a year. Read more here on how ESOS can be a long-term investment to your business.


EVORA employs qualified Lead assessors and can support you to develop a practical compliance strategy that is appropriate for your organisation.  To ensure you fully comply with ESOS Phase 2, we offer a range of practical solutions. Find out more in our ESOS Compliance Guide .

ISO 50001 2018 revision

Earlier this week, the International Standard for Energy Management Systems (EnMS), ISO 50001 was given its official reboot through the launch of the 2018 revision; updating the 2011 issue. Organisations with existing ISO 50001 certifications have up to three years to transfer to the new standard. Whereas, businesses seeking energy management accreditation for the first time can progress directly with the 2018 version.


The ISO 50001 standard is an internationally recognised framework for the supply, use and consumption of energy in all types of organisations. As well as the direct benefits of saving energy, if you have an ISO 50001 energy management system that’s certified by an approved certification body and covers all your energy use, this can count as your company’s compliance route to Article 8 of the EU Energy Efficiency Directive (Energy Savings Opportunity Scheme- ESOS – in the UK) .

The revision follows similar recent updates to other standards including ISO 9001:2015, and ISO 14001:2015, to include common terms, definitions and structures to provide a high level of compatibility across the ISO suite of standards.


The main changes in the 2018 revision include:

  • Adoption of “high level structure” and common terminology already reworked into ISO 9001:2015 and ISO 14001:2015
  • Stronger focus of the role of top management and leadership engagement
  • More clarity on definitions, including “energy performance improvement”
  • Greater emphasis on risk-based approaches to improving energy performance
  • Clarification on exclusions of energy types
  • Clarification of energy performance indicator (EnPI) and energy baseline (EnB) text to provide a better understanding of these concepts.

The focus on continuous improvement remains active in the revised standard. Driving continual improvement is what EVORA specialises in and we can assist you in implementing and/or transitioning your energy management approach to the new ISO 50001 framework.


With our Plan, Do, Act approach, we can help you develop a tailored EnMS aligned to your business needs which takes account of practical measures in reducing your energy consumption. Contact our experts if you’d like to find out more.

GRESB 2018: over, not done with!

With GRESB over we talked to a number of staff across our business to get a view on experiences faced, whilst it was still fresh in the team’s mind.


Supporting the team for our busiest ever GRESB season.

Paul Sutcliffe – Director

I’ve lost count of the number of GRESB submissions I have supported over the years. I do know that this year at EVORA we supported around 70 submissions, from a broad array of clients (covering sector Number 1s through to first time participants). Our busiest ever GRESB season!

Whilst we represent a broad array of participants with different fund structures and objectives, we do see some common themes. Our clients universally want to ensure that:

  1. Sustainability policies and practices are effective and appropriate for their organisations
  2. Their GRESB submission correctly and accurately reflects their true sustainability position.

There is a clear recognition and acceptance that GRESB is a one size fits all approach. To use a sloppy analogy – sometimes the shoe fits perfectly, other times it’s a bit loose, sometimes too tight, but everyone can still walk in it.

With the GRESB deadline of 12 noon Eastern US time fast approaching, I prepared myself for some long nights. I needn’t have worried though. Our team and clients mobilised, focused, used SIERA (our sustainability software platform) and worked hard to get everything in on time. Final confirmation, of the last submission (for me) came from the last of my clients early on Saturday morning. I breathed a sigh of relief. I had a weekend to enjoy!

One last thing. GRESB has been able to galvanize the industry and drive forward the sustainability agenda. Our industry should work with this and in particular, reflect when the results come out in September. I am a strong believer that GRESB should be used to inform, not drive individual organisational ESG agendas.


Time flies when it’s your first GRESB year!

Katie Brown – Junior Sustainability Consultant

As this was my first year supporting GRESB, there was a lot to grasp and a lot to learn, fast! The time flew, and on reflection preparation is key. Some elements of the submission would have been extremely challenging and time intensive to complete without the help of our SIERA software. We would not have been able to support so many submissions without it. It was important to plan well and communicate early – time well invested should be reflected in an accurate (and higher) GRESB score.

