Standard 1 Governance Standard

Standard 1 Governance Standard The Sustainable Development Management System provides the mechanism by which Mondi ensures strong corporate governance in the area of Sustainable Development, an issue which presents material risk and opportunity to the future success of the Group. This document details the standard of governance to which Mondi has committed. The requirements of this Governance Standard have been divided into five categories: responsibilities and accountabilities; risk identification and management; performance improvement; audit and assurance; and communication and consultation. 2.1 Responsibilities and Accountabilities Employees at every level of the Group are responsible for Sustainable Development (SD). Responsibilities and accountabilities are clearly defined and, where appropriate, explicitly detailed in individual s performance contracts, with associated objectives and key performance indicators. Executives remuneration is directly linked to both the financial and non-financial performance of the business. The DLC SD Committee has overall responsibility for the approval of our policies and targets for the management of SD issues and reviewing our performance in implementing these policies and achieving targets. The Group Technical Director has overall accountability for ensuring that the standards to which Mondi has committed are met, whilst at an operational level, Operations Managers are accountable for the performance of their operations. SD specialists are responsible for advising and supporting the Group Technical Director and the Operations Managers. 2.2 Risk Identification and Management In line with the Group s corporate governance requirements, all material SD issues are identified, prioritised and integrated into the Group-wide risk register. Steps and subsequent actions are taken to manage them. Risk registers are reviewed and updated on an annual basis. SD risks are identified at each level of the business: Group, divisions, business units and operations, in accordance with the Mondi SD Risk and Change Management Standard and the associated Mondi Consequence and Severity Risk Matrix. The Group-level risk register includes both those risks identified by Group-level processes, and those identified at divisional, business unit and/or operational which present a material risk to Mondi s performance. All material risks identified at each level of the Group have risk managers and management plans. Internal audit is scoped in a manner which enables a risk assurance process to be completed, whereby risk management plans and mitigation measures are checked. 3 SD Standards

An assessment of all SD risks shall form part of any proposal for acquisition or divestment. Potential liabilities due to proposed acquisitions shall be assessed. Post-acquisition reviews and audits shall be carried out and a time-table defined for acquisitions to implement improvement programmes to conform to Mondi s Policies and Standards. 2.3 Performance Improvement Mondi is committed to continuous improvement in both our management of SD issues and in our actual SD performance. Mondi has made stretching public commitments. In recognition that improving SD performance will enable improved business performance, systems are in place to ensure that SD is an integral part of business planning. Stretching objectives and targets for SD performance improvement are set on an annual basis at Group, divisional, business unit and operations levels. Objectives and targets take into account public commitments, and the significant risks, legal and other requirements presented by SD issues. Performance is measured by reference to both leading and lagging indicators that are measurable, documented, communicated, monitored and reviewed. Indicators are typically reported on a monthly basis. Indicators have strict definitions and criteria thereby enabling complete, consistent, and accurate reporting, and are subject to internal and external audit. The indicators are consistent with the SD Policy and underlying sector policies. Plans and programmes to achieve objectives and targets are in place, and updated and communicated as changes, modifications or when new developments occur. Incidents, including close calls are reported, investigated and analysed. Immediate corrective and preventative actions are taken and lessons from reviews of performance, accidents and incidents are communicated as learning tools and taken into account when SD Policies, Standards and Performance Requirements are reviewed. 2.4 Audit and Assurance The SD Audit Management Standard requires that an auditing process to check that our Standards and Performance Requirements are being applied at all levels. This audit process is integrated with the Internal Audit and Risk Assurance processes, thereby ensuring a joined approach with internal assurance activities. Corrective actions are tracked by the Group SD and follow-up audits undertaken to confirm key issues have been closed out where appropriate. In addition to the internal audits, a self-assessment process requires Operations Managers to confirm compliance with the Mondi Standards on an annual basis. Mondi commissions an external assurance programme on an annual basis to support the internal auditing processes; provide the DLC SD Committee with an independent view on Mondi s SD performance; ensure that the Mondi Sustainability Report is robust and based upon correct information; and provide stakeholders with confidence in the quality of this external disclosure. 4 SD Standards

2.5 Communication and Consultation Systems are in place to identify and consult with stakeholders, and to identify and address their concerns. In addition, open consultation and communication with governments, authorities and other organisations is maintained in order to contribute to development of public policy and legislation. Concerns, complaints and relevant external communications related to SD issues are recorded in a register, acknowledged, investigated as incidents and outcomes reported back to relevant stakeholders. Mechanisms are in place to resolve conflicts where they arise, through consultation and participation directly with stakeholders or their intermediaries. The principles of the SD Management System, SD risks, plans and performance are communicated throughout the Group to all persons, and to external stakeholders on a regular basis. External communication is principally through the company s internet site and the annual Sustainability Report, which is subject to independent assurance. 5 SD Standards

