Elopak

Elopak explains that the Board of Directors is accountable for sustainability matters, including the material IROs, and is committed to building a culture of integrity and to ensuring the Group has the appropriate sustainability skills. The Board Audit and Sustainability Committee (BASC) is mandated to oversee ESG governance, frameworks and reporting, while the Board Succession and Compensation Committee (BSCC) oversees management compensation and succession. Management executes sustainability initiatives and approves sustainability targets. In 2024 Management delegated adherence to sustainability regulations and reporting to a new ESG council, chaired by the EVP of Product and Development, which meets quarterly and is supported by several expertise networks. The Board has a gender diversity ratio of 75% (three females and four males), consists exclusively of non-executive members with 57% independent, and includes five shareholder-elected directors and two employee representatives. Management has a gender diversity ratio of 25% (two females and eight males). Composition and expertise are detailed in the Governance chapter.

Elopak describes how its governing bodies are informed about sustainability matters. During 2024 the company made progress integrating risk assessments, target setting and KPIs into the business planning process, aligning IROs with the business plan and strategy. The Board was informed about sustainability matters regularly, both directly and through its committees, while Management was informed on a day-to-day basis and kept a range of sustainability matters on its monthly meeting agenda. A table summarizes the main agenda points addressed by each body in 2024. Management addressed items such as sustainability targets and projections, the Sustainability frontrunner program, the Packaging and Packaging Waste Regulation, and safety updates. The BASC focused on CSRD readiness, the updated gap analysis and the CSRD audit plan. The Board approved the combined annual and sustainability report, mid-term sustainability targets, the Human and labor rights transparency statement, the CSRD targets per material topic and the new ESG governance model. In 2025 Elopak will further strengthen the information flow.

Elopak reports that sustainability-related performance is integrated into its incentive schemes through the Long Term Incentive Program (LTIP). The LTIP aims to ensure achievement of Elopak's long-term strategic goals in a sustainable way and applies to Management and senior management. It includes performance on GHG emission reduction targets as part of the incentive scheme, linking remuneration to climate-related outcomes. Elopak states that the LTIP scheme is described in detail in the Remuneration report, which is referenced through incorporation by reference for this disclosure requirement.

Elopak states that the objective of sustainability due diligence is to identify, prevent, mitigate and take responsibility for managing actual and potential impacts on the environment and people. The company is committed to conducting due diligence in line with the UN Guiding Principles on Business and Human Rights, the OECD Guidelines for Responsible Business Conduct and the Norwegian Transparency Act. The Sustainability statement provides an overview of risk assessments and due diligence processes for each material topic where relevant, including Elopak's assessment of identified adverse impacts, the actions taken to address them and the results. Elopak will publish a statement of due diligence assessments in accordance with the Transparency Act on its website. An assessment of the core elements of due diligence is provided in the Appendix, and the statement on due diligence is also incorporated by reference to the Human and Labor Rights Transparency Statement.

Elopak explains that its general approach and systems for risk management and internal controls are described in the Governance chapter, and that the sustainability reporting process builds on this approach and on the ESRS requirements. The CSRD project management has monitored risks related to the reporting of the material topics covered in the Sustainability statement, and this has been reported to the relevant management bodies on a monthly basis. The double materiality assessment and the identification of material IROs form the foundation for the reporting, and a priority has been to ensure appropriate internal control mechanisms in relation to the DMA results. During 2024 Elopak reviewed the DMA and IROs based on input from internal stakeholders, identified risks related to reporting on new disclosure requirements, and implemented controls to review all data shared by business areas through an internal CSRD compliance tool. In 2025 the company will develop internal policies and procedures, including a new CSRD procedure covering internal controls and DMA updates.

Elopak provides end-to-end packaging solutions, delivering fiber-based packaging, filling machines and technical and aftermarket services. It has sales to over 70 markets across Europe and North America as well as emerging markets in MENA and India, supplying industries and segments such as dairy, juice, plant based and home and personal care. Sustainability is embedded in the strategy 'Repackaging tomorrow', a main pillar of which is to leverage the plastic replacement shift and drive the global move away from plastic bottles. Elopak maps its value chain across upstream, own operations and downstream. Upstream includes raw materials such as wood (mainly from Sweden, Finland and the US), bauxite, petrochemicals and iron ore (with iron sourced from Australia, Brazil, China and India). In own operations, plants convert paperboard, aluminium and polymers into products, and filling machines are produced in Germany with some bought from Shikoku. Downstream, customers fill cartons, filled cartons are transported to retailers mainly by truck, and cartons are recycled after use. Filling machines have an expected 20 year lifetime.

Elopak states that stakeholder engagement is a key part of the DMA, focusing primarily on qualitative interviews, with input from various stakeholders used to prioritize topics of strategic importance. Stakeholders' views were considered when assessing the ESRS long-list of topics to determine material topics. The company maintains ongoing dialogue with key stakeholders including customers and retailers, suppliers, shareholders and investors, financial institutions, employees, governments and regulators, NGOs and associations, local communities, and unions. In Europe it collaborates with unions through the European Works Council (EWC), which represents the majority of its sites and holds bi-monthly and annual meetings, with separate site dialogues outside Europe. A table sets out each group's interaction methods, topics raised (such as raw material sourcing, circularity, climate, health and safety and human rights) and the purpose and outcomes. Elopak acknowledges that communication with affected communities and workers in the value chain is not directly covered in its current stakeholder dialogue and will be addressed in the 2025 reassessment of the DMA.

Elopak presents its material impacts, risks and opportunities and their interaction with strategy and the business model. A matrix illustrates the final scores on impact and financial materiality for all material topics, and detailed overview tables list the material IROs for E1 Climate change, E2 Pollution, E4 Biodiversity and ecosystems, E5 Resource use and circular economy, S1 Own workforce, S2 Workers in the value chain, an entity-specific S4 Food safety topic, and G1 Business conduct, mapped to the value chain (upstream, own operations, downstream) and to short, medium and long-term time horizons. A separate table describes how each topic interacts with strategy and the business model, covering climate change, biodiversity and ecosystems, own workforce and workers in the value chain, noting for example that biodiversity negative impacts sit in the upstream value chain rather than own sites. Elopak has initiated an ESRS-compliant resilience analysis to assess how the identified IROs interact with its strategy, to be finalized in 2025, and applies a phase-in for anticipated financial effects under SBM-3 48e.

