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Full Disclosure 2016

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

2016 update

2015 company reports

In relation to legal compliance, Illovo’s 2015 Integrated Annual Report states:

During the year under review, no instances of material non-compliance were noted and no judgements, damages, penalties or fines were recorded or levied against any group company, its directors or employees for non-compliance with any legislation.1

In relation to environmental compliance specifically, Illovo states:

The key risks and opportunity categories which received focus during the year under review were energy and greenhouse gas management, water management; weather-related responses, adoption of new regulatory systems, including the pending carbon tax in South Africa; and embedding systems such as the SUSFARMS initiative to enhance the group’s future sustainability profile. We continuously strive to comply with all applicable in-country environmental regulations.2

Full Disclosure 2015

The following statement is regularly made in Illovo’s annual and sustainable development reports: “(d)uring the year under review there were no instances of major non-compliance, fines or prosecutions for non-compliance.”3 This statement constitutes all of the information that Illovo discloses about non-compliances with environmental laws and permits.

However, in the 2013 Annual Report the following information appears:-

During the year under review, a 5000 litre effluent spillage occurred at our ethanol distillery plant at Merebank in South Africa as a result of a cracked gasket in the pipeline taking effluent from the factory to the sewage works. Various preventative measures have been taken… At our Sezela factory, one breach of the environmental licence occurred due to the Chemical Oxygen Demand (COD) being above that stipulated in the permit. However, the average for the season is below the permitted limit. Temporary measures, in line with the Integrated Coastal Management Act, have been taken and the factory has undertaken a number of initiatives to minimize effluent discharge.

No enforcement notices, environmental prosecutions or environmental citations were issued to any of the group’s operations and no fines or penalties were imposed.4

  1. Illovo Sugar Limited Integrated Annual Report 2015, at p66.
  2. Illovo Sugar Limited Integrated Annual Report 2015, at p15.
  3. 2012 Integrated Annual Report, at p44, available at:
  4. 2013 Integrated Annual Report, at p101, available at: