Environment,
Social &Governance2019 Report

Stahl GroupThis report has been prepared,
whenever possible, in accordancewith the GRI Standards: Core option.

ESG Team

Michael Costello

Ingrid Weijer

Mi Yanmichael.costello@stahl.com

ingrid.weijer@stahl.com

mi.yan@stahl.com

ESG 2019 Report | Introduction | Environment | Social | GovernanceContents

1
2
3
4

5

Message from the CEO

About this report

5

6

6

Introduction

7

About Stahl

8

Our commitments

10

ESG strategy

11

Responsible Chemistry & LCA

11

Environment

13

Climate change: GHGs and Energy

14

Water

18

Waste

19

ESG Performance20

Social21

Occupational Health & Safety

22

Attractiveness & talent retention

23

Ethical behaviour

24

Public-private partnerships

25

Stahl Campus®

26

7
8
9

Governance27

Stahl governance28

Industry governance29

Diversity

30

Ethics & compliance

30

Stakeholder engagement

31

Topics that matter

32

GRI table / ESG data

33

Code of Conduct

37

Statement of continued support

40

ESG 2019 Report | Introduction | Environment | Social | Governance“We continued to integrate ESG into
all aspects of our business in 2019, likethe Road to Zero safety campaign,
mandatory employee compliancetraining and the Responsible Chemistry
initiative focused on reducing theenvironmental footprint of the supply
chains that we serve.”

ESG 2019 Report | Introduction | Environment | Social | Governance

Message from the CEO
I am proud to present the latest Environment, Social &The 17 UN Sustainable Development Goals (SDGs) are

Governance (ESG) report, which provides an overview

a call for governments, businesses, civil society andof Stahl’s activities in 2019.

other organizations around the world to take action
and achieve a better future. With this in mind, we have

For this report we have adopted the commonly usedprovided updates throughout this report on those SDGs

ESG terminology to assess the more specific actions

for which we believe Stahl can make the greatest impact.

that Stahl has taken on Corporate Social Responsibility(CSR) during the year. Acronyms aside, I have always feltthat sustainability and the welfare of its stakeholders
are critical for Stahl’s success. I also believe that ESG
performance is directly linked to financial performanceand is necessary for creating lasting value for ourcustomers and shareholders. That’s why we continued tointegrate ESG into all aspects of our business in 2019, likethe Road to Zero safety campaign, mandatory employee
compliance training and the Responsible Chemistry
initiative focused on reducing the environmental footprintof the supply chains that we serve. Another significant
ESG highlight in 2019 was the certification of Stahl’s
global leather portfolio in the ZDHC Gateway - Chemical
Module, which underlines our long-standing commitment
to transparency in the complex world of chemical

2019 was a challenging year but we emerged from it

substance compliance.

stronger than ever. Indeed, the industry will always face
new challenges but Stahl will continue to view them as an

Climate change is the defining issue of our time andopportunity, to take action and create a better future.

Stahl fully recognizes the need to continuously reduce
its Greenhouse Gas emissions. In 2019 we beat our

Sincerely,

5-year target and reduced CO2 emissions by 25% (since2015) but there is still more to do. Stahl is investing in

Huub van Beijeren

renewable on-site energy sourcing, we have stepped-up

CEOresearch into renewable carbon technologies, andthroughout our offices and manufacturing sites wecontinue to reduce the use of single-use plastics.

5

ESG 2019 Report | Introduction | Environment | Social | Governance

About this report
The 2019 ESG report (formerly Corporate Responsibility

resulting from its activities. This review covers the risks& Sustainability Report) covers the key activities overlinked to employees, suppliers, and to the external supply

the period and corresponds to Stahl’s strategy andchain that we serve. Stahl has adopted due diligencestakeholder desire for transparency on environment,

policies on health, safety, environment and humansocial and governance.

rights that mitigate the risks identified in this review.
This risk assessment was cross-checked with two

This report has been prepared, whenever possible, in

types of organizations, used as reference sources:

accordance with the GRI Standards: Core option / self�	independent standards: MSCI (Morgan Stanleydeclared. Environmental, Safety and HR data has been

Capital International) and SASB (Sustainability

validated by a 3rd party verifier (Deloitte).

Accounting Standards Board)�	companies comparable to Stahl in terms of

Stahl has published its annual reports on environment,

industry sectors, geographical spread, disclosuresocial and governance topics since 2013. The Globalof CSR risks and materiality

Reporting Initiative (GRI), the United Nations (UN) Global
Compact and the 17 Sustainable Development Goals

Stahl’s identified gross risks are listed below. Gross risks(SDGs) have been key references in the preparation of

are those which impact the company and its external

these reports and continue to provide valuable guidanceshareholders, independent of mitigation policies thatfor the company.

may be in place to reduce them.

Stahl’s approach to ESG is grounded in its long-termbusiness strategy and based on the insights ofHealth and safety

Occupational healthand safety

ESG performanceof products and services

Increasing demand
and regulation forsustainable chemical
products

Environment

Lowering GHG
emissions that
contribute toclimate changeshareholders, clients, supply chain and industry partners.
CSR versus ESG
CSR (Corporate Social Responsibility) describes a
company’s efforts on having a positive impact on
the environment, employees, consumers and thewider community.

Impact on water
resources

ESG (Environment, Social and Governance) measures CSR
activities to give a precise assessment of a company’s

Hazardous waste
management

actions, and is used as a key marker for investors. Stahl’s
ESG reporting looks at how the company is responding toexternal influences, risks and trends like climate change
and decarbonisation, but also at how it treats its workers
and manages its supply chains.

