Australian Packaging

Covenant

Action Plan

GUD Automotive Pty. Ltd.

2011 to 2015

CHIEF EXECUTIVE MESSAGE

As part of GUD Automotives commitment as a signatory to the Australian

Packaging Covenant, we aim to utilise packaging which will assure

protection and quality of our products while being conscious of designing

and developing packaging to minimise environmental impact and

encouraging effective use of resources. This commitment is reflected in

GUD Automotives current Environmental and Quality policy which

highlights the importance of conservation of natural resources and

prevention of pollution.

GUD Automotives policy states that we shall ensure the responsible use of

natural resources through out our business, including the conservation and

effective use of energy, and give preference to renewable over non-

renewable natural resources when feasible. GUD shall seek to develop and

improve operations and technologies to prevent emissions, minimise waste,

purchase recycled material where appropriate and dispose of waste safely

and responsibly.

GUD also recognise the importance of encouraging and working with our

supplier chain partners to meet the objectives of the Australian Packaging

Covenant.

GUD Automotive look forward to providing continued support for the

Australian Packaging Covenant through ongoing investment in existing

projects and future packaging initiatives.

Bob Pattison

Chief Executive Officer

GUD Automotive Pty Ltd.

COMPANY OVER VIEW

GUD Automotive Pty. Ltd. is a wholly owned subsidiary of GUD Holdings

Limited, which is a top 500 listed public company based in Tottenham

Victoria.

GUD Manufacturing Company Pty. Ltd changed its name to GUD

Automotive Pty. Ltd in April 2004. In September 2004 the board of GUD

announced the forth coming closure of filter manufacturing activities in

Australia. GUD is now a company that imports its entire product range

which includes a wide range of automotive products covering filtration and

fuel pumps for Automotive and light commercial vehicles.

Through its brand names “RYCO" and “GOSS” it is market leader in the

automotive segment.

As a producer of packaged products GUD is committed to the philosophy

of “effective management of used packaging based on the principles of

shared responsibility and product stewardship” which is the basis of the

Australian Packaging Covenant.

GUD is ISO9001-2008 certified which enables the company to develop a

frame work and implement policies in accordance with local and national

legislation as well as an aid in the management, control and reporting of

environmental performance.

GUD Automotive products are sold to major wholesalers through the sales

and marketing division who inturn sell to the end user.

GUD AUTOMOTIVE PTY LTD PRODUCTS AND THE

SUPPLY CHAIN

GUD Automotive Pty. Ltd. is a major supplier of the Ryco brand of oil air

and fuel filters and the GOSS brand of fuel pumps and accessories for the

automotive industry. As well as automotive applications, our filters and

pumps are used in agricultural, marine, commercial and industrial

applications.

Packaging materials While the majority of our packaging is cardboard,

polyethylene and polypropylene are also used.

Our Market We have about a 20 % market share of the 30 million filters

changed in Australia annually and 9% of the fuel pump

market.

SCOPE OF ACTION PLAN

GUD Automotives Action Plan has been developed to support the

fundamental objectives and goals of the APC and has been prepared in

accordance with the APC Strategic plan (July 2010 and June 2015),

Sustainability Packaging Guide lines (SPG) and Covenants Handbook.

GUD Automotives Action Plan covers the period of 2011 to 2015 and

activities outlined will be measured and reported on.

GUD Automotive Pty Ltd is classed as a brand owner in accordance with

APC industry classifications. The major product brands owned by GUD

Automotive Pty Ltd are RYCO and GOSS.

For the purpose of reporting GUD will identify packaging materials by

product categories and report per calendar year in alignment with the APC

requirements.

Results are processed and generated internally using inputs from packaging

and sales data held on file, inputs from our supplier chain partners will also

be used to finalise the report.

:

Goals 1 2011 2012 2013 2014 2015 Format

Notify and identify relevant /responsible persons about the new APG SPG. Q.D

.