Some elements of the submission would have been extremely challenging and time intensive to complete without the help of our SIERA software. We would not have been able to support so many submissions without it.

I have been impressed that despite the focus on environmental performance of assets forming a core element of the survey, there is a broad spectrum of the sustainability agenda covered, with attention also on social and governance topics including health and safety, management, policies, and supply chains, just to name a few! Also, the inclusion of the health and wellbeing module, and this year a new module on resilience, brings to the forefront important and emerging ESG trends.

The GRESB survey promotes much needed transparency of the sustainability efforts by businesses in the real estate sector, both as a benchmarking tool and providing greater visibility for investors, but also provides a great opportunity to guide and inform more ambitious and rigorous ESG strategies going forward.


It’s all about the data.

Nick Hogg – Associate Director (SIERA Software)

As those that have participated in the GRESB submission process will know, the amount of information and effort that can be required to provide a seemingly straight forward number in answering a GRESB question can be sometimes underestimated. The Performance Indicators is an aspect where this can challenge participants due to sheer quantum of data that might need to be handled across all the impact areas for an entity, not least with more participants submitting data at asset level.

Across all the submissions we were supporting on this year we found that SIERA handled over half a million datapoints through the Asset level interface alone. We have blogged before that GRESB have allowed the automated transfer of Performance Indicator (PI) data from sustainability management software systems, such as SIERA, directly into the GRESB portal for the last few years. We found this automated transfer of data through SIERA vital, not just in trying to make the complexity of reporting more efficient but essential in establishing a robust and transparent method of reporting asset level data.

Across all the submissions we were supporting on this year we found that SIERA handled over half a million datapoints through the Asset level interface alone.

We introduced additional functionality in SIERA this year to further automate the calculation of energy, GHG and water intensity and have plans to continue expansion of SIERA’s GRESB capability over the coming months.


Submissions are done, but it’s not over!

Louise Russell –  Senior Sustainability Consultant

This will have been my fourth year supporting GRESB clients. I support a variety of clients each at a different stage on their sustainability journey.  Existing clients who are already hot on sustainability continue to maintain leading positions principally due to their wider sustainability programmes which we support during the year. For them, GRESB is useful to benchmark the position of their various funds against peers and internally. However, GRESB is not the driver and broader sustainability as well as responsible investing is something that is taken very seriously.

For my clients that were newcomers to GRESB this was the first time that they as an organisation considered what sustainability means to them. Clients are often surprised by what is already in place within their organisations albeit via an unstructured approach. Where we assist is coordinating the various stakeholders to collate the responses. Whilst we never advise that a sustainability strategy should be GRESB driven it does act as a gateway for those approaching sustainability for the first time.

The key to this is starting early especially for those clients that report in calendar year, waiting until the results come out in September will only allow just over three months to December to make improvements before the GRESB reporting year is over.

Now that we are post-GRESB these same clients are looking to build on their existing processes, formalise their sustainability strategy and put in place a sustainability programme that will deliver an improved score in 2019. The key to this is starting early especially for those clients that report in calendar year, waiting until the results come out in September will only allow just over three months to December to make improvements before the GRESB reporting year is over.

If you have anymore questions about the content of this blog or GRESB in general, get in touch and our team of experts will be happy to help.


GRESB Premier PartnerAs a GRESB Real Estate Premier Partner, we are perfectly positioned to provide GRESB support. View our official Premier Partner profile.

We can work with you to complete the submission and understand your scoring, as well as develop a sustainability plan that will improve your future GRESB performance and align with your organisation’s key environmental objectives.

Energy Savings Opportunity Scheme (ESOS) – a burden or an opportunity?

Regulatory reporting can often feel a burden, and in areas which are more specialist, such as energy and carbon reporting, it can be a daunting experience.

Energy and carbon reporting regulations have principally been introduced to highlight the materiality of the impacts and provide visibility of the opportunities to deliver both energy and cost savings.

