Smurfit Kappa Group

Stakeholder engagement
Smurfit Kappa Group discloses how often and through which channels it engages with various stakeholder groups.

Resource exploitation and circularity
Smurfit Kappa Group discloses its inputs, including its material footprint.

Water
Smurfit Kappa Group has reported its target to reduce their water by 1% annually in their paper and board mill network compared to a baseline year of 2020 and reports progress against the target. The company has set a target to reduce the organic content of water returned to the environment from our mill plants (COD) by 60% compared with 2005 levels by 2025 and reports progress against the target. It also has a commitment to respect the right to water.

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

Sustainability strategy and accountability
Smurfit Kappa Group 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. However, the company does not disclose group-wide targets on key sustainability topics for the most material parts of its value chain. It reports consistently against all its targets. Smurfit Kappa Group links performance criteria in senior executives’ remuneration policies to targets and objectives which cover nature but does not cover social issues. The company could disclose whether its highest governance body has expertise regarding nature-related topics.

Stakeholder engagement
Smurfit Kappa Group discloses an overview of the issues raised during its stakeholder engagement activities.

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

Impact and dependencies assessment
Smurfit Kappa Group does not disclose any assessment of its impacts on nature, including biodiversity, within its own operations and in its supply chain. Furthermore, the company does not disclose any assessment of its dependencies on nature within its own operations and of its upstream business relationships.

Key areas and species
Smurfit Kappa Group discloses the locations that are in or adjacent to areas important for biodiversity within its own operations but does not disclose the locations of its suppliers in this regard. The company only discloses its threatened species existing in Smurfit Kappa Colombia Forestry Division’s properties; however, it has an opportunity to disclose species populations existing in or adjacent to all of its own locations. It also does not disclose species populations existing in or adjacent to the locations of its suppliers. It could disclose the status according to national and international conservation lists of species identified in its own locations.

Ecosystem conversion and restoration
While Smurfit Kappa Group commits to producing and purchasing all fibre under FSC, PEFC, or SFI Chain of Custody certifications, no evidence could be found suggesting that the company is committed to phasing out deforestation or any activity that might lead to ecosystem conversion. While CoC certificates provides assurance that the imported raw material is certified throughout the value chain, no evidence has been found of the type of certifications, and therefore it is not possible to determine whether the company is progressing towards zero deforestation targets. Similarly, while the company has targets related to the certification of its raw material, no evidence could be found that these targets contribute to overall zero deforestation goals. Smurfit Kappa Group has a commitment to minimise ecosystem conversion and discloses some activities in that regard. However, it does not disclose a commitment to restore ecosystems. Still, the company discloses details and outcomes of ecosystem restoration projects in areas affected by its own operations or by its suppliers.

Resource exploitation and circularity
Smurfit Kappa Group 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 practice but does not disclose a target in respect to this.

Water
Smurfit Kappa Group demonstrates it is reducing water withdrawal in its own operations. It reports how much water is withdrawn for its own operations in water-stressed areas. However, the company does not engage with suppliers to reduce water withdrawal. It reports a decrease in water pollution and regularly reports on it but does not disclose its processes for managing and monitoring discharge water quality. Smurfit Kappa Group could 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
Smurfit Kappa Group is reducing the production of hazardous waste. There is no evidence that the company reduces plastic use and waste in its own operations. Furthermore, the company does not report on the amount of plastic waste generated and proportions directed from or to disposal. It reports regularly on air quality parameters of emissions of harmful air pollutants. However, it does not report time-bound targets to reduce air pollutants across the most material parts of its value chain.

GHG emissions
Smurfit Kappa Group is reducing its scope 1 and 2 greenhouse gas emissions. The company has a time-bound target to reduce its scope 1 and 2 emissions and also reports progress against these targets. However, there is no evidence that the company’s scope 1 and 2 emissions target is aligned with a 1.5-degree trajectory. There is also no evidence that the company reduces its scope 3 emissions and has a time-bound target in that regard. It has an opportunity to report progress against its scope 3 emissions target and align those targets with a 1.5-degree trajectory.

Invasive species
Smurfit Kappa Group has an opportunity to identify the activities that could lead to the introduction of invasive species in its own operations and in its value chain.

Safe, clean, healthy and sustainable environment
Smurfit Kappa Group does not disclose a commitment to respecting local communities’ right to a safe, clean, healthy and sustainable environment. It could track its actual or potential negative impacts on the health of local communities. Furthermore, 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
Smurfit Kappa Group does not disclose a commitment to respect Indigenous Peoples’ rights. The company has an opportunity to disclose its processes for identifying and recognising the rights of Indigenous Peoples when activities in its own operations may impact their rights and to describe how could obtain Indigenous Peoples’ free, prior and informed consent. Furthermore, 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. Smurfit Kappa Group could require 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 Smurfit Kappa Group discloses that it conducts due diligence in general, it has an opportunity to specify that it conducts human rights due diligence that includes a process for identifying human rights risks and impacts through its business relationships. Even if the company suggests that it assess human rights risks and impacts through audits, there is no evidence found that the company has identified what human rights are at risk of being impacted as a result of its operations and supply chains. Hence, there is no evidence of a process for assessing the saliency of these risks. The company states that it conducts training programme to increase awareness and understanding of the risk of forced labour and human trafficking occurring in its direct operations and supply chain. However, there is no evidence found the company discloses what it considers to be its salient human rights risks. Therefore, it has an opportunity to disclose what it considers to be its salient human rights risks and thereafter describe the global system in place to act on, prevent or mitigate its salient human rights issues. Smurfit Kappa Group could provide 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. Also, 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. It has an opportunity to provide examples of its engagement with stakeholders whose human rights have been or may be affected by its activities.

Smurfit Kappa Group has a publicly available policy statement which shows it is committed to respecting the health and safety of workers. Similarly, it has a publicly available policy statement which shows it expects its suppliers to commit to respecting the health and safety of their workers as well. However, there is 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. It could describe how it determines a living wage for the regions where it operates. Also, while Smurfit Kappa Group states that it requires 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. On the other hand, the company discloses the proportion of its total direct operations workforce covered by collective bargaining agreements. Even if Smurfit Kappa Group states that it requires its suppliers to support employees’ right to freedom of association and the right to collective bargaining, it has an opportunity to describe how it works to support the practices of its suppliers in relation to those.

Smurfit Kappa Group discloses a global tax strategy. Furthermore, the company discloses that it conducts due diligence which involves examination of the target organisation’s policies and practices on anti-corruption. It also states that it has designed controls to mitigate the risks related to corruption. However, there is no evidence found that the company describe the process to identify its bribery and corruption risks and impacts in specific locations or activities covering its own operations. The company has a supplier code of conduct in which it prohibits bribery and corruption, however, it is unclear if its supplier contracts/relationships will or could be terminated as a result of breach of the standards of manufacturing practices or bribery and corruption. Smurfit Kappa Group could have publicly available policy statement or policy setting out its lobbying and political engagement approach and specifying that it does not make political contributions.