Methodology – Profit

The taxonomy regulation has not yet adopted explicit criteria for the minimum social safeguards beyond the references to OECD guidelines and UN Guiding Principles. Still, our understanding is that defined requirements on minimum social safeguards need to be placed on our company and the activities in question in order to assess activity-alignment. Elopak has therefore based compliance with minimum social safeguards on an assessment of several requirements derived from the process of due diligence on responsible business conduct as described in OECD’s Guidelines for Multinational Companies and the UN Guiding Principles for Business and Human Rights. Please see below for the actual criteria.

Minimum social safeguards criteria from the EU Taxonomy:

• Does your company have a policy commitment on social responsibility including human rights, labor rights and anti-corruption – either as a stand-alone policy or integrated into other policies?

Elopak has a Code of Conduct and a Human Rights Policy available on our website. In addition, we have internal policies on Anti-Corruption, Anti-Money Laundering and Sanctions and Trade Compliance, available for all employees.

• Does your policy or code of conduct contain social responsibility requirements and/or expectations towards suppliers and other key business partners?

Elopak has a Global Supplier Code of Conduct and an internal Business Partner Procedure. Incorporated in the business partner integrity due diligence process are requirements for how we assess country risk, including evaluation of sanctions and trade compliance, corruption, rule of law, and human rights.

• Does your company have written procedures ensuring that you have an iterative process in line with OECD’s due diligence process including mapping of risks for adverse negative impact on people, implementation of ceasing or preventive measures, tracking and reporting?

This process is described in our Human Rights Policy. Read more about our approach here.

• Have you identified and assessed the salient risks, potential or factual, related to your taxonomy activity/ activities, covering your value chain? Include also an explanation of why these are your prioritized risks.

Our climate risk impacts are described in this report. Further assessed risks are described in the Business risks chapter on page 53 in the Annual report.

• Can you provide information and documentation on the overall measures you have implemented to reduce, cease or prevent the risks identified?

This is described in the climate risk impacts in this report and in the Business risks chapter on page 53 as well as in note 34 in the Annual report.

• Do you have a whistleblower mechanism or similar in place, that is known and accessible for internal and external stakeholders?

Elopak has externally available information about our third-party hosted whistleblower helpline. It is also described in our Code of Conduct. Internally we have a Speak-up Policy and a Whistleblower and internal investigation procedure available for all employees.

• Do you track whether your policies and identified risks are properly managed through optimal implementation in your day-to-day business?

Elopak is in the process of establishing a Management System ensuring all business processes are clear and easy to understand for all employees. On an annual basis we do a compliance risk assessment for the Elopak Group (read more here).

• Does your company report on how it addresses adverse impact on human rights, labor rights and anticorruption – where such risks exist – and the results of its actions taken?

Elopak’s human rights risk assessment is described in this report.

• Is the board and top-management kept informed about risks, and progress and results reached in the management of these?

The BoD receive regular updates on relevant areas related to sustainability, such as human rights and climate risk assessments. This is also part of strategy processes and the annual business plan process.

• Are the above-mentioned steps of policy commitment, risk assessment, implementation, tracking and reporting performed on a regular and iterative basis in order to cover changes in risk exposure that can trigger more in-depth assessment and enhanced mitigation?

Elopak is in the process of implementing a Management System ensuring all business processes are clear and easy to understand for all employees. This system will also ensure key processes (such as risk assessments) are regularly updated. Governing documents are available in an internal Document Management System with defined responsibilities and frequencies for updates.