Greif, a global manufacturer of industrial packaging | Environmental Management Systems

Why Environmental Management Systems Matter

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Explanation of the material topic and its Boundary

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Explain management approach components

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Evaluate management approach

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Following the various environmental laws and regulations applicable to our business is an integral part of Greif’s ongoing operations. Our environmental management systems and collaborative relationships with regulators enable us to proactively and efficiently demonstrate to our stakeholders our deep understanding of the complex regulatory obligations we are subject to, while illustrating our ability to consistently meet them.

Governance

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ISO14001 Certified Facilities

We take our responsibility towards environmental standards and regulations seriously and implement systems to manage our obligations.

In 2011, Greif implemented our proprietary Compliance Management System (CMS) to allow us to track and monitor our compliance with certain laws and regulations, including environmental compliance related to emissions, energy, water and waste in our facilities. CMS is administered by our Environmental Health and Safety (EHS) Team, led by our Vice President of EHS and Operations for North America with support from our EHS Director and regional managers supporting each of Greif’s four operating regions. Environmental compliance within our Paper Packaging and Services (PPS) operations is managed by two dedicated EHS professionals.

Greif is a diverse, complex global manufacturer subject to a wide range of EHS regulations that may impact our organization in a variety of different ways. Across our organization, we use a variety of tools and processes to appropriately manage geographic and business specific needs, however all of our global environmental management systems are administered under a consistent set of principles. All Greif facilities globally have an environmental management system that is supported by a compliance management software. All required compliance tasks are linked to an escalation process to ensure they are fully and accurately completed on time. Escalations can go as high as our CEO, if necessary. Audits are performed to confirm that work is completed and facilities remain in compliance with all required regulations.

CMS is accessible to all Greif facilities worldwide. All Rigid Industrial Products & Services (RIPS), Container Life Cycle Management and Delta facilities in the United States and Canada use CMS to manage environmental compliance tasks. Management at each of these facilities leverage CMS to track progress on upcoming regulatory tasks and deadlines. As deadlines approach, CMS sends notifications to facility managers reminding them of their obligations. If progress on a task is not made in a timely manner, notifications are escalated through Greif’s EHS Team, ultimately reaching the CEO, if necessary. Each task follows a standard escalation protocol and facility management is incentivized to minimize escalations.

Legacy Caraustar sites will continue to operate their own compliance systems in 2020. Caraustar’s legacy systems provide their facilities the same tracing, management and escalation capabilities as Greif’s CMS.

Both legacy Caraustar and Greif facilities in North America supplement their compliance management systems through Dakota, an advanced EHS compliance and risk management software that tracks new and upcoming regulations applicable to each facility’s unique profile. Dakota improves our ability to assess our readiness to comply with upcoming regulations. Greif began using Dakota in our RIPS business unit in 2018 in conjunction with third-party audits to determine additional resources and support that is needed at each facility to better manage their unique environmental risks. Through 2019, 16 third-party audits have been conducted and 10 more are planned for 2020. Legacy Caraustar facilities have been using Dakota since 2010 to support both third-party audits and manage compliance tasks. In these facilities, colleagues, that will be using Dakota to manage compliance tasks, will receive two days of training on how to use and fully complete tasks in Dakota. Since 2018, Dakota has been used to perform quarterly compliance audits to better manage environmental risks.

In 2018, we introduced a monthly task to all Greif facilities globally to report waste data in an effort to improve the efficiency, accuracy and reliability of our waste data. In 2019, we worked to further improve how we collect and report our waste data by offering as-needed training to facility teams on best practices for collecting and inputting data, sharing best practices for organizing and reviewing data and educating on identifying gaps and potential errors in data. These efforts were taken as part of a larger effort to improve the support and communication we provide to each facility to best set expectations for environmental management and reduce the risk of falling out of compliance with any of our obligations. In 2019, Greif was not subject to any fines of material significance to the organization.

We are actively taking steps to prevent any equipment or materials that may introduce compliance risks to our facilities from entering our doors. In 2019, we introduced two programs in support of this objective. The New Chemical Request form must be submitted and approved by our EHS team prior to any new chemical being approved for use in our operations. The review assesses the potential for the requested chemical to create hazardous waste, impact air emissions or otherwise jeopardize Greif’s compliance with regulations. Similarly, any new piece of equipment that Greif is considering installing at any of our facilities must undergo an Equipment Pre-Acceptance Review (EPAR) to assess the overall environmental, quality, health and safety of equipment prior to being approved for purchase and installation. In 2019, 100 EPAR’s were completed. In RIPS North America any material or process change is subject to a Management of Change (MOC) review. The reviews assess potential commercial, EHS, plant, quality and regulatory impacts of the change prior to being implemented. In 2019, 12 MOC reviews were completed.

Our global Flexible Products & Services (FPS), PPS and RIPS production facilities manage quality, safety and environmental standards through certifications such as OHSAS, ISO, FSSC and SQF. Our PPS operations maintain ABI, FSC, OSHA, PEFC, SFI and PEFC certifications. Globally, 17 sites have achieved ISO 14001 certification.

2020 will see continued growth and sophistication of our environmental compliance practices. We will pursue ISO 14001 certification for our Naperville, Illinois facility. To support continued growth and enhancement of our compliance programs, we will add additional EHS managers with the goal of providing more facility-level support and consistency in implementation. Within our PPS operations, we will implement Dakota at our mill in Riverville, Virgina and all CorrChoice facilities and expand our use of Dakota at our Massillon, Ohio facility to include air compliance and spill prevention, control and countermeasures by the end of 2021.