Report - COP Prototype

2022 Communication on Progress

Sappi Limited

Published date

May 31, 2022

No. of questions

Supplemental files

Sappi-Group-Environmental-Policy-English-E5N.pdf Sappi-Group-Human-Rights-Policy-E4 (1).pdf Sappi-Group-Whistle-blowing-Policy-E4.pdf Sappi Group Human Resources Policy.pdf Sappi FY2021 Assurance Report Final (00000002).pdf Sappi-Group-Sustainability-Charter-English-E4N.pdf Sappi-Southern-Africa-Water-Stewardship-Policy.pdf Sappi-Group-Climate-Change-Policy-E4N.pdf Sappi-Group-Sensitive-Payments-and-Conflicts-of-Interest-Policy-E3 (1).pdf

CEO Statement

Signed

Governance

Policies and Responsibilities

1. Does the Board / highest governance body or most senior executive of the company:

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

2. Does the company have a publicly stated commitment regarding the following sustainability topics?

	No, this is not a current priority	No, but we plan to have a commitment within 2 years	Yes, and the commitment is focused on our own operations	Yes, and the commitment includes our own operations and the value chain	Yes, and the commitment includes our own operations and the value chain along with communities and society
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

3. Does the company have in place a code of conduct regarding each of the following sustainability topics?

	No, this is not a current priority	No, but we plan to have a code of conduct within two years	Yes, focused on employee conduct	Yes, focused on employees and suppliers	Yes, focused on employees, suppliers, and other business relationships
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Optional comment

These issued are covered in the policies submitted in the previous question and in our Code of Ethics https://cdn-s3.sappi.com/s3fs-public/slices/downloads/Sappi-Code-of-Ethics-brochure-English-UK-External-2.pdf

4. Has the company appointed an individual or group responsible for each of the following sustainability topics?

	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

5. Does the company have a formal structure(s) (such as a cross-functional committee) to address each of the following sustainability topics?

	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

Prevention

6. Does the company have a process or processes to assess risk?

	No, this is not a current priority	No, but we are planning to develop one in the next two years	Yes, related to our own operations	Yes, related to our own operations and entire value chain and other business relationships
Human rights risks
Labour rights risks
Environmental risks
Corruption risks

6.1. During the assessment of risk, which business relationships are reviewed?

	A few suppliers or business relationships [approximately less than 25 %]	Several suppliers / business relationships (i.e., first tier or other high priority) [approx. 25 - 50 %]	Most suppliers / relevant business relationships [approx. 51 - 99 %]	All suppliers / relevant business relationships outside the supply chain
Human rights risks
Labour rights risks
Environmental risks
Corruption risks

7. 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?

	No, this is not a current priority	No, but we are planning to develop one in the next two years	Yes, related to our own operations	Yes, related to our own operations and entire value chain and other business relationships
Human rights risks
Labour rights risks
Environmental risks
Corruption risks

7.1. During the due diligence process, which business relationships are reviewed?

	A few suppliers or business relationships [approximately less than 25 %]	Several suppliers / business relationships (i.e., first tier or other high priority) [approx. 25 - 50 %]	Most suppliers / relevant business relationships [approx. 51 - 99 %]	All suppliers / relevant business relationships outside the supply chain
Human rights risks
Labour rights risks
Environmental risks
Corruption risks

Concerns and grievance mechanisms

8. 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?

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)

Yes, we have a formal process

Optional comment

Hotlines in each region , communication about hotlines widely disseminated in a wide variety of languages.

8.1. 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.

	No	Yes
Is the process communicated to all employees/workers in local languages?
Is the process available to non-employees (e.g., contractors, vendors, suppliers)?
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 information)

9. Does the company provide or enable access to effective remedy to right holders / stakeholders where it has caused or contributed to the adverse impact?

