Profile, Boundary and Scope of Sustainability Reporting

This Sustainability Report follows the same reporting cycle and fiscal year as the Annual Report, i.e. to 31 March 2012, and includes all Group subsidiaries. Joint ventures are not included in the carbon emissions or LTI data, except where they are under the operational control of a DCC subsidiary. There are no significant changes from previous reporting periods in the scope, boundary, or measurement methods applied in the report. There is no restatement of data from the 2011 Sustainability Report.

The content of the report is the same as the prior year, with the material aspects having been initially identified by the Corporate Sustainability Working Group and developed to include additional areas relevant to investors and other stakeholders. Engagement with senior executives at sustainability workshops held during the year confirmed the importance of the material aspects included in this Report.

There is an increasing trend towards integrating sustainability information and analysis into mainstream annual reports to provide stakeholders with a clear and concise representation of how a company creates and sustains value over the long term. The issues highlighted in the sections below are reflected in the operating reviews as appropriate to those businesses and we expect to continue this process until, ultimately, a fully integrated report becomes our practice.

This report meets the requirements of the Global Reporting Initiative level C+ standard, as identified in the content table on page 54. Feedback on this report is welcome and should be addressed to John Barcroft, Head of Group Sustainability or David Byrne, Deputy Chairman and Senior Independent Director.

Governance, Structures and Processes

Good progress has been made in introducing sustainability into existing business processes. Sustainability is now a formal agenda item at subsidiary and divisional board meetings and a number of subsidiaries are formally reporting on the sustainability issues that are material to their businesses. Internal sustainability reporting is evolving and will become a standard process in the short term.

In November 2011, the Corporate Sustainability Working Group (CSWG ), established in 2009, was replaced by a new high level Sustainability Committee which meets quarterly. It is chaired by the Chief Executive and includes divisional and subsidiary managing directors and senior Group executives. The Committee's purpose is to provide strategic oversight and direction to sustainability initiatives. It is focused on ensuring that sustainability delivers tangible value to the businesses and continues to be integrated into existing management processes, rather than being a stand alone function. The Committee has begun the process of developing a medium term sustainability strategy for DCC, setting out clear objectives at both Group and subsidiary level.

Stakeholder Engagement

Investor input is important to our sustainability strategy and we welcome all opportunities to engage with investors. We have responded positively to feedback received and implemented actions to improve our communication and reporting.

One of our key stakeholder groups are the senior executives who lead and develop our businesses. As part of our engagement with this group, over 100 senior executives from all divisions participated in a series of one day sustainability workshops, each tailored to their specific business sectors. The purpose of these workshops was to establish a clear understanding of sustainability and determine actions that could realise value from social and environmental trends. The workshops greatly benefited from the experience and insights of speakers from companies who are sustainability leaders in their respective sectors, including Marks & Spencers, Carillion, BT and Bodyshop International.

Employee issues are reported up through DCC's devolved structure by continuous interaction between subsidiary, divisional and Group management. Employee forums and communications channels within our subsidiaries already include sustainability issues, including health & safety, energy efficiency and community involvement. One of the outcomes from the workshops is a recognition that employee engagement on sustainability could be more systematic.

Material Aspects

Four aspects of sustainability - our people, direct economic value, environment and health & safety - are considered to be material at Group level. These were determined in 2010 by the CSWG , following consultations with senior executives around the Group. A materiality matrix, with levels of importance to stakeholders and to DCC forming the two axes, was used to rate a wide spectrum of sustainability issues, allowing those issues that ranked highly on both axes to be prioritised for reporting. Over time these aspects will develop, for example climate change is now included in a wider commentary on the environment, and we will review them to take account of feedback from investors, customers, employees and other stakeholders.

Individual subsidiaries and divisions have additional aspects that are of particular relevance to them, for example customer engagement, supply chains, employee training and development, waste reduction, water conservation and resource scarcity, which were identified and explored in more detail at the sustainability workshops.