The reality is that many organisations only want to be compliant and it is only the few who see the opportunity to push forward opportunities and create a competitive advantage.

A good example of this is the Energy Savings Opportunity Scheme (ESOS).


ESOS (Article 8 in Europe) is upon us again in the guise of Phase 2 and will impact large undertakings both in the UK and Europe, requiring them, in simple terms, to measure 12 months of energy across their organisation and identify energy efficiency initiatives through energy audits. For more information on meeting compliance read our ESOS compliance guide.

ESOS has been developed to help organisations understand their total energy use and identify opportunities to deliver energy and cost savings, which is presented to senior management. It is hoped by the government that ‘low hanging fruit’ with pay backs of less than a year will be a no brainer to organisations to implement.

Although the deadline is the 5thDecember 2019, there are advantages in kicking off early with the energy audits, firstly to have a project plan in place to ensure you meet the deadline and secondly to identify cost-effective energy efficiency opportunities, which could provide immediate benefit to the financial bottom line. In Phase One, EVORA identified £2.8M of low cost energy savings for its clients.

Do you see ESOS as a cost to your business or an investment?

ESOS only requires you to identify the opportunities and ironically many organisations did not implement the initiatives found in Phase One. This turns ESOS regulation into a cost rather than an investment – a significant missed opportunity.

An example of the quick win opportunities is highlighted by work EVORA delivered in collaboration with a property management company to deliver an energy efficiency programme utilising EVORA’s energy management software, SIERA. The graph below displays the weekly energy profile at the office building (110 Queen Street in Glasgow) before (light blue line) and after interventions (dark blue line) were brought about by the improvement programme.

Significant improvements in the energy profile can be seen, especially at the weekend, which has delivered savings of 30% (greater than £30,000 actual savings in the year) without any capital expenditure. This was achieved despite increased occupancy at the property throughout the year and payback was less than three months.

For more information on how we delivered these savings read the full case study here.

This is certainly not the exception and we have worked with an array of sectors including power generation, real estate, retail and hotel & leisure to optimise energy efficiency, often achieving surprising results.

If you’d to learn more about how we can support you with your ESOS regulation and turn a compliance cost into a long term investment, contact us.

GRESB Survey: We answer your questions

With many of us currently knee-deep in spreadsheets for this year’s GRESB submissions, we took some time out to speak with one of our Consultants and ask your questions about the GRESB survey.

About the survey

GRESB is an investor-driven assessment of sustainability performance, that gives Real Estate and Infrastructure funds of all shapes and sizes the opportunity to measure and showcase their performance on a range of environmental, social, and governance issues, and compare themselves to similar entities in the industry.

Real Estate and Infrastructure funds participate in two separate GRESB Surveys which, whilst having a different set of questions, have a similar structure and cover many of the same core ESG issues. At EVORA we have in-house experts on both surveys, so if you’re looking for assistance with your submission or just want some more information, then give this blog a read to get the basics and feel free get in touch if you want to know more.


Q.  How long is the overall submission process to the GRESB portal? Is there a timeline for the submission process?

The final GRESB deadline is July 1st, but a submission doesn’t come together over night! I would say that, to allow time for careful completion of the portal and a proper review, you generally need to have started collating data and evidence in March and you want the pieces in place by early June.

GRESB also offer a ‘Response Check’, where a GRESB employee will evaluate your response and help ensure you’re not going to miss out on points through mis-completion or insufficient evidence. The deadline for this is June 8thso, whilst you don’t have to be finished at this juncture, you want to be most of the way there to get the maximum benefit from the Check.

Q. What kind of evidence do I need to prepare before the GRESB portal opens?

To uphold the credibility of GRESB, a large amount of supporting evidence is required throughout the Survey, and rightly so. Certain indicators are entity specific, such as tenant surveys, risk assessments and completion of technical building audits, whereas others do allow responses from the Organisation / investment manager, such as employee and governance issues.

The key thing here is to make sure people on all levels are well-informed of what GRESB entails for them and that, linking back to the previous question, you start getting organised early!

