Packaging Corporation of America (PCA)

No leading practices were identified in the governance and strategy area

No leading practices were identified in the ecosystems and biodiversity area.

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

Sustainability strategy and accountability
The company 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 does not disclose group-wide targets on key sustainability topics for the most material parts of its value chain. The company does not report consistently against all its targets. 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. 

Stakeholder engagement
The company does not disclose an overview of the issues raised during its stakeholder engagement activities. The company does not disclose its process for engaging with stakeholder groups beyond its materiality assessment. 

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 they utilize NatureServe and states’ Natural Heritage websites to check for threatened or endangered species and ecosystem conservation priorities in combination with on-the ground inspections prior to harvest activity. They further report that this enables them to ensure that biodiversity constraints are identified and that an effective plan of action is in place before, during and after forest management activity. However, this disclosure is not sufficient to translate into evidence that the company assesses its impacts on nature, including biodiversity, within its own operations, at a business model level. 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 does not disclose the locations that are in or adjacent to areas important for biodiversity within its own operations. 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
The company does not disclose a commitment to ensure zero conversion. Through the certification of its raw materials, the company seeks to mitigate the possible impact that its activity may have on the conversion of natural forests. While these efforts are valuable, they do not represent a proxy for the company’s efforts to reduce ecosystem conversion, in this case, deforestation completely. 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
The company does not provide adequate evidence of 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 discloses 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 has reported an increase in its water withdrawal by source (in billion liters) from 270.8 in 2020 to 274.9 in 2021. The company does not disclose a time-bound target to reduce water withdrawal across its own operations. The company does not report how much water is withdrawn for its own operations in water-stressed areas. The company does not engage with suppliers to reduce water withdrawal. The company reports a decrease in water pollution. The company does not provide adequate disclosure on its processes for managing and monitoring discharge water quality. The company regularly reports on water pollution. The company does not disclose targets to reduce water pollution. The company does not disclose a commitment to respect the right to water. 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
Company’s scope 2 emissions (location based) show a decrease. However, its Scope 1 and scope 2 market-based emissions show an increase from 2020 to 2021. The company does not disclose a time-bound target to reduce its scope 1 and 2 emissions.  The company does not report progress against its scope 1 and 2 emissions target. No evidence that the company’s scope 1 and 2 emissions target is aligned with a 1.5-degree trajectory was found. The company has reported an increase in its scope 3 emissions (tons CO₂e) from 2.30 in 2020 to 2.48 in 2021.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.

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. 

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 conducts a materiality assessment to identify the main risks to the business and it has identified human rights broadly as a material topic, 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. No evidence that the company describes its process for assessing its human rights risks and discloses what it considers to be its salient human rights issues was found.  No evidence was found that the company has a 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 discloses that it partnered with the United Steelworkers (USW) to launch a pilot program in 2017 to reduce the overtime rate, there is no evidence that the company provides at least two examples of its engagement with stakeholders whose human rights have been or may be affected by its activities (or their legitimate representatives or multi-stakeholder initiatives) in the last two years. 

The company has a publicly available policy statement which shows it is committed to respecting the health and safety of workers.  The company has a publicly available policy statement which shows it expects its suppliers 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. The company discloses the proportion of its total direct operations workforce covered by collective bargaining agreements. While the company states that it expects its suppliers to support and uphold the employees’ right to freedom of association, it has an opportunity to describe how it works to support the practices of its suppliers in relation to those. 

No evidence that the company has a publicly available global tax strategy was found. The company discloses that it conducts due diligence on third parties acting on PCA’s behalf, however, it does not describe the process 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. The company discloses that its employees have the right to voluntarily participate in the political process, including making personal political contributions, however, it does not provide a publicly available policy statement setting out its lobbying and political engagement approach. The company discloses that its employees have the right to voluntarily participate in the political process, including making personal political contributions, however, it does not provide a publicly available policy statement that specifies that it does not make political contributions.