Our People

At 31 March 2012, DCC employed 8,868 people across the Group, approximately 90% of whom are in permanent employment. This figure has increased by approximately 10% from the prior year due to a number of recent acquisitions, in particular the acquisitions by DCC Energy of Maxol Direct, Pace and Butler Fuels in the UK and Swea Energi in Sweden and the acquisition by DCC Environmental of Oakwood Fuels in the UK.

An analysis of DCC employment by division and by geography is as follows:

Graduate Recruitment Programme
The DCC Graduate Programme was put in place to support the development of a pipeline of senior executives who can grow and develop into international business leaders in the future. This two year programme commenced in September 2011 with the first intake of graduates. The 2011 graduates are currently progressing through the rotations within the programme which are designed to expose them to diverse sectors and businesses. To date feedback on the 2011 programme has been very positive, from the perspective of both the participating companies and the graduates. Projects which the graduates have been involved in include:

  • research and review of a warehouse picking technology product to evaluate its potential business value and benefits, including the ease and viability of implementation;
  • marketing and sales support activities, including depot and stakeholder engagement and creation of marketing materials and campaigns;
  • management of 15 networking vendors by creating and executing marketing plans based on specific budgets.

Given the success of the 2011 programme we have hired another tranche of graduates for commencement in September 2012, also on a two year rotational programme.

Business Ethics
DCC published Business Conduct Guidelines in 2011. These record the values of openness, honesty, trust, respect and accountability that are vital to the success of any organisation and provide more detailed guidelines for our employees on specific aspects of business ethics. The Guidelines have been circulated to employees across the Group and are available on our website. We will be taking further steps during the current year, including as part of our Group compliance programme, to ensure that awareness and use of the Guidelines remains strong across the Group.

The DCC Whistleblowing Policy provides a clear mechanism for employee reporting of malpractice or misconduct within the organisation.

Following the enactment of the Bribery Act 2010 in the UK, training workshops were held in August and September 2011 for all UK subsidiaries. Subsequently all Group subsidiaries completed a standard risk assessment to provide information on existing bribery policies and procedures, which were used to finalise anti bribery and corruption policies for each subsidiary. Gifts and hospitality registers were also put in place at both subsidiary and corporate level. The DCC Group Anti Bribery and Corruption Policy was approved by the Board in November 2011 and is on our website.

Direct Economic Value Added

A key measure of our sustainability is the economic value generated from our activities over the long term. Other sections of the Annual Report present detailed financial information, which is summarised in the graphic to represent the principal value added to stakeholders.

In the year ended 31 March 2012, €562 million of added value was created, taking account of the cost of inputs from suppliers of €10,177 million and total income of €10,739 million (€10,690 million revenue as per the Group Income Statement, €32 million finance income and €17 million other operating income). This value added is distributed in the form of remuneration to employees of €345 million, corporate taxes of €28 million, interest to lenders of €50 million and dividends1 to shareholders of €65 million. €74 million is retained in the business to fund further growth.

Community Support
Across the DCC Group, subsidiaries are involved in activities to support local communities and local and national charities. Employees are actively involved in fund raising and giving their time and effort to these campaigns, supported by direct financial contributions from subsidiaries. These financial contributions are managed at local level and are not collated at Group level.

Naomi House
In early 2011, Micro P, a subsidiary of DCC SerCom, took the decision to focus its support for worthwhile causes on specific charities based within the local community. Employees were asked to nominate a charity and they chose Naomi House, a Hampshire based hospice for children. Over the next year Micro P employees actively undertook a host of initiatives ranging from physical undertakings, such as scaling three UK peaks, holding auctions and giving up their time to undertake gardening and maintenance projects, both in work and personal time.

The relationship with this specific charity has developed in a genuine and mutually beneficial way where Micro P has been able to share its most valuable asset, time, and in return feel that it is adding value to the communities in which it operates. An additional benefit has been Micro P's ability to involve key suppliers and customers in the various activities to create a sense of purpose and community.