	No process to enable remedy to stakeholders	Remedy available to some stakeholders (i.e., some geographies, employees only)	Remedy is available to all affected stakeholders	Remedy is available to all stakeholders, and suppliers are expected to have similar policies
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Lessons

10. How does the company capture lessons regarding each of the following sustainability topics?

	No lessons are regularly captured	Conducts root cause analyses/investigation of major 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
Labour Rights / Decent Work
Environment
Anti-Corruption

Executive Pay

11. Is executive pay linked to performance on one or more of the following sustainability topics?

Board Composition

12. Percentage of individuals within the company’s Board / highest governance body by:

	Number/Percentage	Not applicable (Please provide additional information)
Total number of board members (#)	12
Male (%)	75
Female (%)	25
Non-binary (%)
No members of the board identify as non-binary
Under 30 years old (%)
There are no board members under 30 years wold
30-50 years old (%)	15
Above 50 years old (%)	85
From minority or vulnerable groups (%)	35
Executive (%)
Independent (%)	80

Data Assurance

14. Is the information disclosed in this questionnaire assured by a third-party?

No assurance for any metrics

Limited assurance for minority of metrics (e.g., GHG emissions only)

Limited assurance for Scope 1 and 2 GHG emissions and safety statistics

Limited assurance for majority of metrics

Reasonable assurance for minority of metrics

Reasonable assurance for majority of metrics

Other (Please provide additional information)

Optional comment

In addition to GHG emissions, we also have limited assurance for safety

Human Rights

Commitment

2. Does the company have a policy commitment in relation to the following human rights issues?

	No, and we have no plans to develop a policy	No, but we plan to in the next two years	Yes, included within a broader policy	Yes, articulated as a stand-alone policy
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation
2021

2.1. For each human rights policy, is it:

	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 supply chain and/or other business relationships?	Developed involving human rights expertise from inside and outside the company?	Other (Please provide additional information)
Freedom of expression
Digital security / privacy
Rights of women and/or girls
Access to culture
Rights of indigenous peoples
Free, prior and informed consent
Rights of refugees and migrants
Access to water and sanitation

Prevention

3. 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 issues?

	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
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

4. 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 issue?

	Provided internal training/ capacity building for the direct workforce	Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)	Conducting an audit process and/or corrective action plan	Collective Action with peers or other stakeholders to address the issue	Collaboration with governmental or regulatory bodies	Other (Please provide additional information)	No action within reporting period
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

Optional comment

Sappi has established a Water Stewardship agreement with the World Wide Fund for Nature South Africa (WWF-SA), aimed at improving the water security in the uMkhomazi catchment area in South Africa. With our significant manufacturing and forestry footprint in this catchment area, which forms part of the Southern Drakensberg Strategic Water Source Area in KwaZulu-Natal, it makes sense for us to focus our collaborative efforts here, where our Saiccor Mill and 42,000 ha of forestry land are situated. The catchment also serves commercial farmers, subsistence farmers and domestic users in dispersed settlements across the area. To meet the future needs of all users, sufficient water at an acceptable level of assurance and quality must be secured. We believe that this can only be achieved through multi-stakeholder collaboration across the landscape. To help coordinate and facilitate the approach, we have launched a two-year project with WWF-SA to engage local communities, civil organisations, leadership and regulatory authorities in dialogue and cooperation focused on water stewardship. This collaborative approach is an extension of an innovative structure, known as the Integrated Community Forum (ICF), which we pioneered and through which we engage with local adjacent communities.

5. Who receives training for the following human rights issues?

	No training provided	Select employees	All employees	Contractors	Direct suppliers of the organization	Indirect suppliers of the organization	Other – such as partners, clients, etc.
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

6. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following human rights issues?

	No monitoring of progress	Review issues on ad-hoc basis	Set annual targets/ goals, track progress over time (internal programs only)	Set annual targets/ goals, track progress over time (internal and external programs)	Other (Please provide additional information)
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

Response

7. During the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to adverse impact associated with the following human rights issue(s)?

	Yes	No	Choose to not disclose	Not applicable (Please provide additional information)
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation
No adverse impacts.