Management Standard 2 Policies, Leadership and Commitment To implement the SD Management System, management shall demonstrate leadership and proactive commitment to SD in line with the Mondi Policies and Management Standards. This Management Standard shall be applied to Mondi. 2.1 Policies Mondi shall maintain SD Policies that are appropriate to the nature and scale of its activities and the level of strategic importance being given to SD performance. The DLC SD Committee endorses the policies and reviews them regularly to ensure they remain current and relevant. The SD policies are available to all relevant stakeholders. Divisional, business unit and operations policies shall be aligned with Mondi Policies. 2.2 Leadership and Commitment Mondi shall have clearly defined SD roles, responsibilities and accountabilities at all levels and functions within the Group to ensure the effective implementation of the SD Management System. These shall be defined, documented and communicated to all appropriate personnel. All operations shall have a management appointee to act as a focal point for ensuring the effective implementation of the SD Policies and the SD Management System. Adequate resources (human, technical and financial) shall be made available to ensure the effective implementation and maintenance of the SD Management System. This shall include the use of appropriate, competent advice in specialist areas. Executives and management shall demonstrate that SD is as important as costs, production, quality, customer service, employee relations and other key business priorities. Executives, management, employees and contractors shall demonstrate a clear understanding of the need to comply with corporate and site-specific SD Standards and of the consequences of non-compliance. This shall include the prevention and/or correction of at-risk behaviours or unsafe work conditions. Executives, management and first-line supervision shall proactively demonstrate their commitment to SD by maintaining their visibility in the field and utilising their time to demonstrate SD leadership and commitment and participate in SD programmes, audits and reviews to ensure that SD Standards, including those which are sitespecific, are embedded in business practices and people behaviours. Executives and managers shall adopt formal processes that recognise, reinforce and reward desired SD outcomes. All operations shall ensure that processes are in place to ensure the effective review of the SD Policies and their associated systems on a periodic basis to ensure that they remain relevant and appropriate to the nature and extent of the associated risks. 6 SD Standards

3. Responsibilities The DLC SD Committee is ultimately responsible for the sign off and approval of the SD Management System s Policies. The Group Technical Director is responsible on the Executive Committee for SD matters. The Group Technical Director is the chair of the SD Leadership Panel, which promotes sustainability matters, measures SD performance, identifies priority issues and builds consensus for the way forward. The Operations Managers are ultimately accountable for SD performance at an operational level. They have a clear responsibility to set priorities for SD and demonstrate a commitment to continual improvement within their operation. Performance contracts shall formally define SD accountabilities and responsibilities of senior executives and senior management. Senior management is accountable for establishing and maintaining local policies and management systems that as a minimum shall reflect the Mondi s SD Policies, Management Standards and local relevant legislation. All operations shall ensure that proactive processes are in place to ensure continual improvement in SD performance. 7 SD Standards

Management Standard 3 Legal Review All operations shall ensure that applicable legal, regulatory and other SD requirements and commitments are identified, documented, maintained, accessible, communicated, understood and complied with. This Management Standard shall be applied to Mondi. All levels of Mondi shall ensure that formal systems are in place to identify and access all applicable laws, regulations, approvals, licences, permits, and other requirements relating to SD issues (e.g. codes, charters, policies, standards, protocols, commitments), and document them in a legal register that is reviewed and kept up-to-date. Compliance with legal and other requirements, including Mondi SD Standards and Performance Requirements shall be demonstrated through the implementation of documented procedures that ensure effective communication of specific requirements, periodic evaluation, and record keeping and reporting. All levels of the Mondi shall have systems in place to track the development of emerging legislation relevant to Mondi operations. All operations shall have, or have access to, competent personnel for the interpretation and application of all relevant legal, regulatory and other requirements. All operations shall refrain from seeking exemptions related to environmental, health, safety, labour, taxation, financial incentives or other issues. 3. Responsibilities Legal requirements shall be managed by nominated persons at the operations level, or where multiple operations exist within a country, operations may identify an individual or committee to coordinate legal reviews of national legislation. 8 SD Standards

Management Standard 4 Risk and Change Management To implement Sustainable Development, SD risks shall be proactively identified, assessed, managed, communicated and reviewed. This management standard applies to all activities that Mondi can control or influence, including planned and unplanned changes to operations, processes, personnel and routine and non-routine activities. This Management Standard shall be applied to Mondi. The SD risks are identified, assessed, prioritised and managed as appropriate to the nature, scale and impacts of Mondi s operations and activities. The SD risk identification, assessment and management process involves competent persons at the appropriate level of management with relevant knowledge and experience, including employees, contractors and other stakeholders as appropriate. Risks are classified and prioritised according to severity of impact and likelihood of occurrence to determine significance. The risk assessment process considers, as a minimum, routine and non-routine activities, products, all personnel and other stakeholders, including contractors, suppliers and visitors, all equipment and facilities, the design, commissioning, and operation of the workplace, processes, installations, machinery, operating procedures and work organisation. Communication with external stakeholders should be proactively undertaken during the risk management process. SD risks are recorded and maintained in a risk register. The risks are reviewed and the risk register updated at least annually or more often if the nature of the risk requires, and following new information, change or a significant incident. Risk management decisions are documented and the implementation of resulting actions tracked. The results of the risk assessment processes are fully communicated to all relevant personnel and considered when establishing training, awareness and competency requirements. The hierarchy of control shall be used in developing risk mitigation measures, with primary focus on elimination of the risk, then reducing the risk through reducing the probability or minimising the impact and finally from control including physical and procedural measures. Operations shall ensure that formal change management systems are in place to manage SD risks associated with planned changes, or to manage such risks when unplanned changes occur, whether permanent, temporary or as the result of incremental change. Operations shall ensure that authorised employees or contractors evaluate and approve changes, either permanently or for a defined period, once the level of SD risk has been demonstrated to be acceptable, and that changes are communicated to, and understood by, all those who may be affected, including external 9 SD Standards

stakeholders. Where appropriate, risk assessments should be updated to take account of the implications of the changes undertaken. Similarly other relevant documentation should be updated to reflect such changes. Processes shall be in place to ensure the effective review of the systems and to ensure that they remain relevant and appropriate to the nature and extent of the associated risks. 3. Responsibilities The Group Technical Director shall maintain an up-to-date SD risk register, which shall contain the significant SD risks for the Mondi business. This shall include evaluation of risk across Mondi from the operations, business units and divisional risk registers, as well as Group-wide issues. Divisional and business unit Chief Executives shall maintain their risk registers, which shall include an evaluation of operations risk registers as well as any risks specific to the types of operations within the business unit or division. Operations Managers shall maintain an up-to-date risk register, which shall contain the significant risks for their operations. Risk registers shall be maintained, updated and reviewed at least annually or when circumstances or events change the risk profile of the operation. Any changes should be communicated to affected persons and risk managers. 10 SD Standards