SocialAttractiveness andtalent retention

GovernanceCorruption and bribery

Risk assessment
Stahl has performed a detailed review of its risk
assessment and control policies, in accordance with

� ESG reports since 2013

the requirements of the European Law (including the� Compliance reports

Non-Financial Statement and the Duty of Care), on� Topics that matter – GRI materiality matrix

environmental, social, human rights and corruption risks

6

Read further:

Introduction

WANT TO LEARN MORE?
Stahl’s History

Life Cycle Assessment

Stahl’s Sustainability Strategy for a better future

The complexity of sustainability

The Stahl Sustainability Standard

Circularity: refurbishing a leather couch with

Igniting the age of Responsible Chemistry

Stahl chemistryESG 2019 Report | Introduction | Environment | Social | Governance

Stahl creates the chemistry for coatings and processing

Bangladesh, Brazil, China, Colombia, France, Germany,

that makes many everyday materials look good, feel

India, Indonesia, Italy, Japan, Mexico, Netherlands,

softer, resist scratching, repel stains, diffuse heat, andPakistan, Singapore, Spain, Turkey and the USA.

last longer. There is a little bit of Stahl everywhere.
As a supplier of chemical products and related services,

1. About Stahl

Stahl considers the health and safety of its employees

Stahl provides products and services to high-end

to be its primary responsibility. Stahl is a model forindustries in mobility, fashion & footwear, architecture &workplace safety, with a low accident frequency rate.

construction, interior spaces and paint, ink & packaging

Stahl also ensures that the impact of its activities on themarkets. In close collaboration with our partners, wesurrounding ecosystems is limited. Stahl’s Environment,

initiate activities that promote transparency and provide

Social & Governance (ESG) strategy is to promote greater

high-performing, low-impact solutions to drive thetransparency throughout the whole supply chain, leadingtransition to a fully sustainable supply chain and a

to a progressively lower environmental footprint for thecircular economy.

industry. ESG also represents a significant opportunity
for Stahl, to gain competitive advantage, attract potential“Our purpose is to create
responsible chemistry thatmeets tomorrow’s needs”

employees and to drive operational excellence throughout
the company.
Indeed Stahl is committed to attracting (and retaining)

In 2019 Stahl operated 11 manufacturing sites andqualified and talented people, and strives to achieve this by

35 applications laboratories in 24 countries aroundthe proactive use of employee engagement tools, diverse

the world, employing 1,847 people, 30% of whom aretraining modules and a deep-rooted corporate culture.

focussed on technical support. The key countries where
Stahl does business are, in alphabetical order: Argentina,

8“If it can be imagined, it can be created.”Stahl at a glance
Input
Stahl creates specialty chemistry for coatings, processing,and treatments of many different everyday materials.

11

61

Manufacturing sitesof which 50% are locatedin emerging markets

600

Nationalities

35

Sales
38 offices

4

100
00

Stahl Campus®
locations+

Workforce

Technical Centers

1800
24% |

73

76%

Global suppliers from54

Technical experts
30% in technical activities

people working on
innovations every day

countries

11

Active patent families**Including patent applications

9

R&D
Labs

Centers of
ExcellencePowered by Wendel Group

Markets & products
Our products enhance:

Automotive | Footwear, Apparel & Accessories | Architectural & Interior
Design | Industrial Applications | Leisure & Lifestyle | Home Furnishing

Leather | PU | PVC | TPO | Fabric | EPDM | Bio-based substrates

Process
Stahl provides responsible, high-performance technologies and drives thetransition to a transparent, sustainable supply chain and a circular economy.

Our driving values

Cooperation

Responsibility

Initiative

Imagination

One team, one task, one Stahl

Always contribute to a sustainable future

Go for it!

Think beyond boundaries

ESG* performance of our productsLife Cycle Assessment
Low-Impact
Manufacturing Chemicals

Overall goal/output
Responsible
Chemistry

Biotechnology

Improving environmental
footprint

Circularity*Environment, Social and Governance (ESG)

Our commitments

Our partnerships

UNIVERSITIESA responsible organization

A sustainable future

OutputAs a world leader, Stahl uses responsible chemistrythat meets tomorrow’s needs - for our customers and society.

The result of our efforts
Environmental, Social andGovernance performance

Responsible
Operations

Industry Education& Training

Leader in environmental improvement
projects in emerging countries

Cleaner
Ganges in2022�	€ 809 million sales revenue in 2019�	Technologies for durable andmarket-compliant products�	1,200+ products in the ZDHC gateway
highest conformance level�	93% ISO 14001 | 100% ISO 9001
of global production volume�	76% of our coating solutions
are water-based� -25% CO2 emission since 2015�	100% renewable energy at
European Manufacturing sites
�	35% of all electricity isrenewable�	50% of energy generated
with on-site solar panels
at Stahl Brasil�	842 people trained at
Stahl Campus® in 2019 in
The Netherlands, Mexico,
India and China (8420
beneficiaries - every trainee
impacts 10 others)�	Public Private Partnership with
Solidaridad & other non-profits.
Target to reduce leather-related
water pollution by up to 40% in
Kanpur, India

ESG 2019 Report | Introduction | Environment | Social | Governance2. Our commitments
The below ESG landscape provides a flavor of all the laws

ISO certification, safe workplace monitoring, waterand regulations, (mandatory and voluntary) guidelines andcontrols, social audits, risk assessment questionnaires

initiatives that impact the company. Stahl is subject toand chemical conformance testing of its products.

continuous assessment of its ESG performance, e.g.:
Figure 1: ESG landscape

Our world

Our stakeholders

Our shareholders

Environmental laws are focusedSocial laws centered on universal human

Governance laws focused on board

on a healthy sustainable planet

rights and environmental self-governanceeffectiveness, organizational hierarchy,

� UN Global Compact

focused on chemical compliance &management responsibility,

environmental stewardshipremuneration, stakeholder engagement

�	
UN Sustainable Development
�	Client specific policies and initiatives

Goals (SDGs)�	
UN Universal Declaration of� International laws and regulations�	
Zero Discharge of Hazardous

Human Rights

Chemicals(ZDHC)� Paris Climate Agreement
�	International Labour Organization
(ILO)
�	
Global Reporting Initiative (GRI)

information
� Local laws and regulations
� Duty of Care

� Ecovadis

� Sapin II�	International Organization for� Chemical legislation includingStandardization (ISO)- ECHA / REACh�	
Global Automotive Declarable

Co-operation andSubstance List (GADSL)

Development (OECD)of non-financial and diversity

� bluesign®

� UK Modern Slavery Act�	Organization for Economic�	
Directive 2014/95/EU disclosure- Toxic Substances Controle Act(TSCA)

� Leather Working Group (LWG)

� European Commission

� OEKO-TEX®

� EUR-Lex

Responsible chemistry
Our commitments focus on our Environment, Social and Governance performance�	
Stahl Safety, Health andEnvironment Policy

Substances List (Stahl MRSL)� Stahl Sustainability Standard�	Code of Conduct for Business Partners

� 12 Principles of Responsible Chemistry�	Code of Conduct for Employees

� Diversity & inclusion policy

10�	
Stahl Manufacturing Restricted

ESG 2019 Report | Introduction | Environment | Social | Governance3. ESG strategy
5.	People & society: employees and the communities

Stahl’s goal is to achieve a more transparent industry

around usthat continuously reduces its environmental and social
footprint. The company promotes environmentally andsocially responsible practices through its Codes of

These focus areas allow the internal organization to

Conduct, the use of natural and renewable resources

implement its ESG strategy.

where possible and a continuous commitment to
reduce Greenhouse Gas (GHG) emissions.