Elopak conducted its double materiality assessment in 2023 following the ESRS 1 methodology and readdressed it in 2024, treating a topic as material if it significantly impacts people or the environment or presents risks and opportunities affecting financial performance or position. The process ran across four phases: Understand (mapping activities, business relationships, value chain and stakeholders), Identify (classifying impacts by direction and type and linking them to value chain, time horizon and ESRS sub-topics), Evaluate (scoring impacts on severity using scale, scope, irremediability and likelihood, with a 1 to 5 scale and Elopak's financial thresholds), and Decide (applying thresholds so topics rated high or medium were considered material). Results were reviewed and validated by the project team, Management and the BASC. Climate risks were assessed using the TCFD framework with IPCC-based low emission (2C) and high emission (4C) scenarios. Biodiversity was assessed with the WWF Biodiversity risk filter, with a LEAP assessment planned for 2025. No material water and marine resources IROs were identified, and affected communities were not consulted. An update is planned in 2025.

Elopak explains that it applied the thresholds for both impact and financial materiality defined in the DMA process and mapped material topics on sub and sub-sub levels in accordance with ESRS 1 AR 16. It used the ESRS 1 Appendix E flowchart to determine the material disclosure requirements and data points. The material topical standards covered are E1 Climate change, E2 Pollution, E4 Biodiversity and ecosystems, E5 Resource use and circular economy, S1 Own workforce, S2 Workers in the value chain, an entity-specific Food safety topic reported under S4, and G1 Business conduct. E3 Water and marine resources and S3 Affected communities were not assessed as material. The material topics are presented in the Environmental, Social and Governance information sections. The full ESRS content index listing the disclosure requirements complied with, together with the table of all data points deriving from other EU legislation, is provided in the Appendix. Elopak also applied phase-in provisions under ESRS 1 Appendix C for several anticipated financial effects disclosures and work-life balance.

Elopak describes its general approach and key actions to reduce GHG emissions as an initial, high-level transition plan that only partly meets ESRS requirements. A more detailed plan is under development and is expected to be included in the 2025 sustainability statement, specifying decarbonization levers, quantitative annual contributions toward SBTi targets, and significant CapEx or OpEx. The SBTi validated scope 1 and 2 targets are compatible with limiting warming to 1.5C in line with the Paris Agreement, while the scope 3 target follows the Well below 2C pathway. These targets form the foundation of the transition plan, which supports the strategy Repackaging tomorrow. The current approach is approved by relevant members of Management, with the detailed plan to be approved once complete. A qualitative assessment of key assets identified no locked-in GHG emissions. Scope 1 and 2 account for 1 percent of total emissions and are not considered significant. Elopak completed an EU Taxonomy assessment in 2024 and is not excluded from EU Paris-aligned benchmarks.

Climate change is covered by Elopak's Sustainability policy and Environmental policy. The Sustainability policy is the overarching document describing the environmental, social and governance approach and all material topics. The Environmental policy sets out the approach for identifying and managing impacts, risks and opportunities related to climate change mitigation and adaptation, and anchors Elopak's commitment to the UN Paris Agreement (COP21). It describes efforts to mitigate climate change through the approved science-based targets and includes Elopak's target of purchasing 100 percent renewable electricity for all sites where it has operational control. All operations are committed to initiate and report on projects related to GHG reductions and energy saving and efficiency. Because Elopak does not currently have renewable energy production at its sites, that topic is not covered. Climate change adaptation is addressed through climate risk analysis based on the TCFD framework, which will be updated in 2025 and regularly thereafter. Both policies are owned by the EVP Product and Development and are internal.

Elopak's Sustainability frontrunner program guides internal key actions for reducing GHG emissions and will form the base for developing the detailed transition plan. In 2024 Elopak strengthened sustainability governance by updating the Sustainability and Environmental policies, expanded the sustainability team working on carbon accounting and product carbon footprints, and established an Environmental network and ESG council. Key mitigation actions in 2024, all ongoing, cover energy efficiency measures replacing fossil fuels in own operations, dialogues and collaboration with key suppliers on raw material GHG impact and lower-footprint boards, certification of raw materials to standards such as FSC, ISCC+ or ASI, improving data quality by collecting Life Cycle Assessments, optimizing transportation through end-to-end supply chain planning and investigating biofuels, electrification and hydrogen, and improving filling machine efficiency and technology adoption. Elopak has initiated transition plan work by anchoring its approach and allocating internal resources. The detailed plan will include quantitative annual contributions and any significant CapEx or OpEx required. Nature-based solutions are not yet included in the decarbonization levers.

Elopak has set targets for each emission scope using the SBTi Corporate Net-Zero Standard (Version 1.0, October 2021), validated by SBTi and compatible with the Paris Agreement. It was among the first three companies worldwide to have its net-zero target approved after the launch of the Corporate Net Zero Standard. Elopak committed to reduce scope 1 and scope 2 emissions by 42 percent by 2030 from a 2020 base year, aligned with the 1.5C pathway, and to cut absolute emissions in selected scope 3 categories by 25 percent by 2030 from a 2020 base year, aligned with the Well below 2C pathway. Long-term targets are to reduce absolute scope 1, 2 and 3 emissions by 90 percent by 2050 from a 2020 base year. Scope 2 emissions use a market-based approach, and Elopak will continue purchasing renewable electricity for the full consumption at all wholly owned sites. In base year 2020 scope 1 accounted for 87 percent of the combined scope 1 and 2 target emissions. Targets are gross, using no carbon credits, and are reviewed at least every five years.