Management Standard 5 Objectives, Targets and Performance Sustainable Development is an integral part of business planning, with SD goals and targets integrated into the overall business planning process. Measuring SD performance against objectives and targets is fundamental to continual improvement. Reporting of quantifiable key performance indictors allows for evaluation against objectives and targets and clear communication of performance. This Management Standard shall be applied to Mondi. Systems are in place to ensure that SD is an integral part of business planning based on identified significant SD issues, risks and opportunities. Mondi sets SD goals, targets and leading and lagging key performance indicators (KPIs) that are measurable, documented, communicated, monitored and reviewed. They are consistent with the SD Commitments, consider the interests of stakeholders and have defined time-scales. Divisions, business units and operations annually set measurable SD goals, targets and leading and lagging performance indicators that are documented, communicated, monitored and reviewed. They are consistent with the Mondi SD targets, take into account the significant SD risks, legal and other requirements, and consider technological options, Mondi requirements and the interests of stakeholders and are used to develop operation level improvement programmes with defined time-scales. SD performance information is used to define and refine plans, goals and targets to improve risk management and performance. All operations shall have formal systems in place to ensure that KPIs, targets and objectives and performance against these, are assigned, communicated and understood by all appropriate personnel, including senior management, line management, employees and contractors. All operations shall ensure that all relevant employees and contractors understand the targets and objectives and ensure that SD obligations are incorporated into their agreements. All operations shall have formal systems in place to monitor and regularly report on performance against regulatory compliance, objectives and targets. Data gathered for reporting against objectives and targets shall be evaluated for completeness, appropriateness, accuracy and precision. All operations shall have formal systems in place to monitor the calibration and maintenance of measurement and monitoring equipment used. All operations shall ensure that there is a formal process in place to monitor and review the targets and objectives to ensure they remain relevant, on track for completion within defined timeframes, and contribute to continual improvement in performance. As a minimum the review process shall be undertaken on an annual basis. 11 SD Standards

Lessons from review of performance and accidents and incidents shall be taken into account when reviewing targets and objectives. 3. Responsibilities Core SD governance is provided by Group SD leading the development of strategy, commitments and objectives, which are endorsed by the Group Technical Director in consultation with the SD Leadership Panel and submitted for formal approval to the Executive Committee and the DLC SD Committee. Operations management has a responsibility to ensure that adequate resources (human, technical and financial) are made available and deployed to ensure the commitments, targets and objectives are met. Operations management has a responsibility to monitor progress towards meeting the commitment, targets and objectives and report progress to management, employees and stakeholders as appropriate. Operations Managers are responsible for capturing and verifying data, which shall be approved by the business units CEOs. Data shall be consolidated at divisional level and shall be reported at Group-level by the Group Technical Director. All managers shall be responsible for collating data at each level of the company and internally reporting performance against KPIs. Operations Managers are responsible for ensuring that operational improvement plans are prepared within a framework of management review and SD objectives. Business unit and divisional Chief Executives are responsible for ensuring that summarised plans with cost implications and priorities are included in the annual budget review. Operations Managers are responsible for ensuring that employees are aware of how their activities affect performance against KPIs, that KPI awareness is included in inductions and refresher training as appropriate and for communicating KPI performance and review to relevant employees and contractors. 12 SD Standards

Management Standard 6 Training, Behaviour, Awareness, Competence and Empowerment All employees, contractors and visitors are aware of relevant SD requirements, hazards, risks and controls, and are competent to conduct their activities and to behave in a responsible manner. This Management Standard shall be applied to Mondi. All operations shall have formal systems in place to ensure that all personnel, including contractors and visitors are aware of the SD requirements and competent to perform their activities when engaged at Mondi managed operations or where they are acting on behalf of Mondi operations. As part of the broader competencies required for employees and contractors, SD competencies shall be identified, documented and periodically reviewed. All operations shall ensure that regular training and coaching is designed and delivered to ensure an understanding of the importance of employees and contractors in identification, assessment and control of SD risks in their workplace or areas of responsibility and the benefits of conforming to Mondi requirements and these Standards. Training shall also ensure an understanding of the consequences of not conforming. Training records for employees, contractors and visitors shall be documented, readily accessible and maintained in a suitable medium. All operations shall ensure that all pertinent organisational roles, positions and job functions have the required SD competencies formally defined in terms of appropriate education, training and experience. Recruitment/commissioning criteria for employees and contractors shall include an assessment of SD awareness, competencies, behaviours and performance, and shall encourage diversity. Inductions that address relevant SD objectives, risks, controls, and behaviours shall be conducted and documented for all employees, contractors and visitors at the commencement of their employment, contract or visit. A behavioural observation and auditing process that engages all personnel and covers all activities shall be in place to reinforce desired SD behaviours and correct at-risk behaviours. Data from interactive behavioural auditing processes shall be analysed and used to identify, plan, implement and track initiatives and appropriate corrective actions. All operations shall ensure that training programmes take into consideration the cultural and educational diversity of the workforce, varying levels of responsibility, ability, and workplace risk. Where appropriate the programmes shall be adapted to account for these considerations and reviewed for effectiveness. Training shall be delivered in an effective and appropriate medium. Training shall take into consideration all changes to the operations and personnel that may impact upon SD requirements, hazards, risks and controls. Specifically, issues such as return from absence, changing roles and changes in operations shall be addressed. 13 SD Standards

