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Corporate Social Responsibility (CSR) Assessment Report Company Assessed : PALLADIO ZANNINI INDUSTRIE GRAFICHE CARTOTECNICHE (GROUP) CSR engagement: Advanced Size: Medium Country (company headquarters): Italy Presence in Risk Countries: Yes Category/Industry: Manufacture of corrugated paper and paperboard and of containers of paper and paperboard Overall Score: October 2016 73/100 Giampaolo Carone ©Copyright EcoVadis™ 21/10/2016 7.39.27 – All rights reserved www.ecovadis.com │ +33 (0) 1 82 28 88 88 [email protected] Ecovadis Assessment Report - October 2016 Page: 1/32

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Page 1: PALLADIO ZANNINI INDUSTRIE GRAFICHE CARTOTECNICHE (GROUP) · PALLADIO ZANNINI INDUSTRIE GRAFICHE CARTOTECNICHE (GROUP) has an overall score of 73 and the company is ranked alongside

Corporate Social Responsibility (CSR) Assessment Report

Company Assessed : PALLADIO ZANNINI INDUSTRIEGRAFICHE CARTOTECNICHE (GROUP)

CSR engagement: Advanced

Size: MediumCountry (company headquarters): ItalyPresence in Risk Countries: YesCategory/Industry: Manufacture of corrugated paper and paperboard and ofcontainers of paper and paperboard

Overall Score:October 2016

73/100

Giampaolo Carone ©Copyright EcoVadis™ 21/10/2016 7.39.27 – All rights reservedwww.ecovadis.com │ +33 (0) 1 82 28 88 88

[email protected]

Ecovadis Assessment Report - October 2016

Page: 1/32 

Page 2: PALLADIO ZANNINI INDUSTRIE GRAFICHE CARTOTECNICHE (GROUP) · PALLADIO ZANNINI INDUSTRIE GRAFICHE CARTOTECNICHE (GROUP) has an overall score of 73 and the company is ranked alongside

TABLES OF CONTENTS

1. Score Overview

2. Supplier Scorecard Objectives

3. Assessment Process

4. Ecovadis Methodology

a. Four themes with 21 criterias

b. Seven management indicators

c. Scoring Scale

5. How to understand company Scorecard

a. Quantitative information: score & activated criteria

b. Qualitative information: Strengths & Improvement Areas

6. Theme: Environment

7. Theme: Labor Practices & Human Rights

8. Theme: Fair Business Practices

9. Theme: Sustainable Procurement

10. 360° ­ Stakeholder Information

11. Specific Comments

12. Contact us

ABOUT CORPORATE SOCIAL RESPONSIBILITY (CSR)

Corporate Social Responsibility (CSR) is the continuing commitment to behave responsibly by integrating social and environmental concernsinto business operations. CSR goes beyond regulatory compliance to focus on how companies manage their economic, social, andenvironmental impacts, as well as their relationships with stakeholders (e.g. employees, suppliers, government).

ABOUT THE ASSESSMENT

The EcoVadis methodology framework assesses the policies and measures put in place as well as the reporting published by companies withregards to environmental, labor practices & human rights, fair business practices and sustainable procurement issues. The assessmentconducted by CSR experts is made on the basis of the company answers to a survey which is dynamically adapted to their country, sectorand size, on the basis of supporting documentation, and on public and stakeholder (NGOs, trade unions, press) information.

ABOUT ECOVADIS

EcoVadis operates the 1st collaborative platform allowing companies to assess the environmental and social performance of their supplierson a global basis. EcoVadis combines technology and Corporate Social Responsibility (CSR) expertise to deliver simple and reliable supplierscorecards, covering 150 purchasing categories and 21 CSR criteria.

This document cannot be reproduced or distributed unless otherwise specified in EcoVadis contractually granted license right. No part of this document may be modified in wholeor in part and in any form prior express written permission of EcoVadis. EcoVadis does not warrant the accuracy, reliability, completeness of the information, content, text,

graphics provided on this document.

EcoVadis Assessment for PALLADIO ZANNINI INDUSTRIE GRAFICHE CARTOTECNICHE (GROUP) - October 2016

Giampaolo Carone ©Copyright EcoVadis™ 21/10/2016 7.39.27 – All rights reservedwww.ecovadis.com │ +33 (0) 1 82 28 88 88

[email protected]

Ecovadis Assessment Report - October 2016

Page: 2/32 

Page 3: PALLADIO ZANNINI INDUSTRIE GRAFICHE CARTOTECNICHE (GROUP) · PALLADIO ZANNINI INDUSTRIE GRAFICHE CARTOTECNICHE (GROUP) has an overall score of 73 and the company is ranked alongside

CSR PERFORMANCE

Environment ENV 80

Labor Practices LAB 70

Fair Business Practices FBP 70

Sustainable Procurement SUP 70

BENCHMARK

Benchmark is done on all suppliers of the same businesscategory on the EcoVadis database

Corrective Action Plan in progress

1. Score Overview

The overall and theme scores summarize the CSR performance of PALLADIOZANNINI INDUSTRIE GRAFICHE CARTOTECNICHE (GROUP) on a scale of 1 to100.

Legend

Outstanding Advanced Confirmed Partial None

The grey bars on this graph represent the benchmarks. Benchmarks comparea company’s overall score and theme scores to other companies operatingwithin the same industry. Here the Benchmark on over 150 suppliers.NOTE:

The top and bottom 5% of performers are excluded to ensure statisticalrelevance.ENV : EnvironmentLAB : Labor Practices & Human RightsFBP : Fair Business PracticesSUP : Sustainable Procurement

This graph depicts the distribution of overall scores for several thousandcompanies on the EcoVadis p lat form. PALLADIO ZANNINI INDUSTRIEGRAFICHE CARTOTECNICHE (GROUP) has an overall score of 7 3 and thecompany is ranked alongside 2% which have Advanced CSR engagement.

The red dot represents the average of all suppliersThe blue diamond refers to company position

PALLADIO ZANNINI INDUSTRIE GRAFICHE CARTOTECNICHE (GROUP) hasbeen identified as Gold regarding their approach to CSR management. Toachieve this recognition, a company must have an overall score of [62-100].

The Corrective Action Plan (CAP) is an interactive tool shared betweensuppliers and buyers. It helps to develop Action Plans, a starting point for aneffective dialogue on actions taken by the supplier to improve their CSRperformance. PALLADIO ZANNINI INDUSTRIE GRAFICHE CARTOTECNICHE(GROUP) has a CAP in place and is working on improving their CSRmanagement system.

OVERALL SCORE 73/100

EcoVadis Assessment for PALLADIO ZANNINI INDUSTRIE GRAFICHE CARTOTECNICHE (GROUP) - October 2016

Giampaolo Carone ©Copyright EcoVadis™ 21/10/2016 7.39.27 – All rights reservedwww.ecovadis.com │ +33 (0) 1 82 28 88 88

[email protected]

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management system.

2. Supplier Scorecard Objectives

UNDERSTAND:

Get a clear picture of the company’s CSR performance. With a score on four CSR themes (environmental, labor practices &Human Rights, fair business practices and sustainable procurement), that highlight the company’s strengths and possible areas forimprovement.Know the company’s positioning compared to their industry sector peers. On which theme is this company better positionedthan their peers? How is this company positioned in comparison to their sector average?Identify sector specific initiatives. What are the main international CSR regulations and sector initiatives specific to the industrysector of the company?

COMMUNICATE:

Meet client needs. More and more companies raise questions about their supplier’s environmental and social performance. Thisassessment allows to demonstrate company commitment.Leverage a unique communication tool. Directly share the assessment results with all clients.

3. Assessment Process

EcoVadis Assessment for PALLADIO ZANNINI INDUSTRIE GRAFICHE CARTOTECNICHE (GROUP) - October 2016

Giampaolo Carone ©Copyright EcoVadis™ 21/10/2016 7.39.27 – All rights reservedwww.ecovadis.com │ +33 (0) 1 82 28 88 88

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4. Ecovadis Methodology is based on

A. Four themes with 21 criteria

The EcoVadis methodology takes into account 21 CSR criteria which are contained under four themes: ENVIRONMENT, LABOR, FAIRBUSINESS PRACTICES, and SUSTAINABLE PROCUREMENT. The methodology and criteria are in line with international CSR standardsincluding the Global Reporting Initiative, United Nations Global Compact, and ISO 26000.

B. Seven management indicators

The EcoVadis assessment evaluates a company CSR management system by looking at seven management indicators. The four themesand their subsequent 21 CSR criteria are assessed on the basis of the following management indicators that a company has in place.

