UN Global Compact 2023 Communication on Progress

COMMUNICATION ON PROGRESS QUESTIONNAIRE

Governance
Policies and Responsibilities
What is the time period covered by your Communication on Progress? (MM/YYYY) – (MM/YYYY)
01/2022-12/2022
G1. Does the board/highest governance body or most senior executive of the company:
Linked to: GRI Disclosures 2-12, 2-14, 2-22 (2021)
(Multiple choice -Select all that apply)
Issue an annual statement about the relevance of sustainable development to the company
Issue an annual statement that addresses impacts on both people and the environment
Issue an annual statement highlighting a zero tolerance for corruption
Sign off on organizational sustainability targets
Supervise Environmental, Social, and Governance reporting
Regularly review potential risks related to the business model
None of the above
Please provide additional explanation:
Please refer to our annual report pages 26-35. At Huhtamaki, sustainability is ultimately governed by the Board of Directors and at the operational level, by the CEO, the Global Executive Team, the Sustainability Global function and other senior staff across the different business units. The Board is the highest body to approve the guiding policies for sustainability and outline sustainability principles regarding the Group’s strategy. It monitors and evaluates the risk management activities of the Group, including the sustainability risks and impacts such as climate-related financial risks. It approves the risk level that the Group is capable and prepared to accept and the extent to which risks have been identified, addressed, and followed up. The Group’s sustainability performance is tracked regularly in its operations. The results are collected and monitored at Group-level in the sustainability dashboard which is reviewed and discussed in the Global Executive Team and presented quarterly to the Board of Directors. Annual statements about sustainability's relevance and Huhtamaki's impacts on people and the environment as well as a zero tolerance statement can be found in our annual reports under the Non-Financial Review. The Audit Committee of the Board supervises our sustainability reporting.
G2. Does the company have a publicly stated commitment regarding the following sustainability topics?
Linked to: GRI Disclosure 2-23 (2021)
(Matrix – Select one answer option per line)
No, this is not a current priority
No, but we plan to within the next two years
Yes, and the commitment is focused on our own operations
Yes, and the commitment includes our own operations and suppliers
Yes, and the commitment includes our own operations and the value chain (including suppliers, consumers, communities, other business relationships)
Human Rights
Labour Rights/ Decent Work
Environment
Anti-Corruption
Please provide additional explanation:
We have our Human Rights Policy, Code of Conduct (covering human rights, labor rights, environment and anti-corruption), Environmental Policy publicly available on our website. These policies provide principles which outline the standards for our own work and we expect the same standards from our suppliers. Moreover, our Supplier Code of Conduct states the expectations for our suppliers. Our policies also include commitments made that cover communities we operate in, consumers or business relationships. References: Human rights: Annual report, pages 183 & 196; Human Rights Policy: https://www.huhtamaki.com/en/sustainability/reports-and-policies/global-human-rights-policy/ Labor rights: Annual report, pages 180, 196; Human Rights Policy: https://www.huhtamaki.com/en/sustainability/reports-and-policies/global-human-rights-policy/ Environment: Annual report, pages 180, 181, 183; Environmental Policy: https://www.huhtamaki.com/globalassets/global/sustainability/policies/group-environmental-policy/huhtamaki_group_environmental_policy_-v3.0.pdf Anti-corruption: Annual report, page 191; Code of Conduct: https://www.huhtamaki.com/en/sustainability/reports-and-policies/code-of-conduct/ For all, also check our Supplier Code of Conduct here https://www.huhtamaki.com/en/sustainability/reports-and-policies/code-of-conduct-for-suppliers/.

huhtamaki-global-human-rights-policy-1.2.pdf
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huhtamaki_code_of_conduct_english.pdf
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huhtamaki-oyj-annual-report-2022 (2).pdf
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huhtamaki_group_environmental_policy_-v3.0 (1).pdf
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code-of-conduct-for-huhtamaki-suppliers.pdf
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G3. Does the company have in place a code of conduct regarding each of the following sustainability topics?
Linked to: NASDAQ G6.1; GRI Disclosure 2-23 (2021)
(Matrix – Select one answer option per line)

No, this is not a current priority
No, but we plan to within the next two years
Yes, focused on employee conduct
Yes, focused on employees and suppliers
Yes, focused on our own operations and the value chain (including suppliers, consumers, communities, other business relationships)
Human Rights
Labour Rights/ Decent Work
Environment
Anti-Corruption
Please provide additional explanation:
We have publicly available our Human Rights Policy, Code of Conduct (covering human rights, labor rights, environment and anti-corruption), Environmental Policy and Supplier Code of Conduct available on our website. These policies provide principles which outline the standards for our own work and we expect the same standards from our suppliers. References: Code of Conduct here https://www.huhtamaki.com/en/sustainability/reports-and-policies/code-of-conduct/ Supplier Code of Conduct here https://www.huhtamaki.com/en/sustainability/reports-and-policies/code-of-conduct-for-suppliers/ Human Rights Policy: https://www.huhtamaki.com/en/sustainability/reports-and-policies/global-human-rights-policy/ Environmental Policy: https://www.huhtamaki.com/globalassets/global/sustainability/policies/group-environmental-policy/huhtamaki_group_environmental_policy_-v3.0.pdf
G4. Has the company appointed an individual or group responsible for each of the following sustainability topics?
Linked to: GRI Disclosure 2-13 (2021)
(Matrix – Select one answer option per line)
No one is specifically responsible for this topic
Yes, with limited influence on outcomes (e.g., limited access to internal information, limited decision-making authority)
Yes, with moderate influence on outcomes (e.g., has access to relevant information, reports to senior manager)
Yes, with direct influence of some outcomes (e.g., has access to relevant information, includes one or more senior manager with decision making rights)
Yes, with direct influence at the highest levels of the organization (e.g., has access to relevant information, includes most senior members of organization)
Human Rights
Labour Rights/Decent Work
Environment
Anti-Corruption
Please provide additional explanation:
Please refer to our annual report page 26: At Huhtamaki, sustainability is ultimately governed by the Board of Directors and at the operational level, by the CEO, the Global Executive Team, the Sustainability Global function and other senior staff across the different business units. At highest levels of the organisation, our EVP Sustainability and Communications is responsible for Human Rights and Environment, our EVP HR for labor rights and our EVP Legal for Anti-Corruption.
G5. Does the company have a formal structure(s) (such as a cross-functional committee) to address each of the following sustainability topics?
Linked to: GRI Disclosures 2-9, 2-13 (2021)
(Matrix – Select one answer option per line)
No formal structure
Yes, and with limited influence on outcomes (e.g., limited access to internal information necessary to understand risks, poor representation from relevant departments or functions)
Yes, with moderate influence on outcomes (e.g., it includes representatives of some functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, reports to senior manager)
Yes, with direct influence on some outcomes (e.g., it includes representatives of functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, it involves one or more members of senior management)
Yes, and with direct influence at the highest level of the organization (e.g., full access to relevant information, it involves members at highest level of organization)
Human Rights
Labour Rights/Decent Work
Environment
Anti-Corruption
Please provide additional explanation:
Huhtamaki has working groups and committees for specific topics. Sustainability matters including environmental and social topics are discussed in a quarterly Sustainability Committee which consists of the CEO and President, EVP Sustainability and Communications, EVP Legal, EVP Strategy and Business Presidents. HR Leadership team and Social Sustainability Steering Group discuss social sustainability topics.
Prevention
G6. Does the company have a process or processes to assess risk?
Linked to: GRI Disclosure 205-1 (2016)
(Matrix – Select one answer option per line)
No, this is not a current priority
No, but we plan to within the next two years
Yes, related to our own operations
Yes, related to our own operations and suppliers [Prompts G6.1]
Yes, related to our own operations and the value chain (including suppliers, consumers, communities, other business relationships) [Prompts G6.1]
Human rights risks
Labour rights risks
Environmental risks
Corruption risks
Please provide additional explanation:
Please provide additional information: Please see pages 140-141 (materiality assessment), 143 (governance structure), 184 (human rights working group), 192-193 (anti-corruption), 194-195 (responsible sourcing), 34-36 (details of our risk management process and sustainability risks). Huhtamaki conducts risk assessments for company risks annually. The Enterprise Risk Management (ERM) of Huhtamaki covers the assessment of sustainability risks and opportunities. Huhtamaki's risk management process is based on Enterprise Risk Management (ERM) framework of Committee of Sponsoring Organizations of the Treadway Commission (COSO). Our risk management is an on-going process focusing on events - opportunities or threats - potentially accelerating or compromising the achievement of the Group's strategic, operational and financial objectives in a changing business environment. Huhtamaki risk review process is conducted parallel to the strategic planning process at the business unit, segment and Group levels. The risk assessment results are consolidated from business unit to segment and further to Group level and used to identify the key risks at segment and Group levels. At each level from business unit to Group, risk treatment actions are subsequently defined in order to reach acceptable risk levels. The acceptable risk levels associated with appropriate risk management efforts are approved by the Global Executive Team (GET), reviewed by the Audit Committee of the Board of Directors and finally approved by the Board of Directors (BoD). Decisions on managing local and less significant risks and opportunities are taken by the relevant business segment and/or unit management. Decisions on significant risks are escalated to GET and, if needed, to the BoD. Strategic sustainability risks relate to changes in the business environment or events that may impact the Group’s reputation. Operational sustainability risks relate to production, human resources, crime and fraud. Environmental risks include e.g. disruption in raw material or energy supply, natural disasters possibly leading to property damage or business interruption. To minimize the impact of a potential business interruption, Huhtamaki maintains and further develops its disaster recovery and business continuity plans and allocates manufacturing capacity to several locations. In terms of human rights and labor risks, they are implemented in the sustainability risk review process. In the 2022 ERM assessment, occupational health and safety, product safety and quality risks, non-compliance with laws and sanctions, human rights and sustainability requirements affecting manufacturing units or processes were considered medium or medium-low risks to the Group. Sustainability is also considered in connection with reputational risks relating to products, employer image, governance, and corporate citizenship. Reputational risks are considered to pose a medium-low risk to the achievement of Huhtamaki’s objectives.