Lessons from review of performance and accidents and incidents shall be communicated as learning tools. All operations shall ensure that management are specifically trained and apply effective leadership techniques (visible felt leadership) that reinforce desired behaviours and correct at risk behaviours in the workplace. Processes shall be in place to ensure the effective review of competencies and training programmes to ensure that they remain relevant and appropriate to the nature and extent of the associated risks. 3. Responsibilities Operations Managers shall be accountable for developing and implementing formal training, awareness and competence programmes, which are applicable to all relevant levels and functions within their operations. Line Managers shall be accountable for ensuring that systems and procedures are in place to ensure that, prior to any work or project commencing, relevant personnel are competent to assess the SD issues and to perform their activities. Line Managers shall be accountable for the development, implementation and monitoring of the effectiveness of this training. 14 SD Standards

Management Standard 7 Operational and Document Control All operations under Mondi s control shall apply appropriate control measures for the effective management of hazards and risks arising from processes and activities. All relevant SD information shall be identifiable, readily available and understandable to the user as required and, where appropriate, controlled. All operations shall establish, implement and maintain systems and procedures for those processes and activities that require control measures to be applied, based upon the results of risk assessments. The operational controls shall be consistent with the nature and extent of the risks associated with the operations. Group SD shall issue SD Operating Standards defining the overarching expectations of Mondi in each of the Sector Policies, and Performance Requirements defining the mandatory minimum requirements for management and control of risks at the operations level. The systems and procedures at the operations shall be documented to control situations where their absence could lead to deviation from the SD Policy, these Management Standards and other Mondi requirements. Systems, procedures and work practices shall be reviewed regularly to ensure that they continue to be applicable, relevant and effective in controlling the risks for which they were developed or intended. Where non-conformances are identified, immediate preventative and remedial action shall be taken. Formal control measures shall be established, implemented and maintained by relevant competent personnel and approved by senior management. Group Operating Standards, Performance Requirements, operational management systems, procedures and work practices shall be formally reviewed on a periodic basis and/or following an event or incident to ensure that they continue to be applicable, relevant and effective in controlling the risks for which they were developed or intended. The results of these reviews shall be used for continual improvement and discussed with all appropriate personnel. Relevant control measures, including procedures and other documented requirements, shall be clearly communicated to all relevant personnel, including suppliers and contractors. All operations shall ensure appropriate systems are in place for the effective training (training for understanding) of all relevant personnel in the appropriate operational controls and requirements. Processes shall be in place to ensure the effective periodic review of the operational control systems, measures and processes to ensure that they remain relevant and appropriate to the nature and extent of the associated risks. This shall include a system for task observations. The core elements of the SD Management System and their interaction, including indexes or maps that provide direction to related documents, shall be described and maintained. Documents forming the SD Management System shall be approved by senior management prior to issue. 15 SD Standards

Documents from external sources necessary for the planning and operation of the SD Management System shall be approved for use, registered and current. All documentation shall be formally reviewed by authorised personnel at appropriate intervals and amended as appropriate, to ensure that they remain relevant and appropriate to the nature of the business. The current approved versions of all documentation within the SD Management System shall be the electronic copy held on the divisional intranets and on the Reporting and Information system (MORIS). All documents shall be readily identified with the current version number and approval date. Documents and records shall be identified, securely stored, protected, readily located and retrievable, have established retention times based on legal requirements and/or knowledge preservation, and responsible custodians assigned. Obsolete documents and data shall be promptly removed or otherwise archived and protected from unintended use. All confidential records, including medical, personnel, legal and other, are controlled and maintained securely. All operations shall maintain records adequate to demonstrate conformance to the Group SD Standards and SD Performance Requirements. 16 SD Standards

Management Standard 8 Communication, Consultation and Involvement All operations shall have systems in place that enable transparent, effective and appropriate two-way communication and consultation with both internal and external stakeholders regarding company activities. Stakeholders are encouraged to participate in and contribute to Mondi s SD initiatives and performance. This Management Standard shall be applied to Mondi. Operations shall provide the opportunity for regular dialogue and engagement on issues of interest and concern to internal and external stakeholders. Communication and consultation shall be undertaken in a manner which is culturally appropriate, and takes consideration of the diversity of the audience. A readily accessible grievance mechanism shall be in place to allow internal and external stakeholders to raise grievances and concerns and for these to be addressed by Mondi. All grievances and concerns raised are to be recorded, acknowledged and investigated. The outcome of investigations shall be reported back to the parties concerned. Where government matters affect our employees, shareholders, customers or the communities associated with our operations, we shall make our positions known to governments. Operations shall refrain from improper involvement in political activities. Operations shall ensure the timely provision of relevant and appropriate information to internal and external stakeholders about the operation s activities and performance. The accuracy of data reported shall be verified. Operations must engage with suppliers and contractors, to raise their awareness of Mondi s policies, these standards and the company s expectations of their performance in this regard. Business partners, including suppliers and contractors, shall be encouraged to apply principles of corporate conduct. Reasonable information and access shall be provided to stakeholders seeking to verify conformance with standards and principles to which Mondi is committed. The effectiveness of communication and consultation shall be regularly reviewed. Where appropriate this shall be carried out in collaboration with stakeholders. 2.1 Internal Stakeholders Processes are in place to enable the flow of information within Mondi including the sharing of lessons learned, good practices and opportunities for improvement of Mondi s SD Management System. Employees and contractors shall receive relevant information about the SD Management System and associated safety, environmental, health and community matters. Where appropriate, stakeholders shall be consulted on the system s effectiveness and given an opportunity to participate in its continuous improvement. 2.2 External Stakeholders Informed consultation with external stakeholders about Mondi activities shall be supported through the timely provision of relevant and appropriate information, including annual reports on SD performance, initiatives, risks and opportunities. All external communications shall be formally approved prior to release. 17 SD Standards