Policies (weight: 25%)

1. Policies: Mission statements, commitments, principles, objectives and/or policies issued by the company.2. Endorsement: Endorsement of CSR external initiatives, principles and/or active participation to international/sector CSR initiative.

Actions (weight: 35%)

3. Measures: Concrete actions put in place to support commitments, objectives and deployment of policies (e.g. training, manualprocedures).

4. Coverage: Level of deployment/dissemination of measures and concrete actions put in place throughout the company to supportcommitments and/or policies.

5. Certifications: Certifications received for the management system and/ or labels received for the products/ services delivered.

Results (weight: 40%)

6. Reporting/ KPI: Quality and level of reporting readily available to stakeholders7. 360°: Controversies, condemnations or positive developments reported by stakeholders (NGOs, Trade Unions, Press) having an

impact on the company's CSR performance.

EcoVadis Assessment for PALLADIO ZANNINI INDUSTRIE GRAFICHE CARTOTECNICHE (GROUP) - October 2016

Giampaolo Carone ©Copyright EcoVadis™ 21/10/2016 7.39.27 – All rights reservedwww.ecovadis.com │ +33 (0) 1 82 28 88 88

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5. How to understand company Scorecard

The overall score can be better understood by looking at quantitative information - theme scores, activated criteria - and qualitativeinformation - strengths & improvement areas.

A. QUANTITATIVES INFORMATION: SCORES & ACTIVATED CRITERIA

THEME SCORES: Like the overall score, theme scores are on a scale of 1 to 100.

ACTIVATED CRITERIA: Each of the four themes - ENVIRONMENT, LABOR, FAIR BUSINESS PRACTICES, and SUSTAINABLEPROCUREMENT- have specific criteria associated to them. It is important to note that not all 21 criteria are activated for everycompany and some criteria have more weight than others in the overall assessment. The weights for the criteria are determinedbased on the CSR risks faced by the company according to their industry of operation and their country of operation(s). For moreinformation see Appendix: category profile.

Non ActivatedIf criteria are not activated, this means that the specific associatedissue is not relevant or has very low CSR risk for the company

Medium ImportanceMedium importance criteria are the issues where there is some CSRrisk, but it is not the most pressing criteria.

High ImportanceHigh-importance criteria are the issues where the company facesthe greatest CSR risk.

Only in Risk countriesCriteria classified as Only in Risk Countries are activated only if thecompany has significant operations in one or more risk country.

B. QUALITATIVE INFORMATION: STRENGTHS & IMPROVEMENT AREAS

Qualitative information provides more details and insights into the theme scores. For each theme the company is assigned Strengths (theelements of the CSR management system that are positive) and Improvement Areas (the elements of the CSR management system thatneed to be improved). The strengths & improvement areas are divided according to the 3 management indicators - Policies, Actions,Results – and are also classified by level of importance/priority (i.e. Priority.)

Green check marks indicate the Strengths Alert signs indicate the Improvement Areas

Improvement Areas are a focus point for improvement. The EcoVadis Corrective Action Plan Tool allows companies to improve their CSRperformance on specific improvement areas. It is an interactive tool shared between suppliers and buyers. It supports the development ofAction Plans, a starting point for an effective dialogue between buyers and suppliers on actions taken by a supplier to improve their CSRperformance.

Each improvement area is given a priority levelwhich can be used to set up corrective actionplans.

Priority Level

High

Medium

Low

EcoVadis Assessment for PALLADIO ZANNINI INDUSTRIE GRAFICHE CARTOTECNICHE (GROUP) - October 2016

Giampaolo Carone ©Copyright EcoVadis™ 21/10/2016 7.39.27 – All rights reservedwww.ecovadis.com │ +33 (0) 1 82 28 88 88

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C. THE SCORING SCALE

EcoVadis Assessment for PALLADIO ZANNINI INDUSTRIE GRAFICHE CARTOTECNICHE (GROUP) - October 2016

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Page 8: PALLADIO ZANNINI INDUSTRIE GRAFICHE CARTOTECNICHE (GROUP) · PALLADIO ZANNINI INDUSTRIE GRAFICHE CARTOTECNICHE (GROUP) has an overall score of 73 and the company is ranked alongside

6. ENVIRONMENT

The environment theme takes into account both operational factors (e.g. energy consumption, waste management, etc.) and productstewardship (e.g. product end of life, customer health and safety issues).

ENVIRONMENT: SCORES

CSR PERFORMANCE

Environment ENV 80

Labor Practices LAB 70

Fair Business Practices FBP 70

Sustainable Procurement SUP 70

WEIGHT of the Theme ENV 3 out of 10 -> 30% of the global score

Themes are weighted according the CorporateSocial Responsibility (CSR) risks associated tothe company industry of operation and countryof operation(s). The theme weights influence theresulting overall score.

BENCHMARK

This benchmark shows the company overall score incomparison to the scores of industry sector peers on theEcoVadis platform. The top and bottom 5% of performersare excluded to ensure statistical relevance.

DETAILED SCORE BENCHMARK

The theme benchmark is a more detailed comparison ofthe company’s theme score in comparison to othercompanies operating within the same industry. NOTE:Benchmark is only activated when they are at least 3suppliers to compare with.

ENVIRONMENT: ACTIVATED CRITERIA

Non Activated Medium Importance High Importance Only in Risk countries

Note: Not all 21 criteria are activated for every company and some criteria have more weight than others in the overall assessment. Theweights for the criteria are determined based on the CSR risks faced by the company according to their industry of operation and theircountry of operation(s).

ENVIRONMENT: STRENGTH & WEAKNESSES

Note: The number of alert signs or checks next to a strength or weakness does not represent the performance of the company; ratherthey indicate the level of importance of each individual strength and/or weakness

This icon informs that the company has a Corrective Action Plan (CAP) in place associated to a particular weakness. The CAP is aninteractive tool shared between suppliers and buyers. It helps to develop Actions to improve the supplier’s CSR performance.

EcoVadis Assessment for PALLADIO ZANNINI INDUSTRIE GRAFICHE CARTOTECNICHE (GROUP) - October 2016

Giampaolo Carone ©Copyright EcoVadis™ 21/10/2016 7.39.27 – All rights reservedwww.ecovadis.com │ +33 (0) 1 82 28 88 88

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ENVIRONMENT:POLICIES

Priority Strength or Weakness Additional Definition CAP

Quantitative objectives set on some relevant issues [i.e. energy consumption & GHGs ]

More Information • The company has formally defined and communicatedquantitative objectives with regards to the main environmentalissues it is confronted with.

Guidance • Quantitative objectives or targets on environmental issues areconsidered as fundamental elements of comprehensive policymechanism. They provide a monitoring framework that helpsestablish whether policy objectives are being met, and highlightthe progress towards set goals. Some examples of specifictargets on this topic include quantitative objectives on energyconsumption reduction, percentage targets to reduce waste, ortargets for a number of products to be eco-labelled. As policyelements, targets can be expressed in absolute or relative termsand must have a valid future deadline (i.e. by 2020 we commit toreduce our energy consumption by 20% from 2015 levels).

• To achieve the maximum score on the policies indicator, validquantitative objectives or targets should be present for allrelevant environmental issues. Cl ick on the l ink below forECOVADIS HOW­TO GUIDES — Developing an EnvironmentalPolicy.

Standard policy on a majority of environmental issues More Information • A standard environmental policy includes commitments and/oroperational objectives on the main environmental risks thecompany faces.

Guidance • A comprehensive environmental policy includes commitmentsand/or operational objectives on the majority of environmentalrisks the company faces, and integrates quantitative objectives(i.e. targets) on those risks. It is also mandatory for the policy toincorporate some of the following elements: scope of application,allocation of responsibilities, and/or a formal review process.Policies are deemed exceptional when all environmental issues arecovered by qualitative and quantitative objectives, in addition toall of the aforementioned elements. Click on the link below forECOVADIS HOW­TO GUIDES — Developing an EnvironmentalPolicy.

No supporting documentation or only basic policy onsome relevant issues [ i.e. water ]

More Information • The company has either no supporting documentation onpolicies, or only provided evidence of basic policy statements thatdo not cover all the major environmental issues the company isconfronted with.

Guidance • A standard environmental policy integrates commitmentsand/or operational objectives on the main environmental risksthe company faces. It is communicated to internal and externalstakeholders through a formal dedicated document (e.g. QHSEPolicy). A standard environmental policy contains qualitativeobjectives/commitments specific to those issues. The policyshould also incorporate some of the following elements: scope ofapplication, allocation of responsibilities, quantitative objectives(i.e. on energy consumption & GHG emissions and materials,chemicals & waste management), and review mechanisms. Clickon the link below for ECOVADIS HOW­TO GUIDES — Developingan Environmental Policy.