G6.1 During the assessment of risk, has your company reviewed those suppliers and/or other business relationships where the risk related to human rights, labour, environment and/or anti-corruption may be particularly severe?
(Matrix – Select one answer option per line)
No
Yes
Human rights risks
Labour rights risks
Environmental risks
Corruption risks
Please provide additional explanation:
Our supplier risk assessment process outlines that where risk is considered to be particularly severe, key suppliers are contacted. See annual report pages 194-195.
G7. Does the company have a due diligence process through which it identifies, prevents, mitigates, and accounts for actual and potential negative impacts on sustainability topics?
Linked to: GRI Disclosures 2-12, 2-23-a-ii, 3-1, 3-3-d (2021)
(Matrix – Select one answer option per line)
No, this is not a current priority
No, but we plan to within the next two years
Yes, related to our own operations
Yes, related to our own operations and suppliers [Prompts G7.1]
Yes, related to our own operations and the value chain (including suppliers, consumers, communities, other business relationships) [Prompts G7.1]
Human rights risks
Labour rights risks
Environmental risks
Corruption risks
Please provide additional explanation:
We are committed to taking responsibility for the impact we have on individuals and communities we operate in. This means for example continuing to systematically incorporate human rights due diligence processes into our overall operations, guidelines and processes. Ensuring that human rights are respected throughout our value chain is a key element of Huhtamaki’s 2030 sustainability agenda. Since 2020, we have worked with a cross-functional team and external human rights experts to identify our potential human rights risks and impacts. This work has included both a global-level gap analysis, as well as two human rights impact assessments – in Egypt in 2021 and Thailand in 2022. More about our human rights due diligence process can be found in our annual report on page 184. At Huhtamaki we have a risk assessment process in place for suppliers that looks at corruption and ESG (including human rights). Our current supply chain due diligence processes are based on the following key elements: 1. Code of Conduct for Huhtamaki Suppliers 2. Screenings and questionnaires, targeted to key suppliers through the NAVEX RiskRate tool 3. Third-party corporate responsibility audits, utilizing Sedex tools. As a global company, we work with approximately 20,000 suppliers around the world. To better manage our risks and impacts efficiently, our due diligence efforts are currently focused on our key suppliers. These are strategically important suppliers that fall into the top 80% of our procurement spend, or that act as the only suppliers of a specific raw material or service to Huhtamaki, falling mainly into one of the following categories: Traded Goods, Distributor, Raw Material Supplier, Transportation or Warehouse, Consultant, Insurance or Benefits Supplier, Utility or Energy Supplier, or Contractor. The Code of Conduct for Huhtamaki Suppliers is the governing basis for our supply chain due diligence and clearly lays out what we expect our suppliers to comply with. It covers topics related to social and environmental sustainability, as well as business ethics.
G7.1 During the due diligence process, has your company reviewed those suppliers and/or other business relationships where the risk of adverse impacts on human rights, labour, environment and/or anti-corruption may be particularly severe?
Linked to: GRI Disclosures 2-23-e, 3-1 (2021)
(Matrix – Select one answer option per line)
No
Yes
Human rights risks
Labour rights risks
Corruption risks
Please provide additional explanation:
Our current supplier DD screening process currently assesses and assigns risk based on factors including country of location, total spend, type of service or product supplied and beneficial owner relationships. We apply extra scrutiny to those identified as high risk based through a more in-depth onboarding questionnaire. If there are unsatisfactory answers in the questionnaires we follow up with the supplier to get more information.
Concerns and Grievance Mechanisms
G8. Are there any processes through which members of the company’s workforce can raise concerns about the company’s conduct related to human rights, labour rights, environment, or anti-corruption?
Linked to: Reporting Guidance on the 10th Principle Against Anti-corruption – B3; GRI Disclosure 2-26 (2021)
(Radial – Select One)
No, this is not a current priority
No, but we plan to within two years
Yes, we have an informal process (e.g., through supervisors, others) [Prompts G8.1]
Yes, we have a formal process [Prompts G8.1]
Please provide additional explanation:
Please refer to our annual report page 192-193: Huhtamaki maintains multiple channels for voicing concerns. In cases where direct reporting is not possible, employees can report any suspected violation through the Huhtamaki Speak Up channel. This is a global, online whistleblowing system operated by an external provider and managed by Huhtamaki Global Ethics and Compliance.
G8.1. Please provide additional detail regarding the process(es) the company has through which members of the company’s workforce can raise concerns about the company’s conduct.
Linked to: GRI Disclosure 2-26 (2021)
(Matrix – Select one answer option per line)
No
Yes
Is the process communicated to all employees/workers in local languages
Is the process available to non-employees (e.g., suppliers, consumers, communities, and other business relationships)
Is the process confidential (e.g., whistleblowing process)
Are there processes in place to avoid retaliation
Can concerns be raised about suppliers or other business relationships (e.g., clients, partners, etc.)
Other
Please provide additional explanation:
Please refer to our annual report page 192-193: Huhtamaki maintains multiple channels for voicing concerns. In cases where direct reporting is not possible, employees can report any suspected violation through the Huhtamaki Speak Up channel. This is a global, online whistleblowing system operated by an external provider and managed by Huhtamaki Global Ethics and Compliance.
Lessons
G9. How does the company capture lessons regarding each of the following sustainability topics?
Linked to: GRI Disclosure 3-3-e (2021)
(Matrix – Select one answer option per line)
No lessons are regularly captured
Conducts root cause analyses/investigation of incidents
Conducts root cause analyses/investigation and changes organizational policies, processes, and practices accordingly
Systematically conducts root cause analyses/investigation and leverages learnings to influence both internal and external affairs
Human Rights
Labor Rights/Decent Work
Environment
Anti-Corruption
Please provide additional explanation:
Executive Pay
G10. Is executive pay linked to performance on one or more of the following sustainability topics?
Linked to: CDP W6.4 (2022), CDP F4.3a (2022), CDP C1.3a (2022); Nasdaq G3 2335; GRI Disclosure 2-19 (2021)
(Matrix – Select one answer option per line)
No, and we have no intention to change for this is not a current priority
No, but we plan to within two years
Yes
Human Rights
Labour Rights/Decent Work
Environment
Anti-Corruption
Please provide additional explanation:
For the reporting year 2022, we rolled out sustainability linked objectives to all employees that participate in the short-term incentive plan. This took the form of either a site- or segment-specific sustainability objective or our Global Sustainability Index, the GSI. The GSI was first introduced into the incentives of the Global Executive Team in 2021. The index tracks our progress towards our 2030 sustainability ambitions. KPIs within the index are linked to our sustainability dashboard and relate, for example, to frequency rate of medical treatment injury, the share of renewable or recycled materials, the share of renewable electricity, and the share of non-hazardous waste recycled. We are currently assessing our options on linking human rights and anti-corruption-related KPIs to executive pay incentives. We have a Code of Conduct that aligns Huhtamaki's minimum conduct standards expected of every Huhtamaki employee on human rights, labour rights & decent work, environment and anti-corruption. All our employees, including executives must follow these principles and failure to comply with the Code may result in disciplinary actions and even termination of employment.
Board Composition
G11. Percentage of individuals within the company’s board/highest governance body by:
Linked to: ISAR D.1.2 (2019), ISAR D.1.3 (2019); GRI Disclosures 2-9 (2021), 405-1 (2016)
(Matrix – Percentage & Radial)
Number (Please input answer as a whole number (e.g., 95% = 95))
Not applicable
Total number of board members (#)
Male (%) Note: Please input answer as whole number (e.g., 95% = 95)
Female (%) Note: Please input answer as whole number (e.g., 95% = 95)
Non-binary (%) Note: Please input answer as whole number (e.g., 95% = 95)
Under 30 years old (%) Note: Please input answer as whole number (e.g., 95% = 95)
30-50 years old (%) Note: Please input answer as whole number (e.g., 95% = 95)
Above 50 years old (%) Note: Please input answer as whole number (e.g., 95% = 95)
From minority or vulnerable groups (%) Note: Please input answer as whole number (e.g., 95% = 95)
Executive (%) Note: Please input answer as whole number (e.g., 95% = 95)
Independent (%) Note: Please input answer as whole number (e.g., 95% = 95)
Please provide additional explanation:
Please refer to our annual report pages 113-117. We do not collect information about Board members' minority status.
G12. Do you produce sustainability reporting according to:
Linked to: Nasdaq G9.1
(Select all that apply)
National/local regulation on sustainability
Security exchange regulations
Non-Financial Reporting Directive of the European Union (NFRD)
Global Reporting Initiative (GRI)
Sustainability Accounting Standards Board (SASB, now consolidated into the IFRS Foundation)
International Integrated Reporting Council (IIRC, now consolidated into the IFRS Foundation)
Climate Disclosure Standards Board (CDSB, now consolidated into the IFRS Foundation)
Task Force on Climate-related Financial Disclosures (TCFD)
Other voluntary frameworks (Please specify in text box) [Makes text box mandatory]
No sustainability reporting according to any frameworks nor regulations outside of this Communication on Progress
Please provide additional explanation:
See Annual Report pages 28, 204-209.
Data Assurance
G13. Is the information disclosed in this questionnaire assured by a third-party?