Where appropriate, external stakeholders shall receive relevant information about the SD Management System and associated safety, environmental, health and community matters. Where appropriate, external stakeholders shall be consulted on the system s effectiveness and given an opportunity to participate in its continuous improvement. 3. Responsibilities The Group Technical Director shall establish clear lines of responsibility for the management and execution of internal and external communication and engagement. The Group Technical Director, Group SD and the Group Communications are responsible for the development, maintenance and review of appropriate communication and consultation systems and processes in relation to Group-wide stakeholders. Operations Managers are responsible for the development, maintenance and review of appropriate internal communication and consultation systems and processes in relation to their operation and their local stakeholders. 18 SD Standards

Management Standard 9 Auditing Sustainable Development performance and management systems shall be monitored audited and reviewed to identify trends, measure progress, assess compliance and establish applicability and relevance. This Management Standard shall be applied to Mondi. 2.1 Group Audits Mondi shall develop an Audit Programme for operations to assess compliance with Mondi SD Policies and Standards. The Audit Programme shall be defined: In terms of scope, frequency, methodologies, competencies, roles and responsibilities and the requirements for conducting audits and reporting results. Based upon the results of the business unit and operations risk assessment, the results of previous audits and be appropriate to the nature and scale of the associated SD risks and must be undertaken in an impartial and objective way. The Audit Programme shall comprise the following categories of audit: Compliance audits including against legal and Mondi requirements. Management systems audits, including the SD Management System and certification audits, e.g. ISO 14001, ISO 22000, OHSAS 18001, FSC or PEFC. Issue audits specific to the risks and nature of operations including contractors and 3 rd -party audits. Critical task-based audits including interactive behavioural audits. External assurance over the annual Sustainability Report. The Audit Programme shall include: A mixture of internal, peer review and independent audits. Centralised tracking of audit results and completion status of corrective actions. Routine status reviews and reporting. Analysis of audit findings and identification of SD gaps and opportunities. An audit matrix will define the frequency of each category of audit for each type of site and define whether the audit is internal, a peer review or independent. The conclusions and findings from SD audits shall be analysed and utilized in the process of continual improvement. This review shall be documented and as a minimum address the possible need for changes to policy, objectives and other elements of the SD Management System. 2.2 Operational Audits All operations shall establish and maintain programmes to monitor and measure SD performance of their operation on a periodic basis. 19 SD Standards

All operations shall implement a formal audit programme that ensures the effective monitoring of conformance to the Mondi Policies and these Standards. Operations Management shall be actively engaged in appropriate audits, ensuring effective visible leadership, mentoring and coaching are demonstrated. Systems shall be place to identify report, respond to and manage non-conformities and improvement opportunities. Non-conformities shall be investigated and corrective and preventative actions implemented and their effectiveness reviewed to prevent recurrence. 3. Responsibilities Group SD has accountability for ensuring that the Audit Programme is developed and implemented. Group SD shall periodically review the Audit Programme to ensure their continuing implementation and effectiveness and to ensure that it remains appropriate to risk profile of the company. Operations Managers have a responsibility to ensure that audits are effectively implemented and resources are available to address non- conformities. 20 SD Standards

Management Standard 10 Management Review SD performance and systems are required to be reviewed to identify trends, measure progress, assess conformance, ensure applicability and relevance and drive continual improvement. This Management Standard shall be applied to Mondi. Executive management shall periodically review the SD Management System to ensure its continuing implementation and effectiveness and to ensure that it remains relevant to the operations. The review shall be documented and, as a minimum, address the possible need for changes to policy, standards, objectives and other elements of the SD Management System. The findings from the Audit Programme and SD key performance indicators shall be analysed and utilised in the process of continual improvement. All reviews must be documented, including observations, conclusions, recommendations, and follow up. The SD Management System shall be reviewed at least bi-annually and revised as required. 3. Responsibilities Group SD is responsible for undertaking the management review. 21 SD Standards

Operating Standard 11 Sustainable Forestry All natural forests and plantations over which Mondi has control shall actively identify, implement, monitor and evaluate sustainable forestry management practices to ensure that operations are environmentally responsible, socially beneficial and economically viable. Where Mondi purchases forest products, Mondi shall implement transparent and risk-based purchasing strategies to ensure legality and credibility of product. Forestry operations shall: Ensure that all applicable laws of the countries in which Mondi operates, and all relevant international treaties and agreements to which the countries are a signatory are understood and adhered to. Clearly document all land ownership, tenure and land use rights and responsibilities and ensure that these are legally established and clearly defined. Ensure that the cultural values and rights of indigenous people and local communities are respected. Ensure that the operation will support the efficient use of forestry resources, the long term ecological function and integrity and the social and economic welfare of forest workers and local communities. Ensure that High Conservation Value areas are identified and preserved or enhanced and biological diversity and its associated values are identified, evaluated and conserved. Ensure that forestry operations in plantations and natural forests are based on sound Site-specific principles that optimise sustainable forest productivity. Require that a forestry management plan appropriate to the scale, intensity and nature of the resources is drafted, implemented, evaluated and kept current. Where operations may have a significant impact on ecosystems and biodiversity ensure that a plan for ecosystems and biodiversity is developed, implemented and reviewed within the Management Plan. Ensure that appropriate monitoring and assessment is undertaken to assess the forest condition, forest product yield, Chain-of-Custody, management activities and the resulting social and environmental impacts. Ensure the transparent and systematic tracking of all virgin wood-based materials so that the origins and legality are traceable and can be independently verified. Ensure that forestry issues, ecosystems and biodiversity, wood product procurement, are included in consultations and communications with stakeholders. Ensure that operations maintain sustainable forestry certification or have a plan in place to achieve credible sustainable forestry certification. Mondi has adopted the Forest Stewardship Council s (FSC) controlled wood standard. For timber, pulp and biomass procured from third parties, Mondi shall ensure that suppliers meet the responsible wood requirements, and are encouraged to achieve FSC or a credible alternative. Duly promote and support forest and ecosystems research including research on the potential socioenvironmental effects of our products and processes. Ensure that no hazardous materials are used which are prohibited by the FSC. Understand and promote the sustainable use of all forest products and ecosystem services. 22 SD Standards