Global Compact signatory

Dedicated responsibility for environmental issues More Information • A dedicated individual responsible for the environmental policyhas been identified with a name and a credible title.

EcoVadis Assessment for PALLADIO ZANNINI INDUSTRIE GRAFICHE CARTOTECNICHE (GROUP) - October 2016

Giampaolo Carone ©Copyright EcoVadis™ 21/10/2016 7.39.27 – All rights reservedwww.ecovadis.com │ +33 (0) 1 82 28 88 88

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ENVIRONMENT:ACTIONS

Priority Strength or Weakness Additional Definition CAP

61-80% of operational sites ISO 14001 certified

Waste management measures in place

Declares measures on environmental impacts fromproduct end-of-life, but no supporting documentationavailable

More Information • The company declares it has implemented actions on mitigationof environmental impacts from product end-of-life. However, noinformat ion was found on th is topic in the support ingdocumentation.

Guidance • Some examples of actions on this topic include company takeback programs, formal life cycle analysis on key products anddesigning packaging for easy dismantling or recyclability.

Energy audit or carbon assessment performed

Measures to reduce energy consumption

Measures to reduce paper consumption

Reduction of water consumption through employeeawareness programs

Reduction of energy consumption through innovativetechnologies

Implementation of VOC treatment techniques

Reduction of water consumption through the use ofefficient equipment or technology

EcoVadis Assessment for PALLADIO ZANNINI INDUSTRIE GRAFICHE CARTOTECNICHE (GROUP) - October 2016

Giampaolo Carone ©Copyright EcoVadis™ 21/10/2016 7.39.27 – All rights reservedwww.ecovadis.com │ +33 (0) 1 82 28 88 88

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ENVIRONMENT:RESULTS

Priority Strength or Weakness Additional Definition CAP

Comprehensive reporting on environmental issues More Information •There is evidence of reporting implemented regardingenv i ronmenta l i ssues wi th in the company support ingdocumentation, including key performance indicators (KPIs),statistical figures or associated concrete actions. The reportingcovers the main issues and is regularly updated.

Guidance • The reporting covers the entity under evaluation (e.g. KPIsmight be aggregate at group level). KPIs may include: directenergy consumption by primary energy source, total directgreenhouse gas emissions, total volume of water recycled andreused (Source: Global Reporting Initiative). Additionally, KPIs arereported in a formal public document available to stakeholders,and are in compliance with the Global Reporting Initiativeguidelines or other external CSR reporting standards. Click onthe link below for ECOVADIS HOW­TO GUIDES — Developing anEnvironmental Report. Cliquez sur le lien ci­dessous pour accéderà: ECOVADIS HOW­TO GUIDES — Developing an EnvironmentalReport (en anglais).

CSR report follows GRI guidelines [ In accordance - Core]

More Information •The company has endorsed the Global Reporting Initiative (GRI)reporting guidelines.

Guidance •GRI, the Global Reporting Initiative, provides the guideline forcompanies to disclose their environmental and social impact in astandard framework (Global Reporting Initiative). There areseveral levels of reporting: including alpha rankings from A to C,'self declared' or GRI 'Checked' levels, and finally In accordance -Core without external assurance. The level of reporting can beaudited by a third party or can be self-declared.

The company's scope 1 and 2 CO2 emissions (per unitof revenue) have increased since the previous year

Company reports to Carbon Disclosure Project (CDP) More Information • The company has responded to the Carbon Disclosure Project(CDP) survey (either Investor or Supply Chain Responses) andmade its response publicly available on the CDP website.

• The Carbon Disclosure Project is an independent not­for­profitorganization, after an initiative led by the institutional investorcommunity. Each year, large corporations are asked throughcomprehensive questionnaires to disclose their greenhouse gasemissions and climate change strategies in their CDP response.

Reporting on direct CO2 emissions

Reporting on fossil fuel energy consumption

Reporting on electricity consumption More Information •The company has reported KPIs with regard to electricityconsumpt ion e i ther through formal documentat ion orquestionnaire declaration.

Guidance • The company reports on electricity consumption from facilities,plants, property or assets that are owned or controlled by thecompany. Examples of key performance indicators include totalelectricity consumption, electricity consumed per kg of product orper unit produced.

Reporting on water consumption

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7. LABOR PRACTICES & HUMAN RIGHTS (LAB)

The labor theme takes into account both Labor Practice issues (e.g. health and safety, working conditions, etc.) and Human Rightsissues (e.g. discrimination, child labor, etc.).

LABOR & HUMAN RIGHTS: SCORES

CSR PERFORMANCE

Environment ENV 80

Labor Practices LAB 70

Fair Business Practices FBP 70

Sustainable Procurement SUP 70

WEIGHT of the Theme LAB 4 out of 10 -> 40% of the global score

Themes are weighted according the CorporateSocial Responsibility (CSR) risks associated tothe company industry of operation and countryof operation(s). The theme weights influence theresulting overall score.

BENCHMARK

This benchmark shows the company overall score incomparison to the scores of industry sector peers on theEcoVadis platform. The top and bottom 5% of performersare excluded to ensure statistical relevance.

DETAILED SCORE BENCHMARK

The theme benchmark is a more detailed comparison ofthe company’s theme score in comparison to othercompanies operating within the same industry. NOTE:Benchmark is only activated when they are at least 3suppliers to compare with.

LABOR & HUMAN RIGHTS: ACTIVATED CRITERIA

Non Activated Medium Importance High Importance Only in Risk countries

Note: Not all 21 criteria are activated for every company and some criteria have more weight than others in the overall assessment. Theweights for the criteria are determined based on the CSR risks faced by the company according to their industry of operation and theircountry of operation(s).

LABOR & HUMAN RIGHTS: STRENGTH & WEAKNESSES

Note: The number of alert signs or checks next to a strength or weakness does not represent the performance of the company; ratherthey indicate the level of importance of each individual strength and/or weakness

This icon informs that the company has a Corrective Action Plan (CAP) in place associated to a particular weakness. The CAP is aninteractive tool shared between suppliers and buyers. It helps to develop Actions to improve the supplier’s CSR performance.

EcoVadis Assessment for PALLADIO ZANNINI INDUSTRIE GRAFICHE CARTOTECNICHE (GROUP) - October 2016

Giampaolo Carone ©Copyright EcoVadis™ 21/10/2016 7.39.27 – All rights reservedwww.ecovadis.com │ +33 (0) 1 82 28 88 88

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LABOR PRACTICES & HUMAN RIGHTS:POLICIES

Priority Strength or Weakness Additional Definition CAP

Standard policy on a majority of labor or human rightsissues

More Information •  A  s tandard   labor  and human  r ights  po l i cy   inc ludescommitments and/or operational objectives on the main laborand human rights risks the company faces.

Guidance • A comprehensive labor and human rights policy includescommitments and/or operational objectives on the majority oflabor and human rights risks the company faces, and integratesquantitative objectives (i.e. targets) on those risks. It is alsomandatory for the policy to incorporate some of the followingelements: scope of application, allocation of responsibilities,and/or a formal review process. Policies are deemed exceptionalwhen all labor practice and human rights issues are covered byqualitative and quantitative objectives, in addition to all of theaforementioned elements. Click on the link below for ECOVADISHOW­TO GUIDES — Developing a Labor Practices & HumanRights Policy.

Dedicated responsibility for labor practice issues

Global Compact signatory

No quantitative target on labor & human rights issues More Information • Company policy does not contain quantitative targets on laborand human rights issues.

Guidance • Quantitative objectives or targets on labor and human rightsissues are considered as fundamental elements of comprehensivepolicy mechanism. They provide a monitoring framework thathelps establish whether policy objectives are being met, andhighlight the progress towards set goals. Some examples ofspecific targets on this topic include quantitative objectives onhealth & safety indicators (i.e. accident frequency and accidentseverity rates), quantitative objectives on percentage ofemployees trained on discrimination and quantitative objectiveson number of employees covered by social benefits. As policyelements, targets can be expressed in absolute or relative termsand must have a valid future deadline (i.e. by 2020 we commit totrain 100% of employees on discrimination). Click on the linkbelow for ECOVADIS HOW­TO GUIDES — Developing a LaborPractices & Human Rights Policy.

LABOR PRACTICES & HUMAN RIGHTS:ACTIONS

Priority Strength or Weakness Additional Definition CAP

Internal audits on health & safety issues

61-80% of operational facilities OHSAS 18001 certified

Company-wide collective agreement signed on workingconditions, including agreement on remuneration

Training of relevant employees on health & safety risksand best working practices

No information on measures regarding child and/orforced labor issues

More Information • No company declaration and no evidence within the supportingdocumentation on actions implemented to mitigate the risk ofchild and forced labor.