Elopak reports total energy consumption of 122,575 MWh in 2024, up from 118,043 MWh in 2023. Total fossil energy consumption was 21,713 MWh, representing 18 percent of total energy, comprising natural gas of 14,941 MWh, propane and other fossil sources of 6,694 MWh, and petroleum products of 78 MWh. Consumption from nuclear sources was nil. Total renewable energy consumption was 100,862 MWh, representing 82 percent of total energy, including purchased electricity from renewable sources of 96,351 MWh and district heating of 4,511 MWh. Elopak purchases 100 percent renewable energy for its own operations. Renewable electricity contractual instruments totaled 96,351 MWh, sourced mainly from EECS GO at 74 percent, REC at 15 percent, I-REC at 11 percent and REGO at 0 percent. Energy intensity in 2024 was 0.106 MWh per EUR 1000. Fossil energy covers diesel, natural gas and propane used in production and leased cars, while renewable energy covers renewable electricity and district heating at Elopak sites.

Carbon accounting follows the GHG Protocol using the financial control consolidation approach. In 2024 gross Scope 1 emissions were 4,379 tCO2e, down 7 percent from 4,731 in 2023. Gross location-based Scope 2 emissions were 23,312 tCO2e and market-based Scope 2 emissions were 978 tCO2e. Combined Scope 1 and 2 was 27,692 tCO2e location-based and 5,357 tCO2e market-based, against a 2020 base year of 8,547 market-based and a 2030 target of 4,957. Scope 3 emissions part of the Science Based Targets totaled 591,993 tCO2e in 2024, up 5 percent from 566,392, with a 2030 target of 406,393; the largest categories were purchased goods and services at 374,981 and use of sold products at 148,790. Scope 3 across all categories summed to 752,673 tCO2e. Total GHG emissions were 780,364 tCO2e location-based and 758,030 tCO2e market-based, both up 2 percent. GHG intensity per net revenue was 0.675 location-based and 0.655 market-based. Emission factors draw on DEFRA, IEA and supplier-specific inputs.

In 2024 Elopak offered customers carbon neutral packaging by offsetting emissions through carbon credits, with a CarbonNeutral package offsetting all emissions associated with the carton from raw material production to retail. To comply with EU regulations and avoid greenwashing risk, Elopak is assessing the future of such claims and exploring alternative ways to communicate that cartons are a low-carbon alternative. It holds the CarbonNeutral company certification under the 2024 version of the CarbonNeutral Protocol. Elopak does not use carbon credits in its carbon accounting or to reduce reported Scope 1, 2 or 3 emissions. The total volume of credits purchased and cancelled in 2024 was 88,856 tCO2e, with no unretired credits held. By volume, 94 percent came from avoidance or reduction projects and 6 percent from removal projects. By recognized quality standard, 94 percent was Gold Standard-VER and 6 percent VCS, with 0 percent issued from EU projects and 0 percent qualifying as a corresponding adjustment under Article 6 of the Paris Agreement. Removal credits came from the Degraded Grasslands Afforestation project in Uruguay.

Pollution of air and soil emerged as a material sub-topic in Elopak's DMA, with pollution material across the value chain from transportation, ink component sourcing and production, and bauxite mining. To manage these impacts, Elopak adopted an Environmental policy that specifically covers supplier engagement to mitigate emissions such as SOx, NOx and black carbon in the upstream and downstream value chain. The policy also describes pollution management, incident management, and ongoing vigilance regarding concerning substances, and states that local guidelines shall be implemented at all production sites. Suppliers are assessed against environmental criteria set out in the Procurement policy and the global Supplier Code of conduct. In line with responsible sourcing, Elopak's ambition is to exclusively source certified aluminium and minimize the use of aluminium. The Environmental policy is approved by the EVP Product and Development and is internal.

In 2024, Elopak took steps to address pollution across its value chain. It collaborated with raw material suppliers and external partners to identify best practice and share data to reduce transportation-related pollution. Global transportation routes were mapped to analyze feasible changes such as switching from fossil fuels to electric vehicles and using biofuel for trucks and sea transportation. Key actions taken included minimizing transport amounts and optimizing routes with suppliers and customers, holding regular upstream and downstream supplier meetings, conducting first customer meetings, and investigating market opportunities for alternatives such as biofuels or electrification, with longer-term consideration of hydrogen. Elopak is committed to sourcing more certified raw materials and reducing aluminium use where feasible to mitigate soil pollution. Planned actions include performing a LEAP assessment covering data collection, scenario planning, risk assessment and evaluation of dependencies and impacts, expected in 2025, and reducing the amount of aluminium where feasible, also expected in 2025.

Elopak decided not to set specific external pollution targets in 2024. Instead it chose to continue focusing on the process of establishing collaboration with key internal and external stakeholders so that its future targets will be realistic, impactful, and aligned with industry best practices. Elopak committed to developing these targets in 2025, guided by thorough assessments and stakeholder engagement to ensure its pollution management strategies are robust and effective. In the meantime, Elopak stated it will continue to procure certified raw materials and optimize transportation of its products as an approach to mitigate the negative impacts from pollution. These actions are embedded in the company's operations and internal processes, and the outcomes are monitored closely to track their effectiveness.

Elopak's value chain involves multiple transportation links that impact air pollution. Road transportation emits nitrogen oxides (NOx), carbon monoxide (CO) and noise pollution, while maritime transportation emits NOx, sulfur oxides (SOx) and black carbon (BC). Soil pollution risks stem mainly from sourcing pigment binders, solvents and additives for ink production, as well as sourcing steel and bauxite through land-use intensive mining. Non-biodegradable or non-recyclable ink materials can end up in landfills or incinerators and contaminate recyclable materials like paper and cardboard, bauxite mining can cause local soil pollution through tailings management and chemical discharge, and steel production emits toxic pollutants such as naphthalene through the use of metallurgical coke. On metrics, Elopak stated it is setting up a process for the collection of metrics related to pollution of air and soil in the value chain, in line with the identified IROs, and it aims to disclose the material metrics for 2025.

Biodiversity and ecosystems emerged as a new material topic for Elopak from its DMA. The company reports that its business is highly dependent on nature and its resources, with a negative impact on biodiversity through the sourcing of raw materials upstream, particularly wood, which may deplete local biodiversity and ecosystem services, and bauxite, which can be sourced in biologically sensitive areas. In 2025, Elopak plans to perform a full LEAP assessment to update its DMA, support the development of a transition plan, and build a resilience analysis for biodiversity and ecosystems, with the outcome being a holistic biodiversity strategy. In response to stakeholder expectations, Elopak is considering reporting in accordance with the TNFD to enhance transparency and accountability. It does not plan to use biodiversity offsets in its action plans and will explore how to incorporate local and indigenous knowledge and nature-based solutions.