Social Entrepreneurs Ireland
Following a review in 2010, DCC is focusing its corporate giving resources more strategically and consistently. 2011 was the first year of a three year partnership with Social Entrepreneurs Ireland, an organisation that enables high potential social entrepreneurs to maximise their potential impact. In 2011, DCC contributed management time and direct funding of €120,000 to support the awardee selection process which culminated in an awards ceremony last October, addressed by An Taoiseach, Enda Kenny.

Seán Love, profiled below, is an example of an awardee who is creating real social change using an entrepreneurial business model.

Fighting Words is a creative writing centre that is the brainchild of Seán Love, former director of Amnesty Ireland, and writer Roddy Doyle. Staffed mainly by volunteers, Fighting Words runs free creative writing and storytelling workshops for students of all ages to enhance their creative writing skills and build their confidence in writing ability and self expression.

In just three years the centre has hosted over 32,000 students of all ages in workshops in fiction writing, film-making, song writing and graphic novels. The centre is booked out a year in advance and Social Entrepreneurs Ireland is working with Seán Love to examine models to scale Fighting Words to enable much greater numbers of people to benefit from these workshops.



Climate Change Strategy
Climate change continues to remain high on our agenda. In 2011 we substantially reviewed and updated the DCC Carbon Management Plan to a new DCC Climate Change Strategy designed to identify and prepare for the risks and opportunities arising from climate change. The strategy also introduces a requirement for all subsidiaries to develop a business specific carbon intensity metric (for example kg of CO2e emissions per 1,000 units delivered or manufactured) and establish a target to reduce intensity by 15% in 2015 and 20% in 2020 against performance in the base year to 31 March 2011. We will report on progress towards these targets in subsequent reports. Initiatives to reduce carbon emissions focus on transport emissions and include the continuing roll out of engine monitoring systems, routing software and fuel efficient driver training. Projects such as the installation of heating controls and energy efficient lighting reduce emissions arising from the use of heating fuels and electricity.

Carbon Reduction Commitment Energy Efficiency Scheme
DCC's UK subsidiaries fall within the scope of the Carbon Reduction Commitment Energy Efficiency Scheme (CRC) and a subset of our UK carbon emissions (emissions from transport fuels are not included) for the year ended 31 March 2011 was reported to the Environment Agency in July 2011.

In the second year (to 31 March 2012), a levy of Stg£12 per tonne of relevant carbon emissions generated will be charged resulting in a cost to DCC of approximately Stg£250,000. Following announcements by the UK Chancellor in April 2012, the CRC will be substantially reformed to reduce administrative costs for businesses or will be replaced by an alternative environmental tax by 2014. In either case the incentive remains for our businesses to minimise carbon emissions through energy efficiency measures across all operational areas.

Squadron Medical works with numerous healthcare suppliers to provide NHS Hospitals around the UK with a consolidated logistical service, direct from a central location in Chester field.

As part of their commitment to reducing carbon emissions and providing customers with credible supply chain carbon metrics, Squadron achieved Carbon Trust Standard certification in 2011. As Terry Barnett, Transport Manager explains, "Efficiency measures save energy, cut costs and reduce carbon emissions, delivering real benefits to our business, our customers and the environment. Current initiatives include vehicle telemetry, fuel efficient driver training, introduction of routing software, backhauling and the completion of our new warehouse facility built to a BREEAM2 rating of Very Good."


Fuel Card Services (FCS), a DCC Energy subsidiary, is one of the largest independent agents of fuel cards in the UK, working on behalf of most of the major oil companies.

Anticipating an increasing demand for carbon emissions data associated with fuel use, FCS developed an innovative new service for their customers. CO2Count provides a comprehensive greenhouse gas emissions report with each invoice, detailing emissions data per vehicle and fuel type. At a glance, the user can see their entire fleet's production of greenhouse gases, use the online reporting tool and, month by month, evaluate their emission reduction initiatives.