Guidance • Some examples of actions on this topic include awarenesstraining on child and forced labor issues, disciplinary measuresand whistle blowing procedures, and formal engagements withlocal authorities to prevent child and forced labor.

Awareness training to prevent discrimination and/orharassment

Awareness training specific to fundamental human rightsperformed for relevant employees

Whistleblower procedure on human rights issues More Information • The company has implemented a formal whistle blowingprocedure which encourages employees (and externalstakeholders) to report potential violations of the company

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Priority Strength or Weakness Additional Definition CAP

human rights policies.

• Employees can report on areas such as violations of thecompany's fundamental human rights policies (e.g. on employeesprivacy rights, harassment, moral and physical violence andinhumane treatment) through anonymous and securecommunication channels.

Local employee representatives

Monitoring of employee satisfaction

Provision of protective equipment to all impactedemployees

Official measures to promote work-life balance More Information • The company has implemented working practices thatacknowledge and aim to support the needs of staff in achieving abalance between their home and working lives. Examples of worklife-balance measures include: the possibility to work from home,to work part time, flexible-time schedules, childcare facilities atwork, in-house services.

Employee health & safety detailed risk assessment

Regular assessment (at least once a year) of individualperformance

Company specific health care program for employees More Information • The company has implemented a specific health care programfor employees covering private medical treatment.

• Some examples of areas it could cover include drug treatmentof cancer, health assessments, dental care, surgical proceduresand treatment of conditions relating to alcohol and substanceabuse.

Active preventive measures for stress and noise

Company-specific pension plan for employees

Specific procedures for handling of chemicals orhazardous substances

Provision of skills development training More Information • The company has implemented vocational training andinstruction, which include skills development training, educationpaid for in whole or in part by the company, with the goal toprovide opportunities for career advancement (Source: GlobalReporting Initiative G3).

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LABOR PRACTICES & HUMAN RIGHTS:RESULTS

Priority Strength or Weakness Additional Definition CAP

Comprehensive reporting on labor practices & humanrights issues

More Information •There is evidence of reporting implemented regarding laborpractices & human rights issues within the company supportingdocumentation, including key performance indicators (KPIs),statistical figures or associated concrete actions. The reportingcovers the main issues and is regularly updated.

Guidance • The reporting covers the entity under evaluation (e.g. KPIsmight be aggregate at group level). KPIs may include (but are notlimited to): accident frequency and severity rates, the percentageof employees covered by collective bargaining agreements, skillsdevelopment trainings, and percentage of employees trained ondiscrimination issues. Additionally, KPIs are reported in a formalpublic document available to stakeholders, and are in compliancewith the Global Reporting Initiative guidelines or other externalCSR reporting standards. Click on the link below for ECOVADISHOW­TO GUIDES — Developing a Labor Practices & HumanRights Report.

Reporting on accident severity rate More Information • The company reports a severity rate of accidents among itsemployees during the last reporting year.

Guidance • The accident severity rate measures the time lost due tooccupational injuries in relation to the total amount of timeworked. It indicates how severe the accidents were and how longthe injured employees were out of work as a result of disablinginjuries.

Reporting on accident frequency rate More Information • The company reports a frequency rate of accidents among itsemployees during the last reporting year.

Guidance • The accident frequency rate measures the number of injurieswith lost time in relation to the total amount of time worked. Itindicates the extent to which injury incidents are repeated overtime and their number of occurrence.

CSR report follows GRI guidelines [ In accordance - Core]

More Information •The company has endorsed the Global Reporting Initiative (GRI)reporting guidelines.

Guidance •GRI, the Global Reporting Initiative, provides the guideline forcompanies to disclose their environmental and social impact in astandard framework (Global Reporting Initiative). There areseveral levels of reporting: including alpha rankings from A to C,'self declared' or GRI 'Checked' levels, and finally In accordance -Core without external assurance. The level of reporting can beaudited by a third party or can be self-declared.

4 - 6% of disabled workers out of total workforce

Reporting on number of average training hours peremployee

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8. FAIR BUSINESS PRACTICES (FBP)

The fair business practice theme focuses primarily on corruption and bribery issues, but also takes into account anti-competition andresponsible marketing depending on the industry of operation.

FAIR BUSINESS PRACTICES: SCORES

CSR PERFORMANCE

Environment ENV 80

Labor Practices LAB 70

Fair Business Practices FBP 70

Sustainable Procurement SUP 70

WEIGHT of the Theme FB 2 out of 10 -> 20% of the global score

Themes are weighted according the CorporateSocial Responsibility (CSR) risks associated tothe company industry of operation and countryof operation(s). The theme weights influence theresulting overall score.

BENCHMARK

This benchmark shows the company overall score incomparison to the scores of industry sector peers on theEcoVadis platform. The top and bottom 5% of performersare excluded to ensure statistical relevance.

DETAILED SCORE BENCHMARK

The theme benchmark is a more detailed comparison ofthe company’s theme score in comparison to othercompanies operating within the same industry. NOTE:Benchmark is only activated when they are at least 3suppliers to compare with.

FAIR BUSINESS PRACTICES: ACTIVATED CRITERIA

Non Activated Medium Importance High Importance Only in Risk countries

Note: Not all 21 criteria are activated for every company and some criteria have more weight than others in the overall assessment. Theweights for the criteria are determined based on the CSR risks faced by the company according to their industry of operation and theircountry of operation(s).

FAIR BUSINESS PRACTICES: STRENGTH & WEAKNESSES

Note: The number of alert signs or checks next to a strength or weakness does not represent the performance of the company; ratherthey indicate the level of importance of each individual strength and/or weakness

This icon informs that the company has a Corrective Action Plan (CAP) in place associated to a particular weakness. The CAP is aninteractive tool shared between suppliers and buyers. It helps to develop Actions to improve the supplier’s CSR performance.

FAIR BUSINESS PRACTICES:POLICIES

Priority Strength or Weakness Additional Definition CAP

Standard policy on a majority of business ethics issues

Ethics committee in place More Information • The company has nominated an Ethics Committee.

Guidance • The Ethics Committee can have various attributions but itusually has the authority and responsibility for supervising thecompany ' s bus iness e th i c s po l i c y , f o r r ev i ew ing i t simplementation and for acting as an arbitrage committee in caseof potential violations.

Global Compact signatory

No supporting documentation or only basic policy oninformation security

Structured mechanisms to deal with policy violations

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FAIR BUSINESS PRACTICES:ACTIONS

Priority Strength or Weakness Additional Definition CAP

Audits of internal controls to prevent informationsecurity breaches

Awareness training performed to prevent corruption &bribery

Whistleblower procedure to report corruption & bribery More Information •The company has implemented a formal whistle blowingprocedure which encourages employees (and externalstakeholders) to report potential violations of the company'scorruption and bribery policies.

Guidance • Employees can report on areas such as violations of thecompany's corruption and bribery policies (e.g. on gift giving,conflict of interest, fraud, corruption) through anonymous andsecure communication channels.

FAIR BUSINESS PRACTICES:RESULTS

Priority Strength or Weakness Additional Definition CAP

Comprehensive reporting on business ethics issues

CSR report follows GRI guidelines [ In accordance - Core]

More Information •The company has endorsed the Global Reporting Initiative (GRI)reporting guidelines.

Guidance •GRI, the Global Reporting Initiative, provides the guideline forcompanies to disclose their environmental and social impact in astandard framework (Global Reporting Initiative). There areseveral levels of reporting: including alpha rankings from A to C,'self declared' or GRI 'Checked' levels, and finally In accordance -Core without external assurance. The level of reporting can beaudited by a third party or can be self-declared.

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9. SUSTAINABLE PROCUREMENT (SUP)

The sustainable procurement theme focuses on both social and environmental issues within the company supply chain.

SUSTAINABLE PROCUREMENT: SCORES

CSR PERFORMANCE

Environment ENV 80

Labor Practices LAB 70

Fair Business Practices FBP 70

Sustainable Procurement SUP 70

WEIGHT of the Theme SUP 1 out of 10 -> 10% of the global score

Themes are weighted according the CorporateSocial Responsibility (CSR) risks associated tothe company industry of operation and countryof operation(s). The theme weights influence theresulting overall score.

BENCHMARK

This benchmark shows the company overall score incomparison to the scores of industry sector peers on theEcoVadis platform. The top and bottom 5% of performersare excluded to ensure statistical relevance.

DETAILED SCORE BENCHMARK

The theme benchmark is a more detailed comparison ofthe company’s theme score in comparison to othercompanies operating within the same industry. NOTE:Benchmark is only activated when they are at least 3suppliers to compare with.

