Graphic Packaging International

Sustainability strategy and accountability
Graphic Packaging International discloses its process for identifying and prioritising its most relevant sustainability impacts as well as the outcome of this process, in relation to its sustainability strategy. The company reports consistently against all its set targets. It provides evidence that its highest governance body has expertise regarding the company’s most material nature-related topics.

Stakeholder engagement
Graphic Packaging International discloses how often and through which channels it engages with various stakeholder groups.

Water
Graphic Packaging International has targets to reduce water pollution and reports progress against them. The company has a commitment to respect the right to water.

Solid and air pollution
Graphic Packaging International reports some activities to reduce plastic use and waste in its own operations.

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

Sustainability strategy and accountability
While the company discloses some sustainability targets, no evidence that the company has group wide targets on key sustainability topics for the most material parts of its value chain based on the SBTN Sectoral Materiality Tool could be found in the public domain. The company does not provide adequate evidence that it links performance criteria in senior executives’ remuneration policies to targets and objectives which cover nature (including biodiversity), and social issues.

Stakeholder engagement
The company does not disclose an overview of the issues raised during its stakeholder engagement activities.

Lobbying
The company discloses a list of trade associations of which it is a member wherever it operates. The company does not disclose a clear and detailed framework for assessing alignment of its trade associations with nature-positive policies. The company does not report (potential) misalignment between the lobbying activities of its trade associations and nature-positive policies.

Impact and dependencies assessment
The company has reported that through their sourcing of fiber through the SFI Certified Wood Sourcing Standards and FSC Controlled Wood, they have minimal impact caused by our forest operations. However, this is not sufficient to translate into evidence that the company assesses its impacts on nature, including biodiversity, within its own operations. The company does not disclose any assessment of its impacts on nature, including biodiversity, in its supply chain. The company does not disclose any assessment of its dependencies on nature within its own operations. The company does not disclose any assessment of dependencies on nature of its upstream business relationships.

Key areas and species
The company has reported that it has 90 facilities across 14 countries encompassing four continents. It has further reported that it owns approximately 6K acres where the Texarkana Mill is located and there are no known sensitive areas near it. However, no evidence that the company discloses all the locations that are in or adjacent to areas important to biodiversity across all its facilities could be found.  The company does not disclose the locations of its suppliers that are in or adjacent to areas important for biodiversity. The company does not disclose species populations existing in or adjacent to its own locations. The company does not disclose species populations existing in or adjacent to the locations of its suppliers. The company does not disclose the status according to national and international conservation lists of species identified in its own locations.

Ecosystem conversion and restoration
While the company makes efforts to avoid deforestation, no specific commitment to eliminate deforestation from its value chain could be found. The company does not disclose activities to achieve conversion-free supply chains. The company does not disclose time-bound targets to achieve conversion-free supply chains. The company has a commitment to minimise ecosystem conversion. The company discloses some activities to minimise ecosystem conversion. The company does not disclose a commitment to restore ecosystems. The company does not disclose details and outcomes of ecosystem restoration projects in areas affected by its own operations or by its suppliers.

Resource exploitation and circularity
It is unclear whether the company discloses all its inputs, including its material footprint, according to an international standard. The company does not report quantitatively on its group-wide circularity performance. The company does not disclose activities to improve soil health or agrobiodiversity in its production or sourcing practices. The company does not disclose a target to improve soil health in its production or sourcing practices.

Water
The company demonstrates it is reducing water withdrawal in its own operations. The company does not disclose a time-bound target to reduce water withdrawal across its own operations. The company reports how much water is withdrawn for its own operations in water-stressed areas. The company does not provide adequate evidence that it engages with upstream business partners to reduce water withdrawal. The company reports a decrease in water pollution. The company does not adequately disclose its processes for managing and monitoring discharge water quality. The company does not regularly report on water pollution. The company does not disclose its processes for implementing preventive and corrective action plans for identified specific risks to the right to water and sanitation in its own operations.

Solid and air pollution
No evidence that the company is reducing the production of hazardous waste was found. No evidence that the company reduces plastic use and waste in its own operations was found. The company does not report on the amount of plastic waste generated and proportions directed from or to disposal. The company reports regularly on air quality parameters of emissions of harmful air pollutants. The company does not report time-bound targets to reduce air pollutants across the most material parts of its value chain.