8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the human rights principles, including any challenges faced and actions taken towards prevention and/or remediation.

1) In South Africa, we make water available to neighbouring communities, providing the Bhamjees informal settlement close to Ngodwana Mill in Mpumalanga province with treated water. During droughts, Lomati Mill in the same province sent water tankers to the local community. 2) Alien invasive species like bugweed, lantana, pompom weed and water hyacinth, to mention just a few, are a threat to biodiversity and water security. Our mills are surrounded by extensive landholdings, where some of these species could previously be found. In 2018, the Wildlife and Environment Society of South Africa (WESSA) trained and mentored youths from communities close to our operations on the management of alien and invasive plant species. This initiative is an example of true community empowerment: there are now five legal business entities (32 trained youths) providing services to our pulp and paper mills, with five-year service contracts beginning in 2019 entered into with these SMEs. Apart from rendering an important environmental management service, the programme has created and sustained a total of 47 jobs in local communities. Between 2019 and 2021, we spent a total of ZAR12.2 million with these companies, some of whom are now expanding their footprint beyond Sappi to offer services to other companies

Labour

Commitment

1. Does the company have a policy commitment in relation to the following labour rights principles?

	No, and we have no plans to develop a policy	No, but we plan to in the next two years	Yes, included within a broader policy	Yes, articulated as a stand-alone policy	Not applicable (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
2020
Forced labour
2020
Child labour
2020
Non-discrimination in respect of employment and occupation
2020
Occupational safety and health
20202
Working conditions (wages, working hours)
2020

Optional comment

Many of the issues described above are covered not just in policies, but in our Group Supplier Code of Conduct

1.1. For each labour rights policy, is it:

	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 supply chain and/or other business relationships?	Developed involving labour rights expertise from inside and outside the company?	Other (Please provide additional information)
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
Occupational safety and health
Working conditions (wages, working hours)

Prevention

2. 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 issues?

	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)
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
Occupational safety and health
Working conditions (wages, working hours)

3. 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 issue?

	Provided internal training/ capacity building for the direct workforce	Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)	Conducting an audit process and/or corrective action plan	Collective Action with peers or other stakeholders, in particular workers' organizations, to address the issue	Collaboration with governmental or regulatory bodies	Other (Please provide additional information)	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
Occupational safety and health
Working conditions (wages, working hours)

4. Who receives training for the following labour rights issues?

	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
Occupational safety and health
Working conditions (wages, working hours)

5. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following labour rights issues?

	No monitoring of progress	Review issues on ad-hoc basis	Set annual targets/ goals, track progress over time (internal programs only)	Set annual targets/ goals, track progress over time (internal and external programs)	Other (Please provide additional information)
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
Occupational safety and health
Working conditions (wages, working hours)

Performance

6. What is the percentage of employees covered under collective bargaining agreements?

	Percent of employees (%)	Unknown
Employees covered under collective bargaining (%)	71.53

7. What is the percentage of employees in a trade union or other workers' organization?

	Percent of employees (%)	Unknown	Not applicable (Please provide additional information)
Employees in a trade union or on a worker committee (%)	56.43

8. In the course of the reporting period, what was the percentage of women in:

	Percent of women (%)	Unknown
Senior leadership level position	20
Non-executive board	15

9. What was the average ratio of the basic salary and remuneration of women to men (comparing jobs of equal value) during the reporting period?

	Salary ratio (%)	Unknown	Choose to not disclose
Women / Men (%)	100

Optional comment

Please see page 86 of our 2021 Group Sustainability Report. The group percentage is 102/104%. The data used in the comparison is the comparative ratio against the midpoint of the person’s salary scale. This is only measured for permanent employees as fixed term contractors are generally not linked to specific grade-based salary scales.