Elopak manages biodiversity impacts through its Environmental policy, which addresses the sourcing of raw materials such as wood and bauxite, considered a material negative impact for biodiversity and ecosystems. The policy prioritizes access to responsibly sourced raw materials through certifications with the highest standards, preferably from independent third parties, such as FSC, ISCC+ and ASI, which also allow traceability. It supports initiatives to protect forests and biodiversity and to combat illegal logging and deforestation, and commits Elopak to comply with the EU Deforestation Regulation (EUDR). The policy covers other impact drivers including climate change related to wildfire, land use change related to forest management and restoration, and pollution related to bauxite. The biodiversity-related risk assessment concluded that none of Elopak's operations sites are in or near a biodiversity sensitive area, so a separate biodiversity and ecosystem protection policy was not considered necessary. The policy does not currently address the social consequences of biodiversity impacts, which will be assessed in 2025 as part of the LEAP assessment.

Elopak has been certified by the Forest Stewardship Council (FSC) since 2010, and all of its plants are FSC-certified for chain-of-custody. Since 2015, 100% of purchased raw board has come from certified or controlled wood sources, and 100% of the renewable polymers purchased are ISCC+ certified using a mass balance approach. In 2022, Elopak received its Aluminium Stewardship Initiative (ASI) Performance Standard certification, to be renewed in 2025, and all relevant plants hold ASI certification. In 2024, Elopak sold 57% FSC-labeled cartons worldwide and 82% of sales volume in Europe carried the FSC logo. Completed 2024 actions include a biodiversity-related risk assessment using the WWF Biodiversity risk filter and an assessment of how biodiversity projects with suppliers can be scaled up. Planned 2025 actions include performing a LEAP assessment to produce a holistic biodiversity strategy, extending ISCC+ certification to Elopak Germany GmbH, supplier collaboration to accelerate biodiversity projects, and developing a compliant biodiversity transition plan, which has not yet started.

Elopak's biodiversity targets aim to ensure a sustainable supply chain for raw board, renewable polymers and aluminium by 2025 through product certifications according to the most stringent and credible standards. Specifically, by 2025 Elopak's targets are that purchased raw board is 100% FSC, SFI or PEFC certified or controlled wood, purchased renewable polymers are 100% ISCC+ certified (fossil-based polymers excluded), and purchased aluminium is 100% ASI certified, each including the option of a similar strict certification. The targets relate to the material negative impact of raw materials in the upstream value chain, apply to all own operations and all volumes, do not consider any biodiversity offsets, and are primarily related to the avoidance layer of the mitigation hierarchy. Elopak stated it will explore how future targets can apply ecological thresholds and align with national policies such as the Kunming-Montreal Global Biodiversity Framework and the EU Biodiversity Strategy for 2030, which are not currently included in its assessment.

Elopak discloses impact metrics based on the share of purchased certified raw materials covered by its targets for 2024. Raw board reached 100% FSC certified or controlled wood, measured as the percentage of purchased raw board that is FSC certified or controlled wood across all volumes. Renewable polymers reached 100% ISCC+ certified, measured as the percentage of purchased renewable polymers that are ISCC+ certified across all volumes, with fossil-based polymers excluded. Aluminium reached 51.9% ASI certified, measured as the percentage of purchased aluminium that is ASI certified. These metrics track progress against Elopak's 2025 certification targets and relate to the material negative impact of raw material sourcing in the upstream value chain. Elopak noted that all aluminium sourced in 2025 is expected to be ASI certified.

Resource use and circular economy is covered in Elopak's Sustainability policy and Environmental policy. The Environmental policy outlines the approach for identifying and managing IROs related to resource use and circular economy across the value chain, and addresses resource outflows related to own operations and downstream in the value chain, as well as recycling, packaging alternatives, investments in technological developments, and waste management throughout the value chain. The Environmental policy also sets out the commitment to minimizing waste and ensuring the recycling of waste from all production sites. Elopak particularly aims to keep hazardous waste at a minimum and to ensure it is disposed of according to best practice and local regulation. Progress is tracked monthly through reporting from all sites. Both policies are approved by the EVP Product and Development and are internal. This work aligns with the Packaging and Packaging Waste Regulation (PPWR) set to take effect in 2030 and the Single-Use Plastics directive.

Elopak's approach to recyclability starts with product development, following Design for Recycling (DfR) guidelines to optimize packaging designs and ensure easy separation of components. Key actions include establishing a recycling laboratory at the Elopak Technology Center in Spikkestad, launched in 2024 and to be operational in 2025, with the aim of a portfolio that is 100% designed for recycling by 2030. Other actions include offering renewable sourced polyethylene (PE) instead of fossil-based PE, developing innovative fiber-based opening devices to replace plastic caps (Easy Opening), material reduction and value engineering to reduce board and plastic coatings, developing alternative barriers such as fiber-based, metallized or polymer-based options to replace aluminium foil, and collaborating with PE suppliers to incorporate post-consumer recycled advanced recycled PE (arPE) content into cartons and closures. Most of these actions target 2030. Elopak is preparing to meet the PPWR, holds the presidency of the global Food and Beverage Carton Alliance (FBCA), and participates in alliances such as 4evergreen.

Elopak's main target for resource use and circular economy is that 100% of its cartons will be designed for recycling by 2030. This target applies to global operations, not just the EU market, and responds to the Packaging and Packaging Waste Regulation (PPWR), which introduces the concept of Design for recycling. Pending the definition of recyclability in the PPWR, Elopak stated it will monitor and adapt to meet the upcoming requirements, with the target of complying with upcoming standards in all its global markets. For production waste, Elopak has a long-standing practice of setting internal targets as part of its sustainability efforts, prioritizing waste prevention in alignment with the waste hierarchy, but it does not currently have an external waste target. Elopak also noted it will develop appropriate metrics related to its target once the definitions for recycling are defined in the PPWR.

