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Mondi Group's disclosure of environmental non-compliances in annual reports

Mondi classifies incidents as either Level 2 (moderate impact, medium term effect) or Level 3 (significant impact, extensive or long-term effect).1 Level 1 incidents were not reported at Group level.2 In 2012, Mondi also classified incidents as serious, significant or critical.3 In 2013 Mondi reported that it had revised its  methodology on reporting complaints in order to categorise and report complaints and incidents separately.4

2008 company reports

In Mondi’s 2008 Sustainability Report, it was stated that “a total of 232 community complaints were reported in 2008, compared to 397 in 2007, all of which related to air emissions and noise levels. Most of these complaints were reported by the Richards Bay mill for bad odour caused by Total Reduced Sulphur (TRS) emissions which are set to be reduced further over the next year as a result of current investments.”5 It was also reported that Mondi had received fines to the total value of 12,780 Euro in the 2008 reporting period, which related to air and water emission limits that were exceeded in terms of the applicable permit requirements. The company reported 33 Level 2 incidents, again relating to water and air emissions which exceeded permissible limits.6

2009 company reports

In the 2009 Annual Report, it was stated that “all Mondi operations comply with local emissions regulations”7 and also “we operate in a highly regulated environment…and have acted in compliance in all the regions in which we operate”.8 The company reported 23 Level 2 incidents across the group, and these “all related to water and air emissions which exceeded permissible limits over an extended period of time during applicable reporting periods”.9

2010 company reports

In the 2010 Sustainable Development Review, Mondi commented on the complaint made by the Centre for Environmental Rights to the JSE Limited in December 2010 in respect of the company’s inclusion in the SRI Index.10 The complaint related to a statement in the 2009/2010 National Environmental Compliance and Enforcement Report that Mondi had been requested to provide clarity in relation to certain compliance issues, but that “this information is still outstanding”. It was stated in the 2010 Sustainable Development Review that the request to Mondi for more information came at the end of the Department’s reporting period and that Mondi’s response, which had been provided in March 2010, was therefore not reflected in the National Environmental Compliance and Enforcement Report.

Later in this report it was also stated that, “as a minimum standard, we ensure that all our operations comply with the environmental laws and regulations of the countries in which we operate”.11 The company reported 22 Level 2 incidents throughout the Group “largely a result of longer-term exceedances of permits; release of dust, malodorous gases and oil; and repeated complaints about odour from communities”.12 Some of these incidents occurred at Richards Bay. In 2010 there were 137 complaints received, mainly relating to odour.13

2011 company reports

In the 2011 Sustainable Development Review it was stated that, “Mondi did not receive any significant fines or non-monetary sanctions for non-compliance with laws and regulations”.14 However, the company reported 9 Level 2 incidents across the group during the year15 and there were 209 complaints recorded, mainly relating to odour.16

In the 2011 Annual Report, it was stated that “in South Africa, Mondi acts in compliance with the South African National Environmental Management: Air Quality Act”17 and that “as a minimum standard, we ensure that all our operations comply with the environmental laws and regulations of the countries in which we operate. No significant fines or non-monetary sanctions were imposed on Mondi as a result of non-compliance with environmental laws or regulations during 2011.”18

2012 company reports

In 2012 the company reported 16 serious environmental incidents and 1 significant environmental incident across the group. The significant incident occurred at the Richards Bay mill, where there was a loss of heavy fuel oil into the Indian Ocean through the Waste Water Treatment Plant.19 In 2012, 169 complaints were received, 138 of which related to odour.20

2013 company reports

In the 2013 Annual Report, the following statement was provided, “we comply with or exceed local regulatory standards wherever we operate”.21 The company reported five Level 2 incidents in 2013, throughout all of Mondi’s operations.22

2014 company reports

In the 2014 Sustainable Development Report, an “oil leakage incident” at the Richards Bay mill was referenced, but no further details were given.23 It was also reported that two Level 2 incidents occurred across the group that year, although neither of these were in South Africa24 and that “no material fines or non-monetary sanctions for non-compliance with laws and regulations were received during 2014”.25 In 2014, the Richards Bay mill received an increased number of odour complaints.26

No further statements were made in relation to the National Environmental Compliance and Enforcement Reports.