Linked to: CDP C10.1 (2022); GRI Disclosure 2-5 (2021)
(Select all that apply)
Limited assurance for minority of metrics (e.g., GHG emissions only)
Limited assurance for majority of metrics
Reasonable assurance for minority of metrics
Reasonable assurance for majority of metrics
Other (Please provide additional information) [Makes text box mandatory]
No assurance for any metrics
Please provide additional explanation:
See Annual Report page 203.
Human Rights
Materiality (including Saliency)
HR1. Which of the following has the company identified as material human rights topics connected with its operations and/or value chain, whether based on their salience (e.g., the most severe potential negative impacts on people) or another basis?
Linked to: GRI Disclosure 3-2 (2021)
(Select all that apply)
Freedom of association and the effective recognition of the right to collective bargaining
Child labour
Forced labour
Non-discrimination in respect of employment and occupation
Safe and healthy working environment
Working conditions (wages, working hours) [Prompts additional line ‘Working conditions (wages, working hours)’ in Questions L1, L2, L3, L4, L5, L11]
Freedom of expression [Prompts additional line ‘Freedom of expression’ in Questions HR2–HR7]
Access to water and sanitation [Prompts additional line ‘Access to water and sanitation’ in Questions HR2–HR7]
Digital security/privacy [Prompts additional line ‘Digital security/privacy’ in Questions HR2–HR7]
Gender equality and women’s rights [Prompts additional line ‘Gender equality and women's rights’ in Questions HR2–HR7]
Rights of indigenous peoples [Prompts additional line ‘Rights of indigenous peoples’ in Questions HR2–HR7]
Rights of refugees and migrants [Prompts additional line ‘Rights of refugees and migrants’ in Questions HR2–HR7]
Other [Textbox Mandatory]
No human rights topics have been identified as material
Please provide additional explanation:
In 2021, we performed a global human rights assessment, which gave us a high-level overview of potential human rights risks and impacts in our own operations and across the supply chain. The assessment helped us to better understand our impact on human rights, to identify potential vulnerable groups, and to align our human rights due diligence with the recommendations of the UNGP. The analysis resulted in the development of a heat map and of a preliminary list of salient human rights issues. Along with this global, high-level analysis, we have conducted human rights impact assessments at two of our operating sites. The first assessment was conducted as a pilot at our Flexible Packaging site in Egypt in late 2021, followed by a second assessment at our Flexible Packaging site in Thailand in 2022. The results from both the global assessment and the site level assessments indicate that the potential human rights impacts in our own operations relate to for example, employees’ health and safety, working conditions, working hours and rest, discrimination, and the position of service providers. Through the actions of our suppliers, we can also have an indirect impact on the fundamental human rights of employees upstream in the value chain, including topics such as working hours, wages or forced labor. The assessments have also helped us identify the vulnerable groups that we need to take into special consideration when assessing our human rights impacts. For Huhtamaki, such groups are migrant workers and their families, local communities, as well as women and children. For more information, please see Annual Report pages 141 and 184.
Commitment
HR2. Does the company have a policy commitment in relation to the following human rights topics? Matrix will be populated only for the human rights topics selected in HR1.
Linked to: GRI Disclosures 2-23-a-iv, 2-23-b, 3-3-c (2021)
(Matrix – Select one answer option per line)
No, and we have no plans to develop a policy
No, but we plan to within the next two years
Yes, included within a broader policy or as a stand-alone policy
Gender equality and women’s rights
Rights of refugees and migrants
Please provide additional explanation:
Our Code of Conduct lines that Huhtamaki is committed to diversity and equal employment opportunity. The unique attributes and perspectives of every employee are respected. Equal treatment and equal employment opportunity are provided to everyone without regard to race, color, religion, gender, sexual orientation, national origin, age, disability, veteran, marital or domestic partner status, citizenship, family relationship or any other similar characteristic. Additionally, our Code of Conduct for Supplier lines that all suppliers must provide equal treatment and equal employment opportunity to everyone without regard to race, color, gender, age, religion, marital status, sexual orientation, political opinion, or national or ethnic origin, or other similar characteristics. This applies to all aspects of employment decisions. For rights of refugees and migrants, we have local human rights and employment policies for countries where we employ migrants. They cover topics such as right to breaks, prohibition of forced labor, equal employment opportunity, anti-harassment and working hours. These policies are internal.

huhtamaki_code_of_conduct_english.pdf
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code-of-conduct-for-huhtamaki-suppliers.pdf
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Please input the year the relevant human rights policy was last reviewed
Year (YYYY)
Gender equality and women’s rights
Rights of refugees and migrants
Please provide additional explanation:
2018 for Code of Conduct, 2019 for Supplier Code of Conduct 2022 for one of our most recent policies for migrant workers
HR2.1. For each human rights policy commitment, is it:
Linked to: GRI Disclosures 2-23-c, 2-23-d, 2-23-e (2021)
(Matrix – Select all that apply for each line)
Aligned with international human rights standards
Publicly available
Approved at most senior level of the company
Applied to the company’s own operations
Applied to the company’s own operations and suppliers
Applied to the company’s own operations and the value chain (including suppliers, consumers, communities, other business relationships)
Developed involving human rights expertise from inside and outside the company
Other (Please provide additional information in the mandatory text box)
Gender equality and women’s rights
Rights of refugees and migrants
Please provide additional explanation:
Code of Conduct for own operations, Code of Conduct for Suppliers for value chain for gender equality and women's rights.
Prevention
HR3. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following human rights topics? Matrix will be populated only for the human rights topics selected in HR1.
Linked to: GRI Disclosures 3-1-b, 3-3-f (2021)
(Matrix – Select one answer option per line)
Please select the company’s highest level of engagement. Options progress from left to right.
No engagement on this topic
To better understand the risks/impacts in question
To discuss potential ways to prevent or mitigate the risks/impacts in question
To agree on a way to prevent/mitigate the risks/impacts in question
To assess progress in preventing/ mitigating the risks/ impacts in question
To collaborate in the prevention/mitigation of the risks/impacts in question
Gender equality and women’s rights
Rights of refugees and migrants
Please provide additional explanation:
In relation to gender equality, two key initiatives took place in 2022. In our Flexible Packaging site in Istanbul, Turkey, the local management has introduced a roadmap for diversity, equity and inclusion. In 2022, the site created an initiative to increase the number of female employees in production roles from 0 to 100 with the goal to create a gender-balanced workforce and promote awareness of diversity and inclusion practices. By the end of the year 42 female workers had been recruited. In India, the I-WIN (Women Inclusive Network) program was launched in 2022 to promote an inclusive work environment and to support women employees on their career development journey. The program includes awareness raising about diversity and inclusion, training sessions on topics such as unconscious bias, as well as professional development courses that support female employees in strengthening leadership and management competencies. The program also includes creating local policies and processes that ingrain diversity and inclusion in the day-to-day activities of the company. In relation to rights of refugees and migrants, we visit dormitories for migrants to better understand risks related to migrant workers.
HR4. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this human rights topic?
Matrix will be populated only for the human rights issues selected in HR1.
Linked to: GRI Disclosure 3-3-d (2021)
(Matrix – Select all that apply for each line)
Provided internal training/ capacity building for the direct workforce
Built capacity among relevant business relationships (e.g., suppliers, consumers, communities)
Conducted an audit process and/or corrective action plan
Collective Action with peers or other stakeholders, in particular workers’ organizations, to address the issue
Collaborated with governmental or regulatory bodies
Other (Please provide additional information in the mandatory text box)
No action within reporting period
Gender equality and women’s rights
Rights of refugees and migrants
Please provide additional explanation:
We have provided a modern slavery and human trafficking training targeted to all managers and experts in supply chain and HR organisations, and available for all employees. Human rights is also a part of our sustainability e-learning. Also, we annually hold a global online training day on Sustainability which covers e.g. human rights and DEI topics. For selected employees, we arrange anti-harassment and unconscious bias training. We visit dormitories for migrants to better understand risks related to migrant workers. In addition, external social responsibility audits performed.
HR5. Who receives training for the following human rights topics? Matrix will be populated only for the human rights topics selected in HR1.
Linked to: GRI Disclosure 3-3-d (2021)
(Matrix – Select all that apply for each line)
No training provided
Select employees
All employees
Contractors
Direct suppliers of the organization
Indirect suppliers of the organization
Other – such as partners, clients, etc.
Gender equality and women’s rights
Rights of refugees and migrants
Please provide additional explanation:
For gender equality, we have done various trainings for selected employees, e.g. anti-harassment training, unconscious bias training, a DEI and Gender Equality Case study in Sustainability Learning Day 2022 that takes place annually. Relating to migrants and refugees, we have provided a modern slavery and human trafficking training targeted to all managers and experts in supply chain and HR organisations, and available for all employees.
HR6. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following human rights topics? Matrix will be populated only for the human rights issues selected in HR1.
Linked to: GRI Disclosure 3-3-e (2021)
(Matrix – Select one answer option per line)
Please select the company’s highest level of engagement. Options progress from left to right.
No monitoring of progress
Review topics on ad hoc basis
Set annual targets/goals, track progress over time (internal programmes only)
Set annual targets/goals, track progress over time (internal and external programmes)
Other (Please provide additional information in the mandatory text box)
Gender equality and women’s rights
Rights of refugees and migrants
Please provide additional explanation:
Response and Reporting
HR7. During the reporting period, has the company been involved in providing or enabling remedy if it has caused or contributed to adverse impact associated with the following human rights topic(s)?
Matrix will be populated only for the human rights topics selected in HR1.
Linked to: GRI Disclosure 3-3-d-ii (2021)
(Matrix – Select one answer option per line)
No remedy provided/enabled
Yes, remedy provided/enabled
No adverse impact identified or caused
Choose to not disclose
Gender equality and women’s rights
Rights of refugees and migrants
Please provide additional explanation:
HR8. Briefly describe additional relevant practical actions the company has taken during the reporting period and/or plans to take to implement the human rights principles, including goals set and any challenges faced and actions taken towards prevention and/or remediation.