Operating Standard 12 Environmental Impact All operations under Mondi s control shall ensure that environmental impacts are identified, managed and, where necessary, mitigated. All operations shall have in place: A certified environmental management system when the environmental impact is significant. The criterion for significance is determined using the one-percent rule. A waste management plan that includes the identification and characterisation of all waste streams and the identification and use of appropriate reuse, recycling and disposal routes as well as minimisation opportunities. Systems of work to ensure that emissions to water, land and air emanating from Mondi activities are identified, characterised, treated and monitored and, if significant, are mitigated. Characterisation, safe storage and handling of hazardous materials. Environmental Impact Assessments (EIAs) for all new operations and for significant changes to current operations that are in line with local regulations and international good practice. For all significant projects, Environmental and Social Impact Assessments in line with the Equator Principles are required. Impact assessments to identify, characterise and address community health and community nuisance issues. Internal and external reporting of impacts to the environment. There shall be systems to prevent pollution of land and groundwater arising from operations activities including landfills. Each operation shall identify, assess and review at regular intervals their potential hazards and risks, and the need for protective or remedial measures. Operations shall maintain a dossier with the history of activities, register unplanned losses of material and record the protective or remedial actions undertaken. 23 SD Standards

Operating Standard 13 Cleaner Production All operations over which Mondi has control shall ensure the continuous application of an integrated preventative environmental strategy to processes and products in order to increase overall efficiency and reduce or eliminate the use and production of hazardous materials, emissions and wastes. Operations shall identify and implement integrated environmental technology including Best Available Techniques (BAT) in order to reduce consumption of raw materials and emissions with environmental impacts. There shall be systems for the evaluation, implementation, monitoring and periodic review of: Source Reduction Initiatives in order to reduce the use of raw materials, including changes or modifications to processes, process efficiency optimisation and raw materials used, improvements to process controls and changes in raw materials. Recycling Initiatives, including on site recovery and reuse of materials and creation of useful byproducts. Operations shall undertake assessment and audit of: Hazardous materials used to determine the use of materials with the potential to cause environmental harm. Materials balance to identify the origin, composition and quantity of wastes and emissions and their potential for reduction. Energy audits, to assess the use of energy and associate efficiencies and costs. Significant operations shall undertake these assessments through cooperation with UNEP or other partners and stakeholders on an annual basis; all other operations shall determine a schedule appropriate to the nature of their activities. All new projects shall implement Best Available Techniques (BAT). Existing operations shall evaluate the implementation of BAT and determine a timescale for implementation. Significant operations shall undertake these assessments through cooperation with UNEP or other partners and stakeholders on an annual basis; all other operations shall determine a schedule appropriate to the nature of their activities. All new projects shall implement Best Available Techniques (BAT). Existing operations shall evaluate the implementation of BAT and determine a timescale for implementation. All operations with significant environmental impact shall have in place certified environmental management systems. Dialogue and communication with stakeholders on the implementation of preventive strategies shall take place. 24 SD Standards

Operating Standard 14 Climate Change All operations over which Mondi has control shall evaluate their contribution to climate change through understanding the carbon balance relating to their operation. Mondi shall evaluate physical, regulatory and financial risks and opportunities arising from operations, products and competitive positioning in relation to climate change, and evaluate the risks and opportunities of an internal carbon trading system. Operations shall have in place procedures to identify the energy balance of their activity and identify, evaluate and where practicable implement energy efficiency projects and upgrades. These shall include, but not be limited to: Efficiency of existing equipment. Opportunities for use or increased use of combined heat and power. Opportunities for increasing use of carbon-neutral biomass or other renewable based fuels. Opportunities for increase in forest productivity. Operations shall develop and maintain an annual estimate of their carbon balance using accepted carbon accounting methodologies such as the WRI/WBCSD GHG Protocol. The carbon balance shall have defined boundaries and include all activities over which Mondi has operational control. Operations shall identify, evaluate, and where feasible implement projects that will deliver carbon credits under the EU Emissions Trading Scheme (EU ETS) and the flexible mechanisms of the Kyoto Protocol or other internationally accepted market based mechanisms. Operations that have implemented successful carbon reduction projects shall proactively share knowledge and experience with other Mondi operations. Reductions (or increases) in carbon emissions shall be reported as absolute and intensity (per unit product) figures. All new projects shall include a review of energy use and carbon reduction opportunities. 25 SD Standards