  1. Mondi Group Sustainable Development Report 2011, at p44, available at  http://www.mondigroup.com/PortalData/1/Resources/sustainability_2012/Mondi-sustainable-development-review-2011.pdf
  2. Mondi Group Sustainable Development Report 2012, available at http://sd-report.mondigroup.com/2012/downloads/MONDI-SD12-environment-09-incident-reporting.pdf
  3. Mondi Group Sustainable Development Report 2012, available at http://sd-report.mondigroup.com/2012/downloads/MONDI-SD12-environment-09-incident-reporting.pdf
  4. Mondi Group Sustainable Development Report 2013, at p20, available at http://sd-report.mondigroup.com/2013/download/MONDI-sd-report.pdf
  5. Mondi’s 2008 Sustainability Summary Report, at p16, available at: http://www.mondigroup.com/PortalData/1/Resources/sustainability/reports/SD_Summary_ReportLoRes.pdf
  6. Mondi’s 2008 Sustainability Summary Report, at p16, available at: http://www.mondigroup.com/PortalData/1/Resources/sustainability/reports/SD_Summary_ReportLoRes.pdf
  7. Mondi Group Annual Report 2009, p37, available at: http://www.mondigroup.com/microsite/AR2009/files/mondi_AR09.pdf
  8. Mondi Group Annual Report, p40, available at: http://www.mondigroup.com/microsite/AR2009/files/mondi_AR09.pdf
  9. Mondi Group Sustainability Summary Report 2009, at p10, available at: http://www.mondigroup.com/PortalData/1/Resources/sustainability/reports/Mondi_SDR09.pdf
  10. Mondi Group Sustainable Development Review 2010, at p11, available at: http://www.mondigroup.com/PortalData/1/Resources/sustainability_2010/documents/Mondi_SD_Review_FINAL.pdf
  11. Mondi Group Sustainable Development Review 2010, at p33, available at: http://www.mondigroup.com/PortalData/1/Resources/sustainability_2010/documents/Mondi_SD_Review_FINAL.pdf
  12. Mondi Group Sustainable Development Review 2010, at p33, available at: http://www.mondigroup.com/PortalData/1/Resources/sustainability_2010/documents/Mondi_SD_Review_FINAL.pdf
  13. Mondi Group Sustainable Development Report 2010, at p34, available at http://www.mondigroup.com/PortalData/1/Resources/sustainability_2010/documents/Mondi_SD_Review_FINAL.pdf
  14. Mondi Group Sustainable Development Review 2011, at p9, available at: http://www.mondigroup.com/PortalData/1/Resources/sustainability_2012/Mondi-sustainable-development-review-2011.pdf
  15. Mondi Group Sustainable Development Report 2012, available at: http://sd-report.mondigroup.com/2012/downloads/MONDI-SD12-environment-09-incident-reporting.pdf
  16. Mondi Group Sustainable Development Report 2011, at p36, available at http://www.mondigroup.com/PortalData/1/Resources/sustainability_2012/Mondi-sustainable-development-review-2011.pdf
  17. Mondi Group Integrated Report and Financial Statements 2011, at p37, available at: http://www.mondigroup.com/PortalData/1/Resources/investor_relations/reports_presentations/Mondi_AR_Final_2Mar12.pdf
  18. Mondi Group Integrated Report and Financial Statements 2011, at p41, available at: http://www.mondigroup.com/PortalData/1/Resources/investor_relations/reports_presentations/Mondi_AR_Final_2Mar12.pdf
  19. Mondi Group Sustainable Development Report 2012, available at: http://sd-report.mondigroup.com/2012/downloads/MONDI-SD12-environment-09-incident-reporting.pdf
  20. Mondi Group Sustainable Development Report 2012, available at http://sd-report.mondigroup.com/2012/downloads/MONDI-SD12-environment-07-air-quality.pdf
  21. Mondi Group Integrated Report and Financial Statements 2013, at p11, available at: http://www.mondigroup.com/PortalData/1/Resources/investor_relations/reports_presentations/2014/Mondi_Group_Integrated_Report_2013_low_res_FINAL.pdf
  22. http://sd-report.mondigroup.com/2013/download/MONDI-sd-report.pdf at p13.
  23. Mondi Group Sustainable Development Report 2014, at p41, available at: http://reports2014.mondigroup.com/downloads/sustainable-development-report-2014.pdf
  24. Mondi Group Sustainable Development Report 2014, at p43, available at: http://reports2014.mondigroup.com/downloads/sustainable-development-report-2014.pdf
  25. Mondi Group Sustainable Development Report 2014, at p24, available at: http://reports2014.mondigroup.com/downloads/sustainable-development-report-2014.pdf
  26. Mondi Group Sustainable Development Report 2014, at p43 available at http://reports2014.mondigroup.com/downloads/sustainable-development-report-2014.pdf