GN4.1: An energy policy

Guidance Note purpose 

The purpose of this Guidance Note is to guide asset managers, property managers and facilities managers in the development of an Energy Policy. The principles covered in this Guidance Note could also inform the development of a wider ‘energy and water’ or ‘utilities policy’. 


An Energy Policy sets out a company’s high-level energy intent, and describes the framework through which energy will be managed.  The policy should demonstrate senior management’s commitment to improving energy performance, and can provide a foundation on which to develop any wider Energy Management System. 


There are no regulatory requirements to establish an Energy Policy within commercial real estate.  However, certain rating and certification schemes, for example ISO5001, do require that an Energy Policy is in place. An Energy Policy can also contribute towards outcomes of regulatory processes, such as the requirement to conduct an energy assessment as part of the UK Government’s Energy Saving Opportunity Scheme (ESOS)

The primary benefit provided by an Energy Policy relates to the positioning of energy within a company as a topic which requires specific focus and continual improvement in management and performance. This positioning provides a range of positive outcomes, including: 

  • Raising the awareness of stakeholders, such as investors and occupiers, of the importance of energy to the company, and its intent manage energy effectively. 
  • Clarifying the scope and boundaries of energy management, along-with high level energy management responsibilities.   
  • Establishing a company’s energy performance aspirations and primary focus areas. 
  • Supporting engagement with employees, occupiers and other stakeholders as part of a collaborative approach to continual improvement. 

Responsibilities & Interests

The table below summarises the key activities associated with developing and maintaining an Energy Policy, and highlights where asset managers, property managers and facilities managers are likely to have a responsibility or specific interest. 

  • AM - Asset Manager
  • PM - Property Manager
  • FM - Facilities Manager

Develop scope 

Stakeholder :

Identify legal and other obligations 


Set performance objectives and targets 


Secure resources and establish responsibilities 


Review energy management and performance 


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How to



An Energy Policy is usually established at the company level.  While the focus of an Energy Policy may vary between asset managers, property managers and facility managers, the process for developing and maintaining an Energy Policy can be applied consistently. 

It is important that an Energy Policy is endorsed by a company’s senior management, is documented, and is communicated to employees throughout a company and is available to stakeholders.  The Energy Policy should be reviewed at least annually, and updated to reflect to update its suitability for the organisation. 

Developing and maintaining an Energy Policy, you should include the following steps: 

Step 1: Develop scope


An Energy Policy should clearly set out the scope of the organisation within which energy will be managed.  The scope of an Energy Policy may be set at either the company, portfolio of individual property level and should describe the location and types of properties covered, as well as energy sources and significant utilization. 

It is important to address the operational boundaries of energy use between individual occupiers, as well as reference to shared spaces. 

Step 2: Identify legal and other obligations


It is important that an Energy Policy includes a clear commitment to comply with applicable legal and other obligations relating to energy utilisation. 

This may include regulatory requirements, for example ESOS.  It may also include non-regulatory requirements, for example associated planning conditions, such as the on-site renewable generation, or voluntary commitments, such as the adoption of green tariffs.  Legal and other obligations should be collated in a register for reference. 

Step 3: Set performance objectives and targets


An Energy Policy should make reference to the continual improvement of energy performance.  This should be accompanied by a commitment to establish objectives, improvement targets and associated actions.   

Objectives could relate to reducing energy consumption, improving energy efficiency or and increasing the proportion of energy from renewable sources. Targets should be Specific, Measurable, Achievable, Relevant and Timebound. 

Consideration should be given to the scope of the energy policy, and the way in which objectives, targets and actions relate to consumption that is specific to operators as well as within common or shared areas. 

Step 4: Secure resources and establish responsibilities


The resources available to support the achievement of energy objectives and targets, alongside high-level responsibilities for implementing actions and governing progress, should be clearly described within an Energy Policy. 

This may include responsibilities of a dedicated Energy Manager, were relevant. In addition, responsibilities should make reference to managers of key functions, such as facilities management, occupiers and contractors. It is also important to reference the oversight responsibilities of senior management. 

Step 5: Review energy management and performance


An Energy Policy should make reference to the way in which energy performance, and progress towards energy objectives and targets, are reviewed.  This may involve establishing a dedicated forum to review energy management, or it could relate to the inclusion of energy within existing environment or health and safety forums.   

An Energy Management System  

An Energy Policy can provide the foundation for a wider Energy Management System (EnMS).  With potential to certify to schemes such as ISO50001.  An EnMS enables the systematic management of energy and should involve consideration of the following factors:  

  • Review historic and current energy use. 
  • Identify sources of significant energy use. 
  • Create an energy baseline. 
  • Establish objectives, targets, and timeframes. 
  • Develop an energy action plan to achieve objectives and targets. 
  • Provide training to employees and contractors. 
  • Raise awareness of energy performance and the EnMS with stakeholders. 
  • Document related policies and procedures. 
  • Monitor, measure, and review energy performance. 
  • Address under-performance and non-conformities and take corrective action. 
  • Undertake a management review of the Energy Policy and Energy Management System.  

Related Guidance Notes

The following Guidance Notes contain related information: 

Additional Resources