UK fleet managers have welcomed CO2Count's accurate emissions reporting. "Absolutely sold on the idea, think it's great, will be a real benefit to our company as we need to know this information for when we tender, and when we deal with other companies." Heather Stone, Keith Walton Brickwork Ltd.

Steve Clarke, Fuel Card Services head of marketing, says: "Whether running vans, cars or trucks, customers all face growing pressure to reduce carbon footprints. That has to start with measuring emissions."

Carbon Trust Standard
The Carbon Trust Standard (CTS) is a leading certifier of organisational carbon footprint reductions, providing stakeholders with credible and independent validation of an organisation's performance. Three subsidiaries were newly certified to the CTS in the past year - Wastecycle, GB Oils and Squadron Medical - and Flogas UK successfully passed the CTS recertification process for a further two year period.

Greenhouse Gas Emissions
Details of our energy use and greenhouse gas emissions are set out in the tables opposite. The DCC Energy and Carbon Reporting Guidelines, based on the Greenhouse Gas Protocol, set out in detail the scope and sources included in the DCC Group carbon footprint3. Total carbon emissions were flat compared to the prior year. Within the total, however, there were a number of significant movements in carbon emissions as follows:

  • Reduced transport emissions in the Energy division as a result of lower activity due to the mild winter.
  • The acquisitions of Butler Fuels (DCC Energy) and Oakwood Fuels (DCC Environmental) increased emissions by 2,713 and 2,558 tonnes CO2e respectively and bolt on acquisitions by GB Oils (Pace, Severn Fuels) and Wastecycle (Maxi Waste) further increased emissions.
  • Reduced warehouse and office heating demand as a result of the mild winter.
  • Reduced emissions (4,218 tonnes CO2e) in the Food & Beverage subsidiary Allied Foods, driven by the loss of a significant contract in the logistics business which reduced demand for transport fuels and for electricity to maintain cold storage units.

There were no internal structural changes, for example outsourcing of emitting activities, site openings or closures or new business developments, which had significant impact on the Group's carbon emissions.

Transport and heating fuels from non renewable sources make up the direct sources of primary energy purchased within the Group. In total they represented 1,127,780 Gigajoules (GJ ) of energy. Indirect energy consumption amounted to 159,855 GJ from electricity purchased. Green tariff electricity accounts for less than 1% of indirect energy purchased.

Scope 3 emissions are indirect emissions outside of our immediate control, for example business travel, extraction of raw materials, supplier emissions, consumption of products and waste disposal. While we have not systematically quantified Scope 3 emissions, the use of products sold within the Energy division is a significant source of carbon emissions. The use of oil, LPG and natural gas sold by DCC Energy subsidiaries accounted for approximately 21 Mtonnes of CO2e emissions, an increase from 19 Mtonnes in the prior year. Acquisitions by GB Oils lead to an increase in sales of forecourt diesel and petrol, offset by a decrease in the sale of kerosene heating oil.

Carbon Disclosure Project
In 2011, DCC's response to the investor led Carbon Disclosure Project achieved a score of 83%, placing DCC in the Ireland Carbon Leaders index and in 4th place out of 33 responding companies. The CDP is a global initiative, funded by the investment community, to encourage companies to measure carbon emissions and disclose information on carbon management. We will work to maintain our excellent position on disclosure rankings and, furthermore, demonstrate progress against our carbon reduction targets. In addition to responding to the CDP investor questionnaire, there are early signs that a number of our subsidiaries will be impacted by the CDP Supply Chain Programme as customers increasingly look for carbon data from their suppliers.

Compliance and Spills
No fines or non-monetary sanctions for non-compliance with environmental laws and regulations (for example in relation to waste packaging, waste electronic and electrical equipment, pollution, or environmental licencing) have been incurred in the reporting period and no environmental cases have been brought through dispute resolution mechanisms.