Operating Standard 15 Product Management Mondi shall ensure that the life cycle environmental, social, safety and health impacts from products are identified, minimised and managed in an ethical and responsible manner. Mondi shall ensure that the environmental, social, safety and health implications of existing and new products or product groups are assessed for their potential risk to provide benefits over their life-cycle. Hazards and potential impacts shall be assessed and minimised to reach leading industry practice. Mondi must ensure that all product-related aspects, including distribution, storage, sale, use, reasonably foreseeable misuse, reuse, recycling and disposal are managed responsibly. Mondi must ensure that while enhancing the social, environmental and economical performance of a product, the growth, manufacturing, transportation and sales processes reflect the principles of quality management. All relevant product information and advice to all those who handle, use, recycle or dispose of Mondi products shall be provided and a dialogue encouraged. Requirements for the purchase of raw materials, products, services, toll conversion and equipment shall be specified, monitored and met. Relevant information from suppliers concerning the effects of their products and activities on the safety and health of people and the environment shall be sought and potential risks to Mondi shall be managed. A complete and current inventory shall be available of all materials used, produced or sold, including intermediates and wastes. Their hazards shall be identified and assessed. Appropriate information shall be maintained to enable the safe handling, storage, transportation, use and disposal of all materials. Natural resources shall be conserved by efficient energy use, by minimising their consumption throughout the product life-cycle and by preventing wastes. All operations shall ensure the recyclability of their products where possible and promote reuse and recycling of its materials having regard for safety, health, environmental, social and economic factors. Mondi shall contribute to the goals for recovery of consumed paper and board materials in the countries where it has significant operations. Opportunities shall be sought to conduct research or support research and innovation that promote the use of products and technologies that are safe and efficient in their use of energy, natural resources and other materials. Mondi shall have systems in place that identify, evaluate and respond to SD-related external influences that could impact on Mondi products and business activities. This includes customer needs, expectations and inquiries, regulations, voluntary standards and competitor initiatives. Fulfilment of environmental criteria for selected products shall be required. 26 SD Standards

Food safety shall be assured by deploying good manufacturing practice standards for hygiene management and product traceability including certification to a recognised management standard. 27 SD Standards

Operating Standard 16 Community Engagement and Development All operations under Mondi s control shall seek opportunities for contributing to sustainable community development. Mondi shall have systems in place to work with local communities to identify needs and aspirations. The completion of the Socio-Economic Assessment Toolbox (SEAT) process shall be facilitated for all large operations every three years, to identify and manage their social and economic impacts to make any necessary improvements in the operation s overall social performance. Community Engagement Plans (CEP) shall be developed for all material operations for a three-year period and reviewed annually. Mondi shall prioritise support for sustainable community development by enabling effective Corporate Social Investment that follows the requirements provided in the Community Engagement Plan. Neighbouring residents shall be consulted regarding the relevant aspects of emergency preparedness and response plans, to ensure that they are confident that the plans will provide them with sufficient protection, and are informed of the necessary course of action to take in the event of an emergency. Where plant and equipment is installed as part of community development programmes, the provision of appropriate technology, training in its use and maintenance shall be considered. Training needs of local communities that facilitate employment or enhance skills shall be considered. 28 SD Standards

Operating Standard 17 Human Rights and Working Conditions All operations under Mondi s control shall be conducted in an ethical manner that respects the fundamental human rights. Employee and contractor working conditions shall be compliant with national legislation and, where this is deemed to be insufficient, with the relevant International Labour Organisation (ILO) Standards. Mondi will provide appropriate arrangements for the protection of workplace rights and employees interests. Operations shall comply with the labour legislation of the countries in which they operate. Systems shall be in place to ensure that the Articles of the United Nations Universal Declaration of Human Rights are assessed, prioritised and implemented as they apply to Mondi s sphere of influence. Operations, contractors and business partners shall be expected and suppliers shall be increasingly required to meet this SD Operating Standard. Operations shall ensure that remuneration practices are compliant with national legislation and provide equal pay for equal work. All employees shall have the right to join a trade union and to bargain collectively. Where this is restricted under law, operations shall have procedures in place to facilitate parallel means of independent and free employee representation. Operations shall ensure that employee working hours are in compliance with national legislation and have systems in place to verify that no persons under the age of 15 or the local minimum employment or mandatory schooling age (whichever is higher) are employed. The hours worked during a normal week shall not exceed forty-eight hours on a regular basis. Employees must receive a weekly rest period of twenty-four consecutive hours for every seven days worked (although exceptions can be made in accordance with national legislation), and an annual paid holiday of three working weeks. Employees may be required to work mandatory overtime to meet a short-term business demand in situations where there is a collective bargaining agreement which has been freely negotiated with worker organisations (as defined by the ILO) and which represents a significant proportion of its workforce. No inhumane treatment of employees shall be accepted, including any form of forced labour, physical punishment or other abuse. A complaints system shall be in place to allow employees and personnel external to the operations to make complaints regarding any perceived infringement of their rights. It shall be designed to ensure that complaints are impartially and fairly addressed. Employees and contractors are encouraged to raise any genuine concern about suspected misconduct or malpractice, including bribery and extortion. Operations shall work against corruption and illegal practices in all their forms and shall have whistle-blowing systems in place, which ensure that no form of retribution, harassment or discrimination takes place as a result of a raised concern. 29 SD Standards

Equitable processes for recruitment, promotion and remuneration shall be in place, which ensure employment and promotion on the basis of job requirements and merit, and which support the establishment of a diverse workforce and ensure that all employees and employment applicants are treated equally irrespective of race, colour, sex, sexual orientation, religion or belief, family circumstances, political opinion, trade union membership, age, nationality or disability. Where security personnel are required, systems shall be in place to ensure that they are familiar with and operate in accordance with the US-UK Voluntary Principles on Security and Human Rights. Security personnel shall be screened for criminal records or human rights abuses. They shall be given clear instructions on the use of force. Part-time employees shall receive the same protection, basic wage and employment conditions equivalent to those accorded to comparable full-time workers. Operations shall ensure that contracting arrangements and false apprenticeship schemes are not undertaken in an effort to avoid fulfilling obligations under applicable laws relating to labour and social security legislation and regulations. Operations shall have systems in place to mitigate adverse social and economic impacts arising from land access and acquisition. Wherever possible, involuntary resettlement of people to gain access to land required for company activity shall be avoided. However, where this is unavoidable, appropriate measures to mitigate adverse impacts on economically or physically displaced people and host communities will be implemented, in accordance with the relevant international standards. Where issues are identified, community health and nuisance impacts from Mondi activities shall be communicated, investigated and mitigated. There shall be no discrimination against workers on the basis of real or perceived HIV/Aids status. HIV/AIDS screening is not permitted for job applicants. People working for Mondi are encouraged to undertake confidential screening, to assist in the provision of company support to HIV positive persons. 30 SD Standards