Linked to: GRI Disclosures 3-3-c and 3-3-d (2021)
(Text Box)
In 2022, we continued building on efforts launched in 2021 to strengthen our existing processes to better integrate human rights considerations into our processes and operating model. We also conducted our second human rights impact assessment at site level, to complement a high-level, global assessment that was performed in 2021. The results of these assessments inform the development of our human rights due diligence activities. Other actions that we took in 2022: We established a cross-functional working group to drive initiatives and to follow up on the findings from human rights impact assessments. We worked together with the mergers and acquisitions team to look for ways to strengthen the due diligence process related to mergers and acquisitions from a human rights perspective. We also continued developing the framework to enhance monitoring our own sites, using an external human rights expert to identify gaps in our current auditing practices and looking for ways to incorporate human rights assessments more comprehensively. Our supply chain due diligence process was strengthened for example by increasing the number of supplier audits. In addition, a cross-functional team has worked together throughout 2022 to identify potential improvements to our current supply chain due diligence practices. In June 2022, we increased the awareness of human rights internally by organizing a global online training session on human rights as part of our Sustainability Learning Day. We also launched two e-learning courses. The first is a global, sustainability e-learning course that is mandatory for all employees, which includes the topic of human rights. The second is a separate e-learning course on Modern Slavery and Human Trafficking, mandatory for all managers and experts in the supply chain and human resources functions globally, and also available to all other Huhtamaki employees as well.
Labour
Commitment
L1. Does the company have a policy commitment in relation to the following labour rights principles? For the user, the “Working conditions (wages, working hours)” option would be visible only if selected in HR1.
Linked to: GRI Disclosure 3-3-c (2021) for topics GRI 407 (2016), GRI 409 (2016), GRI 408 (2016), GRI 406 (2016), GRI 403 (2018)
(Matrix – Select one answer option per line)

No, and we have no plans to develop a policy
No, but we plan to within the next two years
Yes, included within a broader policy or as a stand-alone policy [Prompts L1.1]
Not applicable (Please provide additional information in the mandatory text box)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Safe and healthy working environment
Working conditions (wages, working hours)
Please provide additional explanation:
We have a Code of Conduct that aligns Huhtamaki's minimum conduct standards expected of every Huhtamaki employee on human rights, labour rights & decent work, environment and anti-corruption. On top of that we have our Global Human Rights Policy. Some internal documents are Working Conditions Requirements that outline how our operational working conditions should be and Global Employment guidelines which complement those with other employment related commitments such as equal opportunity employment. We also have a separate internal policy for Occupational Health and Safety which outlines minimum requirements for safety at work and safety management. Finally, we set the standards as high for ourselves as for our suppliers through our Supplier Code of Conduct.

code-of-conduct-for-huhtamaki-suppliers.pdf
Download
huhtamaki-global-human-rights-policy-1.2.pdf
Download
huhtamaki_code_of_conduct_english.pdf
Download
Please input the year the relevant labour rights policy was last reviewed
Year (YYYY)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Safe and healthy working environment
Working conditions (wages, working hours)
Please provide additional explanation:
Global Human Rights Policy, 2018: Freedom of association and the effective recognition of the right to collective bargaining, Forced & Child labour, Working conditions, Safe and healthy working environment Code of Conduct 2018: Non-discrimination in respect of employment and occupation Other policies where these topics are covered are the Occupational Health and Safety policy, Global Employment Guidelines, Code of Conduct for Suppliers.
L1.1. For each labour rights policy, is it:
Linked to: ILO C155 - Occupational Safety and Health Convention 1981 (No. 155); GRI Disclosures 2-23-c, 2-23-d, 2-23-e (2021)
(Matrix – Select all that apply for each line)
Aligned with international labour standards
Publicly available
Approved at most senior level of the company
Applied to the company’s own operations
Applied to the company’s own operations and the value chain (including suppliers, consumers, communities, other business relationships)
Developed in consultation with workers and their representatives
Developed involving labour rights expertise from inside and outside the company
Other (Please provide additional information in the mandatory text box)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Safe and healthy working environment
Working conditions (wages, working hours)
Please provide additional explanation:
Our Supplier Code of Conduct commits our suppliers to conducting business in a way that complies with laws and regulations, meets high ethical standards and respects fundamental rights of employees.
L1.2. Does the existing company’s policy on freedom of association and collective bargaining:
Linked to: ILO C155 - Occupational Safety and Health Convention 1981 (No. 155); GRI Disclosures 2-23-c, 2-23-d, 2-23-e (2021)
(Multiple choice – Select all that apply)
Reference the respect for the right of all workers to form and join a trade union of their choice without fear of intimidation or reprisal and protect workers against acts of antiunion discrimination
Prohibit any acts of interference in trade unions
Facilitate the collective bargaining with the trade union representatives
Provide trade union representatives with information required for meaningful bargaining in the context of bona fide negotiations
Reference the respect for the right of workers to submit grievances without suffering
We do have a policy on freedom of association and collective bargaining, but it does not include any of these details
We do not have a policy on freedom of association and collective bargaining
Please provide additional explanation:
Huhtamaki is a global organisation and has operations in countries where unionizing is prohibited. We support our employees in unionizing in the boundaries of local legislation. Our Working Conditions Requirements outline that "The management shall allow elected employee representatives to carry out their representative duties without interference or intimidation."
Prevention
L2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following labour rights topics? For the user, the “Working conditions (wages, working hours)” option would be visible only if selected in HR1.
Linked to: GRI Disclosures 3-1-b and 3-3-f (2021) for topics GRI 407 (2016), GRI 409 (2016), GRI 408 (2016), GRI 406 (2016), GRI 403 (2018)
(Matrix – Select one answer option per line)
Please select the company’s highest level of engagement. Options progress from left to right.
No engagement on this topic
To better understand the risks/impacts in question
To discuss potential ways to prevent or mitigate the risks/ impacts in question
To agree on a way to prevent/mitigate the risks/impacts in question
To assess progress in preventing/ mitigating the risks/ impacts in question
To collaborate in the prevention/ mitigation of the risks/ impacts in question
Other (Please provide additional information) [Makes text box mandatory]
Freedom of association and the effective recognition of the right to collective bargaining
Forced Labour
Child labour
Non-discrimination in respect of employment and occupation
Safe and healthy working environment
Working conditions (wages, working hours)
Please provide additional explanation:
For Freedom of association and the effective recognition of the right to collective bargaining, conversations are had as part of the Human Rights assessments. The topic overall is not actively discussed, but we adhere to our co-operations practices everywhere, with or without a union.
L3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this labour rights topic? For the user, the “Working conditions (wages, working hours)” option would be visible only if selected in HR1.
Linked to: GRI Disclosure 3-3-d (2021) for topics GRI 407 (2016), GRI 409 (2016), GRI 408 (2016), GRI 406 (2016), GRI 403 (2018)
(Matrix – Select all that apply for each line)
Provided internal training/ capacity building for the direct workforce
Built capacity among relevant business relationships (e.g., suppliers, consumers, communities)
Conducted an audit process and/or corrective action plan
Collective Action with peers or other stakeholders, in particular workers’ organizations, to address the issue
Collaborated with governmental or regulatory bodies
Other (Please provide additional information) [Makes text box mandatory]
No action within reporting period
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Safe and healthy working environment
Working conditions (wages, working hours)
Please provide additional explanation:
Freedom of association and the effective recognition of the right to collective bargaining: Round table meetings for voluntary employees and management where topics covering labor rights such as working conditions, salaries and social spaces can be brought up by employees. Meetings are held with fixed schedules. For ensuring no child or forced labor is used in our operations or in suppliers' operations, we have conducted human rights assessments and supplier audits and we have developed our supply chain due diligence process. We have provided a modern slavery and human trafficking training targeted to all managers and experts in supply chain and HR organisations, and available for all employees. Human rights is also a part of our sustainability e-learning. Also, we annually hold a global online training day on Sustainability which covers e.g. human rights and DEI topics. For selected employees, we arrange anti-harassment and unconscious bias training. On health and safety, leadership at Huhtamaki involves balancing core values whilst continuously improving the safety of our working environments and our employees. Our leaders are essential in creating an open and honest environment where reporting is encouraged, and every worker is engaged and committed to ensure that nobody gets hurt. It is the ultimate duty of our leaders to ensure that our people remain safe by providing them with the platform to engage and upskill our employees, contingent works, contractors and visitors to continue building our strong resilient safety culture. Our central OHS team provides continuous guidance to all our professionals across our operational locations and is focused on building world-class safety processes to support our business in achieving Zero Harm to all across our manufacturing facilities by 2030. Factories undertake regular risk reviews to identify areas for improvement. Consolidated risk reviews take place quarterly at the segment level and periodically at the global level, based on lagging and leading indicator trends. Organizational training is a key enabler of a safe and healthy working environment. To achieve this, we deliver site and job-specific health and safety training as part of our induction process for all new employees. Employee participation and consultation ensures the successful implementation of our OHS systems and drives engagement in safety across all our teams. We believe that a health and safety committee with representation from leadership, health and safety professionals and employees provides an excellent forum for local dialogue and a foundation for improvement. The health and safety committees at our factory sites are formed and managed as per local laws and practices. Topics for the committee’s agenda typically arise from employee feedback, suggestions, occurred incidents, trends and improvement programs. Committees review injuries, near misses and any outstanding corrective actions and results from the latest safety audits. We strive to create an environment where our employees are an integral part of safety decision-making, and we always monitor their feedback to guide our programs and future focus areas. For working conditions, all mentioned above contribute to creating good working conditions. In addition, our current supplier DD screening process currently assesses and assigns risk based on factors including country of location, total spend, type of service or product supplied and beneficial owner relationships. We apply extra scrutiny to those identified as high risk based through a more in-depth onboarding questionnaire. If there are unsatisfactory answers in the questionnaires we follow up with the supplier to get more information.