Elopak focuses on renewability and recyclability for circularity. On average, 75% of its Pure-Pak cartons are made from naturally renewable paperboard from northern hemisphere forests, and the remaining portion, mainly polymers, is also available as renewable through its bio-circular offering. Cartons are single use but designed for recycling and are recyclable where infrastructure exists, containing high quality fibers that can be recycled up to seven times. Today there is no recycled content in the cartons, and Elopak will introduce recycled materials in compliance with forthcoming regulatory requirements. Resource outflows consist of three categories: cartons (Pure-Pak, Roll Fed material and D-PAK), filling machines with an estimated 20-year lifetime and lifecycle support, and secondary packaging using paper wrap and corrugated boxes made from virgin fiber. A material consumption overview shows paperboard at 81%, polymers at 17% and aluminium at 2% of materials purchased. PolyAl recycling of the non-fiber polyethylene and aluminium components is available in some EU member states but remains a novel process requiring further development.

Elopak reports waste in weight by category and treatment type from all sites, split into hazardous and non-hazardous. In 2024, total waste generated was 30,793 tons, comprising 242 tons hazardous and 30,551 tons non-hazardous. Total waste diverted from disposal was 30,203 tons, all through recycling, of which 56 tons were hazardous and 30,147 tons non-hazardous, with no preparation for reuse or other recovery operations reported. Total waste directed to disposal was 590 tons, made up of 526 tons incineration (122 hazardous, 404 non-hazardous), 1 ton landfill (hazardous), and 63 tons other disposal operations (hazardous). Total non-recycled waste was 590 tons, representing 77% of hazardous waste, 1% of non-hazardous waste, and 2% of total waste. Hazardous waste includes inks, solvents and other hazardous waste, while non-hazardous waste is mainly board, paper and polyethylene. Waste performance continued to improve in 2024 on the back of the internal Elovation waste reduction program, which is based on optimizing flow to eliminate waste.

Elopak's approach to its own workforce is guided by its promises of Empower, Unite and Accelerate and its Code of conduct, which are integrated across policies and procedures. The report lists several relevant policies. The Safety policy commits to a safe work environment for all employees, contractors and authorized visitors. The Health, safety and working environment procedure promotes physical and psychosocial working conditions and manages sick leave. The Human rights policy and Code of conduct anchor respect for internationally recognized human and labor rights, referencing the International Bill of Human Rights and ILO principles. The Remuneration policy ensures competitive total remuneration. The Diversity, Equity and Inclusion policy sets principles for enhancing diversity and non-discrimination. Further policies include the Recruitment procedure, Senior employee retention standard, Performance management and development procedure and MyPDP procedure. Most are internal, while the Code of conduct and Human rights policy are external. Policies are approved at executive or Board level.

Elopak engages employees and measures satisfaction across the employee life cycle through performance reviews, one-to-one meetings, various surveys and its whistleblower channel, with corrective actions followed up in improvement forums. The Chief Human Resources Officer holds operational responsibility for engagement with the workforce. Elopak maintains working relationships with local works councils and unions, alternative forums in India and Saudi Arabia, and a European Works Council, where management informs delegates and addresses concerns. In 2024 Elopak launched a Pulse survey with an overall response rate of 74%, and 8 out of 9 questions showed positive improvement versus 2023. A new diversity and inclusion question showed 82.9% of employees feel treated equally and fairly, with the largest positive development seen in managing change. Results were shared with managers to define actions. Onboarding includes one-to-one interviews, onboarding surveys and exit interviews, with stay-on interviews planned for new employees in 2025.

Elopak is committed to providing remediation for identified negative impacts or harm to people caused by its own operations or supply chains. Concerns of misconduct or grievances are reported through internal channels or through the company whistleblower helpline. The effectiveness of these channels is ensured through information shared with all employees and external stakeholders, and through publicly disclosed metrics on reported concerns of misconduct. Where a negative impact is identified requiring remediation, Elopak assesses the circumstances on a case-by-case basis. Elopak also engages employees through a dedicated human rights section on its intranet, which provides information on how the company works with human rights and how to raise grievances and concerns. For further details, including protection of whistleblowers, the report refers readers to the G1 Business conduct section. Annual and mandatory Code of conduct training covers how to report grievances such as human rights violations.

Elopak identifies actions using its purpose-driven vision, mission and strategy to attract, retain and motivate its workforce. In 2024 actions included conducting the Employee Pulse survey, achieving a 96% completion rate on Performance and Development plans, developing new communication principles and guidelines with a line manager checklist, revisiting the onboarding process, and recruitment improvements to staff its new US plant. It revised its safety procedure for travel to high-risk countries under a Duty of Care concept. Safety activities focus on machine safety, safety culture through the Safe by Choice program and a safety perception survey, and special safety topics using KPIs. Diversity and inclusion actions were reflected in succession planning and performance management, achieving 30% female successors in critical management and specialist positions. A Global Senior Employee Retention Standard launched in December 2024, and the Mercer grading structure was expanded to address pay gaps. Planned actions for 2025 include stay-on interviews, an Employee Assistance Program and DEI training.

Elopak reports two main targets for its own workforce. The safety target is a total recordable injury frequency rate (TRI FR) of 3.2 per one million hours worked by 2030, linked to IRO S1.1. This top-level target is broken down into annual sub-targets agreed with business units, areas and sites, using the previous year's performance as a base. The 2024 actual level was 4.3, down from 7.5 shown for earlier years, and performance is monitored through KPIs, internal audits and ISO45001 audits. The diversity target is 40% females in Senior Management positions by 2030, linked to IRO S1.4, approved by Management as a group target. To achieve it Elopak will use targeted recruitment, mentorship programs, succession management, retention strategies and an inclusive culture, with progress measured through selected ESG KPIs yearly. Elopak states it does not have specific external targets for human and labor rights or for training and skills development.