10. In the course of the reporting period, how frequently were workers injured (injuries per hour worked)?

	Frequency of injury	Unknown	Choose to not disclose
Frequency of injury	0.48

Optional comment

The figure for contractors (LTIFR) was 0.31

11. In the course of the reporting period, what was the company’s incident rate?

	Incident rate	Unknown	Choose to not disclose
Incident rate	0.48

Optional comment

We calculate LTIFR by dividing the product of lost-time injuries and a group-wide standard for man hours by the unit’s man hours, ie LTIFR = LTI * 200 000/unit’s actual man hours. As from FY2021, we excluded LTIs that result in light duty from the calculations.

Response and Reporting

12. In the course of the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to the adverse impact associated with the following labour rights issues?

	Yes	No	Choose to not disclose	Not applicable (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
No such incidents
Child labour
No such incidents
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

13. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the labour rights principles, including any challenges faced and actions taken towards prevention and/or remediation.

1) Sappi endorses the principles of fair labour practice as entrenched in the United Nations Global Compact and Universal Declaration of Human Rights. At a minimum, we conform to and often exceed labour legislation requirements in countries in which we operate. Protecting the right to freedom of association and collective bargaining is fundamental to the manner in which we do business. We engage extensively with representative trade unions. Discussions range from remuneration issues, to training and development, health and safety and organisational changes. 2) Given the complex labour situation in South Africa, we have established a number of structures to enhance ongoing positive engagement with union leadership. This is facilitated by structures such as the National Partnership Forum which includes senior members of management and senior union leaders who hold regular meetings where business, safety and union challenges are discussed. 3) The health and safety committees at all our operations provide a forum for consultation about the development/ review of policies and procedures and changes that affect workplace safety or health. Wellness programmes include fitness and medical screening programmes, as well as psychological and financial support. 4) We conduct engagement surveys every second year, with the most recent taking place in FY2021. The survey tool provides a priority matrix that overlays the Sappi results with the factors that have the highest impact on engagement levels. Using the matrix, we have established areas of improvement for each region. On a global level these include senior manager relationships, department relationships, manager relationships, together with learning and development. 5) In FY2021, we made a concerted effort to encourage our people to vaccinate through ongoing communication campaigns and, in South Africa, established vaccinations stations at our operational sites to enable access to our people, their families and our contractors

Environment

Commitment

1. Does the company have a formal policy on the following environmental topics?

	No, and we have no plans to develop a policy	No, but we plan to in the next two years	Yes, included within a broader policy	Yes, articulated as a stand-alone policy	Not applicable (Please provide additional information)
Climate Action
2022
Water
2020
Oceans
Forests / Biodiversity / Land Use
2022
Air Pollution
2022
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
2022
Energy & Resource Use
2021

1.1. For each environmental policy, is it:

	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 supply chain and/or other business relationships?	Developed involving environmental expertise from inside and outside the company?	Other (Please provide additional information)
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

Optional comment

In terms of air pollution, we publicly report annually on NOx, SOx and particulate matter in our group sustainability report

Prevention

2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following environmental issues?

	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)
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

Optional comment

In terms of climate action and air pollution, we participate in a number of initiatives, including the WBCSD Forest Solutions Group; the Global Climate Change Institute at the University of the Witwatersrand, water: WWF water stewardship project in KwaZulu Natal province, forests/ biodiversity: the Textile Exchange, CAMCORE, waste: Circular Bioeconomy Alliance; energy: Manufacturing Circle (SSA). Partnerships are detailed on page 56 of the 2021 Sappi Annual Integrated Report The survey tool provides a priority matrix that overlays the Sappi results with the factors that have the highest impact on engagement levels. Using the matrix, we have established areas of improvement for each region. On a global level these include senior manager relationships, department relationships, manager relationships, together with learning and development.

3. 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?

	Provided internal training/ capacity building for the direct workforce	Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)	Conducting an audit process and/or corrective action plan	Collective Action with peers or other stakeholders to address the issue	Collaboration with governmental or regulatory bodies	Other (Please provide additional information)	No action within reporting period
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

4. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following environmental topics?