SUSTAINABLE PROCUREMENT: ACTIVATED CRITERIA

Non Activated Medium Importance High Importance Only in Risk countries

Note: Not all 21 criteria are activated for every company and some criteria have more weight than others in the overall assessment. Theweights for the criteria are determined based on the CSR risks faced by the company according to their industry of operation and theircountry of operation(s).

SUSTAINABLE PROCUREMENT: STRENGTH & WEAKNESSES

Note: The number of alert signs or checks next to a strength or weakness does not represent the performance of the company; ratherthey indicate the level of importance of each individual strength and/or weakness

This icon informs that the company has a Corrective Action Plan (CAP) in place associated to a particular weakness. The CAP is aninteractive tool shared between suppliers and buyers. It helps to develop Actions to improve the supplier’s CSR performance.

SUSTAINABLE PROCUREMENT:POLICIES

Priority Strength or Weakness Additional Definition CAP

Sustainable wood and wood products sourcing policy

Sustainable procurement policies on both environmentand social factors

More Information • The company has issued formal policies that integratecommi tments and/or opera t iona l ob jec t i ves on bo thenvironmental and social issues it is confronted with in its supplychain.

Guidance • The importance of issues covered by the policies may varyaccording to the industry or sector. Such issues can include CSRrequirements for both supplier practices (environmental andsocial), and product/service characteristics (e.g. use ofindependently verified labeling schemes). It is contained in aformal policy document (i.e. CSR Procurement Guidelines).

• There are at least qualitative objectives/commitments withspecificities on the main issues.

• The policies might also incorporate some of the followingelements: scope of application, allocation of responsibilities,quantitative objectives (i.e. number of suppliers audited orcertified) , and review mechanisms.

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SUSTAINABLE PROCUREMENT:ACTIONS

Priority Strength or Weakness Additional Definition CAP

Supplier CSR code of conduct in place

PEFC/FSC chain-of-custody certified More Information • The company has provided a valid PEFC or FSC Chain ofCustody certificate for at least one of its operational sites.

• The company's PEFC or FSC Chain of Custody certificateprovides external assurance ofsourcing from sustainablymanaged forestry.

• The Programme for the Endorsement of Forest Certification(PEFC) schemes (a lso known as Pan-European ForestCertification) promotes sustainably managed forests throughindependent third party certification. The Forest StewardshipCouncil (FSC) is an international not for-profit organization,which promotes responsible management of the world’s forest bydirectly or indirectly addresses issues such as illegal logging anddeforestation.

• Chain of custody (CoC) tracks certified wood material throughthe production process including all stages of processing,transformation, manufacturing and distribution.

Regular supplier assessment (e.g. questionnaire) onenvironmental or social practices

More Information • The company demonstrates evidence of suppl ier CSRassessments (in-house, 3rd party, or self-assessments) throughchecklists or questionnaires to verify compliance with its own pre-defined set of CSR requirements.

• CSR assessment questionnaires can be in­house driven orsupported by a third-party organization, and include questionson environmental (including regulatory issues), social and ethicalissues.

• CSR assessment can also consist in checklists, online forms 

• Assessment can be conducted by the client, a reliable thirdparty, or by the supplier itself.

Declares CSR performance of suppliers integrated inbuyer performance appraisal, but no supportingdocumentation available

Traceability measures to ensure wood/ paper pulp doesnot come from genetically modified trees

Conflict minerals taken into account in supplier selectionprocess

Traceability measures to ensure wood/paper pulp comesfrom sustainable logging

Use of monitoring organisation to ensure compliancewith European Union Timber Regulation

Integration of social or environmental clauses intosupplier contracts

More Information • The company's contractual agreements with subcontractorssystematically contain a binding clause that requires thosesuppliers to comply with international CSR standards or todemonstrate a proactive CSR approach.

• Such contract clauses can contain defined measures that theclient can impose in case CSR clauses are not respected (e.g.contract termination).

• Some specific issues covered in supplier contracts can includechild labor, conflict minerals, REACH and RoHS.

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SUSTAINABLE PROCUREMENT:RESULTS

Priority Strength or Weakness Additional Definition CAP

Standard reporting on sustainable procurement issues More Information • The company publishes formal reporting within supportingdocuments on the management and mitigation of CSR issues inits supply chain.

• Reporting is comprised of key performance indicators (KPIs),statistical figures or associated concrete actions in a formalizeddocument.

• KPIs can be sector­specific and include for instance theabsolute number of: suppliers assessed against CSR criteria,suppliers for which on-site audits where conducted, suppliershaving formally signed the client's Supplier Code of Conduct, theamount of procurement team members or suppliers formallytrained etc.

• Please note that EcoVadis gives more credit to transparency onabsolute figures over percentages (e.g. number of suppliers forwhich an action was implemented instead of the proportion ofspend covered).

• Comprehensive reporting is available in a CSR or Annual reportand includes recent KPIs covering several years. KPIs areexternally verified by a independent third party. The GRI G4offers a description of more than 10 CSR indicators directlyrelated to the supply chain.

No progress report on sustainable sourcing of woodand wood products

21-40% of papers/carton coming from recycledpaper/carton

A b o v e 5 0 % o f p a p e r / c a r t o n o r w o o d b a s e dproducts/materials coming from certified forest

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10. The 360° WATCH: stakeholders' information

360º WATCH

09/2016 No records found for this company on Compliance Database. .

The 360° is a web based tool to collect stakeholders insight on a company‘s CSR approach and impacts. A corporate stakeholder is a partythat can affect or be affected by the actions of the company and the achievement of its objectives (i.e. employees, clients, suppliers).

Note: If a strength or weakness is activated on the 360°, this is an indicator that the 360° has had an impact on the score.

Only legitimate stakeholder sources are selected:

Governmental organizations (i.e. government environmental protection administrations, anti-trust agencies, customers protectionagencies)CSR networks and initiativesTrade unions and employers’ organizationsInternational organizations (i.e. UN, ILO, UNEP, …)NGO’s (i.e. Greenpeace, Clean Clothes Campaign, Transparency international, UFC, …)Research institutes and reputable press (CSR Asia, Blacksmith Institute, …)

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11. SPECIFIC COMMENTS

Specific comments are key points which indicate some specific characteristics of the company CSR evaluation and will help to betterunderstand the company’s performance.

Some supporting documents were considered too outdated to be included in this evaluation The company demonstrates a comprehensive CSR management system that covers all four themes under review. The company is not included in any compliance-related watch lists or sanction lists.

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MORE INFORMATION

For more information, please refer to our website (http://www.ecovadis.com) where you can also connect to the EcoVadis platform.

If you have any questions or problems, do not hesitate to contact us:

By email at: [email protected] phone : +33 (0) 1 82 28 88 88

Provided under contract for exclusive use of subscriber: Giampaolo Carone - 21/10/2016

This assessment is valid for 12 months only.

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APPENDIX : CATEGORY PROFILE

A Category Profile offers practical insights into the key sustainability issues which are applicable to the company industry of operation. Itprovides a link to major regulations, sector initiatives, and eco-labels.

The company industry of operation has been determined based on International Standard Industrial Classification of AllEconomic Activities (ISIC), which is a compilation of all global economic activities published by the United Nations StatisticalCommission.

The International Standard Industrial Classification of All Economic Activities (ISIC) main purpose is to provide a set ofactivity categories that can be utilized for the collection and reporting of statistics according to such activities.

International Standard Industrial Classification of All Economic Activities, Rev.4, United Nations, New York, 2008

It is possible that a company has operations in more than one category, but EcoVadis classifies companies based on their main area ofoperation.

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CRITERIA ACTIVATION BY THEME:

Each category faces specific CSR issues and risks based on their industry of operation. The below chart shows the criteria activated for thecompany category name : Manufacture of corrugated paper and paperboard and of containers of paper and paperboard.

Environment

Energy Consumption & GHG

Water

Biodiversity

Local Pollution

Materials, Chemicals & Waste

Product Use

Product End-of-Life

Customers Health & Safety

Sustainable Consumption

Labor Practices

Employee Health & Safety

Working Conditions

Social Dialog

Career Management & Training

Child & Forced Labor

Discrimination

Fundamental Human Rights

Fair Business Practices

Corruption & Bribery

Anti-competitive Practices

Responsible Marketing

Sustainable Procurement

Suppliers & Environment

Suppliers & Social

Non Activated Medium Importance High Importance Only in Risk countries Noteworthy Practices

KEY CSR ISSUES

This section shows a qualitative explanation of the key CSR issues and risk pertaining to Manufacture of corrugated paper andpaperboard and of containers of paper and paperboard.

