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Summary of findings and company response

The Illovo website describes the company’s “environmental philosophy” as follows:

Our underlying environmental philosophy is to continually investigate ways to reduce the environmental impact of our operations. Against the background of our Strategic Intent principle to maximise the return on every stick of cane, we are particularly mindful of the possible impacts of our operations on the use of natural resources. We therefore strive to minimise our impacts through efficient use in a responsible and sustainable way and through committing ourselves to continuous improvement. We also strive to comply with all applicable in-country environmental regulations.1

Illovo does not feature in the National Environmental Compliance and Enforcement Reports. In its response to Full Disclosure the company confirmed that the only facility connected to Illovo that has been inspected by Environmental Management Inspectors is the Gledhow Sugar Company Limited, in which Illovo has a 30% shareholding. The company advised that it has not yet received the report from this inspection. Illovo states in its response that its facilities are however regularly visited by “other environmental regulators”.

While Illovo’s company reports provide no information on environmental non-compliances other than statements to the effect that the company has not been issued with any enforcement notices, environmental prosecutions or environmental citations, and that no fines or penalties were imposed, there is no publicly available information to indicate the existence of significant environmental non-compliances that are not being reported by the company.

In Illovo’s response to Full Disclosure, it is stated that “Illovo…applies standards such as NOSA and ISO14001”.

ISO 14001 (the current version being ISO 14001: 2015) sets out the criteria for an Environmental Management System. An Environmental Management System refers to the management of a company’s environmental programmes in a comprehensive, systematic, planned and documented manner. ISO 14001 does not stipulate any requirements for environmental performance, but rather maps out a framework that companies can follow to set up and maintain an effective Environmental Management System.

Retention of ISO 14001 certification is therefore not an indication that a company is in compliance with environmental laws and permits, nor is it a substitute for reporting environmental non-compliance.

Illovo engaged extensively with the CER in its response to Full Disclosure, and provided a more detailed response than that of some companies with records of significant environmental non-compliances.