Identify and asses existing consumer and distribution packaging materials.

a) Inner packaging. Q.D.

b) Outer packaging R

Identify and asses new consumer and distribution packaging materials . . Q.D.

a) Inner packaging including blister packs from overseas R R

b) Outer packaging R R

Review existing design development process for packaging materials and include the considerations Q.D.

of the APC goals 1.

a) Identify packaging materials with recycled content R R R R R R

B )Identify any packaging materials with increase of recycled content R R R R R R

C )Identify recyclable and reusable packaging R R R R R R

d) Describe progress where GUD avoided and minimised the use of materials and other resources R R R R R R

of its packaging components. R R R R R R

Review GUD Automotives complaint mechanism for the inclusion and reporting product packaging R Q

Document formal procedures where necessary R R R R R QQ

Describe possible areas of where the APC SPG may be implemented Q

a) Report progress of NPD development to incorporate SPG. R R

:

Describe any formal procedures with suppliers to improve packaging design and increase recycling Q

of used packaging R R

Review exiting supplier chain partners Q.D

a)Report on number of successful supplier chain partners R R

R = Report at end of calendar year

D = Data required

Q = Qualitative Information

:

Goals 2 2011 2012 2013 2014 2015 Format

Identify whether GUD AUTOMOTIVE have a take back recycling system directly form consumer. R Q.

.

Identify recovery/recycle systems for distribution and consumer packaging materials at major Q.D.

Distributors. R R R R R

Internal recovery/recycling system for distribution and consumer packaging materials which can be .

Recycled /reused through external processing R R R R R Q.D.

Identify and document processes to buy packaging made from recycled materials. R

Identify policy to buy products made form recycled packaging R Q

Monitor the amount of consumer packaging sourced by packaging type annually R R R R R QQ

Monitor total weight of non recyclable packaging sold annually R R R R R Q

R = Report at end of calendar year

D = Data required

Q = Qualitative Informant

:

Goals 3 2011 2012 2013 2014 2015 Format

Describe any formal processes with suppliers to improve packaging design and increase recycling Q.D

Of used packaging

a) Supplier Questionnaire R

.

Investigate where and how the APC SPG can be implemented during the design and procurement process. R R R R R Q.

Identify packaging without take back systems and why no take back system. Investigate what happens to .

that packaging material Q.

a) Repco R R

b) Bursons R R

Identify industrial waste management contractors and what packaging materials they collect for recycling R Q.D.

a) JJ Richards R

b) Visy recycling R

Identify policy to buy products made form recycled packaging R Q

Monitor the amount of consumer packaging sourced by packaging type annually R R R R R QQ

Monitor total weight of non recyclable packaging sold annually R R R R R Q

R = Report at end of calendar year

D = Data required

Q = Qualitative Information

Environment Management policy

:

ENVIRONMENTAL MANAGEMENT POLICY As a responsible corporate citizen, GUD Automotive Pty. Ltd. is committed to protecting the environment. We are committed to complying with accepted environmental practices. We shall meet or exceed applicable legal requirements and commitments and continually improve the environmental aspects of our business for the benefit of our employees, shareholders and the community at large. Our company will work towards:

• Managing processes and materials to prevent pollution and reduce their impact on the environment

• Reducing usage of hazardous and toxic chemicals

• Reducing and recycling waste and packaging

• Improving the efficiency of energy usage

• Improving our filters to reduce pollution

• Educating employees in environmental management Our environmental management system is based on the International standard ISO 14001 Environmental Management Systems and we shall meet the requirements of this standard as a minimum.

Page 12 of 12National Packaging Covenant August 2005 Issue: Draft CRN:

Feed back

GUD Automotive Pty. Ltd. welcomes your feedback on this action plan,

or any aspect of our interaction with the environment. Any comments

should be addressed to:

George Dearden

Engineering Manager

GUD Automotive Pty. Ltd.

245 Sunshine Road

Tottenham

Victoria

Australia

3012