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Sappi Limited's disclosure of environmental non-compliances in annual reports

2009 and 2010 company reports

In Sappi’s 2009 Sustainable Development report it was stated that in 2010 the company would report on the findings made by the environmental inspection teams in the audits,1 but in the 2010 Sustainable Development report, it was only recorded that queries had been responded to and discussions were ongoing with the Department of Environmental Affairs.2

In the 2010 Sappi Southern Africa Annual Report, it was stated that the Ngodwana mill had been inspected by environmental management inspectors and that “no major findings were raised”.3 This does not correlate with the information presented in the National Environmental Compliance and Enforcement Reports. In relation to the Enstra mill, it was stated that following the initial and follow up visits there was correspondence with the DEA regarding “some aspects of Enstra’s compliance with standards for atmospheric emissions”.4 It was also stated in that report that the Tugela mill had been inspected in 2010 and that a report was received later that year. A response was to be submitted.

2011 company reports

In the 2011 Sappi Southern Africa Annual Report it was stated that, “both our Ngodwana and Enstra mills have undergone comprehensive initial inspections with subsequent follow up audits done by the EMIs during the course of 2008 to 2010 with no major findings raised to date”.5 It was also stated in this report that the Tugela mill had been inspected in 2010 and that a written report had been received. Monthly progress reports were being submitted to the “lead team member’s office”.6

In the 2011 Sappi Integrated Report, it was stated that, “our Ngodwana, Enstra and Tugela Mills have undergone comprehensive initial inspections with subsequent follow up audits done by the EMIs during the course of 2008 to 2011. We are continuing to make progress on addressing the issues that were identified by the inspectors and, as appropriate, have been voluntarily submitting progress reports to the EMI lead team member’s office.”7

2012 company reports

2013 company reports

2014 company reports

In Sappi’s 2014 Integrated Report, the Chairman of the Social, Ethics, Transformation and Sustainability Committee made the following statement, “(t)here were no substantive areas of non-compliance with legislation and regulation [sic], nor non-adherence with codes of best practice applicable to the areas within the committee’s mandate that were brought to the committee’s attention. The committee has no reason to believe that any such non-compliance or non-adherence has occurred.”8