GHG emissions
The company has reported a decrease in its scope 2 emissions (marked based) (Metric Tonnes CO2e) from 824,155 in 2019 to 680,468 in 2020. However, it has reported an increase in its scope 1 emissions (Metric Tonnes CO2e) from 1,318,746 in 2019 to 1,441,475 in 2020. The company has a time-bound target to reduce its scope 1 and 2 emissions.  The company in its CDP Climate Change Report 2021 has reported that there was an increase in its scope 1 + 2 emissions in 2020 and as such 0% of the target is currently achieved. No evidence that the company’s scope 1 and 2 emissions target is aligned with a 1.5-degree trajectory was found. The company is reducing its scope 3 emissions. The company does not disclose a time-bound target to reduce its scope 3 emissions.  The company does not report progress against its scope 3 emissions target. No evidence that the company’s scope 3 emissions target is aligned with a 1.5-degree trajectory was found.

Invasive species
No evidence was found that the company identifies the activities that could lead to the introduction of invasive species in its own operations. No evidence was found that the company identifies the activities that could lead to the introduction of invasive species in its value chain.

Safe, clean, healthy and sustainable environment
The company does not disclose a commitment to respecting local communities’ right to a safe, clean, healthy and sustainable environment. No evidence that the company tracks its actual or potential negative impacts on the health of local communities was found. The company is not committed to zero tolerance for acts of violence, threats, intimidation or judicial harassment committed against land and environmental rights defenders.

Indigenous Peoples’ and land rights
The company does not disclose a commitment to respect Indigenous Peoples’ rights. The company does not disclose its processes for identifying and recognising the rights of Indigenous Peoples when activities in its own operations may impact their rights, nor does it describe how it obtains Indigenous Peoples’ free, prior and informed consent. The company does not disclose a commitment to respect ownership and use of land and natural resources and related legitimate tenure rights, as set out in the relevant part(s) of the VGGTs or the IFC Performance Standards. No evidence was found that the company requires its business relationships to have a process to identify legitimate tenure rightsholders, paying particular attention to vulnerable or marginalised tenure rightsholders, and to negotiate with them to provide adequate compensation.

While the company indicates that it conducts human rights due diligence to identify issues, there is no evidence it has a process to identify which human rights are at risk of being impacted by its own operations, in specific locations or through specific activities, as part of a human rights due diligence process. While the company indicates that its statement highlights its future objectives, taking into consideration the salient risks identified, it does not disclose a process to assess the human rights that are at risk of being impacted by its activities or those of its business relationships, in specific locations or through specific activities, as part of a human rights due diligence process. While the company discloses that it conducts due diligence to prevent and remediate human rights issues, there is no evidence that the company discloses what it considers to be its salient human rights risks. It has an opportunity to disclose its human rights risks and thereafter describe its global system in place to act on, prevent or mitigate its salient human rights issues.  No evidence that the company provides an example of the conclusions reached and actions taken or to be taken on at least one of its salient human rights issues as a result of assessment processes was found.  While the company discloses the categories of stakeholders it engages with generally on sustainability issues, it is not clear if these stakeholders are those whose human rights have been or may be affected by its activities. While the company provides general examples of engagement with stakeholders, it has an opportunity to clarify if these stakeholders are those whose human rights have been or may be affected by its activities.

The company has a publicly available policy statement which shows it is committed to respecting the health and safety of workers.  While the company discloses a statement related to the health and safety of business relationships’ workers, i.e., management of healthy and safe workplaces, the statement does not constitute an expectation for business relationships to commit to respecting the health and safety of their workers. No evidence that the company discloses a time-bound target for paying all workers a living wage or that it has achieved paying all workers a living wage was found. No evidence that the company describes how it determines a living wage for the regions where it operates was found. While the company states that it expects its suppliers to pay wages that are sufficient for workers and their families to fulfil their basic needs, it has an opportunity to disclose how it works to support the payment of a living wage by its suppliers. While the company discloses proportion of its employees covered by collective bargaining agreements for some of its region, the proportion of its total direct operations workforce covered by collective bargaining agreements is unclear. While the company discloses its expectation from its suppliers to support and uphold the rights to freedom of association, it does not describe how it works to support the practices of its business relationships in relation to freedom of association and collective bargaining.

The company discloses a tax strategy, but it is not applicable to all its operations.  While the company discloses requirement of its record keeping and due diligence in forming customer and contractual relationships, it does not describe the process(es) to identify its bribery and corruption risks and impacts in specific locations or activities covering its own operations. The company includes anti-bribery and anti-corruption clauses in its contracts with direct business relationships. No evidence that the company has a publicly available policy statement or policy setting out its lobbying and political engagement approach was found. No evidence that the company has a publicly available policy statement that specifies that it does not make political contributions was found.