4. Responsible Chemistry & LCA
Stahl and its key partners in the supply chain are

Rethinking priorities, rewiring production

increasingly aligned to the United Nations Global

The world is facing challenges that require us to rethink

Compact, the world’s largest Corporate Sustainability

priorities, drive environmental awareness and adapt

initiative, and to the 17 United Nations Sustainableproduction processes. The road to responsible chemistry

Development Goals (SDGs) established in 2015. To

began in the 1970s with the introduction of Stahl’s first

demonstrate its progress, the Stahl ESG annual reportwater-based polyurethanes for coatings and finishes. In

is submitted to the UN Global Compact each year.

2019 the company introduced its Responsible Chemistry
policy, formalizing its commitment to continuously

The Stahl Sustainability Standard

reducing the environmental footprint of the supply

To achieve our sustainability goals, the company

chain it serves. The policy also ensures the alignment

identified five focus areas:of its product portfolio development to the future

1.	Raw materials: suppliers and the products

needs of its customers.

and services they provide
2.	Responsible operations: all activities associatedThree categories are defined under the Responsible

with our laboratories, offices and manufacturing sites
3.	Trusted partnerships: co-operations with third
parties throughout the supply chain

Chemistry policy:
1. Low-impact manufacturing chemicals
2.	Biotechnology and renewable carbon content

4.	Innovative solutions: the products and services
that we offer to our customers

to replace depleting raw material resources
3. Waste and recycled content, contributing to circularity

Figure 2: Stahl’s Responsible Chemistry model

Low-Impact Manufacturing
Chemicals

Biotechnology

Overall goal/output:
Improving environmental
footprint

11

Circularity

ESG 2019 Report | Introduction | Environment | Social | Governance

Stahl’s 12 Principles of Responsible Chemistry

fruit or plant waste). Stahl’s biobased polyurethanes

1.	
Resource efficiency. Avoid limited, finite

and Proviera® - Probiotics for Leather™ are included

feedstock where possible

in this category.

2.	
Atom efficiency. Chemical solutions witha high atom efficiency

Contributing to circularity

3.	
Decarbonization of energy. Energy efficient

Stahl is committed to the idea of encouraging theoperations, sourcing from renewable energy

restoration and regeneration of resources and inwhere possible

accelerating the transition to a circular economy (as4. Water management. Responsible water usage,clean effluent outflow, reduced demand

opposed to the take, make, waste of a linear economy).
Products or technologies that contribute to the repair

5.	
Waste management. Assign value to waste as

and prolongation of materials, and products derived

a resource for energy and new materials

from waste or by-products which would otherwise be

6.	Best available technology. i.e.: with respect tothrown away, are included in this category. Technology

sustainability and circularity
7.	
Support innovation. Flexible, creative,
insourced and outsourcedthat allows for the successful composting andbiodegradation of chemicals, or substrates,
is also considered in this category.

8.	
Share knowledge (educate). Stahl is aknowledge-based company
9.	
Safety, Health and the Environment (SHE). Minimize

Life Cycle Assessment (LCA)
The impact of a product or process on the environment

risk of exposure to hazards for employees, customers

is measured using Life Cycle Assessment (LCA)

and the environment

methodology. LCA provides quantitative data in the10.	Matching chemistry. Understanding the complete

language of the environmentalist and in a format thatvalue chain of our products – including recycling,allows meaningful comparisons to be made about

composting – & matching usage with end-of-life

environmental impact.

11.	Product stewardship. Chemical compliance, services
for the full life cycle of a product, chemical leasing,production efficiency
12.	Measure and assess. Standardized methodologies
to measure the impact of our products and processes
on health, safety and the environment

Low-impact manufacturing chemicals
This category refers to the impact of chemicals on
human health and the environment. For example,
chemicals which are free of restricted substances
are included in this category, like Stahl Neo® &Stahl EVO®. Stahl products that have demonstrated(either during their own manufacture or when usedby customers) clear improvements in C02 emissions,energy consumption, water pollution or waste reduction,
are also included in this category.

In 2019 Stahl began calculating the environmental
impact of several of its key products in the leather

Biotechnology to replace non-renewable resources

chemicals portfolio. This LCA project will be expandedThis category refers to chemistry derived from bio-basedin 2020 to include more products and processes.

or renewable carbon resources as opposed to fossil fuel12

based or depleting resources, and to products that

The company believes that LCA will be an important

contribute to the performance of substrate materials

value-added service for its customers in the supply

made from renewable or natural resources (e.g.: residual

chain in the future.

Environment

WANT TO LEARN MORE?
Energy: renewable energy sources get first preference

Effluents and waste as a by-product for a circular economy

Water & Effluents: reducing water pollution and

Project to reduce single-use plastics at Stahl Ibérica

effluent emissions

Zero Discharge of Hazardous Chemicals (ZDHC)

Project Pollution Prevention and Efficient Water

bluesign®

Use in Kanpur-Unnao Leather Cluster

ESG 2019 Report | Introduction | Environment | Social | GovernanceOur commitment begins with our widely communicatedGreenhouse gasses (GHG) like methane, PFCs andcorporate strategy on ESG: to achieve transparency

CO2 contribute to global warming, ozone depletion andthroughout the whole supply chain, leading to a moreclimate change. Stahl made an inventory of its scope 1,

sustainable industry and a progressively lower

2 and 3 emissions which gives insight into the impact ofenvironmental footprint. This means reducing thethe greenhouse gas emissions in its value chain. This isenvironmental impact of our own operations (including

a step towards managing emissions-related risks andpurchased raw materials) as well as that of the supply

opportunities and reducing value chain GHG emissions.

chain into which we provide our products and services.