Operating Standard 18 Employee and Contractor Safety, Occupational Health and Security All operations under Mondi s control shall complete all tasks in accordance with well-established standards and operating procedures and consistently with the principles of Zero Harm irrespective of whether employees or contractors complete the tasks. We shall aspire to Just No Harm as the safety of our people working for us, our host communities and the environment is a value which shall not be compromised. Risks to employees from all hazards and security threats shall be identified, assessed and reduced in accordance with leading industry practice. Appropriate risk control and monitoring programmes shall be put in place. Systems of work shall be implemented and maintained to ensure the safety, health and security of employees and contractors, both in the workplace and while travelling on company business. Leaders at all levels shall be safety role models. All people working for Mondi shall have effective skills to lead and work safely, be aware of all hazards and risks in their workplace and act accordingly ensuring compliance with standards and procedures. At risk behaviours shall not be acceptable and shall be immediately addressed when observed. Stakeholders shall be consulted and required to participate in the development of systems of work. A health assessment programme shall be established and maintained. Health promotion programmes shall be implemented. Programmes shall address HIV/Aids in the workplace including a comprehensive prevention strategy, linked to programmes of care for those with HIV/Aids. The SD implications of all aspects of work carried out by contractors on behalf of Mondi shall be considered. Mondi operations shall have a well-documented and fully functional Contractor Management System that ensures that all contractors perform to the same high safety standards as required by employees. Such system must be based on the six steps of Contractor Safety Management. Contractors shall be required to provide sufficient information and to operate in a manner which ensures that the safety and health of their employees, and of others, is not put at risk nor Mondi security and environmental standards compromised. Contractors shall be supplied with sufficient information to ensure that the safety and health of their employees is not at risk from Mondi activities. The purchase, hire, lease of equipment and materials and activities with partners shall be subject to a riskbased SD evaluation prior to contractual arrangements being entered into, taking into account the nature of their products, activities or services and previous performance. Specifications of equipment or materials that 31 SD Standards

have potential SD impacts shall be reviewed to verify fitness for the intended use to prevent the introduction of significant SD risks. All locations shall be maintained and equipped to ensure the appropriate security of information and assets. Facilities and systems shall be reviewed periodically to take account of the current and perceived future security threats and associated risks. 32 SD Standards

Operating Standard 19 Process and Equipment Safety All operations under Mondi s control shall be designed, built, equipped, maintained and managed to ensure continued safe and secure operation, the health of people, the effective protection of assets and to prevent adverse environmental impact. SHE implications shall be taken into account in the development of new processes. A systematic process of choosing the appropriate control methods to manage risks must be in place and based upon the hierarchy of risk controls. The basis for control of risk for new and existing facilities shall be documented. There shall be systems for the management of projects and the design of all new facilities, plants, equipment and processes. Relevant studies shall be carried out to identify hazards and security threats and to assess risks to people, assets and the environment. Identified hazards shall be eliminated or the consequent risks reduced in accordance with leading industry practice. Facility design, construction and maintenance activities shall use sound engineering practices consistent with national, international or recognised codes and standards whichever are the more stringent. During design and prior to start-up, all new workplaces, processes, installations, expansions, modifications and machinery shall be reviewed and the appropriate controls put in place to manage the safety risks. These shall be approved by competent personnel and signed off by the senior manager. The best available, industry recognised practice shall be used in the construction of new plants. For existing plants, there shall be periodic reviews of hazards to identify opportunities for their elimination or the reduction of associated risks and to check the adequacy of risk control measures to ensure asset integrity. Design and key operational limits shall be documented, measured, analysed, monitored and understood by the relevant personnel on all high-risk equipment and these shall be reviewed throughout their life-cycle. 33 SD Standards

Operating Standard 20 Emergency Preparedness and Plans All operations under Mondi s control shall identify the nature and scale of all reasonably foreseeable on-site and off-site emergencies. Effective formal systems shall be established to deal with these emergencies, appropriate to the hazards and risks involved. The arrangements shall adequately include local, national and business crisis management plans which shall be communicated, regularly rehearsed and reviewed. Wherever appropriate, they shall be made in association with the public emergency services, other relevant organisations and appropriate voluntary co-operative schemes. Systems shall be in place to identify potential emergency situations and their impacts including those associated with neighbouring activities. Plans and procedures shall be established and maintained of foreseeable emergency situations and their impacts. They shall be documented, communicated and regularly reviewed. Relevant roles and responsibilities shall be defined for employees and contractors alike. Emergency response plans and procedures shall be aligned with the Mondi Crisis Communication Plan, the Business Continuity requirements and the external response organisations that shall form part of the overall Emergency Plan at all operations. They shall be reviewed after the occurrence of incidents or emergency situations. The learning shall be documented and incorporated into revisions of plans and resources. The appropriate number of competent resources shall be available to respond effectively to an emergency situation at an operation taking into account the external response capabilities. Such resources shall be fit for emergency response and ongoing recovery. Employees, contractors and visitors shall be trained in and understand the emergency response plans, their roles and responsibilities, and the use of the emergency response resources. Emergency response drills must be conducted to determine the effectiveness of the emergency plan and are conducted on a scheduled basis. Where appropriate, these shall include liaison with and involvement of external response organisations. Potential off-site emergencies (transport of personnel or personnel performing work away from a fixed site) shall be identified and appropriate emergency procedures developed. 34 SD Standards