Potential for significant environmental impact from loss of containment of products arises principally in our oil businesses, specifically from sea fed oil terminals. These terminals are regulated under COMAH5 legislation in the UK and subject to regular inspection by the regulatory authorities. Physical control measures, such as bunding and tank gauges/alarms, operational controls, such as tank integrity testing, training and detailed procedures are in place to prevent loss of containment of products. No significant spills were recorded in the reporting period6.

Ozone Depleting Substances
Allied Foods, a DCC Food & Beverage subsidiary, operates chilled and frozen storage warehouses and as such is the most significant user of refrigerant gases, including R22/HCFC22, an ozone depleting substance (ODS)7, within the DCC Group. Smaller quantities of R22 are also used for cooling in Sharptext and Thompson & Capper.
In 2011 a release of 0.208 tonnes of R22 occurred in Allied Foods' Cork facility. This is equivalent to 0.0114 tonnes of CFC-11. Following the release, the remaining R22 was recovered and the unit was refilled with R404A, in advance of the ultimate ban on R22 in 2015. No releases of R22 occurred in Sharptext or Thompson & Capper.
The Allied Foods' Dublin facility uses ammonia as the plant refrigerant gas and small quantities of R404A are used in vehicle chilling units. These gases have an ozone depletion potential of zero.

Health & Safety

Health and safety is a key priority for all divisional and subsidiary managing directors, in particular in the Energy and Environmental divisions where the potential impacts are significant given the nature of the businesses and the products handled. Line managers are responsible for health and safety performance, supported by experienced health and safety professionals.

Near Miss Reporting
A near miss is any situation, behaviour or condition that has the potential to cause an actual incident. As part of our effort to reduce accidents or other losses, employees are actively encouraged to recognise and report near misses. In the past year over 8,000 near misses were reported, including unsafe work practices, substandard housekeeping, defective equipment and unsafe deliveries. Near miss reports are appropriately reviewed and actioned as every report is an opportunity to improve standards and prevent an incident occurring. Over time we believe that this focus, in addition to other health and safety risk management processes, will reduce injury rates, minimise losses and contribute positively to the overall performance of our businesses.

Health and Safety Performance
Health and safety performance is reported monthly to divisional boards and quarterly to the DCC plc Board. Individual subsidiaries use a range of indicators to measure health and safety performance, including both lagging indicators, which measure failures of management systems, for example lost time injury rates, and leading indicators, which monitor the successful implementation of safety management processes, for example performance of safety critical equipment when tested.

Lost time injury rates are recorded at Group level for the operations within the scope of this report. In the reporting period, the lost time injury frequency rate (LTIFR) decreased from 2.5 per 200,000 hours worked to 2.39. At the same time the lost time injury severity rate (LTISR) increased from 48 to 53 days lost per 200,000 hours worked reflecting, on average, more days lost per accident. The improvement in the LTIFR was primarily driven by good performance from the Energy and Environmental divisions. The increase in the LTISR is driven by a relatively small number of accidents resulting in very long periods of time off. In the current year, active case management to facilitate the full recovery of injured parties and their timely return to work will be a focus at a number of subsidiaries, in addition to a renewed focus on the prevention of accidents in the first instance.

Process Safety
Process safety focuses on preventing unintentional releases of products resulting in fire and/or explosion causing a major accident. The provision of an effective process safety management system is a key requirement to minimise the likelihood of a major incident and to meet the safety and environmental standards for fuel storage sites as determined by the Process Safety Leadership Group, which was established to complete the implementation of the Buncefield Major Incident Investigation Board's recommendations. GB Oils is implementing a competence improvement plan for its staff involved with major hazards. In addition, a programme of upgrades has been agreed with the regulator to further reduce the risk and /or consequence of the major hazards at oil terminals, in particular by improving bunding and overspill protection.