Of greenhouse gasses identified, CO2 is the mostimportant for Stahl.

The company is continuously upgrading its manufacturing
sites and laboratory facilities in order to achieve energy,

Stahl’s main direct source of CO2 emissions come from its

waste and water efficiencies and to reduce ourmanufacturing sites, i.e.: burning fuels like gas, furnace oil

environmental footprint. To monitor the effectiveness ofand briquettes (scope 1 / direct emission) and consumingthese mitigation activities, we measure and report on:electricity (scope 2 / indirect emission). Stahl employees� CO2 emissions and energy

travel by car and plane and its products are shipped by air,

� Waterrail and road (scope 1 and 3). CO2 is emitted indirectly when

� Wasteelectricity is generated elsewhere that may have emitted
CO2 (scope 3). CO2 emissions are calculated according to
the GreenHouse Gas (GHG) protocol.

1. Climate change: GHGs and Energy�	Scope 1: Direct GHG emissions are those from sources
owned or operationally controlled by the company:
company owned or leased cars, other company vehicles

QUICK FACTS

and gas and oil used on site�	Stahl achieved its 5-year goal and has�	Scope 2: Electricity indirect emission sources are those

reduced C02 emissions by 25% since 2015
�	On-site generation of solar energy atthat occur through buying in energy (electricity, steam,heat and cooling) from the grid or district heating or

Stahl Brasil site was an example of its

cooling systems

commitment - solar panels are already� Scope 3: All other indirect emission sources

supplying 50% of the factory’s energy needs

Figure 3: GreenHouse Gas (GHG) protocol

Purchased goods
and services

Scope 2

Scope 1

Indirect

DirectScope 3

Scope 3

Indirect

Indirect

Leased assets

Purchased electricity,
steam, heating &cooling for own use

EmployeecommutingCompany
facilities

Capital goods
Business travel

Fuel and energy
related activities
Transportationand distribution

Investments

Processing ofsold products

Franchises

Use of soldproducts

Waste generated
in operations

Upstream activites

14

Company
vehiclesTransportationand distribution

Reporting company

End-of-life
treatment ofsold products

Leased assets

Downstream activites

ESG 2019 Report | Introduction | Environment | Social | Governance

CO2 emissions reduced by 25%
Aligned with Paris Climate Agreement - an agreement(-18% per tons produced). Switching to renewablewithin the United Nations Framework Convention onenergy at European sites and investing in long-term

Climate Change (UNFCCC), relative to greenhouse gas

energy efficiency equipment have been key

emissions mitigation, adaptation, and finance - Stahlcontributors in this achievement.

has reduced its CO2 emissions by 25% since 2015

Graph 1: Absolute C02 emissions since 2015
40
35

Scope 1

-25%

30

Scope 2

25
20
15
10
5
0
2015

2016

2017

2019

2018

100

Data verified and validated by Deloitte.

80
Table 1: Scope 1 & 2 emissions

60

2019

2018

2017

Scope 1

18,38017,114

16,915

16,924

15,569

Scope 2

6,585

7,119

8,984

18,59517,75924,96624,23225,89835,51933,152

0.120

0.106

0.109

0.171

0.169

CO2 emission scope 1+2 (in tons)

40

CO2 intensity

(1)

(1)

20

2016

2015

Scope 1 and 2 CO2 emission / production volume
Data verified and validated by Deloitte.

0
2016

Scope 3 GHG emissions

2017

2018

Scope 3 emissions have been calculated as per the GHG

Purchased goods and services (category 1) represent

Protocol Corporate Value Chain Accounting and Reporting

the largest portion of the company’s indirect emissions.

Standard. This calculation tool is designed to understandThis includes raw materials purchased and also office

the full value chain impact of activities and helps to focus

supplies, IT services and packaging.

Stahl’s efforts on significant sources of GHG emissions.

15

2019

ESG 2019 Report | Introduction | Environment | Social | Governance

40
35
30
Table 2:25
Scope 3 GHG emissions
Scope 3:20
estimation of the other indirectemission sources (CO2-EQ. X 1 million)
15

2019

2018

2017

2016

500-530560-590560-590500-530

10
Data verified and validated by Deloitte.

5
0
2015

2016

2017

2018

6%

5%

5%

5%

9%

9%

10%

Graph 2: Scope 3 GHG emissions per category
100

10%

80
25%

2019

Cat 1: Purchased goods
and services
Cat 12: End-of-life
treatment of sold products

23%

24%

25%
Cat 4: Upstream
transportation anddistribution

60

Other (e.g. Capital goods,
downstream transport anddistributrion)

40
59%

63%

62%

60%

2016

2017

2018

2019

20

0

Data verified and validated by Deloitte.

Our renewable energy commitment
Using energy more efficiently and switching to renewableenergy sources is essential for combating climate change.
Upgrading our production sites and laboratory facilities
helps Stahl to achieve energy efficiencies which, more
importantly, improve our environmental footprint.

“Our site in Brazil has a self-generation
method to obtain 50% of its energy from

Stahl’s energy consumption is the sum of electricity, gas,

the sun. The energy is taken from the sunoil, steam, renewable briquettes and high speed diesel

by solar panels and is injected directly

consumed at the manufacturing sites (see the pie chart

into the company’s electrical system.”on the next page). Energy is reported as the total energy
consumed in terajoule (TJ) and per production volume:

Fabiano André Treinthe energy intensity. Several energy projects are underway

Stahl Brazil

towards the goal of self-sufficiency and renewable energy
sourcing. As production volume decreased in 2019 (dueto softer demand), energy per ton produced slightly
increased at the same time, while total energy
consumption in TJ remained stable.

16

ESG 2019 Report | Introduction | Environment | Social | Governance

Table 3: Energy consumption

2019

2018

2017

2016

Energy (TJ)

380

380

390

319

Share of Renewable energy

35%

34%

34%

-

Total production volume208,114228,440

238,590

207,923

Energy intensity (TJ)*

0.001820.001660.001630.00153

Data verified and validated by Deloitte.

