DL Holdings

Lobbying
The company discloses a list of associations of which it is a member for all business units.

Stakeholder engagement
The company discloses an overview of the issues raised in stakeholder engagement activities, as well as its engagement process.

Sustainability strategy and accountability
The company discloses its process for identifying and prioritising its most relevant sustainability impacts in relation to its sustainability strategy.

Solid and air pollution
The company reports regularly on air quality parameters of emissions of harmful air pollutants.

Water
The company discloses that it is not dependent on water-stressed areas. The company regularly reports on water pollution metrics.

No leading practices were identified in the social inclusion and community impact area.

Provide and promote decent work
The company has publicly committed to respecting the health and safety of workers through a policy statement available on its website. It has also set a time-bound target to increase women’s representation in the management team and total workforce to 0.8% and 13% respectively by 2023, as disclosed in its 2023 Sustainability Report.

Respect human rights
The company has developed a human rights risk management system, guiding operations across all employees, including those in domestic and foreign branches and partner companies. It conducts thorough human rights assessments utilising frameworks like the UN Guiding Principles and OECD Due Diligence Guidelines to address risks to local residents and customers. Notably, 86.4% of its workplaces underwent human rights impact assessments in 2022. These assessments are comprehensive, covering nine areas such as occupational safety and environmental rights, and are informed by 255 detailed indicators. Findings and improvement plans are communicated to key decision-makers, ensuring accountability and ongoing management of human rights practices.

Lobbying
The company has an opportunity to disclose a clear and detailed framework for assessing alignment of its trade associations with its sustainability targets, as well as potential misalignments between the lobbying activities of its trade associations and its sustainability targets.

Sustainability strategy and accountability
While the company has set some targets, it does not disclose group-wide targets on all key sustainability topics for the most material parts of its value chain. No evidence was found that the company links performance criteria in senior executives’ remuneration policies to targets and objectives which cover nature, including biodiversity, and social issues. The company does not disclose whether its highest governance body has expertise regarding nature-related topics.

Ecosystem conversion and restoration
No evidence was found regarding the company’s efforts to avoid ecosystem conversion, including deforestation, or promote restoration. The company has an opportunity to develop a strategy and publicly report on specific, time-bound targets.

GHG emissions
The company should set time-bound targets to reduce its scope 1, 2 and 3 greenhouse gas emissions as well as report progress against them. Crucially, the company needs to reduce its scope 1,2 and 3 emissions and its targets need to align with a 1.5-degree trajectory.

Impact and dependencies assessment
The company has not holistically assessed its impacts or how it depends on nature, including biodiversity. It has an opportunity to start such an assessment across its value chains, focused on quantification of its impacts or dependencies.

Invasive species
The company has not identified any activities that could lead to the introduction of invasive alien species in its own operations.

Key areas and species
The company does not disclose key species or areas important for biodiversity affected by its operations or suppliers. It has an opportunity to increase its transparency.

Resource exploitation and circularity performance
No evidence was found regarding the company’s efforts to work towards a circular economy or which organisms it exploits. The company has an opportunity to develop a strategy and publicly report on specific, time-bound targets.

Solid and air pollution
The company is not reducing the production of hazardous substances and does not commit to avoiding the development or marketing of new chemicals or products with SVHC (substance of very high concern) properties. Additionally, it is not reducing the production of hazardous waste. The company has an opportunity to disclose quantitative evidence regarding plastic use reduction and the use of sustainable packaging, and it does not report on the amount of plastic waste generated or the proportions directed to or diverted from disposal. Furthermore, the company does not report time-bound targets to reduce air pollutants across the most material parts of its value chain.

Water
No quantitative evidence was found of reductions in water withdrawal across the company’s own operations. The company does not disclose a time-bound target to reduce water withdrawal across its own operations, nor does it engage with suppliers to reduce water withdrawal. The company does not report a decrease in water pollution. The company does not report its processes for managing and monitoring discharge water quality, nor targets to reduce water pollution. The company has an opportunity to publicly commit to the right to water and to provide its processes for implementing preventive and corrective action plans for identified specific risks to the right to water and sanitation in its own operations.

Indigenous Peoples’ and land rights
The company does not show if it is committed to respecting Indigenous Peoples’ rights or land rights of local communities.

Safe, clean, healthy and sustainable environment
The company has an opportunity to commit to respecting local communities’ right to a safe, clean, healthy and sustainable environment, and to zero tolerance for acts of violence, threats, intimidation or judicial harassment committed against land and environmental rights defenders. Moreover, it should track its actual or potential negative impacts on the health of local communities.

Act ethically
While adhering to the OECD Anti-Bribery Convention, the company lacks a publicly available anti-corruption policy and does not outline the process for identifying bribery and corruption risks. It also lacks clarity on accessible reporting mechanisms for all stakeholders. The company has an opportunity to formalise its anti-corruption policies and ensure transparent communication about political engagement and lobbyist compliance.

Provide and promote decent work
While the company reports total deaths and injuries, it lacks detailed data on the severity of injuries and does not monitor the health and safety performance of its business relationships. It mentions fair compensation but lacks evidence of living wage commitments or methodologies for determining living wages. Although it strives for gender equality in recruitment and management roles, there is no broader public commitment to women’s empowerment. The company has an opportunity to establish and communicate a clear health and safety policy for business partners, detail its approach to achieving living wages, and strengthen its commitment to gender equality and women’s empowerment with specific targets and disclosures.

Respect human rights
The company pledges to respect stakeholder rights and prevent human rights violations but lacks a formal, robust policy commitment. It has systems to assess human rights risks and impacts, including a partner evaluation system and sector-specific human rights assessments, yet does not disclose its salient human rights issues comprehensively. The company mentions support for the ILO Charter, but with insufficient commitment strength. It has an opportunity to formalise its human rights commitments and improve the transparency and scope of its human rights assessments, making its processes and outcomes more accessible and detailed.