L4. Who receives training for the following labour rights topics? For the user, the “Working conditions (wages, working hours)” option would be visible only if selected in HR1.
Linked to: GRI Disclosure 3-3-d (2021) for topics GRI 407 (2016), GRI 409 (2016), GRI 408 (2016), GRI 406 (2016), GRI 403 (2018)
(Matrix – Select all that apply for each line)
No training provided
Select employees
All employees
Contractors
Direct suppliers of the organization
Indirect suppliers of the organization
Other – such as partners, clients, etc.
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Safe and healthy working environment
Working conditions (wages, working hours)
Please provide additional explanation:
On forced labor, we have held modern slavery and human trafficking e-learnings for HR and Sourcing experts. On non-discrimination in respect of employment and occupation, we have held anti-harassment and unconscious bias trainings for selected employees and DEI sessions for all employees on an annual global Learning Day. For Health and safety and working conditions, we provide all employees global training in our e-learning system and in addition localized training and safety briefings are held for both employees and contractors.
L5. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following labour rights topics? For the user, the “Working conditions (wages, working hours)” option would be visible only if selected in HR1.
Linked to: GRI Disclosure 3-3-e (2021) for topics GRI 407 (2016), GRI 409 (2016), GRI 408 (2016), GRI 406 (2016), GRI 403 (2018)
(Matrix – Select one answer option per line)
Please select the company’s highest level of engagement. Options progress from left to right.
No monitoring on progress
Review topics on ad hoc basis
Set annual targets/goals, track progress over time (internal programmes only)
Set annual targets/goals, track progress over time (internal and external programmes)
Other (Please provide additional information) [Makes text box mandatory]
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Safe and healthy working environment
Working conditions (wages, working hours)
Please provide additional explanation:
We have audits that cover forced and child labor. In case of audit findings, ad hoc review will be conducted. We internally monitor and set targets for targets on non-discrimination and working conditions. Our health and safety targets can be found in our annual report on page 180.
Performance
L6. Do(es) the existing collective bargaining agreement(s) provide(s) more favourable rights than those provided in legislation, where appropriate?
(Select all that apply)
Yes, by providing more favourable conditions related to wages
Yes, by providing more favourable conditions related to working hours
Yes, by providing more favourable conditions related to health coverage and/or sick leave
Yes, by providing additional rights not otherwise provided (Please provide additional information) [Makes text box mandatory]
There is (are) no existing collective bargaining agreement(s)
No
Please provide additional explanation:
Other rights include paid vacation.
L7. In the course of the reporting period, what was the percentage of women in managerial positions? (%)
Linked to: ISAR C.1.1
(Matrix – Text Box with option for Unknown or N/A)
Percent women (Please input a whole number e.g., 50% = 50)
Unknown
Managerial position
Please provide additional explanation:
L8. What was the average ratio of the basic salary and remuneration of women to men (comparing jobs of equal value) during the reporting period?
Linked to: GRI Disclosure 405-2 (2016)
(Matrix – Text Box with option for Unknown or N/A)
Salary ratio (Please input a whole number e.g., 50% = 50)
Unknown
Choose to not disclose
Women/Men(%)
Please provide additional explanation:
We are improving our reporting methodologies and data for the ratio of the basic salary and remuneration of women to men. We expect to disclose this in our annual report 2023.
L9. In the course of the reporting period, how frequently were workers injured (injuries per hour worked)?
Linked to: ISAR C.3.2; GRI Disclosure 403-9 (2018)
(Matrix – Text Box with option for Unknown or N/A)
Frequency of injury (Please input a whole number e.g., 50% = 50)
Unknown
Choose to not disclose
Frequency of injury
Please provide additional explanation:
Our Total Recordable Injury Frequency Rate for 2022 was 3.7. Rate calculated with 1.000.000 factor. Total Recordables include Lost Time Injuries, Medical Treatment Injuries and Fatalities. See more information in our Annual Report, pages 180-182.
L10. In the course of the reporting period, what was the company’s incident rate (injuries per worker)?
Linked to: ISAR C.3.2; GRI Disclosure 403-9 (2018)
(Matrix – Text Box with option for Unknown or N/A)
Incident rate (Please input a whole number e.g., 50% = 50)
Unknown
Choose to not disclose [Makes text box mandatory]
Incident rate
Please provide additional explanation:
With our current reporting methodologies we are tracking occupational accidents and injuries, but we are not tracking number of diseases accurately. We are tracking number of hours due to sick leaves.
Response and Reporting
L11. In the course of the reporting period, has the company been involved in providing or enabling remedy if it has caused or contributed to the adverse impact associated with the following labour rights topics? For the user, the “Working conditions (wages, working hours)” option would be visible only if selected in HR1.
Linked to: GRI Disclosures 3-3-c and 3-3-d (2021) for topics GRI 407 (2016), GRI 409 (2016), GRI 408 (2016), GRI 406 (2016), GRI 403 (2018)
(Matrix – Select one answer option per line)
No remedy provided/enabled
Yes, remedy provided/enabled
No adverse impact identified or caused
Choose to not disclose [Makes text box mandatory]
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Safe and healthy working environment
Working conditions (wages, working hours)
Please provide additional explanation:
For Freedom of association and the effective recognition of the right to collective bargaining: In countries where freedom of association isn't guaranteed by law, we arrange round table meetings for voluntary employees and management where topics covering labor rights such as working conditions, salaries and social spaces can be brought up by employees. Meetings are held with fixed schedules. For discrimination, we have processes where discrimination happens that aims at providing remedy for the victim and results in consequences for the perpetrator. Read more about our actions on page 193 and about our Whistleblowing system on page 192 in our Annual Report. When any actual or potential human rights impacts or risks are identified, we integrate them into our continuous improvement processes and make action plans in order to address them at the appropriate level of the organization. While it is possible to handle some findings at the local level – such as designing appropriate shift patterns to balance the working hours and output or investing in safety equipment – other topics, such as investing in infrastructure to reduce thermal conditions on the shop floor, need to be brought to the corporate level and integrated into globally-aligned improvement processes.
L12. Briefly describe additional relevant practical actions the company has taken during the reporting period and/or plans to take to implement the labour principles, including goals set and any challenges faced and actions taken towards prevention and/or remediation.
Linked to: GRI Disclosures 3-3-c and 3-3-d (2021) for topics GRI 407 (2016), GRI 409 (2016), GRI 408 (2016), GRI 406 (2016), GRI 403 (2018)
(Text Box)
We have conducted Human rights assessments and implemented actions plans to improve. In 2022, we continued building on efforts launched in 2021 to strengthen our existing processes to better integrate human rights considerations into our processes and operating model. We also conducted our second human rights impact assessment at site level, to complement a high-level, global assessment that was performed in 2021. The results of these assessments inform the development of our human rights due diligence activities. We established a cross-functional working group to drive initiatives and to follow up on the findings from human rights impact assessments. We worked together with the mergers and acquisitions team to look for ways to strengthen the due diligence process related to mergers and acquisitions from a human rights perspective. We also continued developing the framework to enhance monitoring our own sites, using an external human rights expert to identify gaps in our current auditing practices and looking for ways to incorporate human rights assessments more comprehensively. Our supply chain due diligence process was strengthened for example by increasing the number of supplier audits. In addition, a cross-functional team has worked together throughout 2022 to identify potential improvements to our current supply chain due diligence practices. We have restructured OHS across company and set up a OHS Center of Expertise team. We launched a Global auditing program for health and safety. In June 2022, we increased the awareness of human rights internally by organizing a global online training session on human rights as part of our Sustainability Learning Day. We also launched two e-learning courses. The first is a global, sustainability e-learning course that is mandatory for all employees, which includes the topic of human rights. The second is a separate e-learning course on Modern Slavery and Human Trafficking, mandatory for all managers and experts in the supply chain and human resources functions globally, and also available to all other Huhtamaki employees as well.
Environment
Commitment
E1. Does the company have a policy commitment on the following environmental topics?
Linked to: CDP C4.1 (2022), CDP F6.1 (2022), CDP W6.1 (2022); GRI Disclosure 3-3-c (2021) for topics GRI 303 (2018), GRI 304 (2016), GRI 305 (2016), GRI 306 (2020),GRI 302 (2016)
(Matrix – Select one answer option per line)
No, and we have no plans to develop a policy
No, but we plan to within the next two years
Yes, included within a broader policy or as a stand-alone policy [Prompts E1.1]
Not applicable (Please provide additional information in the mandatory text box)
Climate change
Water
Oceans
Forests/biodiversity/land use
Air pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & resource use
Please provide additional explanation:
All areas are covered by our environmental policy: https://www.huhtamaki.com/globalassets/global/sustainability/policies/group-environmental-policy/huhtamaki_group_environmental_policy_-v3.0.pdf
Please input the year the relevant environment policy was last reviewed
Year (YYYY)
Climate change
Water
Forests/biodiversity/land use
Air pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & resource use
Please provide additional explanation:
All areas are covered by our environmental policy: https://www.huhtamaki.com/globalassets/global/sustainability/policies/group-environmental-policy/huhtamaki_group_environmental_policy_-v3.0.pdf
E1.1. For each environmental policy commitment, is it:
Linked to: CDP C4.1 (2022), CDP F6.1 (2022), CDP W6.1 2022; GRI Disclosures 2-23-c, 2-23-d, 2-23-e (2021)
(Matrix – Select all that apply for each line)
Aligned with international environmental standards
Publicly available
Approved at most senior level of the company
Applied to the company’s own operations
Applied to the company’s own operations and the value chain (including suppliers, consumers, communities, other business relationships)
Developed involving environmental expertise from inside and outside the company
Other (Please provide additional information in the mandatory text box)
Climate change
Water
Forests/biodiversity/land use
Air pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & resource use
Please provide additional explanation:
Our own environmental policy covers our own operations. Huhtamaki's environmental policies are reviewed and approved by the Sustainability Committee that includes the CEO and President. In addition to our Environmental Policy that covers our own operations, we have a Supplier Code of Conduct that covers environmental areas such as environmental laws, acting towards minimum environmental impacts and commitment to not source materials, directly or indirectly, that contribute to deforestation of high conservation value areas, or interfere with the habitats of endangered species. We require our suppliers to adhere to our Supplier Code of Conduct which covers environmental topics. It can be found here: https://www.huhtamaki.com/globalassets/global/sustainability/policies/code-of-conduct-for-suppliers/code-of-conduct-for-huhtamaki-suppliers.pdf.