* Energy intensity = total energy consumption (TJ) / total production volume (kg)

Energy intensity: total energy consumed
per production volume
The more you produce, the more energy you need.

high speed diesel and renewable vs. traditional and

Therefore we report energy intensity, i.e.: total energy

grey electricity) and it introduced a distinction between

consumed (in TJ) / per production volume. In 2019 Stahlrenewable, traditional and grey electricity sources.

included more energy sources in our reporting (briquettes,

Graph 3: Stahl energy sources2%

2%

Renewable | Briquettes
12%9%Renewable | Electricity - purchased
Renewable | Electricity self-generated
20%

Non renewable | Gas

22%

Non renewable | Furnace Oil
Non renewable | Grey electricity
32%
1%

Non renewable | High Speed Diesel
Non renewable | Steam

Data verified and validated by Deloitte.

17

ESG 2019 Report | Introduction | Environment | Social | Governance

2. Water
QUICK FACTS�	Stahl consumed less water in 2019 because

based products and improving the quality of its own
water effluent stream. On the commercial side, Stahl’s
purpose is to avoid water pollution linked to its products.

production volumes were slightly lower, but

The company invests significantly into projects andalso because of continuing efficiency gains

technology designed to reduce water consumption

at its manufacturing sites

and effluent for its customers in the supply chain.

�	In November 2019 Stahl hosted asustainability seminar for our leather
supply chain partners in China. This training
included over 50 participants from 23
companies who came together with acommon goal of reducing the environmental
impact of the leather supply chain,including its water impact“The goal of the Kanpur cluster project is
to reduce the volume of effluent water
discharged into the Ganges up to 40% andStahl uses water from its adjacent municipality
sources and from groundwater. Water is requiredfor 2 main purposes:�	Commercial products using water-based
technology (where water replaces petrochemicalbased solvents)

persuade tanneries to introduce leathermaking technologies and processes thathave a lower environmental impact.”
Tuncay Deriner
Managing Director IPB Region�	Process water at manufacturing sites (cleaningtanks, pipes and for processing, heating & cooling),
and utility water for labs and offices

Water KPIs
Stahl consumed less water in 2019 because production

Water is one of Stahl’s strategic focus areas. The

volumes were slightly lower but also because ofcompany dedicates significant resources to researchingcontinued efficiency gains at the sites. Water consumed

the reduction of water consumption, developing water-

per ton produced is stable versus previous years.

Table 4: Water consumption

2019

2018

2017

2016

Water consumption (m³)

330,649

344,922370,855

355,041

Other water use (m³)*

460,097456,820561,788

506,056

Total Water Used (m³)

790,746

801,742932,643

861,097

Total production volume (tonnes)

208,114228,440

238,590

207,923

1.588

1.510

1.554

1.708

Water intensity**

Data verified and validated by Deloitte.

* 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 high volumes of withdrawn water). This water (cooling water) is kept completely separated from chemical products and discharged
into the river Seveso at controlled temperature.
** Water intensity is the amount of water used per tons produced = Water consumption (m3) / Total production volume(excluding Other water use).

18

ESG 2019 Report | Introduction | Environment | Social | GovernanceEffluent-reducing technologies

production sites and laboratory facilities to further

In addition to a continuous investment in the on-site

reduce waste and improve its environmental footprint.

treatment of wastewater generated at our sites, Stahl has

Stahl’s policy includes waste management strategies

introduced effluent-reducing technologies to its productthat promote waste minimization, re-use, recovery andportfolios, like Proviera - Probiotics for Leather™,recycling, as appropriate. Waste reduction and finding

Catalix® cationic polymers, water-reducing technologies

useful outlets, especially avoiding waste, are important

like Stahl EasyWhite Tan™ and product portfolios likeeconomically and environmentally. Stahl’s ambition for®

Stahl EVO and Stahl Neo , which are compliant towaste and water is to achieve a high level of circularity,

manufacturing restricted substances lists frombased on the principle that a closed loop system requires

initiatives like the ZDHC foundation.

(no or less) resources, since ‘waste’ is input (raw material)®

®

instead of waste.
Reducing water pollution with our partners
Stahl actively participates in public-private partnerships
in India and Ethiopia to reduce water pollution. In India,
Stahl has joined forces with the NGO Solidaridad andother partners to reduce pollution in the Ganges linked
to the Kanpur Leather Cluster. In Ethiopia, Stahl,
Solidaridad and CSR Netherlands initiated the Green
Tanning Initiative, which introduces low impact leathermaking and aims to create sustainable employment in
the Ethiopian leather industry.
Stahl regularly organizes sustainability roadshows forstakeholders. These seminars focus on safety, health,housekeeping, chemicals management and technology
best practices that reduce water pollution during the
manufacturing process.

“At Stahl Ibérica, we replaced plastic bottles
with glass bottles and have given each worker
an individual cup and bottle. We removed
plastic cups from drinking fountains andvending machines and replaced them withcups made from bamboo waste.”
Maria Sirvent
Stahl Ibérica

In November 2019 the company hosted a sustainability
seminar for its leather supply chain partners in China.

Chemical waste can contribute to a circular economy

This training included over 50 participants from 23

Stahl considers the disposal of waste as a last resort,companies who came together with a common goal ofpreferring to see it and treat it as a by-product that

reducing the environmental impact of the leather supply

contributes to other processes. Its manufacturing sites

chain. Stahl has hosted similar events in India, Pakistanalready have water treatment plants that reduce theand Bangladesh which included presentations fromamount of wastewater (classified as hazardous waste)

UNIDO, the Leather Working Group, Solidaridad and CLRI,

sent to third parties for further treatment.

and attracted an average of over 300 visitors per event.
Wherever Stahl operates around the world, it tracks andreports the different types of waste generated. This

3. Wasteincludes production waste, waste from laboratories,
packaging, cleaning water, glass, paper and plastic.

QUICK FACTS�	Non-hazardous waste reduced by 286 tons

This gives the company an insight into the possibilities
for reducing, reusing, recycling, restoring and prolonging,as part of its circular economy commitment.

�	Waste water sent to external treatment
reduced by 1,223 tons�	Initiated projects to eliminate single-use
plastics at our sites around the world

At multiple locations around the world, the company
has begun initiatives to eliminate single-use plastics,
and will continue until all possibilities have been
explored and enacted.