Key CSR Issues ENVIRONMENT

Energy Consumption & GHG

Definition: Energy consumption (e.g. electricity, fuel, renewable energies) used during operations and transport.Greenhouse gases direct and indirect emissions including CO2, CH4, N2O, HFC, PFC and SF6. Also includesproduction of renewable energy by the company.

Sectorial issues: Corrugated paper and paperboard manufacturing is an energy-intensive process. In the US, forexample, the pulp, paper, and allied products industry is the third largest consumer of energy after the chemicalsand metals industries (1). As a result, energy consumed during manufacturing is the major source of GHGemissions in this category (2). Nonetheless, the forest products industry has demonstrated increased efficiencyover the last decades, becoming a leader in co-generation from biomass-driven combined heat and power (CHP)system (3). According to the IPCC 2014 report, the global pulp and paper industry generates approximately athird of its own energy needs from biomass (2). Figures are much higher in Europe and the US, where 56.5% and66% (respectively) of the industry’s energy consumption is biomass­based, and 95.2% and 96.4% of itselectricity is generated through CHP systems (4)(5). In addition, other energy efficiency technologies andemerging technologies have the potential to provide energy saving opportunities for companies – with anestimated 6.2% energy saving potential of the global energy demand of the pulp and paper industry in 2030 (2).

Water

Definition: Water consumption during operations. Pollutants rejected into water.

Sectorial issues: Water is one of the key resources in this category. In the US, the pulp and paper industry isthe largest consumer of industrial process water (1). Water is used in nearly every stage of the pulping andpapermaking process including in washer filters, bleaching, liquors clarification, cooling towers, and boilers.Consequently, large volumes of wastewater effluents are generated: pulp and paper manufacturers’ wastewaterdischarge can amount to 10-250 cubic meters per metric ton of product (6). Untreated wastewater has adverseconsequences on freshwater and marine environments, arising from high total suspended solids, biochemicaloxygen demand, and dissolved organic compounds (1)(6). To reduce environmental impacts, companies invest inwastewater treatment systems, in reusing water in certain processes, among other measures. Although water isneeded for manufacturing, less than 15% is consumed within the product or lost during production (evaporation)(7).

Materials, Chemicals & Waste

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Definition: Consumption of all types of raw materials and chemicals. Non-hazardous and hazardous wastegenerated from operations. Also includes air emissions other than GHG (e.g. SOx, NOx).

Sectorial issues: A range of chemicals is used for manufacturing in this category. In fact, the diversity ofchemicals used reflecting the diversity of processes used. For example, over 12 different pulping processes are inuse in the US, each having different environmental concerns (1). In addition to having work processes for labeling,storing, handling, and transporting hazardous goods and chemicals, companies in this sector have implementedchemical recovery processes, which have both economic and environmental benefits (1). For example, chemicalrecovery and recycling systems can be very effective: up to 98% of pulping chemicals are recovered and recycled(5). In addition, the industry is experiencing a trend towards material substitutions, to alternative pulping andbleaching chemicals with reduced environmental impacts (1). Likewise, increasing demand means a trend forincreasing use of recycled fibers – with paper being recycled an average of 3.5 times in Europe (4). In regards towaste, there are a number of residual waste streams from mills, the largest by volume being wastewatertreatment sludge (1). Sulphur dioxide and NOx emissions from boilers, and VOC emissions from chip digestersand chemical recovery evaporators can also represent significant emissions from mills (1). Therefore, companiesincreasingly invest in pollution control technologies and improving their waste management processes.

Product End-of-Life

Definition: Direct Environmental impacts generated from the end-of-life of the products. These impacts caninclude hazardous, non-hazardous waste generated, emissions and accidental pollution.

Sectorial issues: Figures on recycling of corrugated paper and paperboard are consistently high. Globally,corrugated products are the most recovered form of packaging, with 91% percent of all being reclaimed forrecycling in 2012 (10). There are 2 steps in the end of life processes that contribute to reduction of environmentalimpact in this category. First is recovery, which refers to collection of used products including old corrugatedcontainers (OCC) for use as raw materials, thus diverting them from landfills. The second step is recycling, whichentails preparation of recycled materials for use in manufacturing of new products (11). Increased recovery ofOCC is one of the primary reasons for the reduction of environmental footprint within this industry, which is dueto diversion of OCC from landfills and thus avoiding methane emissions (11). Therefore to maintain the highrecyclability rates of corrugated paper and paperboard and further reduce the adverse environmental impact ofthe industry, it is important to facilitate recycling programs by manufacturers and industry associations.

LABOR PRACTICES

Employee Health & Safety

Definition: Deals with health and safety issues encountered by employees at work i.e. during operations andtransport. Includes both physiological and psychological issues arising from, among others, dangerousequipment, work practices and hazardous substance.

Sectorial issues: Corrugated paper and paperboard manufacturing poses several health and safety risks foremployees. Among the main H&S hazards of workers in pulp and paper mills are the potential of injury fromfalling, rolling, and/or sliding pulpwood loads, as well as moving machinery accidents from inadequate machineguarding among other factors (12). For example, employee injuries may arise from debarking and chippingequipment in pulp mills (6). Hazards also arise from the various chemicals used, as well as exposure to noise andwood/fiber dust, which in addition poses a fire hazard (6). Although there are many risks, the accident rates ofthe industry are consistently falling: a 60% reduction in accident rate since 2002 in Europe (4) and a 24%reduction in recordable case incidence rate since 2006 in the USA (5). To mitigate health and safety risks withinthis category, companies can set ambitious safety targets and implement measures in line with a comprehensivehealth and safety management systems based on the OHSAS 18001 standard.

Working Conditions

Definition: Deals with working hours, remunerations and social benefits granted to employees.

Sectorial issues: According to the European Commission’s EU­27 statistics, the pulp, paper and paperboardmanufacturing subsector registers high personnel costs, averaging EUR 50 thousand per employee in 2010,compared to a manufacturing average of EUR 35.8 thousand (13). Similarly, the American Forest & PaperAssociation claims that wages at pulp and paper mills are 50% higher than the private sector average (5).Conditions of work, such as wages, working time, rest periods, and holidays, are usually set by national laws andregulations. Companies should minimally ensure compliance to such laws or meet international standards whenthey are more stringent than local laws. Moreover, companies can make efforts to provide conditions of work thatallow workers to enjoy a better work-life balance.

Social Dialog

Definition: Deals with structured social dialogue i.e. social dialog deployed through recognized employeerepresentatives and collective bargaining.

Sectorial issues: According to the 2014 International Trade Union Confederation Global Poll, 63% of surveyrespondents think “workplaces that have a union representing workers provide better wages, conditions andhealth and safety for workers” and 76% “think unions play an active role in society” (14). In this line, active andstructured social dialogue is widely recognized as an important labor practice, including for the manufacturing ofcorrugated paper and paperboard. The International Labor Organization guidance encourages companies to carryout collective bargaining with employee representatives in good faith, and with best efforts to come to anagreement, especially promoting the use of voluntary collective bargaining to regulate terms and conditions ofemployment (15).

Career Management & Training

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Definition: Deals with main career stages i.e. recruitment, evaluation, training and management of layoffs.

Sectorial issues: In order to foster a strong and committed workforce, companies need to invest in training anddevelopment of their employees. As set by international labor conventions, companies should work to ensure theadequate qualification and training of their employees, including establishing skills and knowledge requirements foreach job function, and considerations regarding employment and promotion prospects (15). Moreover, theEuropean pulp and paper industry highlights new challenges including an ageing workforce, reduced appeal amongyoung workers for the industry, and a gap in knowledge transmission (4). It is thus important for companies toestablish proactive measures throughout the employment cycle to face these emerging challenges.

Child & Forced Labor

Definition: Deals with child, forced or compulsory labor issues within the company owned operations.

Sectorial issues: Child labor and forced labor are particularly important issues for companies with operations inrisk countries. Forced labor is prevalent in conflict areas and is considered a criminal offence and a violation ofhuman rights. Child labor is prohibited by UN Convention on the Rights of the Child (16). Companies accused ofexploiting child or forced labor risk serious harm to their reputation and potential loss of market share. Tominimize the risk associated with child and forced labor companies raise internal awareness of the staff, implementmonitoring procedures to prevent human rights violations, and establish reporting mechanisms such as whistle-blowing procedures.

Discrimination

Definition: Deals with discrimination issues at work. Discrimination is defined as different treatment given topeople in hiring, remuneration, training, promotion, termination; based on race, national origin, religion, disability,gender, sexual orientation, union membership, political affiliation or age.