Prevention
E2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following environmental topics?
Linked to: GRI Disclosures 3-1-b and 3-3-f (2021) for topics GRI 303 (2018), GRI 304 (2016), GRI 305 (2016), GRI 306 (2020), GRI 302 (2016), and GRI Disclosure 201-2-a-iv (2016)
(Matrix – Select one answer option per line)

Please select the company’s highest level of engagement. Options progress from left to right.
No engagement on this topic
To better understand the risks/impacts in question
To discuss potential ways to prevent or mitigate the risks/ impacts in question
To agree on a way to prevent/mitigate the risks/impacts in question
To assess progress in preventing/ mitigating the risks/ impacts in question
To collaborate in the prevention/ mitigation of the risks/ impacts in question
Other (Please provide additional information in the mandatory text box)
Climate change
Water
Oceans
Forests/biodiversity/land use
Air pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & resource use
Please provide additional explanation:
Huhtamaki works to understand its risks and impacts to stakeholders through collaborating with agencies and initiatives with extensive expertise on topics such as biodiversity (ENCORE), climate change (various initiatives we belong to such as Climate Leadership Coalition), water (Aqueduct). In addition, we discuss with internal stakeholders to find out any local insights to understand local environmental risks and places for mitigation. In terms of waste, we have collaborated with e.g. WasteAid to mitigate social and environmental impacts in South Africa, India and Vietnam providing local waste entrepreneurs education and training on waste management and circular systems. In addition, a central part of the project was WasteAid’s Zero Cities Challenge, which was initially launched in 2021 and continued in 2022. The aim of the initiative was to find six entrepreneurs with innovative ideas to increase the recovery and reuse of waste. Over a hundred entries were collected, ranging from food waste recovery and refill solutions to apps connecting waste collectors with households. Out of all the entries, 36 entrepreneurs were selected to receive business incubator support to go through an intensive, 8-week business support program. A final pitch to industry experts was held in each region, after which six winners were chosen and each awarded EUR 10,000 for their concept. Also, we have collaborated with various stakeholders in the EU to find Cup Collective - a cup recycling initiative founded in September 2022. This initiative aims at accelerating paper cup recycling across Europe at an industrial scale, aiming to recycle half a billion paper cups in the first two years, while making it easy for consumers and businesses to contribute.
E3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with these environmental topics?
Linked to: GRI Disclosure 3-3-d (2021) for topics GRI 303 (2018), GRI 304 (2016), GRI 305 (2016), GRI 306 (2020), GRI 302 (2016), and GRI Disclosure 201-2-iv (2016)
(Matrix – Select all that apply for each line)
Provided internal training/ capacity building for the direct workforce
Built capacity among relevant business relationships (e.g., suppliers, consumers, communities)
Conducted an audit process and/or corrective action plan
Collective Action with peers or other stakeholders, in particular workers’ organizations, to address the issue
Collaborated with governmental or regulatory bodies
Other (Please provide additional information) [Makes text box mandatory]
No action within reporting period
Climate change
Water
Oceans
Forests/biodiversity/land use
Air pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & resource use
Please provide additional explanation:
Environmental topics are part of our sustainability e-learning that is provided for selected employees. Also, we have an annual sustainability Learning Day that is part of a Global Learning Week. There we discuss environmental and social sustainability topics. In Northern Ireland, we have collaborated with a regional economic development agency to examine opportunities for water efficiency, rainwater harvesting and storm water options as well as improve our actions on carbon emissions, waste, energy and biodiversity.
E4. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following environmental topics?
Linked to: GRI Disclosure 3-3-e (2021) for topics GRI 303 (2018), GRI 304 (2016), GRI 305 (2016), GRI 306 (2020), GRI 302 (2016), and GRI Disclosure 201-2-a-iv (2016)
(Matrix – Select one answer option per line)
Please select the company’s highest level of engagement. Options progress from left to right.
No monitoring of progress
Review topics on ad hoc basis
Set annual targets/ goals, track progress over time (internal programmes only) [Prompts E4.1 and E4.2]
Set annual targets/goals, track progress over time (internal and external programmes) [Prompts E4.1 and E4.2]
Other (Please provide additional information in the mandatory text box)
Climate change
Water
Oceans
Forests/biodiversity/land use
Air pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & resource use
Please provide additional explanation:
Huhtamaki has set our 2030 Strategy where sustainability is at the very core and seen as a key differentiator for us at Huhtamaki. We have distinct targets where we monitor our progress. We have for example SBTs for climate, Water stewardship targets and water management plan targets to follow our progress on water, specific targets to tackle waste to landfill and recycling rates of our waste as well as ambitions to get to 100% recycled or certified fiber and 100% renewable electricity by 2030.
E4.1. For each environmental topic for which the company sets timebound goals/targets, what kind of targets has the company set? Please give a description of targets (e.g., what is the target, absolute vs. intensity, externally verified, on track, etc.)
Linked to: CDP F6.1 (2022); GRI Disclosure 3-3-e (2021) for topics GRI 303 (2018), GRI 304 (2016), GRI 305 (2016), GRI 306 (2020), GRI 302 (2016), and GRI Disclosure 201-2-a-iv (2016)
(Text Box)
Climate change:Huhtamaki is dedicated to its climate commitments that were first launched in 2020. These are: Science-based targets, 100% renewable electricity and carbon neutral production by 2030. Huhtamaki’s GHG emissions reduction targets were validated and approved by the Science Based Targets initiative (SBTi) in 2021. The targets are: a 27.5% reduction in absolute Scope 1 and 2 emissions by 2030 from a 2019 base year, a 13.5% reduction in absolute Scope 3 emissions from end-of life treatment of sold products within the same timeframe and 70% of our suppliers, by spend, sign up to setting their own science-based targets by 2026. We are on track in our climate targets. Water: The foundation of our water stewardship lies in the comprehensive implementation of site-specific water management plans (WMPs) for all our sites. This target was reached in 2022. The new water-related goals developed in 2022 include improving water monitoring and measurement capability, reducing water intensity in our operations and exploring watershed projects for high water stressed areas. 2023 makes the first year when these new targets are monitored for a full year. Forests/Biodiversity/Land Use:We aim to have 100% of our fiber from recycled or certified sources by 2030. We were at 98% at year end 2022. Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.): We have non-hazardous waste recycled & waste to landfill targets for waste. We are well on track on both targets. Energy & resource use: We have a 100% renewable electricity target for 2030. We are on track on this target.
E4.2. For each environmental topic in which the company sets timebound goals/targets, how is progress against target/goal tracked?
Linked to: GRI Disclosure 3-3-e (2021) for topics GRI 303 (2018), GRI 304 (2016), GRI 305 (2016), GRI 306 (2020), GRI 302 (2016), and GRI Disclosure 201-2-a-iv (2016)
(Matrix – Select all that apply for each line)
Progress is reviewed against goals annually or more frequently
Progress is reported internally to the most senior level
Progress is reported externally
Other (Please provide additional information in the mandatory text box)
Climate change
Water
Forests/biodiversity/land use
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & resource use
Please provide additional explanation:
Please find reporting for these targets in our Annual Report: Climate change and Energy: page 157 Water and waste: page 164 Biodiversity: page 148
E5. In the course of the reporting period, has the company been involved in providing or enabling remedy for any impacts associated with the following environmental topic(s)?
Linked to: GRI Disclosure 3-3-d-ii (2021) for topics GRI 303 (2018), GRI 304 (2016), GRI 305 (2016), GRI 306 (2020), GRI 302 (2016), and GRI Disclosure 201-2-a-iv (2016)
(Matrix – Select one answer option per line)
Yes, remedy provided/enabled
No remedy provided/enabled
No adverse impact identified or caused
Choose to not disclose
Climate change
Water
Oceans
Forests/biodiversity/land use
Air pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & resource use
Please provide additional explanation:
Climate Action
E6. What were the company’s gross Scope 1 and Scope 2 global greenhouse gas emissions (GHG) for the reporting period?
Linked to: CDP C6.1 (2022), CDP C6.3 (2022), CDP C6.5 (2022); GRI Disclosures 305-1, 305-2, 305-3 (2016); ISAR B.3.1; ISAR B.3.2
(Matrix – Select one answer option per line)
Measured Total Emissions (tCO2e)
We did not measure our gross GHG emissions [Please explain in the mandatory text box]
Scope 1 emissions
Scope 2 emissions
Please provide additional explanation:
Please refer to our annual report pages 157 - 162. We calculate our Scope 2 emissions using both market-based and the location-based methods, the former in our target setting.
E7. What were the company’s gross Scope 3 global greenhouse gas emissions (GHG) for the reporting period?
