R E G I S T R AT I O N D O C U M E N T

2018

Wendeland Stahl:building a world leader in responsible chemistry
for leather and performance coatings

Wendel in brief
More than	Wendel is one of Europe’s leading listed

investment firms.
	Invests in leaders in their field, such as Stahl,

Bureau Veritas and Saint-Gobain.
	Plans for the long-term growth and knows that acompany’s longevity depends on the balance between its
business model, its markets, the well-being of its people,
and its place in the environment.
 Listed on Eurolist by Euronext Paris.
 More than 310 years of history.

Management€ 9 bnin gross assets

More than

6

office locations

More than7

main investments

Employeesc. 100100%€ 8,389 menvironmental management system

More thanof companies have set up an(in particular through ISO 14001 certificationof all or part of their business scope).

Health and Safety100%

of companies have a dedicated policy

Consolidated sales€ 5 bnof capitalization

Total return (with dividends reinvested)

11,3%

p.a. since 2002

on employee health and safety, and hold training sessions.

Energy transition80%

of companies have implemented measures
to increase the share of renewable energy
in their energy consumption.

“Wendel is an invaluable
partner in our efforts to
expand our market share.”Huub van Beijeren
CEO of Stahl

Read more about StahlIf it can be imagined,
it can be createdThis document contains the informationof the Stahl chapter (page 213 tm 232) ofthe Wendel Registration document 2018,
published by the Wendel GroupWENDEL - Registration Document 2018

HUMANC A P I TA L

1,997

100

EMPLOYEES

76 %
Men

1,160

PEOPLE
working on innovations
every day

24 %
Women

EMPLOYEES
who completed e-learning courses
on responsible preactices

61 nationalities in

24

COUNTRIES

49 %

16 %
India
Pakistan2018 SALES REVENUEPRODUCTS€ 867m• Leather Chemicals

780

20 %
Asia-Paciﬁc

EMEA

15 %
Americas35

TECHNICAL EXPERTS

MARKETS

DISTRIBUTION• Performance
Coatings& Polymers

600

TRAINEES
who completed Stahl
Campus modules

Others• Architectural & Interior
Design,Main sectors• Automotive

sales
ofﬁces• Footwear,
Apparel& Accessories• Home furnishing,• Industrial Applications• Leisure & Lifestyle.

MISSION“If itcan beimagined,
it can becreated.”

R&D

11
100

INDUSTRYI N I T I AT I V E S
FOR AS U S TA I N A B L E
SECTOR

GlobalSuppliers
from 4 2

centers

COUNTRIES

research
Chemists

Zero Discharge ofHazardous Chemicals
Foundation (ZDHC)PEOPLE& SOCIETY

Focus is on technology
and processes that reduce
environmental footprint

Global Automotive
Declarable
Substances List
(GADSL)RAW
M AT E R I A L S

bluesign®, ChemIQ,
OekotexVALUESTransparency as the promoterof Sustainability and Social
Responsibility.

I N N O VAT I V E
SOLUTIONSThe Stahl
Sustainability
Standard

NGOS, ACADEMICC O O P E R AT I O N

Leather Working
Group

RESPONSIBLEO P E R AT I O N S• UN Global Compact

PRODUCTION• UNIDO, Solidaridad• Global Universities

OUTSOURCED
PRODUCTIONE N V I R O N M E N TA L CA P I TA L

0

COAL
used in Stahlmanufacturing sites
in 2018

13
38
9

TRUSTEDPA R T N E R S H I P S

100 %green energy
at all European
factories

50% of leather
chemicals sales

CO2 EMISSIONS
GOAL:

-10 %
by 2020

Status 2018 : ON TARGET+ 85 %
of our coating
solutions are water
based

manufacturing
sites
Application
Labs
Centresof Excellence~ 90 %of global production
volume comes from
ISO14001/9001
certiﬁed sites.

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Stahl governance
The Stahl Board, its highest governance body, consists of members
from its shareholders Wendel, Clariant, BASF and Stahl. The Stahl
Management team consists of the CEO, CFO, and director of
Procurement, director of Innovation, director of Marketing,Communications & Sustainability and two Business Unit directors.
This team meets monthly and determines the implementation ofcompany strategy. A wider executive team, our Executive Control
Group,
which
includesregional
generalmanagers,
communications, sustainability, IT, safety & health functions, meetson a quarterly basis. This team reviews performance and decides
on tactics for the coming cycles.

Manufacturing, suppliers, customers
Stahl produces its portfolio of products at its 13 manufacturing sitesaround the world or at outsourced locations via service
agreements.
Stahl’s suppliers
companies.

aremostlylarge

multinational

chemicalStahl’s customers are leather manufacturers (known as tanneries)
and manufacturers of textiles and synthetic materials (known as
converters or mills). These companies can range from large
corporations to medium and small sized operations. Smaller
customers are typically handled by Stahl’s significant network of
distributors around the world.

Risk from external trends
Lifestyle choices
Stahl respects consumer lifestyle choices with respect to veganism,
leather, plastics and other materials used in the various market
segments and it does not take a position on one or the other. Whileit actively supports and is part of industry initiatives to improve theenvironmental footprint of leather, synthetics and textile
manufacturing, Stahl is also involved in the development ofalternatives materials, like those made from pineapple leaves, fruit
waste, mushrooms and laboratory-grown leather for example. Stahl
respects the choices of brands, such as Tesla, in the automotive
industry or Stella McCartney, in the luxury ready-to-wear sector
about not using leather, and has adopted a perfectly transparent
attitude on the alternatives to leather and their benefits anddrawbacks. Stahl’s Instagram account is a forum for discussion with
consumers and designers that ensures respect of opinion andsharing of knowledge rather than taking a position. Indeed, themovement towards alternative materials is seen as an opportunity
by Stahl, who believes it is better positioned than its competitors toadapt to such macro lifestyle trends. At the same time Stahl also isconvinced that leather will continue to be a material of choice for
consumers in the future, given its long term sustainable features.
Environmental impact
Most of Stahl’s research and applications development is designed
to reduce the environmental impact of its products, or those of its
customers. This is in-line with Stahl’s corporate goal of reducing the

214 WENDEL - Registration Document 2018environmental footprint of the whole supply chain. For example,
25% of Stahl’s basic research projects are linked to the eliminationof restricted substances (i.e: as per ZDHC, Bluesign®, ChemIQ,
Reach, etc., guidelines) and new raw materials to replace them.
With regard to natural products, there are currently 20+ projects in
R & D specifically focused on finding natural resource alternatives
to petroleum based polymers for polyurethanes, a core technology
for Stahl. In other chemistries Stahl is constantly looking foralternatives that are based on renewable resources. With regard towater, a majority of its research time is spent on developing water
based products (already a large portion of its portfolio) or on
products which reduce water pollution originating from thefactories of Stahl’s customers. For the Performance Coatingsbusiness, the recent market switch from solvent to water is a key
driver in product development.
Stahl has also invested in Life Cycle Assessment (LCA)
methodology to quantitatively measure the impact of its productson the environment, and to express it in language that the
stakeholders can recognize (e.g., the impact of ozone depletion,
toxicity, climate change and land use).

Sustainability & Corporate Responsibility
Goals and Strategy
Stahl’s goal is to achieve a transparent supply chain that
continuously reduces its environmental footprint. The Company’s
strategy to achieve this goal is to organize initiatives that promotetransparency and to provide environmental solutions for the supply
chain, involving continuous collaboration with its partners. Stahl’s
influential position as a provider of products and services tomanufacturers of materials used in the automotive, apparel, homefurnishing, footwear, garment and other related industries, is adetermining factor in the implementation of this strategy. Stahl also
recognizes that sustainability represents a significant opportunity,
to gain competitive advantage and to drive operational excellence
that creates sustainable value.

Governance Sustainability and CSR
At the corporate level, Sustainability and Corporate Social
Responsibility (CSR) is part of Stahl’s executive management team,which meets quarterly and sets the Company strategy. The
Sustainability team meets regularly with product managers,
researchers, product stewardship and operations staff to monitor
the implementation of its strategy and to discuss progress on new
initiatives related to innovation, portfolio management andenvironmental performance. The Sustainability team also supportscommercial activities initiated by customers that are related tosustainability. A summary report is sent to the Stahl Board eachmonth. KPIs (key performance indicators) related to safety, healthand environment are also measured and reported monthly byregional operational staff at the Stahl manufacturing sites aroundthe world. These KPIs are then consolidated into a global report,
which is sent to the Stahl Board each month.

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Risk Mapping
In 2018 Stahl carried out a detailed review of its risk assessment
and control policies, in accordance with the new requirements of
the Non-Financial Statement (NFS), with regards to environmental,social, human rights and corruption risks resulting from its activities.
This review covered the risks linked to its employees, suppliers, andto the external supply chain that it serves. Stahl has adopted due
diligence policies covering health, safety, environment and humanrights that mitigate the risks identified in this review. The results
displayed in Stahl’s risk analysis were cross-checked with two typesof organizations, used as reference sources:■ independent standards: MSCI (Morgan Stanley Capital International)
and SASB (Sustainability Accounting Standards Board);

3

The risks identified with the highest gross risk level(1), as agreed inpreliminary work and audited at site and corporate level, are:■ occupational health and safety of employees;■ hazardous waste management;■ impact on water resources;■ GHG emissions contributing to climate change;■ attractiveness and talent retention;■ increase in demand and regulation for sustainable chemical
products;■ corruption.

■ companies comparable to Stahl in terms of sector of activity,
operating in several countries, and disclosing on their CSR risks andmateriality method.

(1) Gross risks are the risk for similar companies and activities (that impact both the company and the external stakeholders) in the same geographic area,
without taking into account the effects of mitigation processes. Stahl explains for each chapter how it manages and mitigates these risks. Note: Becauseof the nature its activities (leather chemicals, coatings and polymers), Stahl believes that some identified risks do not represent critical non-financial risk ;responsible, equitable and sustainable food.for Stahl and do not need to be developed further in this report. These less critical risks are: fight against
food insecurity; respect of animal welfare, responsible, fair and sustainable food production.
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Materiality matrix
Stahl reports on Sustainability and CSR topics in order to promotetransparency and display the progress made. To make sure that it
reports on the topics that matter, the Company uses a materiality
matrix. This tool gives insight into the challenges faced by theCompany and its stakeholders. In 2018, Stahl updated its
materiality matrix (as per the guidelines of GRI, the Global
Reporting Initiative) by reviewing the information provided in themateriality matrix of its important stakeholders. Internally, it
reviewed the input for Stahl, with a team of experts (communicationand sustainability), by checking the matrix we made in 2015. The
outcome of the matrix is in line with what we had already reported.

Additionally the outcome is in line with the risk assessment that was
performed in 2018 under the NFS.
How to read the matrix
CSR and sustainability cover different themes. To keep a very wideview, Stahl has plotted the 33 economic, environmental or social
aspects that are defined by GRI. Those that matter the most(highest impact), to both Stahl and our stakeholders, arecommunicated in the right top corner of the matrix. In the middle
section we show the aspects that score medium. ‘Other topics’ are
the ones that scored the lowest.

Economic
topicsEnvironmental
topicsSocialtopicsOther
topicsHigh

Occupational
health and safety

Efﬂuents
and waste

EnergyMaterials
Training andeducation

Customer healthand safety
Environmental
compliance

Diversity andequal opportunity

MediumImportance to stakeholders

Emissions
Water and
efﬂuents

Employment

Economic
performance

Local
communities
Socioeconomics
compliance
Anti-corruption

Low

Non-discrimination

Procurement
practices

Other
topicsMarketpresence
Low

MediumHigh

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HR - Committed to maximizing the employee
experience

3

Employment

reduction and Value Improvement project implemented in the
Leather organization with the aim to reduce the businesscomplexity grown significantly with major acquisitions completed in
the last years.

The total number of employees (headcount) at 2018 year-end was
1,997, which is a decrease of 76 employees compared to the endof 2017. The reduction is mainly connected to the complexity

The breakdown of FTE’s (full-time equivalent) as of December 31,
2018 and the change compared to the prior year-end per region is
as follows:

Region31-Dec-18

31-Dec-17

Change

EMEA

962.5

974.9

(12.4)

Asia-Pacific

387.0

406.0

(19.0)

India and Pakistan

317.0

349.0

(32.0)

North and South America

305.6

318.6

(13.0)

1,972.1

2,048.5(76.4)

86% of Stahl’s employees are on permanent contracts. Its
workforce is 76% male and 24% female.
Total Full Time Employees (FTE) leaving (dismissals, resignations
and other) during 2018 were 272 and 195 joined in the same
period. These ratios are reasonable and in line with the market for
the kind of activities and the location in which they take place. The
turnover rate in 2018 was 10.58% compared to 14.2% in 2017.

depend on the individual countries. They are also centrally
coordinated, to ensure Stahl remains competitive in the respective
markets. Some employees in the Company, mainly in management
and sales, enjoy a bonus scheme based on annual measurable
objectives. This bonus scheme is coordinated centrally to ensure
proper alignment and consistence with local practices.

Compensation

The turnover rate (only resignations) in 2018 was 5.05% compared
to 4.25% in 2017.

Total compensation excluding bonus, paid in respect of 2018 was€115 million, approximately 6.83% above 2017.

Working Organization

Training

Stahl operates through a complex international organization forhistorical reasons and also to effectively serve the customer base.
Stahl has 13 manufacturing sites, 11 R&D centers, 38 application
labs, 35 sales offices and 9 Centers of Excellence. Working
practices differ by region.

The nature of Stahl’s business requires a focused approach totraining. SHE (Safety, Health and Environment) training is thepriority. Every new employee receives updated SHE training andinstructions in line with their position. This is followed by more
specific job-related training to ensure the best use of theinformation, resources, products and capabilities at their disposal.
In the case of Stahl technicians, there is a strong emphasis on
training designed to provide practical and innovative technicalsolutions for customers.

he majority of the Stahl units have a 5 day working week, withexception of India and Pakistan where they also work on Saturday
mornings. Working hours and incidents are recorded, dependingon the site, by either electronic or manual systems.
All Stahl units report absenteeism (which includes absences for
sickness and work accident) as required by local legislation but
also in a way that can be reported at the corporate level.
The global absenteeism rate in 2018 was 1.70%, compared to
1.57% in 2017.

Labor relations
Given the international set up of Stahl and the relatively small
dimension of the local units, there are only two local company
collective bargaining agreements in place. These are negotiated at
local level with the direction and supervision from the
Headquarter. Level of salaries and other means of remuneration

Individual training programs
Stahl has certain provisions regarding individual training
programs. All employees that have worked for the Company morethan four months are eligible to participate in external training
programs individually or in teams. All trainings should consider
what employees need and how they can learn best. This is why,
Stahl encourages employees and managers to consider multiple
training methods like workshops, e-learning, lectures and more.
Corporate training programs
Stahl also defined a corporate training catalogue to train its
employees.

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Examples of this kind of training and development are:Human rights, modern slavery, anticorruption■ compliance, anti-bribery and anti-corruption and modern slavery;

Stahl’s Code of Conduct ensures that human rights and theenvironment are respected by those parties with whom we dobusiness. Related to this, a whistleblower policy is in place withclear rules that allow employees to report suspicious behavior that
could be in conflict with the Code of Conduct, with the necessary
protection guarantee for the whistleblower in question.

■ workplace diversity and inclusion;■ security Awareness and GDPR training;■ leadership (Management Training and Masterclasses);■ induction program for new employees;■ training teams in company-related issues (e.g. new systems or
policy changes);■ training employees to prepare them for promotions, transfers or
new responsibilities.

Training hours: The indicator of total hours of training is tracked
locally by each Stahl unit and it is consolidated at group level. The
number of hours received per employee in 2018 was 22.3 hours
per full-time equivalent (FTE) compared to 13.13 hours per FTE in
2017. The increase of hours per FTE is mainly caused by the launchof the e-learning programs: Anti-bribery and anti-corruption,
Modern slavery, Workplace Diversity and Inclusion, GDPR training
and Security Awareness training. Safety awareness campaigns are
excluded.

Equality
The nature of Stahl business and the need to respect strict security
and eventually emergency measures, somewhat limits theopportunities for disabled employees; there are currently 12
persons in this category, compared to 16 persons in 2017.

Diversity
In 2018, Stahl published its Diversity and Inclusion Policy on its
website and is committed to embedding equality, diversity andinclusion across the organization rather than viewing it as an
abstract principle. Equal treatment is at the heart of theorganization and Stahl believes this will produce a more innovativeand responsive organization. It also believes that there is much
more to diversity than age, gender, race and cultural background.
A diverse workplace includes people who can offer a range ofdifferent viewpoints and ideas.
Consistent with its strategy of growing its leadership talent,diversity and inclusion principles are also embedded within its
core leadership development programs to encourage managers
to demonstrate them as part of their leadership behavior. Stahl will
also build cultural intelligence and equality into its performance
review, hiring and talent identification processes.
In the third quarter Stahl launched an e-learning training focusedon Workplace Diversity and Inclusion.

Late 2017, Stahl launched e-learning training programs focused onanti-bribery and anti-corruption and in 2018 on modern slavery. To
complete the e-learning training, participants are required to study
the material and take a test at the end. Special attention is given toawareness in these programs, and to the red flags that can indicate
non-compliant behavior in the supply chain. 1,200 employees(more than 50% of the total workforce) received this training in
2018.

Human Resources in Stahl
Stahl is an organization centralized around customers and that
holds customers at the core of its commercial and entrepreneurial
culture. New ideas and creativity are expected, learning is
promoted, product, process, and administrative innovations arechampioned, and continuous change is viewed as a conveyor ofopportunities. While having a global reach, Stahl acts on thepremise: think global, act local. Partnerships are vital to us, as Stahlbelieves that working side-by-side offers the best chances to
produce success stories.
The Stahl HR Team applies the concept that a new job is like a newjourney for an employee and considering the world around us ischanging at fast pace, increasingly unpredictable, impossible toanalyze systematically and beyond accurate interpretation, themain purpose in the coming years will be to offer to the employee
a great experience in Stahl.
HR is responsible for ensuring that the Company has the “right
person” in the “right place” at the “right time” for today andtomorrow and support Stahl in creating responsible partnerships
and to be the leader in its market.
The HR strategy adopted in 2018 is based on the following points:■ further develop and establish Stahl’s culture and Stahl DNA;
■ transfer knowledge and information within the Company;■ hire and develop people in line with current and future businessgoals;■ create an open, transparent and fair management style;■ focuson engagement,
opportunity;

diversity

management

and

equal

■ be a truly international team.

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Considering the HR strategy defined, the project’s focus in 2018has been towards:
1

Transfer knowledge and information within the Company;

2

Hire and develop people in line with current and futurebusiness goals. In addition an analysis (“Attractive and talentretention”) has been run to mitigate the risk “.

1Transfer knowledge and information within the Company■ HR dashboard: As part of continuous improvement, a new HR
dashboard has been defined and implemented. “Management by
figures” providing transparency on data is the basis for, allowing
the Management Team to take proper and fast decisions;■ Employee handbook: The release of an employee handbook

further supports the smooth transition into the new job as part of
Stahl’s HR strategy. Creating a harmonious, fair, employee andemployer supportive workplace allows improvement of the level ofengagement. The handbook introduces employees to our culture,
mission and values. This helps to foster a sense of pride andbelonging and ensures that key company policies are clearly andconsistently communicated, demonstrating that the company
strives to be compliant with these regulations every day.

2

Hire and develop people in line with current and futurebusiness goals■ Digital recruiting: The way Stahl recruits its people has changed.

Compared to just a few years ago, candidates now have far more
power during the job search. Consequently, finding and hiring ideal
job candidates, especially those with in-demand skills, has become
extremely hard, expensive and time-consuming. The change ofparadigm and technology brings new recruiting trends. Stahl has set
an inbound recruiting strategy where Stahl proactively andcontinually attracts candidates with the goal to make them choose
Stahl as their next employer, starting in this way to build a highquality candidate database for current and future needs. This new
way of recruiting and selecting employees will be further supportedby the implementation of a digital recruiting tool, connected with
our Company website and Human Resources Management system.
The objective is to streamline, simplify and automate the hiring
process, making it faster and more efficient and compliant with the
new General Data Protection Regulation (GDPR).

■ Performance development system: Stahl asks employees to focus

on performance development (long-term approach) rather thanappraisal, teaches “People Leaders” to “inspire and empower”
their teams and help employees set real-time priorities based on
customer input, and, ultimately, increases speed and collaboration.
In order to achieve these targets a new performance development3

system has been defined based on the Company leadershipmodel. This model identifies key behaviors for the success of
Stahl's business and the professional maturity of people and its
organization and it is strictly related to the corporate values. It
supports the communication of expected results and increases theawareness of what is necessary in different phases of professional
growth;■ Learning management system: The implementation of a learning
management system has started with the objective to let
employees choose and manage online courses and training
programs and to assign courses directly to employees wheneverneeded. In particular, the aims are to:■ track learning progress and measure performance,■ speed up the onboarding process,■ integrate social learning experiences,■ organize department specific compliance regulations,■ reduce learning and development cost and time,■ show statistics of trained people for external auditing.

■ Global mobility: Global talent deployment is about having theright people, in the right places and roles, at the right cost and forright length of time and results. At Stahl, the demand for global
mobility is increasing rapidly, either as part of a personal
development plans or for knowledge sharing & training of others.
To create added value to the company's business, HR has createda long-term assignment policy. With this policy, HR aims to deliverconsistent results for comparable assignment solutions.

Safety, Health and Environment (SHE)
Risk assessment
Stahl carried out a detailed review of its risk assessment and control
policies in 2018, as part of the requirement of the new French law,
the Non-Financial Statement (NFS), with regards to environmental,social, human rights and corruption risks resulting from its activities.
As a player of the chemical industry, Stahl has identified the risk
linked to the health and safety of employees & contractors,
including accidents, injuries, illness, exposure to chemicals. All its
activities, policies, monitoring and reporting and trainings are
aimed at creating a true safety culture (which is in fact an attitude)that results in zero injuries and accidents. Risks related tooccupational health and safety, including:

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including volatile organic compounds (VOCs);

By implementing the principles described below, and by using thelatest state-of-the-art technology and processes, the gross risks of
Stahl’s operations are being mitigated and the risk for its
employees, the community and the environment is minimized. This
chapter reports on Stahl's health and safety performance.

Safety, health and environment (SHE) policy
Stahl believes that the protection of health and safety of people
and the preservation of the environment will be always considered
its highest priority. This mindset (and policy) is rooted in theemployee culture.

Health and safety
The key principles of the Safety and Health policy are:■ a strong safety culture involving the whole organization;■ safety, health and environment as the top priority;■ safety is more important than a short term result;■ implementing best industrial practices in addition to compliance toall legal requirements;■ knowledge as the basis of all decisions. Stahl will require that
employees are trained in the skills necessary to carry out theirduties and make decisions ensuring safety.

Stahl's safety policy is linked to its business activities andoperations by a management system establishing the need to:■ implement safety principles through process conception, facility
design, operation specification and behavior of people;■ define safety measures to prevent incidents and accidents;■ define safety measures to limit the potential consequences ofincidents and accidents;

take

the

■ success in safety performance shall be celebrated and rewarded;■ consider

safety responsibility as a mandatory individual
responsibility to be spread throughout the entire organisation;■ people must contribute to continuous improvements in safety bymaking suggestions that, assuming they are aligned with the SHE
policy, could be implemented.

Stahl’s SHE organization
All Local Managers and General Managers are responsible for
implementing the safety policy and principles in areas under theircontrol. This responsibility includes systems for the recognition of
hazards, assessment of risks and provision of effective controls. For
outpost sites such as application laboratories, technical service
centers and warehouse operations the Local Manager or General
Manager of the controlling site may delegate this responsibility to
the manager at that site.
Since 2017 Stahl has a Global SHE and Process Safety manager incharge of implementing the SHE policy and R20 (Road-to-Zero)
program. This position implements the fulfilment of Stahl’s SHE
policy, including the changes of behavior and training required tosupport the highest possible standards of SHE. An enhanced
reporting tool will be implemented in 2019. In this sense, in 2018 a
Behavioral Safety Program was defined by Stahl and applied aspilot in Parets, one of the company's production facilities in Spain.
The name of the program is R20 (Road-To-Zero) and the pillars
are:■ a true safety culture defines an attitude in life, inside and outside
the place where you work;■ a good safety record has been never achieved by a big effort of a

■ identify and assess all hazards;

220 WENDEL - Registration Document 2018

■ be open to improvements made available in the industry;
good practices in emergency response and crisis
management preparedness;■ fatal and serious incidents.

and investigate all incidents,
actions & share and learn from them;■ audit and review hazards periodically;■ ensure■ slip, trip and fall;■ report■ monitor safety performance with metrics and indicators;

necessary

small group of people, but by all the small efforts of a big group ofpeople;■ potential consequences of injuries at work are mostly affecting
people and their social network outside work;■ Stahl has defined a zero tolerance policy for unsafe behavior toensure that people do not get injured at work.

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Each site has a dedicated SHE Manager who is responsible toidentify and asses the needs in the field of SHE and manage thenecessary actions to ensure that the organization is pursuing thebest practices in this field. Being a SHE Central figure does notmean in any way being the central responsible for SHE, as said, theresponsibility in this field is distributed throughout the entire
organization and there is no single job position without a certain
degree of responsibility the area of SHE. The SHE Manager reports
to the Local Manager and has the direct support from the Global
SHE&PS Manager.

3

Reporting & SHE manual
Global Safety performance and KPIs(1) are reported and monitored
monthly and annually. The Company tracks progress on safety
indicators and reports different categories of injuries and incidents
including lost time injury (LTI), serious injury, minor injury, first aid,
occupational health and fatalities. Each month it reports injuries,
incidents, audits, trainings, engineering projects and otherprevention methods both internally and externally. The Safety
reporting procedure is recorded in the Stahl SHE manual.

Safety KPI’s
The table below shows a stable rate in lost time injuries (LTI) in and the severity rate (SR).

Work injuries

LTI/Frequency rate of accidents with lost work time*
Severity rate of accidents**

2018

2017

2016

2015

2014

1.22

2.01

0.80

1.60

1.50

2013

0.80

0.03170.10250.00450.03800.05550.0097*

LTI/Frequency rate calculation: (number of reported accidents that resulted in lost days > 1 day x 1,000,000***)/(number of theoretical worked hours). Also
known as Lost Day Rate (LDR). In 2017, Stahl changed the factor to calculate LTI to the European standard. Rates are based the factor of 1,000,000 insteadof the 100,000. Above table is based in the 1,000,000 factor.
** Severity rate calculation: (number of lost days x 1,000***)/(number of theoretical worked hours). The factor of 1,000 of the historical data has been restated(1,000 instead of 1,000,000 which was used in the 2017 registration document).

Environmental footprint
As part of the NFS risk assessment, environmental risks were also
identified:■ hazardous waste management;■ impact on water resources;■ greenhouse gas (GHG) emissions contributing to climate change;■ increasing demand and regulation for sustainable chemical
products.

Stahl is focused on contributing to a lower environmental impact at
our operations and for our customers and supply chain partners.
As a result, the company has implemented policies, KPIs andtargeted actions to mitigate the above mentioned risks.
With regards to environmental footprint of its products, Stahl ispoactively engaged (in addition to legslative requirements) ininitiatives focused on the elimination of certain chemical
substances from the supply chain, e.g.: Zero Discharge ofHazardous Chemicals (ZDHC) and bluesign®.

With regards to the environmental footprint of its own operations,the company is committed to global initiatives and frameworks,
like The Paris Agreement (on reducing CO2), the UN Global
compact, the UN Sustainable Development Goals and theOrganisation for Economic Co-operation and Development(OECD). For reporting, Stahl implements the Global Reporting
Initiative (GRI) guidelines.
Stahl is continuously upgrading its production sites and laboratory
facilities in order to achieve energy, waste and water efficiencies
and to reduce its environmental footprint. Since 2015, it has
placed a strong focus on the following environmental topics:■ CO2 and energy;■ water;■ waste.
The CO2 and energy highlight of 2018 was the installation of solar
panels at the Stahl manufacturing site in Portao, Brasil with acapacity of 840 kW. The significant investment in this solar energy
will result in an important drop in CO2 emissions for the site in
2019, and it will supply approximately 50% of the electricity
consumed at that facility. During 2019 the company will monitor
the success of this project and make plans to introduce solar
energy at its other manufacturing sites.

(1) For safety indicators all Stahl employees are considered.
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Carbon Dioxide (CO2) emissions
Stahl recognizes that reductions in global CO2 emissions will be
required in order to achieve the goals outlined in the Paris Climate
Accord established in 2015. Stahl has set an internal target to
reduce CO2 emissions by 10% by 2020 (using 2015 as a baseline).
The company is considering new goals for 2030. Stahl’s
improvements in CO2 emissions are driven by sourcing green
energy at is European sites and by technology investments thatlead to long term efficiencies at its manufacturing sites. In thelonger term the company is investigating the generation ofrenewable energy at its manufacturing sites, building on the
success of the solar panels already installed at Stahl Brazil.
Stahl estimates and reports also on the scope 2 and 3 indirectemissions since 2017. Scope 2 emissions are indirect emissions
from the generation of purchased energy. Scope 3 emissions are allindirect emissions (not included in scope 2) that occur in the value
chain of the reporting company, including both upstream anddownstream emissions.

Below tables shows the different sources of CO2 emissions calculated by Stahl, as per the Green House Gas (GHG) protocol.

Carbon Dioxide (CO2) emissions
Scope 1

Scope 2

Scope 3Purchased electricity, heat and steam

Purchased goods and services
Business travel
Employee commutingWaste disposalUse of soldproducts
Transportation and distribution (up- anddownstream)
Investments
Leased assets and franchises

Fuel combustion
Company vehicles
Fugitive emissions

In absolute terms Stahl has achieved a CO2 reduction (in scope 2) because of its investment in renewable energy sources that have a lower
carbon footprint.
2018

2017

2016

2015

Scope 1: direct GHG emission (metric tons CO2-EQ.)*

17.11416.91516.92415.569

Scope 2: electricity indirect emission sources (metric tons CO2-EQ.)**

7.119

8.984

18.59517.759500-530

Nocomparable
data

Scope 3: estimation of the other indirect emission sources (CO2-EQ. X 1 million)***560-590560-590*

Scope 1: direct GHG Emissions are those that occur from sources that are owned or operationally controlled by the company: company owned or leased
cars, other company vehicles, gas and oil used on site. In 2018 new energy sources were included in the reporting (High Speed Diesel & Agri briquettes),that were also retrospectively added for 2015, 2016 and 2017.
** Scope 2: electricity Indirect Emission Sources: are those that occur due to purchased energy (in the form of electricity, steam, heat and cooling) from thegrid or district heating or cooling systems. In 2018 renewable energy both purchased and self-generated, were added to the reporting tool, which
explains the big drop in CO2 in scope 2 in 2017 and 2018.
*** Scope 3: other Indirect Emission Sources are calculated since 2016 following the GreenHouse Gas protocol. In 2015 Scope 3 was based on business travel(flights and private cars).

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3

The below table shows the improvement of Stahl's CO2 intensity over the last two years. CO2 intensity means CO2 emissions measured per
production volume.

CO2 intensity
2018

2017

2016

2015

CO2 emission scope 1+2 (in tons)

24.23225.89835.51933.328

Total production volume (in tons)

228.440238.590207.923

195.646

0,106

0,109

0,171

0,170

CO2 intensity(1)(1) CO2 intensity: CO2 emissions per production volume = CO2 per tons produced = CO2 scope 1 + scope 2/production volume.

Corporate Value Chain (Scope 3) Accounting and Reporting Standard
In 2017 Stahl made its first assessment of scope 3 emissions as per
the GHG Protocol Corporate Value Chain Accounting andReporting Standard. This exercise is designed to understand thefull value chain impact of its activities and will help to focus efforts
on significant sources of GHG emissions. In 2018, it updated thematerial categories and the estimated CO2 emissions.

Scope 3 emissions per category
2018

2017

Cat 1: Purchased goods and services

62%

63%

59%

Cat 12: End-of-life treatment of sold products

24%

23%

26%

Cat 4: Upstream transportation and distribution

9%

9%

10%

Other (e.g. Capital goods, Downstream transport. and distribution)

5%

5%

6%

Total as reported in CO2-eq (x 1 million)

560-590560-590*500-530

CO2 emission trend as reported-1,34%

9,74%

CO2 emission like for like (excluding the impact of acquisition)-4,46%

8,66%

*

2016

2017 data restated, which has an impact of +50k CO2-eq in 2017, as a result of a onetime calculation error.

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Wendel’s subsidiaries reviewed by an independent verifier■ increasing biogenic content of the materials that are being

Scope 3 emissions per category

used(1)■ increasing longevity of end products that could reduce lifecycle

Like for like
-4,46%

600,000

CO2-emissions of end products.

-1,34%

Transportation of purchased goods is the third largest source of
scope 3 emissions.

500,000

Transportation of goods (Cat. 4) accounts for around 11-12% of
Stahl scope 3 emissions. Based on the assumptions in thecalculation of transport emissions, the major part of theseemissions is air and road transport. Reducing these emissions
could be achieved by:

400,000

300,000■ choosing a different mode of transportation. Road transport emits

200,000

10 times more CO2-emission per tkm than marine transport. Air
freight emits 100 times the emissions associated with marinetransport. In particular, Stahl is actively looking for ways tominimize air freight shipments in favor of marine transport;

100,000

0■ stimulate
2018

2017

2016

Cat 1: Purchased goods and services
Cat 12: End-of-life treatment of sold products
Cat 4: Upstream transportation and distribution
Other (e.g. Capital goods, Downstream transport. and distribution)

Results and mitigation
Purchased goods and services’ (62% in 2018) and ‘end-of-life
treatment of sold products’ (24% in 2018) remain the largest
sources of indirect (scope 3) CO2 emission. Both categories are
related to the input and output of materials in the production
process. Opportunities to reduce these emissions are:■ selecting (base) chemicals with a lower CO2-footprint;

transportation with cleaner vehicles (e.g. selecttransporters based on their sustainability achievements such as
Dutch “Lean & Green” star rating);■ reduce transporting small quantities of goods. During 2018 Stahl

has consolidated its distributor network around the world, whichmeans larger shipments to a smaller number of distributors.

EnergyStahl’s energy consumption is the sum of electricity, gas, oil,steam, renewable briquettes and high speed diesel, consumed attheir manufacturing sites (see below pie chart). Energy is reported
as the total energy consumed in TJ and per production volume:the energy intensity. There are many energy efficiency projects
underway. In 2018, Stahl included more energy sources(briquettes, high speed diesel and the split in renewable andtraditional/grey electricity). As production volume decreasedslightly in 2018 (ie: like for like), the energy per tons produced wasflat in 2018 vs 2017.

Energy consumption
2018

2017

2016

2015

Energy (TJ)

380

1

390

319

305

Share of renewable energy*

34%

34%

-

-

Total production volume228,440

238,590

207,923

195,646

Energy intensity (TJ)**

0.001660.001630.001530.00156*

European sites and Portao have renewable electricity. In Portao we have invested in solar panels. In Kanchipuram, India the major part of the energy
consumption is agri briquettes (mix of peanut shells and saw dust)** Energy intensity is (energy consumption (TJ) per tons produced) = energy (TJ)/total production volume.
Energy consumption is based on lower heat value (LHV).
2017 energy in tj now also includes briquettes consumption by kanchipuram. This category was added in 2018. To show the trend in 2018 compared to2017, we added this. Stahl included it to compare the 2018 and 2017 trends.
(1) Biogenic materials does not necessarily lead to a lower carbon footprint from a life cycle perspective, because production and processing of biogenic
materials in some cases can be more (fossil) energy intensive.

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Energy sources

Breakdown of energy consumption by source

The below pie chart shows the energy consumption, split between
the different energy sources used in 2018 on manufacturing sites(Stahl added renewable energy, agri briguettes and high speed
diesel were added). Stahl did not use coal. The main source is gas(34,66%) and electricity (33,03%), which partly consists of green
electricity (34%). Renewable (agri) briquettes are made fromrenewable waste materials (peanut shells and saw dust).

Steam (TJ)

2.43%
10.57%

2.78%

Renewable briquettes (TJ)High Speed Diesel (TJ)

35%

23.44%Gas (TJ)

Renewable electricity (TJ)
– purchased

0.07%
Renewable electricity (TJ)
– self-generated

16.35%
Furnace Oil (TJ)

9.35%
Grey electricity

Renewable briquettes (TJ)

10,57 %

40,14

Renewable electricity (TJ) - purchased

23,44 %

88,98

Renewable electricity (TJ) - self-generated

0,07 %

0,25

Grey electricity

9,35 %

35,49

Furnace Oil (TJ)

16,35 %

62,09

Gas (TJ)

35,00 %

132,90High Speed Diesel (TJ)

2,78 %

10,57

Steam (TJ)

2,43 %

9,24

100 %

379,66

Water
Stahl consumed less water in 2018 because production volumes were slightly lower but also because of efficiencies at the sites. Water
consumed per tons produced decreased, so water efficiency improved.

Water consumption
2018

2017

2016

2015

Water consumption (m³)

344,922370,855

355,041

325,864

Other water use (m³)*

456,820561,788

506,056

491,021

Total water used (m³)

801,742932,643

861,097

811,093

Total production volume228,440

238,590

207,923

195,646

1,510

1,554

1,708

1,666

Water intensity***

Other Water use = water in Palazzolo, in particular ground well water, is used for the processes but also as cooling water (for this reason we have highvolumes of withdrawn water). This water (cooling water) is kept completely separated from chemical products and discharged into the river Seveso at
controlled temperature.
** Mater intensity is the amount of water used per tons produced = water consumption (m3)/total production volume (excluding Other water use).

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Waste
Disposal of waste is considered only as a last resort for Stahl and it
has begun to regard waste more and more as a by-product, withvalue for other uses. It is also installing water treatment facilities atmanufacturing sites which do not have such facilities. This will
effectively reduce the amount of wastewater (classified ashazardous waste) sent to third parties for treatment.
2018

2017

Hazardous waste (tonnes)

10,962

10,538

9,48

6,570

Non-hazardous waste (tonnes)

1,807

1,584

1,476

1,276

TOTAL WASTE (TONNES)

12,76912,122

11,224

7,846

2018

2017

2016

2015

Waste water send to external treatment (tonnes)*

15,62018,12415,03815,815

*

2016

2015

This indicator only represents the Stahl sites in Waalwijk and Toluca. Waalwijk= cleaning water of tanks. Toluca=waste water that is collected from theproduction plant (cleaning of tanks, reactors and equipment in general) and also services (bathrooms and showers). The other 9 sites have an on-site waste
water treatment installation.

Environmental provisions
As of the end of 2018, Stahl’s environmental provision for land
pollution are of €0.6 million.

Low-impact innovative solutions
As communicated earlier in the report, Stahl carried out a detailed
review of its risk assessment and control policies in 2018, in
accordance with the requirements of the Non-Financial Statement(the NFS), with regards to environmental, social, human rights andcorruption risks resulting from its activities.
Stahl identified a risk linked to innovation and the ESG
performance of its products: the increasing demand andregulation for sustainable chemical products. With 11 R&D centersaround the world, employing over 100 technical staff, Stahl’s
product research is aimed at providing high performance solutions
that reduce environmental impact. This can be either by using
renewable/bio-based raw materials in its own products or bydesigning products which will reduce the CO2, energy, water or
toxicological footprint of our customers’ products. It is arequirement that all new products developed by Stahl’s researchteam must have a clear environmental benefit. The full integration,in 2018, of the BASF leather chemicals business product range hascomplemented this innovation drive.

■ strong sales of the STAHL EVO products for coated materials andthe Stahl NEO leather chemicals portfolio were important

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commercial highlights in 2018. This growth is linked to the fact thatthese products are compliant with the Manufactured Restricted
Substance List (MRSL) launched by the ZDHC Foundation(Zero-Discharge-of-Hazardous-Chemicals) in 2015, whose goal isto eliminate hazardous substances from the garment and footwear
supply chains, by 2020;■ another example of significant sales growth in 2018 was in theProviera® - Probiotics for Leather™ product portfolio. These
products contribute to the reduction in the environmental footprintof the leather process, notably with regard to water pollution, by
substituting synthetically produced surfactants by natural products
made from a fermentation process;■ over 85% of Stahl’s finishing and coatings-related products are

currently water based. The policy of promoting natural andrenewable resources as raw materials, has driven water based
polyurethane research activities significantly in 2018. As a result,new bio-based polyurethane materials are being prepared forcommercial launch in 2019, for promotion in the Performance
Coatings, Leather Chemicals and Polymers businesses. 25% of
Stahl’s basic research is focused on projects specifically aimed ateliminating restricted substances from the supply chain;■ life Cycle Analysis (LCA) emerged in 2018 as a new element ofinnovation for Stahl, and the company has identified products andprocesses where the impact on the environment can be calculated,
and reported, using established methodology. Stahl believes that
LCA will be an important value-added service for its customers inthe supply chain in the future.

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People & Society
Sustainable Development Goals
Stahl is committed to the guiding principles of UN Global
Compact, the world’s largest corporate sustainability initiative.
With this commitment we confirm the alignment of our strategy
and operations with the universal principles of human rights, labor,
environment and anti-corruption.
This also means that Stahl’s activities are being aligned with the 17
Sustainable Development Goals (SDG’s) announced at the UN
General Assembly in 2015. Stahl’s activities linked to the SDG’s arelisted below.

■ poverty: In addition to local community philanthropy, Stahl isinvolved in wider industrial development in emerging regions with
NGOs and governments. As an example, a Public Private
Partnership between Stahl, Solidaridad and PUM that was
launched in 2017, in Kanpur, India, is progressing well. Although
the five-year project is focused on reducing water pollution, and its
success will also have an impact on securing the estimated400.000 jobs linked to the local leather industry in Kanpur, which isthreatened by forced closures due to environmental pollution;■ good health: Stahl has committed to initiatives that will eliminate

restricted substances from the supply chain, like the Zero
Discharge of Hazardous Chemicals foundation, of which Stahl is amember since 2016;■ education: Stahl Campus® was established to promote goodpractices throughout the supply chain (see the section
Education & Training). Stahl also actively promotes the safe
handling of chemicals and conducts seminars on this topic inemerging regions. For example, in Q4 2018 the company held
Sustainability Seminars on these topics at the 4 main leather
manufacturing clusters in India. In 2018 Stahl Campus® was be
expanded to Kanpur, India, to support the water pollution efforts
being made there;■ gender Equality: Stahl’s Diversity and Inclusion policy wascommunicated in 2018;■ clean Water & sanitation: Water technology is a growing area for

Stahl and we are working jointly with leading universities on
improving water effluent quality. This includes employing a
research specialist focused on specific water pollution projects.
The company has introduced effluent-reducing technologies like
Proviera® - Probiotics for Leather™, Stahl NEO, Stahl EVO andCatalix® as well as water-reducing technologies like Easy White
Tan®. The Public Private Partnerships launched in Kanpur, India
and Ethiopia are also driven by a strong desire to reduce waterpollution in the markets that the company serves;

3■ renewable Energy and Climate Action: Stahl’s goal is a 10%

reduction in CO2 emissions by 2020 (in line with the 2015 Paris
Climate Agreement) and this implies the adoption of renewableenergy sources and raw materials, as well as energy efficienttechnologies at its sites. 2018 emissions improved vs 2017 and thecompany fully expects the 2020 goal to be met. Beyond this, Stahl
has begun to use solar panels at its site in Brazil as part of a longer
term goal of sourcing from on-site renewable energy for its
manufacturing sites;■ jobs, economic growth: The Public Private Partnership in Kanpur,

India, is one example of its commitment to sustainable economic
growth. The EU funded project aimed at promoting efficienttechnologies for the Ethiopian leather industry is another. Bothprojects are focused on reducing pollution which has a directconnection with securing sustainable economic development andtherefore jobs for the local industries. Without such pollution
control initiatives, companies in these sectors would fail andeventually be forced to close;■ reduced Inequalities: Stahl’s Code of Conduct was implemented in2015 and the Stahl Diversity and Inclusion policy was implemented
2018. E-training courses were conducted and completed by 1,200
employees during 2018 on data protection, bribery,corruption & modern slavery.

Trusted Partnerships
The company is proactively involved in many sustainability related
initiatives, like the Leather Working Group (LWG), the largest
voluntary group in the leather industry. The mission of the LWG is
to raise the bar of environmental stewardship via its audit protocol
for tanneries, to allow better choices to be made about sourcing
leather. Audit implementation and its maintenance is the LWG’smain activity and Stahl is an active member of the Executive
Committee of the Leather Working Group. The Executive
Committee consists of four clothing/footwear brands (currently
Wolverine, Timberland, Louis Vuitton and Clarks), four leather
manufacturers and one chemical company (Stahl).
Stahl is an active member of the Zero Discharge of Hazardous
Chemicals (ZDHC) foundation, and became a bluesign® system
partner in 2017.

Non-profit activities in emerging countries■ in 2018 Stahl launched a joint project in Ethiopia with several

partners and NGOs, including Solidaridad and MVO NL, focusedon pollution reduction in the tanning sector. Stahl’s contribution tothis project is training in cleaner technologies, via Stahl Campus®
modules;

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Wendel’s subsidiaries reviewed by an independent verifier■ Stahl’s sustainability roadshows continued in 2018 and were heldin 4 different cities in India. The seminars focused onhousekeeping, chemicals management and clean technology for
reducing water pollution in leather clusters. This years’ attendance
was high, with an average of 350 people for each seminar;■ a Public Private Partnership (PPP) between Stahl, Solidaridad, andPUM was launched in 2017, in Kanpur, India (see section
Sustainable Development);■ UNIDO: The mission of the United Nations Industrial Development

Organization (UNIDO) is to promote and accelerate inclusive andsustainable industrial development (ISID) in developing countries
and economies in transition. UNIDO’s e-learning courses,
designed to promote good practices and responsible chemical
management in leather tanneries, is fully supported by Stahl andwe promote it in the areas where it is needed. Indeed Stahl’s
recent sustainability seminars in India were conducted inconjunction with UNIDO.

aims to prevent the risk of serious violations of human rights andfundamental freedoms as well as harm to human health, safety andthe environment.

Stahl’s approach to Duty of Care
Stahl carried out a review of its risk assessment and control policies
within the scope of the aforementioned French laws on Duty ofCare. This review covered the risks linked to our employees,
suppliers and customers/external markets. Stahl has adopted
governance policies covering health and safety, environment,
human rights in order to mitigate such risks. These policies areincluded in the risk mapping section below.
Stahl plans to set up a Vigilance team that includes HR,
Legal & Compliance, Purchasing, SHE, Sustainability and Businessdirectors, who meet twice a year to monitor the effectiveness of
the Vigilance plan.
1

Education and training (Stahl Campus®)
Stahl is committed to filling the talent gap observed in some of themarkets that we serve by actively seeking ways to educate andtrain university students, NGOs, brands, suppliers, distributors,
customers and other stakeholders in the supply chain. Stahl
Campus® is the global knowledge center established by Stahl toachieve
this.
Startedin
2014
in
Waalwijk(Netherlands) & established in León (Mexico) in 2015 andGuangzhou (China) in 2016, Stahl Campus® was extended in 2018
to Kanpur, India. The goal is to promote good practices andtransparency throughout the supply chain by hosting trainees in
Stahl’s state-of-the-art laboratories to strengthen their knowledge
via theoretical and practical training modules. Stahl Campus® is a
key element of the company’s strategy of promoting transparency
throughout the supply chain.
In 2018, 780 people attended Stahl Campus® training courses
around the world. Notably in 2018, a Post Graduate Certificate
course was organized in Stahl Campus® Mexico - a six-weekcourse developed in collaboration with the University ofNorthampton (UK), in which students receive an official PG
Certificate in automotive leather finishing upon completion. We
will launch the same course for a new set of students in 2019.

Vigilance plan
Stahl’s vigilance plan corresponds to the French law 2017-399(March 2017) on Duty of Care. The vigilance plan identifies and

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Risks linked to human rights and the societal impact of Stahl's
activities, e.g. forced labor, freedom of association, modern
slavery, discrimination, diversity and inclusion.

Stahl recognizes that modern slavery, corruption, diversity anddiscrimination need to be eliminated from its industry at all levels.
Mitigating the risk:■ Stahl’s Code of conduct for employees (introduced in

April 2013) describes its commitment to a working
environment where equal opportunity and respect areprioritized. The Stahl Employee Code of Conduct haschapters on modern slavery, conflicts of interest, businesspractices, data and IP protection, financial reporting and also
outlines the whistleblower rules,■ the Stahl whistleblower policy allows employees to reportsuspicious behavior, by e-mail or phone, that could be inconflict with the Code of Conduct, with the necessary
protection guarantee for the whistleblower in question,■ Stahl introduced a Code of conduct policy in 2015 for its

business partners. Since 2018, it has been using a due
diligence questionnaire to retrieve in-depth backgroundinformation about the business partner upfront (including
relations with government officials, lobbying, the role of thebusiness partner). Additionally, it initiated the first supplieraudits in 2018 as a means to mitigate the risks of
non-compliance with the Code of conduct. The Code of
conduct is also a standard part of all commercial agreements
and contracts with third parties who do business with Stahl,

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Non-financial information
Wendel’s subsidiaries reviewed by an independent verifier■ both Codes of Conduct are discussed during the monthly■ the chemical industry is governed by strict legislation, permits

Management Team and quarterly meetings with the
Quarterly Executive Control Group,and licenses. External organizations, including governmental
bodies, ISO and many industry initiatives, visit and audit Stahlon a regular basis,■ the company has implemented a separate policy on diversity■ Stahl has a strict SHE (Safety, Health and Environment) policy

and inclusion in the workplace (Stahl Group Diversity andInclusion Policy). The policy commits to embedding equality,
diversity and inclusion across the organization rather thanviewing it as an abstract principle. Equal treatment is at theheart of the organization and Stahl believes that this willproduce a more innovative and responsive organization. The
company also believes that there is much more to diversity
than age, gender, race and cultural background. A diverse
workplace includes people who can offer a range of different
viewpoints and ideas,that sets clear rules, guidelines and KPIs for all its
manufacturing sites and work places. With regards to safety
Stahl has drawn up a zero tolerance policy towards unsafe
acts,■ the Stahl Code of Conduct for business partners includes ahealth and safety section,■ auditing of Stahl sites is continuous and reporting on safety

and health, including accidents and incidents, is done
monthly and annually,■ consistent with its strategy of growing its leadership talent,■ training courses are held continuously throughout theDiversity and Inclusion principles have also been embedded
within its core leadership development programs toencourage managers to demonstrate them as part of theirleadership behavior. Stahl has also committed to build
cultural intelligence and equality into its performance review,hiring and talent identification processes,

company on chemicals management and handling of
flammable materials,■ the use of CE certified equipment is mandated as well as

associated training,■ Stahl has identified safety and health risks at customers who■ in 2018 the company ran a series of online training courses,

use its chemicals, and this also requires action for mitigation,
given the potential harm caused by our products to people
working at those organizations. Indeed many of its customers
work in environments which are not as highly regulated as thechemical industry. Stahl has taken action, either alone or in
conjunction with other peer companies and NGOs, to train
users in these cases on (1) the safe use of chemicals, (2) the
correct use of personal protective equipment, and (3)communicating clear rules on exposure prevention forpotentially harmful chemicals. In addition to this, Stahl itself
regularly hosts seminars around the world, for example inIndia, Pakistan and Bangladesh, which are attended by large
groups of customers, which are focused on safety, health,environmental stewardship and sustainability in general.

hosted by Thomson Reuters, to ensure that employees
understand the issues of modern slavery, diversity,
discrimination, equal treatment, sexual harassment etc., withregard to their own behavior and that of the company's
business partners. To complete the e-learning training,participants are required to study the material and take a testat the end. Special attention is given to awareness in these
programs, and to the red flags that can indicate
non-compliant behavior in the supply chain. 1,200 employees(more than 50% of the total workforce) received this training
in 2018.
2

3

Risks linked to the health and safety of employees & contractors,
including accidents, injuries, illness, exposure to chemicals.

The risks in this category range from injuries to employees fromslips or falls, to more significant accidents involving chemical spills,
machinery operations or exposure to dangerous substances.
These are well known in the (heavily regulated) chemical industry
and Stahl holds itself to the highest health and safety standards inthis respect.
Mitigating the Risk:■ Stahl is confident that the residual risk specific to its own

activities related to safety and health is low, given the highly
regulated nature of the chemical business and additional
actions taken by Stahl to mitigate these risks,

3

Risks linked to protection of the environment, e.g. air & waterpollution, water consumption, waste management, restrictedchemical substances, climate change, biodiversity, local
community impact.

These risks are linked to unplanned releases to the environment of
hazardous materials from Stahl sites, as well as the risks linked tothe environmental stewardship practices of its partners in the
supply chain, especially those who use its products in their
manufacturing operations.

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Mitigating the risk:■ Stahl recognizes the challenges for the planet and hasaligned its policies to the 17 Sustainable Development Goals
agreed by the United Nations in 2015,■ climate change: in 2015, Stahl established a 5 year target forCO2 emissions reduction (less than 10%). The company islikely to achieve that target in 2019. CO2 emissions arereported each month, and in the annual Stahl Sustainability
Report,Board member of the Leather Working Group, the largest
leather industry association. The Leather Working Group has
developed an audit protocol for leather tanneries around theworld in order to level the playing field and create arecognized standard for environmental stewardship. Stahlalso hosts annual seminars in India, Pakistan and Bangladesh,
attended by large groups of customers, NGOs and industry
associations, during which safety, health, housekeeping andenvironmental stewardship issues are presented anddiscussed in detail.

■ Stahl’s strict SHE policy covers the risks linked to spills or

releases into the environment, including a dedicated spillteam who are trained regularly,

Reporting methodology for Stahl

spills, releases, incidents and environmental KPIs (CO2,energy, water, waste) are reported and analyzed monthly,■ unless otherwise indicated, HR data are reported for all Stahl■ environmental stewardship in the supply chain: Stahl’s

corporate strategy is to initiate projects that promotetransparency throughout the supply chain. This includes thepromotion of responsible environmental practices in theindustries that the company serves. As an example, Stahl is a

Reporting scope
entities worldwide;■ for safety (SHE) reporting, all Stahl employees are in scope;■ theenvironmental performance indicators relate to Stahl’s
13 manufacturing sites.

Reporting scope – history for environmental data
Site

2018

2017

2016

2015

Calhoun

Y

Y

-

-

Graulhet

Y

Y

-

-

Hospitalet

Y

From October--

Kanchipuram

Y

Y

Y

Y

Leinfelden

Y

Y

Y

Y

Palazzolo

Y

Y

Y

Y

ParetsY

YY

Y

Peabody-

Before OctoberY

YPortaoY

YYY

Ranipet

Y

Y

Y

Y

Singapore

Y

Y

Y

Y

SuzhouYYYY

TolucaY

YY

Y

Waalwijk

Y

Y

Y

Y

Y=Yes, full year and - = not reported.

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Non-financial information
Wendel’s subsidiaries reviewed by an independent verifier

3

Methodological limitations and uncertainties■ oil: guidelines for National Greenhouse Gas Inventories,

The reporting methods for certain CO2 indicators may have certain
limitations due to the pragmatic considerations of collecting andconsolidating the relevant data.

■ oil: guidelines for National Greenhouse Gas Inventories,

Social indicators■ coal: guidelines for National Greenhouse Gas Inventories,

volume 2,
volume 2,
volume 2,

Total workforce

The total workforce is the number of employees with a permanentor fixed-term contract with the Stahl Group on the last calendar
day of the month. The data are reported in terms of full-time
equivalents.

■ steam: emission Factors for Greenhouse Gas Inventories,■ electricity: Ecometrica (2011) electricity-specific emission

factors for grid electricity;■ expected other indirect emission sources (scope 3) following the

Safety indicators

Green House Gas protocol.

Lost-time injury frequency rate

The lost-time injury frequency rate is the number of accidents
involving the loss of one or more days of working time that occur
over a 12-month period, per 1,000,000 hours worked. Accidents
while commuting between home and work are not included in thisindicator.
Environmental indicators
Carbon Footprint

The carbon footprint is calculated according to three scopes ofemissions:■ direct GHG emissions are those that occur from sources that are
owned or operationally controlled by the company—company
owned or leased cars, other company vehicles, gas and oil used on
its sites (Scope 1);■ indirect emission sources related to energy (in the form ofelectricity, steam, heat and cooling) are purchased from thegrid or district (Scope 2). The source of its emission factors are:

The carbon footprint data is reported annually.
Approach and methodology CO2 scope 3
Stahl reports its scope 1 and 2 emissions each year. Indirectscope 3 emissions have been quantified in 2017. Stahl worked
with an external consultant to calculate its scope 3 CO2 emissions
for the year 2017 and to provide the company with a model tocalculate its scope emissions on a yearly basis in the future, thatwas used for the estimation of the emission in 2018. This reportcontains a summary, which is required to report on following the
GHG Protocol “Corporate Value Chain (Scope 3) Accounting andReporting Standard (Chapter 11)”.
Standard
Stahl’s scope 3 emissions have been quantified based on the GHG
Protocol “Corporate Value Chain (Scope 3) Accounting andReporting Standard”. This standard lists 15 sources ofscope 3 emissions.

Category

Methodology

Cat 1: Purchased goods and services

Emissions related to raw materials have been estimated based on top 30 raw materials purchased, Top
15 chemical groups and top 10 types of packaging used.

Cat 12: End-of-life treatment of soldproducts

End-of-life emissions from sold finished goods have been estimated by assuming a carbon content of
80% and the assumption that all finished goods (i.e. coatings on leather) will be incinerated at the endof the product lifecycle.

Cat 4: Upstream transportation anddistribution

Available transport data for Waalwijk, including information about weight, destination, type oftransport (internal/external, paid for by Stahl or not) and mode of transport, has been extended toinclude estimations for travelled distance per destination.
Distances by truck have been estimated using Google Maps.
Intercompany trips were adjusted for by a correction factor of 50%.
Extrapolation from Waalwijk data to Global data has been done based on the amounts (kg) shippedfrom Waalwijk versus amounts shipped globally.

For CO2 eq emissions from scope 1, 2 and 3, there areuncertainties due to the intrinsic uncertainties from emission
factors.

Stahl reports Scope 3 emission in a range of 30 million CO2 eq,
since indirect emissions are an estimated calculation as per the
GHG gas protocol.

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Non-financial information
Wendel’s subsidiaries reviewed by an independent verifier

EnergyWaste

The energy consumption includes all energy sources consumed by
the 13 Stahl production sites around the world. The figuresindicated do not include energy consumed by offices andlaboratories that are not geographically connected to one of the
production sites.

The waste indicator includes all hazardous and non-hazardous
wastes generated by the 13 Stahl production sites around theworld. The figures do not include waste generated by offices andlaboratories that are not geographically connected to one of the
production sites.

Water

Furthermore, Stahl reports wastewater that is sent to an external
treatment center. This data only relates to the sites in Waalwijk andToluca. The other 9 Stahl production sites have their own
wastewater treatment plant.

The water consumption includes all water sources consumed by
the 13 Stahl production sites around the world. The figures do notinclude water consumed by offices and laboratories that are notgeographically connected to one of the 13 production sites.
The “Other water consumed” indicator is related to the Palazzolo
site in Italy. There Stahl is using water in addition to the usual
consumption for cooling, to help the community to maintain the
low level of groundwater. Water is taken and resent to the wellwithout any contamination, and thus does not contribute to water
scarcity.

Consolidation and internal controls

The HR and SHE Departments are responsible for consolidatingsocial and safety data based on the information provided by theindustrial group.
At each industrial site, the SHE Manager reviews safety andenvironmental data reported before the group-level consolidationis performed.
The social data relating to the workforce are compared against theconsolidated data in the group’s finance database for consistency.

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3.2.5 Tsebo

Introduction

The following principles underpin the Tsebo brand:

Tsebo overview and business model■ productivity: Tsebo manages functions that are not part of its

Founded in 1971 in South Africa as a food services company, theTsebo group is now the leading workplace management solutions
provider in Africa and the Middle East. Tsebo employs almost
40,000 people and operates on over 7,500 customer sites in 27
countries.
Tsebo's values are at the heart of its culture, and reflect thecompany's priorities;■ integrity: embrace highly ethical, moral and respectful behaviour,
without exception;■ enterprising: seek opportunity, be responsive, strive for continuous
improvement and nurture an entrepreneurial mindset;■ caring: caring for people, communities and the environment;■ diligent: be rigorous, efficient and dependable.
Tsebo offers to its clients (companies and organizations) a wide
range of integrated including maintenance, facilities management,catering, cleaning and hygiene, energy management and security.
Tsebo also specializes in remote camp services.
It operates in both the public and private sectors across numerous
market segments such as financial services, resources,
manufacturing, healthcare and service companies.

232 WENDEL - Registration Document 2018

customers’ core business but that are essential to their operations.
These services enable its customers to address the difficulties inpenetrating African markets in all tranquility, reduce their costs,
improve their profitability and focus on growing and developing
their business in Africa;■ measurability:

Tsebo supplies its customers with tangible,
quantifiable solutions: lower costs, added value, adherence toquality standards, reduction of risk, clear sales terms and quality
customer service;■ innovation: Tsebo encourages and develops innovation in all of its
divisions so as to improve the quality of service provided tocustomers;■ social development: Tsebo strives to create economic and social
value for African people and communities. The company
collaborates with customers so as to help develop skills, rural
enterprises,
local
small
to
mediumenterprises
andentrepreneurships. Tsebo fosters socially responsible investment
initiatives and supports various charitable causes;■ sustainable development: By making sustainable development

central to its business, Tsebo is attentive to environmental
protection and to the interests of local communities and in this way,promotes collective well-being;

WENDEL - Registration Document 2018