Stahl reduces, improves and monitors waste at its
manufacturing sites and is continuously upgrading its

19

ESG 2019 Report | Introduction | Environment | Social | Governance

Table 5: Waste generation

2019

2018

2017

2016

Hazardous Waste (tonnes)

11,302

10,962

10,538

9,748

Non-Hazardous Waste (tonnes)

1,521

1,807

1,584

1,476

Total Waste (tonnes)

12,824

12,76912,122

11,224

Total production volume208,114228,440

238,590

207,923

Waste intensity*

0.062

0.056

0.051

0.054

Waste water sent to external treatment (tonnes)**

14,397

15,62018,12415,038

Data verified and validated by Deloitte.

* Waste intensity =Total waste (tonnes) / Total production volume** This indicator only represents the Stahl sites in Waalwijk and Toluca. Waalwijk = cleaning water of tanks. Toluca = waste water that iscollected from the production plant (cleaning of tanks, reactors and equipment in general) and also services (bathrooms and showers).
The other sites have an on-site waste water treatment installation.

4. ESG Performance
QUICK FACTS�	Responsible Chemistry initiative
launched, in which technology and productin the materials they provide. To give us a clear indicationof whether restricted substances are present or within
the limits of the MRSL, the company developed its own
Compliance Checker.

development activities are categorized
into three levels of environmental
impact reduction�	Introduction of new ZDHC compliant
waterproof technology with 100% polymericDensodrin® solutions

Member of ZDHC�	Expansion of the Stahl Neo® portfolio

Stahl became a ZDHC Value Chain Affiliate in�	1200 products approved to Level 3

October 2016 and officially joined the foundation in

ZDHC Gateway

its commitment to help lead the clothing and footwear
industry towards its 2020 goals. A positive list of Stahl’s
ZDHC compliant products (over 1,200) are publicly

Much of Stahl’s research and application development

available on the ZDHC Gateway portal.

is focused on reducing the environmental impact of its
products. In 2019, 18% of global R&D projects werelinked to the elimination of restricted substances (e.g.:
ZDHC, bluesign®, ChemIQ and Reach) and the new raw
materials to replace them.

bluesign® system partner
As a bluesign® system partner, Stahl focuses on

There are currently 20+ basic research projects focused

replacing restricted substances in its products withon finding renewable carbon alternatives to petroleum-alternatives that are compliant to the bluesign®

based polymers for polyurethanes, a core technology

substance list. Stahl achieved the bluesign® system

for Stahl.

partner status in 2017. bluesign® approved products
are also visible on the ZDHC Gateway portal.

Chemical Compliance
Stahl works closely with consumer brands in the supply
chain to anticipate restrictions on chemical substances
and act ahead of time. This means that our suppliers are
made aware of the restrictions on substances contained

20

SocialWANT TO LEARN MORE?
Stahl SHE policy

Our trusted partnerships for social responsibility

Occupational Health & Safety at Stahl

Project Pollution Prevention and Efficient Water Use

Employer visionin Kanpur-Unnao Leather Cluster

Stahl company culture

Green Tanning Initiative in Ethiopia

Learning at Stahl

Stahl Campus®

Our CSR Policies and Statements

Video: How a leather product is madeStahl Code of Conduct for Business Partners

Video: Discover how our powder coatings can

Anti-corruption at Stahlmake a differenceESG 2019 Report | Introduction | Environment | Social | Governance

As a supplier of chemical products and related services,

Road to Zero (R20) program & Zero Tolerance

Stahl considers the health and safety of its employees

Stahl’s Zero Tolerance Policy defines unsafe behavior toas its primary responsibility. Its Zero Tolerance policy forensure that people do not get injured at work. Stahl has

workplace injuries is based on behaviour, awareness andalways placed a strong focus on providing safe products

reducing risk.

to its clients and a safe working environment for
employees and on-site contractors.

1. Occupational Health & Safety
QUICK FACTS�	In 2019 Stahl implemented new criteria forgoverning and reporting on SHE and process
safety in order to reflect the occurrence ofsafety incidents more accurately�	Implementation of a new safety awarenesscampaign, called R20 (Road To Zero)�	Total recorded injuries frequency rate was
reduced by 2,178 in 2019

The pillars of Stahl’s R20 (Road To Zero) program are:�	A true safety culture is a mindset that prevails insideand outside the workplace�	A good safety record is achieved by the effortsof everyone

All Stahl’s activities, policies, monitoring, reporting
and training are aimed at creating a true safety
culture with zero injuries and accidents.

� 	The consequences of work-related injuries
affect people’s lives at home�	A zero-tolerance policy on unsafe behavior
ensures people are not injured at work

Stahl’s Safety, Health and Environment (SHE) policy
The key principles of the SHE policy are:

Safety key performance indicators

� A strong safety culture across the organization

To ensure continued improvement in the evaluation

�	Safety, health and environment as Stahl’s priorityand prevention of risks, Stahl tracks safety indicators.

�	Safety is more important than achieving a

Each month it reports injuries, incidents, audits,

short-term result�	Implement best industrial practices,training, engineering projects and other prevention
methods, both internally and to its shareholders.

comply with all legal requirements�	Knowledge as the basis for all decisions
�	Require employees to be trained in thesafety skills required

Table 6: Safety KPIs

2019

2018

2017

2016

Total Recorded Injuries Frequency rate

5,444

7,662

6,641

7,261

Lost Time Injuries Frequency rate

1,134

1,035

1,771

1,613

Severity rate

0.031

0.018

0.059

0.016

Data verified and validated by Deloitte.

TRI = The total recorded injuries frequency rate is calculated as number of total recorded number of injuries in the last twelve months
over total number of worked hours and referenced to a base of 1,000,000 h.
LTI = The lost-time injury frequency rate is the number of accidents involving the loss of one or more days of working time in the lasttwelve months over total number of worked hours and referenced to a base of 1,000,000 h.
SR = The severity rate is the number of lost working days due to injuries in the last twelve months over total number of worked hours
and referenced to a base of 1,000 h.

22

ESG 2019 Report | Introduction | Environment | Social | Governance

2. Attractiveness and talent retention

Employee engagement
Stahl’s new Employee Engagement Platform (EEP)QUICK FACTS�	Implementation of the Employee
Engagement Platform (EEP) in 2019enhances the onboarding process for new employees,with efficient and effective learning tools and progress
tracking for employee learning.