Safety Auditing
The International Safety Rating System (ISRS) tool, developed by DNV, a leading risk management company, is used in the EHS audits carried out at our Energy and Environmental subsidiaries, which present a higher EHS risk profile than other subsidiaries. ISRS addresses a range of management processes, driving continuous review of current policies and procedures to develop efficient and effective management systems. The ISRS audit identifies opportunities to further improve processes and quantitatively measures progress over time. With an increased emphasis on leadership, communication and employee involvement, our expectation is that our safety culture will improve and deliver tangible business benefits. The Safety Climate Tool, developed by the Health and Safety Laboratory10, has been used at a number of subsidiaries to objectively assess employees views on safety culture. These surveys provide a measure of the degree to which company management has been successful in raising safety awareness and communicating their commitment to high safety standards. Opportunities for improvement have been identified from the feedback received.

1Paid and proposed for the year ended 31 March 2012
2 BREEAM is one of the most comprehensive and widely recognised measure of a building's environmental performance and sets a standard for best practice in sustainable building design, construction and operation.
3 Carbon dioxide emissions make up over 98% of the Groups greenhouse gas emissions. Other greenhouses gases emissions include fugitive refrigerant gases (e.g. R404A and R407C) from our chilled foods logistics business (860 tonnes CO2e) and fugitive landfill gas emissions from a closed landfill in Scotland where 80% of the methane is captured to generate renewable energy (872 tonnes CO2e).
4 I ncluding DCC head office emissions (<100 tonnes CO2e)
5 Control of Major Accident Hazards
6 Significant is defined as a major environmental event which exceed EC reporting thresholds under COMAH regulations.
7 R22/HCFC22 is a Class II ozone-depleting substances regulated under the Montreal Protocol on Substances that Deplete the Ozone Layer and has an ozone depleting potential of 0.055 compared to CFC11, the standard reference.
8 A Lost Time Injury is defined as any injury that results in at least one day off work following the day of the accident.
9 Company employees only, contractors are not included in lost time injury rates.
10 The Health and Safety Laboratory is an in-house agency of the UK Health and Safety Executive with a mission to directly help organisations become healthier, safer and therefore, more productive places in which to work.

Content table for GRI Level C
GRI Section No. Standard Disclosure Reported
1.1 Statement from Chief Executive Fully
2.1 - 2.10 Organisational Profile Fully
3.1 - 3.8 Profile, Boundary and Scope Fully
3.10 - 3.12 Restatement Fully
4.1 - 4.4 Governance Fully
4.14 - 4.15 Stakeholder Engagement Fully
EC1 Direct Economic Value Fully
EN3 Direct Energy Consumption Fully
EN4 I ndirect Energy Consumption Fully
EN16 Greenhouse Gases Fully
EN17 Other Indirect Sources Fully
EN19 Ozone Depleting Substances Fully
EN23 Spillage Fully
EN28 Non-Compliance Fully
LA1 Workforce Partially
LA7 Rates of Injury Partially
SO2 Corruption Fully
SO6 Political Contributions Fully


What we did and our conclusions

We planned and performed our work, summarised below, to obtain the evidence we considered necessary to reach our assurance conclusions on the Selected Sustainability Data.

What we are assuring (Selected Sustainability Information)

  • The selected sustainability data for the year ended 31 March 2012 marked with the symbol * presented in the Report (the Selected Sustainability Data).
  • DCC's declared Global Reporting Initiative (GRI) application level of C+ of the GRI "G3" Guidelines as stated on page 47 of the Report.

The scope of our work was restricted to the Selected Sustainability Information for the year ended 31 March 2012 and does not extend to information in respect of earlier periods or to any other information in the Report.

How the information is assessed (Reporting Criteria )

DCC's Reporting Criteria at and the GRI G3 Guidelines at set out how the Selected Sustainability Data is measured, recorded and reported.

Assurance standard applied1

ISAE 3000.

Level of assurance2

Limited Assurance.