At year-end 2024 Elopak had 2,234 employees, comprising 460 female and 1,774 male, with none reported as other or not disclosed. By employment type there were 2,193 permanent and 41 temporary employees, and 2,153 full-time and 81 part-time employees. By country the workforce was distributed across the Netherlands 502 (23.0%), Denmark 302 (14.0%), Canada 284 (13.0%), Germany 245 (11.0%), Norway 192 (8.6%), India 148 (6.6%), Ukraine 145 (6.5%), USA 61 (2.7%) and Morocco 54 (2.4%). Employee headcount is measured at year-end excluding externals, based on Elopak's centralized HR system, with India data reported manually and jointly owned entity data excluded. Employee turnover in 2024 was 153 leavers, giving a turnover rate of 7.1%, calculated as leavers divided by the average number of employees, excluding temporary employees. Due to seasonal production variations, temporary workers are hired in plants in Canada, the Netherlands, Denmark and Morocco.

Elopak reports 219 non-employees in its own workforce at year-end 2024. Non-employees are workers providing working hours through professional contractual relationships with external agencies, and Elopak states all labor code provisions are respected. Non-employees are only registered in the centralized HR system based on need for internal system access, and in some business units full-time equivalents are reported, so the reported figure is a combination of these bases reported at year-end. Due to seasonal production variations, temporary workers are hired in the plants in Canada, the Netherlands, Denmark and Morocco. In Morocco an integration plan for employing temporary workers from a staffing agency has been in force since 2019, and six employees were permanently employed by Elopak in 2024, with the plan continuing in 2025. In Saudi Arabia, foreign guest workers hold contracts with a staffing agency, and Elopak continuously monitors their rights and conditions, with numbers registered by the authorities.

Elopak respects the freedom of employee association and the right to collective bargaining agreements as stated in its Code of conduct. In 2024, 1,357 employees were covered by collective bargaining agreements, representing 60.7% of employees, with percentages calculated from numbers reported by local People and Organization teams. Coverage in the EEA was high, with Denmark in the 60 to 79% band and the Netherlands and Norway in the 80 to 100% band, while Germany fell in the 0 to 19% band. For workplace representation among employees in EEA countries with significant employment, coverage was Germany 98.4%, Denmark 100.0%, Netherlands 100.0% and Norway 100.0%. Associations and collective bargaining are not custom practice in Saudi Arabia, where no formal unions exist and quarterly forums replace a union. In India workers have the fundamental right to form a union but none is registered, and several committees such as Safety and Reward and recognition replace a formal union, with monthly meetings for all employees.

Elopak reports diversity metrics covering gender at senior management level and age distribution. At senior management level there were 139 employees, comprising 32 female (23.0%) and 107 male (77.0%). Senior management is defined using the Mercer global position classification system as employees in positions graded 6 (Senior) Manager or (Senior) Specialist or higher, with jointly owned entity positions excluded. By age group, the total workforce included 268 employees below 30 (50 female, 218 male), 1,151 employees aged 30 to 50 (264 female, 887 male), and 815 employees over 50 (146 female, 669 male). Elopak notes it has a diverse workforce consisting of over 50 different nationalities and aims for a balanced gender distribution across all hierarchical levels. Regarding persons with disabilities, Elopak states that in accordance with personal data regulations it does not keep records of employees' disabilities and therefore does not disclose the percentage of employees with disabilities required by the ESRS.

Elopak aims to have a transparent and trust-based culture for adequate wages. Its Remuneration policy, available to all employees, states that the total remuneration package needs to be perceived as competitive in the industry and in local markets to attract required competencies and talents. Elopak applies a median principle when determining remuneration, meaning pay for any level is in line with the median adapted for sectorial, geographical and business factors. Jobs are classified according to the international Mercer standard to assess the median for a job type and benchmark packages in local markets, which also determines whether employees are treated fairly within the same grade and resolves pay gaps. Elopak states it pays above minimum wages in all countries, which was a focus area when integrating Morocco and Saudi Arabia using Mercer benchmarks. Norwegian companies must report on the EU Equal Pay Directive from 2027 at the latest, and expanding the Mercer structure to all countries will help manage pay risks and compliance.

Elopak reports that all employees are covered by social protection through public programs as well as through benefits offered by the company. This means employees are covered in the events of illness, work-related accidents and acquired disability, unemployment, parental leave, and retirement. As a planned action for 2025, Elopak intends to assess the level of social protection through public programs and internal benefits, with the aim of aligning the level of social protection with adequate personal insurances in line with its mid-market global principles, scoped to its own workforce. Regarding work-life balance, Elopak follows local regulations for parental leave and encourages both parents to use their available parental leave, applying remuneration during parental or other leave as regulated by local laws.

Elopak reports training and performance development metrics. In 2024, 1,680 of 1,937 employees participated in regular performance and career development reviews, a rate of 86.7%, split into 94.0% of female employees (390 of 415) and 84.8% of male employees (1,290 of 1,522). The figures are based on the annual performance review running from December 1st 2023 to March 1st 2024, and the completion rate rises to 96% when excluding groups of employees without PC access whose dialogues are held outside the system. GLS Elopak was excluded due to limited comparable data. The average number of training hours per person was 2.4 overall, comprising 2.9 hours for female employees and 2.3 hours for male employees, calculated from training registered as completed in the global learning platform, with estimates used for units not on the platform. Elopak offers mandatory safety, GDPR, Code of conduct and IT security training, plus leadership programs Learn to Lead and Fundamentals of Excellence.

Elopak makes no compromises on safety and aims for zero work-related injuries. All employees and contractors are covered by its safety management system, and global accountability for Health, Safety and Environment is shared between the Corporate Safety function and the People and Organization department, with local safety officers, P&O partners and line managers responsible for follow-up. In 2024, 100% of the own workforce was covered by the health and safety management system. There were 18 recordable work-related accidents for the own workforce, giving a rate of recordable work-related accidents (TRI FR) of 4.3 per one million hours worked. There were 10 cases of recordable work-related ill health of employees, and no fatalities as a result of work-related injuries and ill health. The number of days lost to work-related injuries and work-related ill health was 145. Improvements are based on internal audits and ISO45001 audits, an international standard for health and safety management systems.