Linked to: CDP C6.1 (2022), CDP C6.3 (2022), CDP C6.5 (2022); GRI Disclosures 305-1, 305-2, 305-3 (2016); ISAR B.3.1; ISAR B.3.2
(Multiple choice– Select one)
We fully measured Scope 3 GHG emissions [Please input the measured tCO2e in the text box below]
We partially measured Scope 3 GHG emissions [Please input the measured tCO2e in the text box below] [Prompts E7.1]
We did not measure Scope 3 GHG emissions
Please provide additional explanation:
3445000 tCO2e. Please refer to our annual report pages 157 - 162.
E7.1. Which Scope 3 categories are included in the organization’s Scope 3 emissions calculation?
Linked to: GRI Disclosure 305-3 (2016); CDP C6.5 2022
(Multiple choice – Select all that apply)
Purchased goods and services
Capital goods
Fuel- and energy-related activities
Upstream transportation and distribution
Waste generated in operations
Business travel
Employee commuting
Upstream leased assets
Downstream transportation and distribution
Processing of sold products
Use of sold products
End-of-life treatment of sold products
Downstream leased assets
Franchises
Investments
Other - upstream
Other - downstream
Unknown
Please provide additional explanation:
Please refer to our annual report pages 157 - 162, 200.
E8. What percentage of the company’s revenue was invested in R&D of low-carbon products/services during this reporting period?
Linked to: CDP C4.3c (2022), CDP4.2b (2022); (partially linked to) ISAR A.3.3
(Matrix – Text Box with option for Unknown or N/A)
Percent of revenue (Please input a whole number e.g., 50% = 50)
Unknown
Not applicable (Please provide additional information in the mandatory text box)
R&D for low-carbon products/services
Please provide additional explanation:
We do not collect specific data on this. However, we have a strong sustainability focus in our innovations. In 2022, we introduced blueloop™, an enterprisewide sustainable brand, that covers our range of sustainable packaging products. The brand promise for our blueloop solutions is that they are designed for circularity and part of delivering on our 2030 Strategy to become the first choice in sustainable packaging solutions.
E9. Has the organization acted to support climate change adaptation and resilience?
Linked to: GRI Disclosure 201-2-a-iv (2016)
(Select all that apply)
We have taken action to increase organization-wide resilience to climate change
We have taken action to increase resilience in our supply chains
We have taken action to increase resilience in the communities in which we operate
We have provided funding for climate change adaptation and resilience initiatives and projects
We have not taken actions to build climate change resilience in the reporting period
Unknown
Please provide additional explanation:
At Huhtamaki, we continuously work to improve the resilience of our own operations to climate change. In addition, we engage with our suppliers on climate issues. As an example of this, we have set a SBT that aims at 70% of our suppliers, by spend, sign up to setting their own science-based targets by 2026.
Energy/Resource Use
E10. Please report the company’s renewable energy consumption as a percentage of total energy consumption in the reporting period.
Linked to: ISAR B.5.1; GRI Disclosure 302-1 (2016)
(Matrix – Text Box with option for Unknown)
% of total energy consumption (Please input a whole number e.g., 50% = 50)
Unknown
Renewable energy consumption as % of total energy consumption:
Please provide additional explanation:
The renewable energy consumption reported in this questionnaire is the same as certified renewable electricity consumption shown in our Annual Report 2022. Please refer to our annual report page 162 & 163.
Technology
E11. What percent of the company’s revenue came from low-carbon products/services during this reporting period? If applicable, please give a description of the products/services included in your calculation (e.g., relevant certifications)
Linked to: SASB CG-MR-410a.1a; WEF Common Metrics
(Matrix – Text Boxes with option for Unknown or N/A)
Percent of total revenue (%) (Please input a whole number e.g., 50% = 50)
Unknown
Not applicable (Please provide additional information in the mandatory text box)
Low-carbon products and services/total revenue for the reporting period
Please provide additional explanation:
We do not collect specific data on this. However, we have a strong sustainability focus in our innovations. In 2022, we introduced blueloop™, an enterprisewide sustainable brand, that covers our range of sustainable packaging products. The brand promise for our blueloop solutions is that they are designed for circularity and part of delivering on our 2030 Strategy to become the first choice in sustainable packaging solutions.
Materiality-specific Questions
E12. Which of the following has the company identified as material environmental topics connected with its operations and/or value chain (e.g. the most severe actual or potential negative impacts on people and/or the environment)?
Linked to: GRI Disclosure 3-2 (2021)
(Select all that apply)
Water [Prompts questions E13 and E14]
Forests/biodiversity/land use [Prompts questions E15, E16 and E17]
Air pollution [Prompts questions E18]
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.) [Prompts questions E19, E20, E21]
None of these topics have been identified as material by the company
Please provide additional explanation:
See our annual report page 199.
Materiality-specific: Water
E13. Please provide details regarding the company’s water withdrawal and consumption (own operations) during the reporting period.
Linked to: ISAR B.1.3; CDP W1.2b (2022), CDP W1.2d (2022); SASB CG-HP-140a.1; GRI Disclosures 303-3, 303-5 (2018)
(Matrix – Text Boxes with option for Unknown or N/A)
Volume of water in megaliters
Unknown
Not applicable (Please provide additional information in the mandatory text box)
Total water withdrawal:
Fresh surface water withdrawal:
Groundwater withdrawal:
Brackish surface water/seawater withdrawal:
Produced water withdrawal:
Third-party water withdrawal:
Percentage of water withdrawn in regions with high or extremely high water stress(%):
Total water consumption:
Fresh surface water consumption:
Brackish surface water/seawater consumption:
Produced water consumption:
Third-party water consumption:
Percentage of water consumed in regions with high or extremely high water stress(%):
Please provide additional explanation:
Please refer to our annual report page 166.
E14. Please provide details about the company’s water intensity of products in regions with high or extremely high water stress.
Linked to: CDP W1.3 (2022); CDP W1.3a (2022 )
(Matrix – Text Boxes with option for Unknown or N/A)
Cubic meter/$ OR cubic meter/product type (Please input a number e.g., 50)
Unknown
Not applicable (Please provide additional information in the mandatory text box)
Water intensity of products
Please provide additional explanation:
We do not collect specific data on product level water intensity.
Materiality-specific: Forests, Biodiversity, and Land Use
E15. Please report the number and area (in hectares) of sites owned, leased, or managed by the company in or adjacent to protected areas and/or key biodiversity areas (KBA).
Linked to: GRI Disclosure 304-1 (2016); ISAR B6.1, WEF Common Metrics
(Matrix – Text Boxes with option for Unknown or N/A)
Number
Unknown
Not applicable (Please provide additional information in the mandatory text box)
Sites
Hectares
Please provide additional explanation:
Huhtamaki sites in areas of high biodiversity value or protected areas are presented in Huhtamaki Annual report 2022 (Appendix: Huhtamaki sites and biodiversity).
E16. What area (in hectares) of natural ecosystems was converted during the reporting period in areas owned, leased, or managed by the company?
Linked to: CDP F1.3 (2022); GRI Disclosure 304-1 (2016)
(Matrix – Text Boxes with option for Unknown or N/A)
Area (hectares)
Unknown
Not applicable (Please provide additional information in the mandatory text box)
Conversion of natural resources
Please provide additional explanation:
We do not collect specific data on this.
E17. Is the company supporting or implementing project(s) focused on ecosystem restoration and protection?
Linked to: CDP F6.11 (2022); GRI Disclosure 304-3 (2016)
(Matrix – Select one option or input a number per line)
No
No, but we plan to within the next 2 years
Yes, Project(s) area to date (hectares)
Forest ecosystem restoration
Other ecosystem restoration
Reforestation
Natural regeneration
Agroforestry
Set-aside land
Biodiversity offsetting
Please provide additional explanation:
Materiality-specific: Air Pollution
E18. Where applicable, please report the company’s emissions of the following pollutants during the reporting period.
Linked to: GRI Disclosure 305-7 (2016); ISAR B.1.4
(Matrix – Text Box with option for Unknown or N/A)
Emissions (t)
Unknown (Please provide additional information in the mandatory text box)
Not applicable (Please provide additional information in the mandatory text box)
NOx
SOx
Volatile organic compounds (VOCs)
Hazardous air pollutants (HAPs)
Particulate matter (PM10)
Persistent organic pollutants (POPs)
Other (Please provide additional information)
Please provide additional explanation:
Our most significant emissions to air are carbon dioxide (CO2) and to a lesser extent, volatile organic compound (VOC) emissions. We report emissions on VOCs only. Please refer to our annual report page 161.
Materiality-specific: Waste
E19. In metric tonnes, please report the company’s total weight of waste generated during the reporting period.
Linked to: GRI Disclosure 306-3 (2020); (partially linked to) ISAR B.2.1
(Matrix – Text Box with option for Unknown or N/A)
Waste generated (t)
Unknown
Not applicable (Please provide additional information in the mandatory text box)
Solid waste
Please provide additional explanation:
Please refer to our annual report page 169.
E20. Please report the percentage of the company’s waste that was hazardous waste (e.g., hazardous waste ratio) during the reporting period.
Linked to: GRI Disclosures 306-4, 306-5 (2020); ISAR B.2.3
(Matrix – Text Box with option for Unknown or N/A)
Hazardous waste ratio (%) (Please input a whole number e.g., 50% = 50)
Unknown
Not applicable (Please provide additional information in the mandatory text box)
Hazardous waste
Please provide additional explanation:
Please refer to our annual report page 169.
E21. Please report the company’s estimated metric tonnes of single-use plastic consumed wherever material along the value chain during the reporting period.
Linked to: WEF Common Metrics
(Matrix – Text Box with option for Unknown or N/A)
Single-use plastic (t)
Unknown
Not applicable (Please provide additional information in the mandatory text box)
Single-use plastics
Please provide additional explanation:
We don't currently collect this information.
Overall Environment
E22. Briefly describe additional relevant practical actions the company has taken during the reporting period and/or plans to take to implement the environment principles, including goals set and any challenges faced and actions taken towards prevention and/or remediation.