Understanding DCC's reporting and measurement methodology

There is not yet an established practice for evaluating and measuring sustainability performance information. The range of different, but acceptable, techniques used can result in materially different reporting outcomes which may affect comparability with other organisations. It is therefore important to read and understand the Reporting Criteria at and the GRI G3 Guidelines at that DCC has used to evaluate and measure the Selected Sustainability Data.

Limited assurance work performed on the Selected Sustainability Information

We performed the following activities:

  • Evaluated the design and implementation of key processes and controls over the Selected Sustainability Data;
  • Assessed the source data used to prepare the Selected Sustainability Data for the period 1 April 2011 to 31 March 2012, including re-performing a sample of calculations;
  • Carried out analytical procedures over the Selected Sustainability Data;
  • Examined on a sample basis the preparation and collation of the Selected Sustainability Data, as well as making inquiries of management and others;
  • Performed site visits to ten sites to review systems and processes in place for managing and reporting on sustainability activities, and examined source documentation on a sample basis;
  • With respect to the carbon figures disclosed and marked with the symbol * on page 52 of the Report, we evaluated the methodology and basis of converting the original reported unit into carbon emission equivalent tonnes. We agreed a sample of emission factors back to the stated source (as detailed in the Reporting Criteria);
  • Reviewed the Selected Sustainability Data disclosures; and
  • Assessed the GRI Index on page 54 of the Report for compliance with the GRI application level requirements for C+. This consisted of examining supporting documentation, on a sample basis, where relevant.

Our conclusions

As a result of our procedures nothing has come to our attention that indicates:

  • The Selected Sustainability Data for the year ended 31 March 2012 is not prepared in all material respects with the Reporting Criteria; and
  • DCC's declared GRI application level of C+ above is not fairly stated in all material respects.

DCC's responsibilities

The directors of DCC are responsible for:

  • designing, implementing and maintaining internal controls over information relevant to the Selected Sustainability Information;
  • establishing objective assessment and Reporting Criteria for preparing the Selected Sustainability Data;
  • measuring DCC's performance based on the Reporting Criteria; and
  • the content of the Annual Report.

Our responsibilities

We are responsible for:

  • forming independent conclusions, based on our limited assurance procedures;
  • reporting our conclusions to the directors of DCC; and
  • reading the other information included in the Report as well as the Chief Executive's Review, Group at a Glance, Business Model and Strategy, Corporate

Governance Statement and Report of the Directors of the DCC plc Annual Report, and considering the consistency of that other information with the understanding gained from our work, and considering the implications for our report if we become aware of any material inconsistencies. Our responsibilities do not extend to any information other than the Selected Sustainability Information in the Report.

This report, including our conclusions, has been prepared solely for the directors of DCC as a body in accordance with the agreement between us, to assist the directors in reporting DCC's sustainability performance and activities. We permit this report to be disclosed in the Annual Report for the year ended 31 March 2012, to enable the directors to show they have addressed their governance responsibilities by obtaining an independent assurance report in connection with the Selected Sustainability Information. To the fullest extent permitted by law, we do not accept or assume responsibility to anyone other than the directors as a body and DCC plc for our work or this report except where terms are expressly agreed between us in writing.

Chartered Accountants
Dublin, Ireland
14 May 2012

1. International Standard on Assurance Engagements 3000 (Revised) - 'Assurance Engagements other than Audits and Reviews of Historical Financial Information' issued by the IAASB.

2. Assurance, defined by the International Auditing and Assurance Standards Board (IAASB), gives the user confidence about the subject matter ("Sustainability Information") assessed against the Reporting Criteria. Reasonable assurance gives more confidence than limited assurance. The evidence gathered to support a reasonable assurance conclusion is greater than that gathered to support a limited assurance conclusion.

3. We comply with the applicable independence and competency requirements of the Chartered Accountancy Regulatory Board (CARB) Code of Ethics.

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