�	90 women in supervisory positions in 2019,23.38% of total supervisory positions�	15.32 training hours per full-time
equivalent (FTE) in 2019
“We introduced a new Employee Engagement
Stahl believes that the future workplace will be defined

Platform, which enables each employee toby personalized solutions, wellbeing, safety and a focus

participate in the most relevant training

on diversity. New generations already expect companies

programs. It ensures that each employee

to “walk the talk” on environmental, social and governancegets the training needed to fulfill their

topics. Rigid and complex hierarchies will be a thing of the

responsibilities.”

past, and leadership will require emotional intelligenceand cross-functional team skills. Organisations will

Sterrin Cremer

become flatter, with more power devolved to teams.

Stahl Holdings

In order to prepare for this, Stahl is focusing on
ensuring it remains attractive for all generations.
Employment
Attractiveness and talent retention

The total number of employees (headcount) was

Activities in 2019 have been focused on talent retention

1,847 at 2019 year-end; 150 less than at the end

and remaining attractive for potential and new employees.

of 2018. The reduction is linked to the completion

�	Focus on employee engagement, diversityof the complexity reduction project and reflects

management and equal opportunity�	Reinforce Stahl culture and DNA

the consolidation of manufacturing sites in 2019,
in Spain and India respectively.

�	Transfer knowledge and information effectively
within the company

The breakdown of FTE’s (full-time equivalent) as�	Hire and coach people in line with business goalsof December 31, 2019 and the change compared�	Create an open, transparent and fairto the prior year-end per region is as follows:management style�	Emphasize the benefits of Stahl’s truly
international team

Table 7: Employment by region

2019

2018

Change

EMEA

901.6

962.5

60.9

Asia-Pacific

384.0

387.0

3.0

India and Pakistan

274.0

317.0

43.0

North and South America

267.0

305.6

38.6

1,826.6

1,972.1

145.5

Data verified and validated by Deloitte.

23

ESG 2019 Report | Introduction | Environment | Social | Governance87.6% of employees are on permanent contracts.

3. Ethical behaviour

The Stahl workforce is 76% male and 24% female.
These ratios are in line with the market for theactivities and location in which they take place.

QUICK FACTS

Voluntary staff turnover rate in 2019 was 4.24%

�	Due diligence on the Stahl Code of Conductcompared to 5.05% in 2018.

for Business Partners - auditing selected

Equality, Diversity & Inclusion�	Accounting procedures with best practices

suppliers on implementation
Equal treatment is at the heart of the organization

for prevention and detection of corruption

as it reflects a motivated, innovative and responsive

for all Stahl locations around the world

workforce. Personality, education, age, nationality,�	90% of employees succesfully completed

gender, race and cultural diversity are critical for

new e-learning courses on bribery,

Stahl’s leadership position. We believe that a

corruption, modern slavery, diversity

diverse workplace allows employees who offer

and equality

different ideas and perspectives to thrive.
Diversity and Inclusion principles are also embedded

With its commitment to the guiding principles of the UN

within Stahl’s core leadership development programs

Global Compact, Stahl has aligned its strategy and policy

to encourage managers to demonstrate them as partwith the universal principles of human rights, labour,of their leadership behaviour. Cultural intelligenceenvironment and anti-corruption. Corruption is a major

and equality is built into its performance reviews

global issue that costs money and lives. It slows down

and the hiring and talent identification process.

economic growth and fuels poverty. Corruption hits poor
people the hardest but while harm is often magnified in

Stahl tracks the ratio of male/female employees andemerging nations, corruption does not recognize national

the number of female employees in supervisory

boundaries: it can be unearthed anywhere.

positions (employees with direct reports and/or
holding a management position). In 2019 there

Compliance with French and EU legislation

were 90 women in supervisory positions, 23.38%

As a portfolio company of the Wendel Group, Stahl isof total supervisory positions.

subject to (and compliant with) French and EU laws onsocial compliance, like the Extra Financial Performance

Training

Declaration (EFPD), Duty of Care and Sapin II.

Stahl encourages its employees to participate intraining and instructions in line with their position.
They are automatically included in the EEP e-learningand training modules for onboarding new employees.

Social human rights

�

Health & safety�

products and capabilities at their disposal. In theEnvironmental protection

�case of Stahl technicians, there is a strong emphasis

Corruption & Bribery

This is followed by more specific job-related training
to ensure the best use of the information, resources,

EFPD

or lectures. Every new employee receives updated

Sapin ||

Duty of caretraining, be it workshops, e-learning, online courses

�

�
�

�

on training designed to provide practical andinnovative technical solutions for customers.
Anti-corruption and the Stahl Code of Conduct
The number of hours received per employee in 2019

for Business Partners

was 15.32 hours per full-time equivalent (FTE)

Stahl expects its business partners to set the same

compared to 22.30 hours per FTE in 2018*.

anti-corruption standards as itself. Anti-corruption ispart of Stahl’s Code of Conduct for Business Partners,* Data verified and validated by Deloitte.

which states that the business partner must not use
corruption, extortion, embezzlement, or bribery toobtain an unfair or improper advantage.

24

ESG 2019 Report | Introduction | Environment | Social | Governance

The Stahl Code of Conduct also stipulates that thesessions on occupational health and safety, the storage,business partner abides by all applicable anti-corruption

handling and use of chemicals, showcasing eco-friendly

laws and regulations of the countries in which it operates,

technologies and safe use of hydrogen sulphide (H2S) gas.

including all applicable international anti-corruption
conventions. Stahl requires its business partners to

The project was presented to King Willem Alexander andeither comply with or demonstrate equivalent ethical

Queen Maxima of the Netherlands on a 2019 visit to India,

standards as those outlined in the Code of Conduct.

as part of a flagship initiative aligned to the Clean Ganga

Any deviations found can have an adverse effect on

Mission of the Government of India.

the relationship with Stahl, ultimately leading to an
immediate discontinuation of the business relationship.
e-Learning anti-corruption and bribery for employees
Stahl introduced new e-learning on the risks of bribery,corruption, modern slavery, diversity and equality in 2019.
Over 90% of new employees were trained and examined“In India, we introduced our pickle-freeon this.

technology which will enable tanners to reducewater consumption by up to 40% and work
towards a more efficient tanning process.”