Sectorial issues: Diversity in the workplace can be a key asset for any company, while discrimination is a seriousissue addressed by specific regulations in most countries. The ISO 26000 guidance for companies to reduce thisrisk include systematically examining potential direct or indirect discrimination that may arise from their laborpolicies and practices, and taking actions to provide for the protection of vulnerable groups. An FAO reportexamining the gender situation in the forestry related industries found that although improvements have beenmade over the years, women are still clearly underrepresented, and it remains a highly male-dominated workingenvironment (17). An ILO study based on the European forest sector found that the gender gap is in the forestryindustry is even more pronounced within managerial/senior roles within companies, and confirmed that femaleemployee wages in most countries are lower than their male counterparts (17). To address issues of genderinequality, companies should not only work towards recruiting more women, but also implementing measures tocreate a workplace conducive to retaining its female employees. In addition, companies in this sector can invest intraining its workforce on discrimination and diversity issues and establish reporting mechanisms such as whistle-blowing procedures to report discrimination.

Fundamental Human Rights

Definition: Deals with fundamental human rights issues at work. This includes the respect of security, propertyrights, employees privacy rights, civil and political rights, rights to freedom of association and collective bargaining,social and cultural rights (including indigenous people) as well as the prevention of harassment, moral and physicalviolence and inhumane or degrading treatment.

Sectorial issues: The respect for human rights at work is a basic principle upheld by several internationalinitiatives such as The Universal Declaration of Human Rights, the ILO Declaration on Fundamental Principles andRights at Work, and the UN Global Compact. It is an issue applicable to companies operating in risk countries inparticular. Corrugated paper and paperboard manufacturers increasingly operate in tropical developing countries,to take advantage of lower costs and favorable climates for fast-growing trees, representing a shift in theproduction and consumption of forest products at large (7). A shift to operating in countries with potentially weakregulatory systems means the exposure to these risks is anticipated to increase and the responsibility furtherplaced on companies to ensure management systems are in place to respect the fundamental human rights oftheir employees. To minimize the risk associated with fundamental human rights, companies in this category areencouraged to implement specific policies designed to safeguard employees’ rights (18). When communicatedacross organization to all employees and reinforced by awareness training, these policies serve as a foundation ofhuman rights management system (19). Other mitigating measures include having a grievance procedure or awhistle blowing system in place to ensure that the victims are heard without fear of retaliation and that thosefound guilty are sanctioned accordingly (20).

FAIR BUSINESS PRACTICES

Corruption & Bribery

Definition: Deals with all forms of corruption issues at work, including among other things extortion, bribery,conflict of interest, fraud, money laundering.

Sectorial issues: Corruption and bribery are major issues for any company. Regulations such as the U.S. ForeignCorrupt Practices Act (FCPA) make companies accountable for unlawful payments made to foreign governmentofficials used to assist in obtaining or retaining business. Corruption in the forest products industry is arecognized issue, with civil society organizations active in monitoring corrupt practices and governments makingefforts to strengthen anti-corruption mechanisms. The context in which 90% of industrial wood harvestedworldwide is produced as a result of government contracts, leads to a high risk of corruption during the allocationof logging licenses and concessions, with this risk then impacting the entire value chain (21). According toTransparency International, there is a strong correlation between illegal logging and corruption, and thatcorporate level corruption plays a central role in facilitating illegal logging (22). Companies can take preventiveactions against these risks such as through implementing effective codes of conduct with internal complianceaudits and whistle-blowing procedures.

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Anti-competitive Practices

Definition: Deals with anti-competitive practices including among others: bid-rigging, price fixing, dumping,predatory, pricing, coercive monopoly, dividing territories, product tying, limit pricing, and the non respect ofintellectual property.

Sectorial issues: Companies in this category face significant anti-trust risk rooted in firms converging oncommon strategy based on control of timber assets. An example of such risk is the recent cartel accusations ofthe Spanish Association of Corrugated Packaging Manufacturers (AFCO) allegedly engaging in anti-competitivebehavior including collective recommendations, price sharing and price fixing (23). To minimize the risk associatedwith anti-trust practices, companies in the industry set internal codes of conducts, provide training on how toavoid anti-competitive practices, conduct audits on compliance and establish formal procedures to reportviolations of anti-competitive policies.

SUSTAINABLE PROCUREMENT

Suppliers & Environment

Definition: Deals with environmental issues within the supply chain i.e. environmental impacts generated from thesuppliers and subcontractors own operations and products.

Sectorial issues: Some of the key supply chain risks faced by corrugated paper and paperboard manufacturersderive from environmental issues linked to their wood fiber procurement. Companies face risks when purchasingwood fiber from suppliers that do not follow sustainable forestry practices or sourced from illegal logging. Adverseenvironmental consequences of unsustainable forestry practices and illegally harvested wood include biodiversityloss and GHG emissions from land-use change, forest degradation, and deforestation. Due to these concerns,and emerging regulatory pressures, companies in this category are increasingly engaged in chain-of-custodyprograms, such as the Program for the Endorsement of Forest Certification (PEFC) and the Forest StewardshipCouncil (FSC) certification program. There are over 140 million ha of FSC-certified and 231 million ha of PEFC-certified surfaces globally and this follows a growing trend (4). Another important issue is the environmentalperformance and practices of subcontractor, for which environmental assessments and audits can be performedto verify compliance.

Suppliers & Social

Definition: Deals with labor practices and human rights issues within the supply chain i.e. labor practices andhuman rights issues generated from the suppliers and subcontractors own operations or products.

Sectorial issues: Companies in this category are inevitably involved in the procurement of wood fiber, andconsequently face associated social and ethical risks throughout their own supply chain. One issue in particular isthe risk of companies purchasing wood fiber originating from illegally harvested wood. Illegal logging not onlypromotes corruption, undermines the rule of law, and is largely controlled by organized crime, but it is alsoestimated to cost US$15 billion in lost assets and revenues per year worldwide (7). The risk of involvement isparticularly high when there lacks a good traceability system, or when sourcing from countries with weakregulatory systems (24). According to the International Labor Organization, the forestry sector is marked bywidespread informality, low wages, and hazardous working conditions (17). Companies can take steps to reducesuch risks in their supply chain by conducting supplier and subcontractor CSR assessments to verify compliancewith labor standards, as well as by providing capacity building for suppliers on best practices related to laborpractices and human rights issues. In particular, companies in this sector can work towards maintaining a reliableand up-to-date traceability system for their wood procurement.

SOURCES

Sources

1- U.S. Environmental Protection Agency (EPA), 2002, Profile of the Pulp and Paper Industry 2ndEdition http://www.epa.gov/compliance/resources/publications/assistan...

2- Intergovernmental Panel on Climate Change (IPCC), 2014, Climate Change 2014: Mitigation ofClimate Change: Chapter 10: Industry http://www.ipcc.ch/pdf/assessment-report/ar5/wg3/ipcc_wg3_ar5...

3- Food and Agriculture Organization (FAO) of the United Nations, 2010, Impact of the Global ForestIndustry on Atmospheric Greenhouse Gases http://www.fao.org/docrep/012/i1580e/i1580e00.pdf

4- Confederation of European Paper Industries (CEPI), 2013, CEPI Sustainability Report 2013 http://www.cepi-sustainability.eu/uploads/Full_sustainability...

5- American Forest & Paper Association, 2014 AF&PA Sustainability Report http://www.afandpa.org/docs/default-source/one-pagers/-2014-s...

6- International Finance Corporation, 2007, Environmental, Health, and Safety Guidelines: Pulp andPaper Mills http://www.ifc.org/EHSGuidelinesRevision

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7- Confederation of Paper Industries, 2014 http://www.paper.org.uk

8- Confederation of Paper Industries, 2013 http://www.risiinfo.com/techchannels/environment/CPI-UK-corru...

9- Greenpeace International, 2013, APP's Forest Conservation Policy: Progress Review, http://www.greenpeace.org/international/en/publications/Campa...

10- International Corrugated Packaging Foundation, 2013 http://www.icpfbox.org/

11- Corrugated packaging alliance, 2014 http://www.corrugated.org/

12- U.S. Dept. of Labor Occupational Safety & Health Administration (OSHA), 2014, Pulp, Paper, andPaperboard Mills https://www.osha.gov/SLTC/pulppaper/

13- European Commission, 2013, Manufacture of paper and paper products statistics - NACE Rev. 2 http://ec.europa.eu/eurostat/statistics-explained/index.php/M...

14- International Trade Union Confederation (ITUC), 2014, ITUC Global Poll 2014 http://www.ituc-csi.org/ituc-global-poll-2014

15- International Labour Organization (ILO), 2005, Guidelines for Labour Inspection in Forestry http://www.ilo.org/safework/info/standards-and-instruments/WC...

16- UNGC, 2013 https://www.unglobalcompact.org/aboutthegc/thetenprinciples/p...