Elopak reports a gender pay gap of 9.9%, calculated as the difference between the average annual base salary for men and women divided by the average annual base salary for men, expressed as a percentage. The calculation includes contractual base salaries but excludes variable pay due to limited data availability, and the potential impact of variable pay has not been estimated. Annual base salary was used rather than hourly pay, employees at all job levels were included, and entities with only male employees were excluded. Elopak states legitimate pay variances arise from different positions under its Mercer job classification system, but not due to gender. The annual remuneration ratio was 9.0, calculated as the ratio between the highest paid individual's base salary and the weighted annual median base salary for all employees minus the highest paid individual's base salary, with the median estimated and variable pay excluded. Data was reported manually by local P&O, and Elopak plans to improve data quality on these metrics.

Elopak reports that it has not received or identified any incidents, complaints or severe breaches of human rights in its organization during 2024. Consequently, no related fines, sanctions or compensation are noted for the reporting period, and the report refers readers to the G1 Business conduct section for further information. Elopak states it is committed to building a culture of trust and speaking up about any suspected misconduct. As part of the Employee Survey 2024, ethics and compliance questions covering ethical behavior and speak-up culture were included, and results demonstrated that employees could report unethical practices without fear of reprisal, an improvement of 9.7% compared to the People Survey conducted in 2023. The ethics and compliance questionnaire in the Pulse Survey was completed by 74% of employees, an increase of 6.1% compared to 2023, reflecting a strengthening compliance culture.

Elopak's approach to supporting human rights in its supply chain follows a risk-based approach based on the UN Guiding Principles on Business and Human Rights and the OECD Due Diligence Guidance for Responsible Business Conduct. The Human rights policy (approved by the CFO, implemented by the Chief Legal and Compliance Officer) explains its commitment to managing human rights risks. The global Supplier Code of conduct (SCoC), approved by the Board, sets expectations on anti-corruption, human and labor rights, health and safety, and the environment, covering forced and child labor including trafficking, freedom of association, collective bargaining, non-discrimination, wages and working hours. It is based on the International Bill of Human Rights, the UN Guiding Principles, the OECD Guidelines and the ILO declarations. The Procurement policy and the Responsible supply chain standard set procurement principles and due diligence tools. Elopak sources from more than 6000 suppliers, with critical raw material at approximately 50% of external purchase spend.

Elopak engages with value chain workers through its SCoC engagement process and its Supplier integrity due diligence (IDD) process. The Procurement process excellence function is responsible for the framework, tools, training and support, while Category and Purchasing managers ensure engagement follows set policies. Risk assessment is conducted both as a high-level exercise for the whole supply chain and as part of supplier qualification and IDD. Risk parameters include product or service category, country of operation, expected commercial exposure and Elopak influence, and known red flags. All suppliers with medium/high or high inherent risk undergo screening via EcoVadis and/or a supplier self-assessment questionnaire combined with desktop screening (IndueD). For certain high-risk suppliers and geographies an external partner conducts third party in-depth IDDs. A more in-depth Supplier human rights assessment and capacity building questionnaire is used for selected key and high-risk suppliers in engagement meetings and as pre-audit questionnaires, and a human and labor rights checklist is built into the on-site audit framework.

As outlined in the SCoC, Elopak encourages suppliers, business partners and their employees to raise concerns and report suspected or potential breaches. Value chain workers and local communities can raise concerns through internal channels or the whistleblower helpline, with awareness partially addressed in engagement and capacity building meetings with selected key suppliers. The effectiveness of the channels is ensured through information shared with employees and external stakeholders and publicly disclosed metrics on reported concerns of misconduct. Where a negative impact is identified that requires remediation, Elopak assesses the circumstances case-by-case and is committed to providing remediation for harm caused by its own operations or supply chains. Re-assessments are conducted approximately bi-yearly, and if non-compliance is material or a supplier is unwilling or unable to improve, Elopak reserves the right to terminate the business relation. In 2024 there were no reported concerns of suspected or potential human rights breaches in the supply chain through other channels.

Elopak actively promotes human and labor rights through dialogue and close relationships with suppliers and continues supplier integrity due diligence of potential and active key suppliers, focusing on high-risk suppliers and geographies. In 2024 prioritized supplier categories underwent Integrity due diligence for qualification, and in-depth IDDs were conducted for critical suppliers from high-risk countries such as China with third-party experts, and for key suppliers and traders supplying its India site. No instances of forced labor, child labor, or significant human rights violations were identified during these assessments. The SCoC was further implemented for local suppliers at sites in India, Morocco and Saudi Arabia. By 2024, 95% of key suppliers (by spend) signed or accepted the SCoC and 84% were screened on social and environmental criteria. The global Procurement network received training on Responsible Supply chain principles, the supplier IDD process, and the Norwegian Transparency Act, plus nano-learning trainings on managing business partners and on human rights.

Elopak is committed to respecting people's rights and ensuring responsible practices throughout the supply chain, continuing human rights due diligence with special focus on high-risk suppliers. Targets are identified and proposed by the Procurement excellence function in alignment with the Procurement leadership team and approved by the EVP Packaging and Procurement as part of the yearly business planning process. The targets are to ensure that 100% of key suppliers sign, accept or demonstrate conformance to the Global SCoC by 2026, including requirements to uphold workers' rights, and to ensure that 100% of key suppliers are screened on social and environmental criteria by 2026. By 2024, approximately 95% of key suppliers, 100% of raw material suppliers and 84% of all suppliers (by spend) had signed, accepted or demonstrated conformance to the SCoC, and 84% of key suppliers (by spend) had been assessed and screened via EcoVadis, the internal IDD process, or in-depth integrity due diligence with external partners.

Following the reassessment of the DMA, Elopak identified Food safety as a material topic and reports it as an entity-specific sub-topic alongside S4 Consumers and End-users. The Code of conduct and the Quality and food safety policy explain how to ensure food safety and reduce food safety incidents. The Quality and food safety policy (responsible: EVP Packaging and Procurement, internal) emphasizes commitment to food safety and high-quality production standards, while the Code of conduct (approved by the Board, implemented by the CEO) outlines commitments for ethical business practices. Elopak follows the European Framework regulation (EC) No. 1935/2004 for food contact materials and applies its principles worldwide, and also complies with US packaging regulations. The Food safety standard for materials in contact with food sets production requirements, and procedures for claims handling and food safety incidents form part of the quality system. Compliance with EU food contact material regulations is mandatory, and third-party certifications such as BRCGS or other GFSI recognized standards, ISO and FDA ensure adherence to international quality and hygiene standards.