Q. What is the most efficient way of collating and submitting to the GRESB portal if I have an international portfolio? 

At 25.6%, the Performance Indicators section carries the greatest weight of all the Aspects. Therefore, whilst it is often a challenge to organise, the hard work is heavily rewarded by GRESB. I would highly recommend that you get some purpose-built environmental data management software such as ours, SIERA, which is designed with GRESB in mind and can produce an import sheet which can be uploaded straight onto the GRESB Portal. Data collection programmes can be at all levels of temporal granularity, from a one-off annual request ahead of GRESB, to half-hourly data imports into our M&T module.

Q.  How can I improve my GRESB scores?

Each entity is a little bit different and will be stronger and weaker in different areas, however these are some general areas that you can target:

  • Get an EMS – Having an Environmental Management System in place not only scores points directly on the GRESB Survey, but has the indirect effect of planning and guiding your ESG strategies to be as effective as possible.
  • Sort your data – As outlined above, PI data is a huge part of the Survey so it’s worth the effort of organising it. EVORA’s bespoke environmental data management software, SIERA, is perfect for minimising effort and maximising performance in these elements of GRESB.
  • Green Building Certifications – with a global average of just 46 out of 100 last year, the Certifications aspect is a common weakness for participants. At EVORA, we have in-house BREEAM, WELL, LEED and Fitwel Assessors, so get in touch if you’re interested in certification to bolster your GRESB score and reap the wider benefits of certification.

Read more about our research and how to improve your score in this blog.

Q.  Can you make a submission without disclosing the results?

A cornerstone of GRESB, as an investor-driven sustainability assessment, is that the results can be made visible to investors. However, there is a “Grace Period” for first time participants allowing them to opt-out of sharing  result whilst they get to grips with the Survey.

Q.  Can I only submit my evidence and responses in English?

Responses do have to be made in English, however, GRESB will allow you to submit foreign language documents as evidence. In these circumstances, be sure to clearly indicate in the open text boxes provided exactly where in the document the relevant information is held, along with a thorough summary of content. This will help ensure nothing is missed or misinterpreted.

Q. What happens after I make my submission?

GRESB’s response validation process takes place in July and August, with the official results released at a series of events across the world in September. You will also receive your Benchmark Report at this point, which gives you the full breakdown of how you did on each Dimension, Aspect, and Indicator. Off the back of this, EVORA offers a “GRESB Gap Analysis” to new and existing clients, where one of our in-house experts will evaluate your performance and pick out key opportunities for improvement, and can then help implement them. In truth, for top GRESB performers, the process never really stops! The Survey really rewards comprehensive, sustained sustainability programmes.


Year-on-year the GRESB survey is becoming increasingly comprehensive. This year increased scrutiny has been placed on some existing questions, such as asking that Green Building Certification ratings be provided, some new questions have been added, and every participant will be subject to at least a low-level of validation. Furthermore, the currently optional Health & Wellbeing and Resilience modules are set to be built into the main Survey next year and in three years respectively. I expect this trend of increasing complexity and moving goalposts to continue as investor demands expand and change, so having an experienced GRESB consultant to provide support will become increasingly important.

Here at EVORA, we are entering our seventh year assisting with GRESB submissions, and have acquired a great knowledge base in this time to help maximise your GRESB performance. We have experience of delivering more than 150 submissions, including a number of 5 Star submissions and Sector Leader status.

In conclusion, I think the key takeaways for a successful GRESB submission is to: make sure everyone on all level is well informed and knows their role, start your submission early, use SIERA, and get an experienced consultant on board to help out.

If you have anymore questions about the content of this blog or GRESB in general, get in touch and our team of experts will be happy to help.


GRESB Premier PartnerAs a GRESB Real Estate Premier Partner, we are perfectly positioned to provide GRESB support. View our official Premier Partner profile.

We can work with you to complete the submission and understand your scoring, as well as develop a sustainability plan that will improve your future GRESB performance and align with your organisation’s key environmental objectives.