	No monitoring of progress	Review issues on ad-hoc basis	Set annual targets/ goals, track progress over time (internal programs only)	Set annual targets/ goals, track progress over time (internal and external programs)	Other (Please provide additional information)
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Included under out Climate Action GHG emissions reduction goals
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

Optional comment

Our targets are aligned with the UN SDGs we have prioritised and are both regional and global. Please see pages 11 - 17 of the 2021 group sustainability report, https://cdn-s3.sappi.com/s3fs-public/2021-Sappi-Group-Sustainability-Report-5.pdf

4.1. For each environmental topic in which the company sets timebound goals / targets, what kind of targets has the company set?

	Description of targets (e.g., what is the target, absolute vs. intensity, externally verified, on track, etc.)
Climate Action	Global: Decrease specific GHG (Scope 1 + 2) emissions by 18% from a 2019 base of 883.4 kg CO2e/adt by 2025. 2021 target:897.7 kg CO2e/adt. FY2021 performance: 840.9 kg CO2e/adt.
Energy & Resource Use	1) Global: Increase share of renewable and clean energy by 8% points by 2025 from a 2019 baseline of 51.6%. 2021 target: 54% 2021 performance: 52.4% 2) Global: Decrease specific total energy by 5% by 2025 from a 2019 base of 22.1 GJ/adt 2021 target: 22.4 GJ/adt 2021 performance: 22.3 GJ/adt
Water	Reduce specific water use in water-stressed locations(South Africa) by 23% by 2025, from a baseline of 44.5 m3/adt. 2021 target: 42.2 m3/adt 2021 performance: 46.2 m3/adt
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)	Global: Reduce specific landfilled solid waste by 15% by 2025 from a 2019 baseline of 65.9 kg/adt. 2021 target: 60 kg/adt. 2021 performance: 52.8 kg/adt
Oceans

Optional comment

Please note that under SDG15, Life on Land, we have established a global target to increase the amount of certified woodfibre supplied to our mills to be above 75% by 2025 from a baseline of 75% in 2019. In FY2021, 77% of the woodfibre supplied was certified. For our biodiversity target in SSA which is to enhance biodiversity in conservation areas by 10% per annum , please see page 17 , https://cdn-s3.sappi.com/s3fs-public/2021-Sappi-Group-Sustainability-Report-5.pdf

4.2. For each environmental topic in which the company sets timebound goals / targets, how is progress against target / goal tracked?

	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)
Climate Action
Energy & Resource Use
Water
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Oceans

Optional comment

We also review biodiversity/ forests targets annually, report them to the most senior level and report externally

5. In the course of the reporting period, has the company been involved in providing or enabling remedy for any actual impacts associated with the following environmental issue(s)?

	Yes	No	Choose to not disclose	Not applicable (Please provide additional information)
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

Climate Action

6. What were the company’s gross global greenhouse gas emissions for the reporting period?

Scope 1 Emissions

Full

None

Emissions (tCO2e)

4.273

Scope 2 Emissions

Full

None

Emissions (tCO2e)

1.023

Scope 3 Emissions

Full

Partial

None

Emissions (tCO2e)

3.275

Optional comment

Scope 3 emissions given here are for upstream (GHG Protocol categories 1 - 7)

7. What percentage of the company's revenue was invested in R&D of low-carbon products/services during this reporting period?

Percent of revenue (%)

Unknown

Not applicable (Please provide additional information)

Not separately accounted for, as we consider all our products to be low carbon

8. Has the organization acted to support climate change adaptation and resilience?

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

Other (Please provide additional information)

Unknown

Energy / Resource Use

9. Please report the company's renewable energy consumption as a percentage of total energy consumption in the reporting period.

% of total energy consumption

52.3

Unknown

Technology

10. What percent of the company's revenue came from environmentally friendly products / services during this reporting period?

Percent of total revenue (%)

100

We consider all our products to be environmentally friendly, as they are based on a renewably resource, woodfibre, grown in sustainably managed forests and plantations

Unknown

Not applicable (Please provide additional information)

Sector-specific: Water

12. Please provide details regarding the company's water withdrawal and consumption (own operations) during the reporting period.