Elopak fosters a strong food safety culture supported by learning programs, monitoring and continuous improvement. Food safety affects all processes, from choosing raw materials and suppliers to production and filling, ensuring products are safe for consumers. The way of working uses a multi-disciplinary approach involving a food safety specialist, the quality department at both corporate and local levels, and the purchasing department. Comprehensive quality and technical handbooks ensure production of high-quality products, well-governed development projects, and the building and validation of new filling machines. The Quality and food safety policy is available in the Elopak Management System and is valid throughout the entire organization. Suppliers are carefully selected based on Elopak's requirements, with raw materials required to meet EU food contact material legislation including sensory evaluation and migration testing, so that potential risks along the value chain from raw materials to finished goods are minimized through continuous efforts and improvements.

Procedures for claims handling and for handling food safety incidents are part of Elopak's quality system. The claim reporting procedure includes descriptions of internal stakeholders, and zero non-compliance with food safety regulations is monitored through the claim reporting and its belonging meeting structure. Non-compliance is defined as a breach of the regulations for food packaging material that might affect food safety, as reported through the claims reporting procedure. Food safety management systems require regular audits and compliance checks, which Elopak's production plants comply with. The Code of conduct and Quality and food safety policy explain how to ensure food safety and reduce food safety incidents, and potential risks can breach food packaging material regulations, which may endanger health, damage reputation, lead to customer loss and have financial impacts. Elopak holds GFSI recognized standards and conducts internal and external third-party audits of its own production plants.

Elopak has several procedures to ensure high-quality production. Suppliers are carefully selected based on Elopak's requirements, and raw materials must meet EU food contact material legislation, including sensory evaluation and migration testing. The way of working involves a multi-disciplinary approach with food safety specialists and the quality department at corporate and local levels, together with the purchasing department. Elopak holds GFSI recognized standards and conducts internal and external third-party audits of its production plants. In 2024, production plants in Morocco and Saudi Arabia completed ISO 9001 certification. ISO 9001 is an international standard for quality management systems, and the GFSI benchmarks existing food safety standards against its criteria to ensure certified organizations meet high requirements. A planned action for 2025, not yet started, is to ensure food safety and quality certification of the new US plant according to ISO and GFSI standards. Elopak closely monitors new EU regulations being created under the European Green Deal.

Elopak's target is zero non-compliance with food and product safety regulations where a product withdrawal is necessary due to food packaging material delivered by Elopak. The target reflects its way of working with quality and is agreed and aligned with the internal stakeholders EVP Packaging and Procurement and Director Quality. Zero non-compliance is monitored through the claim reporting and its belonging meeting structure. Elopak had zero non-conformities to food safety regulations in 2024. In 2024, seven production plants held food safety certifications, all certified to both ISO 9001 and GFSI recognized standards: Aarhus (Denmark), Terneuzen (Netherlands), Fastiv (Ukraine), Montreal (Canada), Casablanca (Morocco), Dammam (Saudi Arabia), and GLS Elopak (India). Food safety metrics are designed to provide accountability and ensure compliance with regulations and active improvement of food safety standards, with production plants complying with the required certifications.

Responsible business conduct is the foundation for Elopak's license to operate. Its governing documents make up the Elopak Management System (EMS), launched in 2024 with the aim to standardize and document all global processes by the end of 2026. The Code of conduct, approved by the Board and implemented by the CEO, outlines commitments for ethical business practices and covers anti-corruption and bribery, business partner integrity, human rights, conflict of interest, gifts and hospitality, anti-money laundering, fair competition, insider trading, and sanctions and trade compliance. All new employees complete the CoC e-learning during onboarding, and all employees conduct annual mandatory CoC training. Supporting policies include the Anti-money laundering policy, the Sanctions and trade control policy, and the Handling of inside information standard. The compliance program, managed by Group Legal and Compliance with an independent reporting line to the BASC, focuses on preventing, detecting and responding to non-compliance. The 2024 employee survey showed a strengthened compliance culture, up 6.1% compared to 2023.

Elopak's Anti-corruption policy outlines a zero-tolerance approach to bribery and corruption, covering facilitation payments, public officials, gifts and hospitality, and conflicts of interest, and is supported by procedures for gifts and hospitality and conflicts of interest. Operating in more than 30 countries, many with high inherent corruption risk, Elopak manages risk through country risk assessments, compliance training and awareness, compliance reviews, and Integrity due diligence (IDD) of business partners via the Business partner integrity procedure and the Country Watch List. An annual legal and compliance risk assessment covered bribery, facilitation payments, sponsorships and donations, gifts and hospitality, and conflicts of interest. In 2024, Elopak followed up with its entities in Morocco and Saudi Arabia on corruption and bribery risk. A specific anti-corruption and bribery course was completed by 294 of 311 employees (95%) in risk-exposed positions, and 128 employees completed business partner integrity training. Concerns can be reported through the whistleblower helpline in eight languages, managed by an external provider and allowing anonymous reporting.

In 2024, nine cases of unethical behavior and breaches of the Code of conduct were reported through Elopak's channels for reporting concerns. Five cases related to inappropriate business conduct, three concerned human resources issues and workplace respect, and one reflected health and work environment. There were zero cases related to the violation of anti-corruption and anti-bribery laws, and hence no such convictions or fines. In the breakdown by category, business integrity (corruption, bribery, conflict of interest) accounted for five cases, human resources, diversity and workplace respect for three, and environment, health and safety for one. The number of cases reported in 2024 was 0.43 reports per 100 employees, compared to 0.25 the previous year. The Chief Legal and Compliance Officer meets the BASC regularly, reporting on whistleblower cases including cases of corruption and bribery, if any, and the CEO is notified immediately about specific concerns.