Skip to Content

Full Disclosure 2016

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

2016 update

2015 company reports

Sappi’s 2015 Integrated Report referenced Full Disclosure and expressed a commitment on the part of the company to greater transparency in its future reports on environmental compliance:

Sappi has taken note of the comments of the CER and for increased transparency, we will align our reporting to any mentions in the NECER. We continue to engage with authorities regarding all issues of environmental compliance.1

The NECER findings relating to Sappi are referred to in Sappi’s 2015 Integrated report as follows:

In the recently published 2014/15 NECER (National Environmental Compliance and Enforcement Report) of the Environmental Management Inspectorate (EMI) of the Department of Environment Affairs (DEA) of the Government of South Africa, an entry is included which makes reference to an EMI inspection which took place at Sappi Saiccor Mill during September 2014. The entry goes on to state that several non-compliances were identified and an inspection report detailing the findings of the inspection had been finalised. We have not yet received any official report resulting from the initial inspection done in 2014 from the EMI or the DEA.2

Sappi states as follows with regard to legal compliance in its “Social, ethics, transformation and sustainability committee report” in its 2015 report:

There were no substantive areas of non-compliance with legislation and regulation, 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.3

Full Disclosure 2015

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,4 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.5

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”.6 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”.7 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”.8 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”.9

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.”10

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.”11

  1. Sappi 2015 Integrated Annual Report, at p38.
  2. Sappi 2015 Annual Integrated Report, at p38.
  3. Sappi 2015 Annual Integrated Report, at p70.
  4. Sappi Sustainability Report 2009, at p60, available at:http://sappi.investoreports.com/sappi_sdr_2009/downloads/Sappi_Sustainability_2009.pdf
  5. Sappi Sustainability Report 2010, at p26, available at: http://sappi.investoreports.com/sappi_sdr_2010/downloads/sappi_sdr_2010.pdf
  6. Sappi Southern Africa Annual Report 2010, at p88, available at: http://www.sappi.com/Investors/bondreportingrequirements/Documents/Annual%20Report%20Sappi%20Southern%20Africa%202010%20-%20pdf.pdf
  7. Sappi Southern Africa Annual Report 2010, at p88, available at: http://www.sappi.com/Investors/bondreportingrequirements/Documents/Annual%20Report%20Sappi%20Southern%20Africa%202010%20-%20pdf.pdf
  8. Sappi Southern Africa Annual Report 2011, at p105, available at: http://www.sappi.com/Investors/bondreportingrequirements/Documents/Annual%20Report%20Sappi%20Southern%20Africa%202011%20PDF.pdf
  9. Sappi Southern Africa Annual Report 2011, at p105, available at: http://www.sappi.com/Investors/bondreportingrequirements/Documents/Annual%20Report%20Sappi%20Southern%20Africa%202011%20PDF.pdf
  10. Sappi Integrated Report 2011, at p185, available at: http://www.sappi.com/Investors/FinancialInformation/Documents/2011%20Integrated%20Report.pdf
  11. Sappi’s 2014 Integrated Report, at p68, available at: http://www.sappi.com/Investors/FinancialInformation/2014%20Annual%20report/2014-Sappi-Integrated-Report.pdf