Water withdrawal (volume of water in megaliters):

	Mega-liters	Unknown	Not applicable (Please provide additional information)
Total	287141
Groundwater:	18652
Surface water:	251854
Rainwater:
Rainwater is not applicable, we do not collect rain water.
Wastewater:
Wastewater is not applicable, we have internal water recycling streams but we do not recycle waste water from final effluent.
Percentage of water withdrawn in regions with high or extremely high water stress (%)	31.7

Water consumption (volume of water in megaliters):

	Mega-liters	Unknown	Not applicable (Please provide additional information)
Total	9758
Groundwater:
Surface water:
Rainwater:
We do not collect rain water.
Wastewater:
We have internal water recycling streams but we do not recycle waste water from final effluent.
Percentage of water consumed in regions with high or extremely high water stress (%)	31.7

13. Please provide details about the company’s water intensity of products in regions with high or extremely high water stress.

Water intensity of products (cubic meter/$):

0.0842

Unknown

Not applicable (Please provide additional information)

Optional comment

The figure given here is for South Africa, the only region where Sappi has manufacturing operations and which is classified as water stressed.

Sector-specific: Forest, biodiversity, and land use

14. 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).

	Number	Unknown	Not applicable (Please provide additional information)
Sites	156
Hectares	38320

Optional comment

The figure given here is for the 156 Important Conservation Areas on Sappi land. ICAs are areas that are important at the local level and are classified using a systematic conservation planning approach. Criteria that are used include the presence of both plant and animal red data species, the threat status of the ecosystem, the size, connectedness, condition and aesthetic and recreational value of the area.

15. What area (in hectares) of natural ecosystems was converted during the reporting period in areas owned, leased, or managed by the company?

Conversion of natural resources (hectares)

Unknown

Not applicable (Please provide additional information)

16. Is the company supporting or implementing project(s) focused on ecosystem restoration and protection?

	No	No, but we plan to in the next 2 years	Yes
Forest ecosystem restoration
Other ecosystem restoration
42000
Reforestation
Natural regeneration
6230
Agroforestry
10956
Set-aside land
136000
Biodiversity offsetting
Other (please specify in text box)

Optional comment

In South Africa, Sappi owns and leases 394,000 hectares of plantations of which 136,000 ha are unplanted and managed for biodiversity conservation. There are seven formally declared nature reserves on this land, totally 6,320 ha. We are involved in an agroforestry project with Meat Naturally on our land (10,956 ha). Sappi is working with communal livestock farmers in the landscape to address ecosystem degradation by implementing improved grazing practices that enhance grassland health. Our water stewardship project with WWF SA covers an area of 42,000 ha.

Sector-specific: Air pollution

17. Where applicable, please report the company's emissions of the following pollutants during the reporting period.

	Emissions (tCO2e)	Unknown	Not applicable (Please provide additional information)
NOx	11267.8
SOx	14360.3
Volatile Organic Compounds (VOC)
Not applicable to Sappi
Hazardous air pollutants (HAP)
Not applicable to Sappi
Particulate matter (PM10)	3430.7
Persistent organic pollutants (POP)
Other (please specify in text box)

Sector-specific: Waste

18. Please report the company's total weight of waste generated in metric tonnes during the reporting period.

Waste Generated (t)

1425162

Unknown

Not applicable (Please provide additional information)

19. Please report the percentage of the company's waste that was hazardous waste (i.e., hazardous waste ratio) during the reporting period.

Hazardous Waste Ratio (%)

0.15

Unknown

Not applicable (Please provide additional information)

20. Please report the company's estimated metric tonnes of single-use plastic consumed wherever material along the value chain during the reporting period.

Single-use plastics (tonnes)

Unknown

Not applicable (Please provide additional information)

Overall Environment

21. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the environment principles, including any challenges faced and actions taken towards prevention and/or remediation.

1) Following an extensive ten month consultation process with the Science Based Target Initiative organisation (SBTi) from June 2021 to March 2022, the following revised science based targets have been proposed: . Sappi Limited commits to reduce scope 1 and scope 2 GHG emissions 41.5% per ton of product by 2030 from a 2019 base year. Sappi Limited commits that 44% of its suppliers (by spend) will have science-based targets by 2026. The capital expenditure between FY2021 - 2030 required to achieve the targets is significant. 2) Our work with the University of Witwatersrand Global Change Institute to ensure progressive science-based understanding and more accurate modelling of climate change impact continued. 3) Sappi Forests completed a Three-Year Genomic Deployment plan to ensure optimal matching of genus and species to site conditions to maximise yield and sustainable cut to meet future market demand. 4) The Sappi/WWF (World Wide Fund for Nature) water stewardship project in the Umkomaas catchment gained momentum and the first community-based alien vegetation clearing and a maintenance project was launched with the Nzinga community. 5) Two pilot projects were launched to test PEFC and FSC group scheme platforms for micro growers. These projects will be concluded by end of September 2022 and will set the base for increasing certification targets

Anti-corruption

Commitment

1. Does the company have an anti-corruption compliance programme?

No, it is not an immediate business priority

No, but we plan to in the next two years

Yes

Optional comment

Reviewed by internal audit on an ongoing basis

2. 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?

No, and we have no plans to develop a policy

No, but we plan to in the next two years

Yes, included within a broader policy

Yes, articulated as a stand-alone policy

Prevention

3. Who receives training on anti-corruption and integrity?

Optional comment

We provide online training to a broad range of select employees on anti-corruption and code of ethics which include integrity we do however provide awareness campaigns to all employees relating to both topics.

3.1. How often is such training provided?

	One time only	Every year	Every two or more years	We do not collect this data
All employees
Select employees
Contractors
Direct suppliers of the organization
Other – such as partners, clients, etc.
Indirect suppliers of the organization

4. Does the company monitor its anti-corruption compliance programme?

No, we do not monitor the anti-corruption compliance programme

Review issues on ad-hoc basis

Yes, through internal employee self-evaluations

Yes, through automated controls monitoring

Yes, through external independent monitoring

Yes, through other mechanisms

Optional comment

We regularly review the relevant policies regarding anti-corruption and introduce changes to ensure we cover all aspects and ensure there is no uncertainty to what behaviour is in contravention of the Group policy. In this regard we review internal audit reports and country specific and global incidents.

Response and Reporting

5. Please report the company's total number and nature of incidents of corruption during the reporting year.

	Number of incident(s)	Unknown	Choose to not disclose
Confirmed during the current year, but related to previous years	12
BEE fronting, conflict of interest, cyber incidents, employee expenses, fraud, procurement complaints, theft
Confirmed during the current year, and related to this year	12
As above, the figure of 12 refers to incidents closed out in the reporting year

6. 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?

Initial case assessment

Internal investigation

Review by risk / ethics committee

Review by board of directors

External audit / review

Other (please provide additional information)

Not applicable/no incidents in the reporting period

7. Does your company engage in Collective Action against corruption?

No, it is not an immediate business priority

No, but we plan to in the next two years

Yes (please explain)

Optional comment

Should it be an identified priority for the business associations to which we belong, like Business Leadership South Africa, we would engage through this channel

8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the anti-corruption principle, including any challenges faced and actions taken towards prevention and/or remediation.

The Social, Ethics, Transformation and Sustainability (SETS) Committee, a fully constituted board committee, monitors our activities on matters such as social and economic development, including the United Nations Global Compact (UNGC) and the OECD Guidelines on Bribery and Corruption, with particular emphasis on section VII of the Organisation for Economic Cooperation and Development (OECD) guidelines for multinational enterprises dealing with combating bribery, bribe solicitation and extortion. No issues were raised for Sappi in fy2021 on compliance with the convention either externally or internally. We regularly review the Code of Ethics to ensure that it remains aligned to current governance and business trends