17- Food and Agriculture Organization (FAO) of the United Nations, 2006, Time for Action: Changing thegender situation in forestry http://www.fao.org/sustainable-forest-management/toolbox/modu...

18- Workplace Bullying and Harassment, 2013. Published by: The Japan Institute for Labor Policy andTraining (JILPT) http://www.jil.go.jp/english/reports/documents/jilpt-reports/...

19- International Labour Organisation, ILO. and International Finance Corporation, IFC. (Undated).Guidelines on the Prevention of Workplace Harassment: Guideline for Employers. http://betterwork.org/indonesia/wp-content/uploads/Guidelines...

20- International Labour Organisation, ILO, 2011. Guidelines on Sexual Harassment Prevention at theWorkplace. http://www.ilo.org/wcmsp5/groups/public/---asia/---ro-bangkok...

21- Transparency International, 2010, Corruption in Logging Licenses & Concessions http://www.illegal-logging.info/sites/default/files/uploads/W...

22- Transparency International, 2011, Analysing Corruption in the Forestry Sector: A Manual http://www.transparency.org/whatwedo/pub/analysing_corruption...

23- EUWID, 2013 http://www.euwid-paper.com/news/singlenews/Artikel/cnc-invest...

24- WWF Global Forest & Trade Network (GFTN), The GFTN Guide to Legal and Responsible Sourcing http://sourcing.gftn.panda.org/

25- International Labour Organization (ILO), 2011, International Year of Forests 2011: What about thelabour aspects of forestry? http://www.ilo.org/sector/Resources/publications/WCMS_160879/...

MAIN REGULATIONS AND SECTORS INITIATIVES

This section provides a list of text references related to major CSR standards, regulations, labels or sector initiatives pertaining toManufacture of corrugated paper and paperboard and of containers of paper and paperboard.

Main Regulations and Sectors Initiatives ( = Regulatory)

ENV : Corrugated paper recycling campaign by the Confederation of Paper Industries - UK

The Confederation of Paper Industries (CPI) has launched a corrugated paper recycling campaignhttp://www.paper.org.uk/current_issues/corrugated_recycles.html

ENV : EU regulation REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals)

The REACH European Community Regulation (18 December 2006) encourages manufacturers and importers of"Substances of Very High Concern" to pre-register them.http://ec.europa.eu/environment/chemicals/reach/reach_intro.htm

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SUP : Label FSC (Forest Stewardship Council )

The FSC is an international non­profit organization established in 1993 to promote responsible management of the world’sforests. Its main tools for achieving this are standard setting, independent certification and labeling of forest products. http://www.fsc.org/about-fsc.html

SUP : Label PEFC (Programme for the Endorsement of Forest Certification schemes)

The PEFC Council is an independent, non-profit, non-governmental organization, founded in 1999 which promotessustainably managed forests through independent third party certification.http://www.pefc.org

SUP : Label SFI® (Sustainable Forestry Initiative® ) 

The SFI program is a comprehensive system of principles, objectives and performance measures developed byprofessional foresters, conservationists and scientists, among others that combines the perpetual growing and harvestingof trees with the long-term protection of wildlife, plants, soil and water quality.http://www.sfiprogram.org/

ENV : Packaging Recovery Organization Europe from Green Dot

Green Dot recycling programs: helps compliance with the Packaging and Packaging waste European Directive (94/62/CEof 20 Decembre 1994)http://www.greendotcompliance.eu/en/about-green-dot.php

ENV : Sustainable Packaging Alliance

SPA aims to be an international focal point for knowledge, tools and expertise that catalyse and facilitate continuousimprovement in the environmental performance and sustainability of packaging systems.http://www.sustainablepack.org/aboutSPA/default.aspx

ENV : Sustainable Packaging Coalition

The Sustainable Packaging Coalition advocates and communicates a positive, robust environmental vision for packagingand to support innovative, functional packaging materials and systems that promote economic and environmental healththrough supply chain collaboration.http://www.sustainablepackaging.org/about_vision.asp

ENV : Standard ISO 14000 (International Standard Organisation)

The ISO 14000 family addresses various aspects of environmental managementhttp://www.iso.org/iso/iso_14000_essentials

LAB : Universal Declaration of Human Rights

The Universal Declaration of Human Rights (UDHR) is an advisory declaration adopted by the United Nations GeneralAssembly (10 December 1948 )http://www.un.org/Overview/rights.html

LAB : International Labor Organization's Fundamental Conventions

The Governing Body of the International Labour Office has identified eight Conventions as fundamental to the rights ofhuman beings at work. These rights are a precondition for 12 the others in that they provide a necessary framework fromwhich to strive freely for the improvement of individual and collective conditions of work.http://www.ilo.org/wcmsp5/groups/public/---ed_norm/---declara...

LAB : Standard OHSAS 18001 (Occupational Health and Safety Assessment Series)

OHSAS 18000 is an international occupational health and safety management system specification. http://www.ohsas-18001-occupational-health-and-safety.com/ind...

FBP : Foreign Corrupt Practices Act of 1977

The Foreign Corrupt Practices Act of 1977 (FCPA) prohibits payments, gifts, or Practices Act contributions to officials oremployees of any foreign government or government-owned business for the purpose of getting or retaining business.http://www.usdoj.gov/criminal/fraud/fcpa/

FBP : United Nations Convention against Corruption (UNCAC)

The UNCAC is the first leg12y binding international anti-corruption instrument. In its 8 Chapters and 71 Articles, theUNCAC obliges its States Parties to implement a wide and detailed range of anti-corruption measures affecting their laws,institutions and practices.http://www.unodc.org/unodc/en/treaties/CAC/index.html

ALL : United Nations Global Compact (10 principles)

The Global Compact asks companies to embrace, support and enact, within their sphere of influence, a set of tenprinciples in the areas of human rights, labour standards, the environment, and anti-corruption:http://www.unglobalcompact.org/AboutTheGC/TheTenPrinciples/in...

ALL : OECD guidelines for multinational enterprises

The Guidelines are recommendations addressed by governments to multinational enterprises operating in or fromadhering countries. They provide voluntary principles and standards for responsible business conduct in a variety of areasincluding employment and industrial relations, human rights, environment, information disclosure, combating bribery,consumer interests, science and technology, competition, and taxation.http://www.oecd.org/about/0,2337,en_2649_34889_1_1_1_1_1,00.html

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ALL : Standard Global Reporting Initiative's (GRI)

The GRI is a network-based organization, that has set out the principles and indicators that organizations can use tomeasure and report their economic, environmental, and social performance.http://www.globalreporting.org/Home

ALL : Standard ISO 26000 (International Standard Organisation)

The future International Standard ISO 26000, Guidance on social responsibility, will provide harmonized, glob12y relevantguidance based on international consensus among expert representatives of the main stakeholder groups and soencourage the implementation of best practice in social responsibility worldwide.http://www.iso.org/iso/pressrelease.htm?refid=Ref972

ENV : Carbon disclosure project

CDP is an international, not-for-profit organization providing the only global system for companies and cities to measure,disclose, manage and share vital environmental information.https://www.cdp.net

SUP : EU Timber Regulation No 995/2010

Regulation (EU) No 995/2010 of the European Parliament and of the Council of 20 October 2010 laying down theobligations of operators who place timber and timber products on the market – also known as the (Illegal) TimberRegulation counters the trade in illegally harvested timber and timber products through three key obligations.http://ec.europa.eu/environment/forests/timber_regulation.htm

ADDITIONAL CATEGORY STATISTICS

Critical Category Strength and Improvement areas (% Suppliers)

Strengths

Reporting on electricity

consumption

Training of relevant

employees on health & safety

risks and best working

practices

Secure communication

channel for employees to

seek advice or voice

concerns (e.g. hotline,

whistleblowing procedure)

PEFC/FSC chain-of-custody

certified

0% 20% 40% 60% 80% 100%

Improvement areas

No certification of

environmental management

system (ISO 14001 or EMAS)

No OHSAS 18001

certification

No information on measures

regarding anti-corruption &

bribery

No sustainable procurement

measures in place

0% 20% 40% 60% 80% 100%

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Supplier PALLADIO ZANNINI INDUSTRIE GRAFICHE CARTOTECNICHE (GROUP) KPIs

Strengths and Improvement Areas

KPIsEcoVadisSuppliers

Active whistleblowing procedure in place 33%

Audit or assessment of suppliers on CSR issues 25%

Carbon disclosure project (CDP) respondent 7%

Formal code of business ethics 39%

Formal sustainable procurement policy 25%

Global Compact Signatory 11%

ISO 14001 certified (at least one operational site) 34%

OHSAS 18001 certification or equivalent (at least one operational site) 20%

Reporting on energy use or GHG emissions 75%

Reporting on health and safety indicators 76%

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