Linked to: GRI Disclosures 3-3-c and 3-3-d (2021) for topics GRI 303 (2018), GRI 304 (2016), GRI 305 (2016), GRI 306 (2020), GRI 302 (2016)
(Text Box)
In 2022, we continued to build on the sustainability roadmaps created for each of our sites in 2021. The roadmaps define concrete actions that guide our sites to reach our 2030 targets. We achieved substantial improvements in waste management at many of our sites, with several sites reducing the amount of waste sent to landfill to zero and other sites reducing significantly. In renewable energy, in addition to the current 80% coverage in Europe, we gained 30% coverage for carbon neutral energy in North America through our second VPPA. Another KPI that we focused on was creating water management plans for all our sites – a goal that we achieved in 2022. Based on this, we have included in 2023 a water intensity reduction target in our Global Sustainability Index (GSI), which links our sustainability performance with short-term incentives. In addition, we have included a solvent reduction target in the GSI. We believe in a regenerative economy and that post-consumer packaging has value as a secondary resource material. In 2022, we launched several collaborative industrial scale pilots to tackle the barriers to recycling. These include The Cup Collective, launched with Stora Enso to collect paper cups for recycling, and a cup recycling pilot project in China in collaboration with S-bag. In India, the Huhtamaki Foundation inaugurated its first flexible plastic packaging recycling plant in Khopoli, Maharashtra, to help drive circularity across the value chain.
Anti-Corruption
Commitment
AC1. Does the company have an anti-corruption compliance programme?
Linked to: GRI Disclosure 3-3-c (2021) for the topic GRI 205 (2016)
(Radial – Select One)
No, it is not an immediate business priority
No, but we plan to within the next two years
Yes [Prompts AC1.1]
Please provide additional explanation:
Huhtamaki is committed to all applicable local and international anti-corruption laws and regulations. At Huhtamaki, all forms of corruption and bribery are strictly prohibited. This commitment is stipulated in the Huhtamaki Code of Conduct, the Code of Conduct for Huhtamaki Suppliers as well as the Huhtamaki Anti-Corruption Policy which has been issued and approved by the Huhtamaki Global Executive Team. The Huhtamaki Anti-Corruption Program, managed by our Global Ethics & Compliance team, aims at ensuring that we take needed steps to mitigate and manage corruption risks in our operations and across our value chain. The program includes, alongside with the anti-corruption policy, related instructions, procedures and trainings that support employees when they face corruption risky situations. Huhtamaki's Ethics & Compliance Program includes a whistleblowing procedure in order to invetigate and address corruption related suspected incidents.
AC1.1. If yes, in what year was this programme last reviewed? (YYYY)
(YYYY)
Programme last reviewed
Please provide additional explanation:
In 2022, Huhtamaki further developed its Anti-Corruption Program by launching a new anti-corruption policy alongside related instructions and procedures on conflicts of interest and gifts and hospitality, which all our employees are expected to follow globally. In 2022, as part of the implementation of the new policy and instructions, Huhtamaki Global Ethics & Compliance team organized local, in-depth anti-corruption trainings to leadership and key functions at 12 units which were chosen on a risk basis. Also as part of the implementation of the Anti-Corruption Program, a new conflict of interest self-disclosure procedure was introduced and implemented in the Huhtamaki’s global HR system to bring more transparency and to mitigate risks involved in conflict-of-interest situations. Huhtamaki has also identified further improvement areas that are planned to be included in the Anti-Corruption Program in 2023.
AC2. Does your company have policies and recommendations for employees on how to act in case of doubt and/or in situations that may represent a conflict of interest, e.g., with regard to gifts and hospitality, donations, sponsorship, or interactions with public officials?
(Radial – Select One)
No, but we plan to within the next two years
No, and we have no plans to develop them
Yes, included within a broader policy or as a standalone policy
Please provide additional explanation:
Huhtamaki's Anti-Corruption Policy (internal document) includes rules for employees to follow in relation to bribery (including kickbacks and facilitation payments) and in situations that require due care such as when facing potential or actual conflict of interest situations, when offering or accepting gifts, when interacting with government officials, when dealing with third parties and when considering charitable donations and sponsorship. Furthermore, Huhtamaki has specific and more detailed instructions and procedures in place for conflicts of interest disclosures and for gift and hospitality approvals. The topic is also covered in our Code of Conduct and Code of Conduct for Suppliers.

code-of-conduct-for-huhtamaki-suppliers.pdf
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huhtamaki_code_of_conduct_english.pdf
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Prevention
AC3. Who receives training on anti-corruption and integrity?
Linked to: WEF Common Metrics; GRI Disclosure 205-2 (2016)
(Select all that apply)
Select employees [Prompts AC3.1]
All employees [Prompts AC3.1]
Contractors [Prompts AC3.1]
Direct suppliers of the organization [Prompts AC3.1]
Indirect suppliers of the organization [Prompts AC3.1]
Other – such as partners, clients, etc. [Prompts AC3.1]
No training provided
Please provide additional explanation:
Huhtamaki launches an annual Code of Conduct e-learning that covers anti-corruption topics. The e-learning is mandatory to all Huhtamaki employees globally and available in 26 languages. In 2022, the completion rate for the e-learning was 94.5%. Furthermore, Global Ethics & Compliance team organised in-depth anti-corruption trainings to leadership and key functions at 12 units which were chosen on a risk basis.
AC3.1. How often is such training provided?
(Matrix – Select one answer option per line)
One time only
Every two or more years
Every year
We do not collect this data
All employees
Please provide additional explanation:
AC4. Does the company monitor its anti-corruption compliance programme?
Linked to: GRI Disclosure 3-3-e (2021) for the topic GRI 205 (2016); SDG Action Manager - SDG 16: Peace, Justice, and Strong Institutions
(Select all that apply)
Review topics on ad hoc basis
Yes, through internal employee self-evaluations
Yes, through automated controls monitoring
Yes, through external independent monitoring
Yes, through other mechanisms (Please provide additional information) [Makes text box mandatory]
No, we do not monitor the anti-corruption compliance programme (Please provide additional information) [Makes text box mandatory]
Please provide additional explanation:
Generally the Huhtamaki Anti-corruption Program is reviewed on ad hoc basis, although some elements are monitored systematically through automated controls monitoring, such as the conflict of interest disclosure procedure. As part of the program review in 2022, new elements were added into the Huhtamaki Anti-corruption Program and the implementation and improvement work is continuing in 2023. In 2023 for instance, Huhtamaki will implement a specific procedure for anti-corruption risk assessment and will launch a separate anti-corruption e-learning targeted to all white-collar employees.
Performance
AC5. Please report the company’s total number and nature of incidents of corruption during the reporting year. If applicable, please describe the nature of the incidents in the text box below
Linked to: GRI Disclosure 205-3 (2016); WEF Common Metrics; ISAR D.2.1
(Matrix – Text Boxes with option for Unknown or N/A)
Number of incident(s) (Please describe the nature of the incidents in the text box below)
Unknown
Choose to not disclose
Confirmed during the current year, but related to previous years
Confirmed during the current year, and related to this year
Please provide additional explanation:
Please refer to our annual report page 193. Although, there were no confirmed corruption instances, the majority of the investigated suspected non-compliance cases were related to possible conflict of interest situations, suspected fraud, embezzlement or corrupt practices. In 2022, a total of 6 conflict of interest cases were investigated and out of these 3 are confirmed. In 2022, 3 suspected corruption cases were investigated and none of these cases have been confirmed.
Response and Reporting
AC6. Within the reporting period, what measures has the company taken to address suspected incidents of corruption independently or in response to a dispute or investigation by a government regulator?
Linked to: GRI Disclosure 3-3-d (2021) for the topic GRI 205 (2016); Reporting Guidance on the10th Principle Against Anti-corruption – B3
(Select all that apply)
Initial case assessment
Internal investigation
Review by risk/ethics committee
Review by board of directors
External audit/review
Other (Please provide additional information) [Makes text box mandatory]
Not applicable/no incidents in the reporting period
Please provide additional explanation:
Huhtamaki maintains a whistlblowing procedure (inc. multiple channels for speaking up) and conducts internal investigations for all suspected corruption incidents. Investigations are conducted by Global Ethics & Compliance team or an external investigator confidentially and by respecting the principle of non-retaliation. All non-compliance cases including suspected corruption instances are reviewed by Huhtamaki Ethics & Compliance Committee and reported to Huhtamaki board of directors through Huhtamaki Audit Committee.
AC7. Does your company engage in collective action against corruption?
Linked to: GRI Disclosure 3-3-d (2021) for the topic GRI 205 (2016)
(Radial – Select One)
No, but we plan to within two years
No, it is not an immediate business priority
Yes (Please explain) [Makes text box mandatory]
Please provide additional explanation:
AC8. Briefly describe additional relevant practical actions the company has taken during the reporting period and/or plans to implement the anti-corruption principle, including goals set and any challenges faced and actions taken towards prevention and/or remediation.
Linked to: GRI Disclosures 3-3-c and 3-3-d (2021) for the topic GRI 205 (2016)
(Text Box)
In 2022, Huhtamaki developed its Anti-corruption Program by introducing new elements, such as an anti-corruption policy and related instructions and procedures. As part of the implementation of the new elements, multiple on site trainings to key functions were held. In 2023, Huhtamaki is continuing to further develop its program by launching a separate risk assessment for anti-corruption (previously such risks have been part of the broader ERM procedure). Furthermore, Huhtamaki is planning of launching a separate anti-corruption e-learning to white collar workers and to improve its third party due diligence procedure to further focus on mitigating third party related corruption risks.

Sustainability Reports*

huhtamaki-oyj-annual-report-2022 (2).pdf

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