4. Public-private partnerships
Prasanna Maduri
Stahl India
QUICK FACTS
Stahl Campus® India (Kanpur) opened tosupport the Public Private PartnershipGreen Tanning Initiative in Ethiopia

focused on water pollution reduction in

The Green Tanning Initiative (GTI) project focuses on

the Ganges riverpromoting responsible production practices in the leather
supply chain in Ethiopia and facilitating market accessfor Ethiopia to the EU. The GTI project is a public-private

Pollution prevention and efficient water use in India

partnership between Stahl, Solidaridad, CSR Netherlands

The five-year project Pollution Prevention and Efficient(MVO) and local leather associations, and is supported by

Water Use in Kanpur-Unnao Leather Cluster is focused

the European Commission.

on reducing water pollution in the Kanpur leather
manufacturing cluster and will contribute to the

The partners organized technical support to Ethiopian

well­being of thousands of families in the local

tanneries on cleaner production and safe working

community in the tanning region as well as

conditions. Representatives of 25 tanneries participateddownstream along the Ganges river. Stahl establishedin an awareness raising workshop at the Stahl Campus®

a Public Private Partnership (PPP) with Solidaridad,

training facilities in The Netherlands, which included

PUM and local stakeholders in the implementation ofusing the Leather Working Group’s “Are Your Ready for an

this project, which is also supported by the Dutch

Audit” self-assessment tool and Stahl Campus® modules.

government under its Sustainable Water Fund (FDW).
Stahl’s contribution to this project focuses on training
and demonstrations at the tanneries and the Stahl Centerof Excellence in Kanpur, the company has reached out tomore than 100 tanneries in the region. Training includes

25

ESG 2019 Report | Introduction | Environment | Social | Governance

5. Stahl Campus®
In 2019, 842 people attended Stahl Campus®

QUICK FACTS

training courses around the world. Notably in 2019, the�	In 2019, 396 university students attended

Automotive Leather Finishing Post Graduate Certificate

our Stahl Campus® modules in China

course was held for the second time in Stahl Campus®

�	842 people attended Stahl Campus

Mexico - a six-week course (3 x 2-week modules held over®

training courses around the world in 2019the academic year) developed in collaboration with the�	Automotive Leather Finishing Post Graduate

University of Northampton (UK), in which students receive

Certificate course was held for the second

an official Post Graduate Certificate from the university

time in Stahl Campus® Mexico

upon completion. This 2nd course will be completed inJune 2020.

Stahl is committed to filling the talent gap observed in
the markets that it serves by actively seeking ways to
educate and train university students, NGOs, brands,
suppliers, distributors, customers and other stakeholders
in the supply chain. Stahl initiated Stahl Campus® - global
knowledge centers - to achieve this, with the first center“Stahl Campus® plays a vital role in theopened in 2014 in Waalwijk (Netherlands) & subsequently

company and throughout the industry.

in León (Mexico) in 2015 and Guangzhou (China) in 2016.

Through Stahl Campus®, we share knowledge

In 2019 the new Stahl Campus® Center of Excellence waswith our stakeholders and encourage younger

opened in Kanpur, India.

generations to work in the industry.”

The goal of Stahl Campus® is to promote good practices

Annelies Janssen-van Drunen

and transparency throughout the supply chain by

Global Stahl Campus® Manager

hosting trainees in Stahl’s state-of-the-art laboratories
and strengthening knowledge via theoretical andpractical training modules. Stahl Campus® is a key
element of the company’s strategy of promoting
transparency throughout the supply chain.

26

Governance

WANT TO LEARN MORE?
Stahl Code of Conduct for Employees

Our trusted partnerships for social responsibility

Stahl Diversity & Inclusion policy

Our memberships for shared commitments

Stahl Policies and Statements

Our educational partnerships with universities

Stahl Compliance Report 2018

United Nations Sustainable Development Goals

Stahl Code of Conduct for Business Partners

Leather Working Group

Stahl Procurement Practices

TEGEWA

Safety, Health and Environment at Stahl

Stakeholder engagement

Stahl Statement on Modern Slavery

Topics that matter – GRI materiality matrix

Stahl Privacy Statement

ESG 2019 Report | Introduction | Environment | Social |1. Stahl governance

Governance

Stahl Executive Control GroupA wider governance body, called the Executive Control
Group, includes Stahl Management team members as

QUICK FACTS

well as Site Managers, Regional General Managers,�	The Stahl Board meets at least five times per

Executives from the Strategic Business Units, andyear to discuss financial results andMarketing, Communications, ESG, IT, Legal & Compliance,

ESG-related topics

Finance and SHE representatives. The Executive Control

�	Corporate Affairs and ESG is represented inGroup meets on a quarterly basis and reviews YTD (year

Stahl’s Senior management and Executive

to date) performance KPIs and decides on tactics forManagement teams

the upcoming business cycles.
Corporate Affairs and ESG

The Stahl Board of Directors, its highest governance body,At the corporate level, ESG is represented in Stahl’s

consists of members from its shareholders Wendel andSenior Management and Executive Management teams,

BASF, the Stahl CEO and CFO plus two independent

which meet monthly and set the company strategy.

members. The Stahl Board meets at least five times per

The Corporate Affairs and ESG team meets regularly

year to discuss financial results and ESG-related topics.

with Finance, Legal Counsel, Product Managers,
Researchers, Product Stewardship and Operations staff to

Stahl Board of Directors 2019

monitor the implementation of its strategy and to discuss�	Huub van Beijeren (Stahl CEO)progress on new initiatives related to ESG performance.

�	Frank Sonnemans (Stahl CFO)

The ESG team also supports commercial activities

�	Félicie Thion de la Chaume (Wendel)

initiated by customers that are related to sustainability.

� Jérome Michiels (Wendel)

A summary report is sent to the Stahl Board each month.

�	Claude Ehlinger (Wendel)

KPIs (key performance indicators) related to safety, health�	Bruno Fritsch (Wendel)and environment are also measured and reported monthly�	Anup Kothari (BASF)

by regional operational staff at the Stahl manufacturing�	Etienne Boris (Independent)

sites around the world. These KPIs are consolidated into

� Piet van der Slikke (Independent)

a global report, which is sent to the Stahl Board eachmonth and are audited annually by a third party (Deloitte
in 2019).

“Governance is the systems
and processes that ensure theoverall effectiveness of an entity –whether a business, government
or multilateral institution.”
United Nations

SHE (Safety, Health & Environment) governance
Each Stahl site has a dedicated SHE Manager
responsible for ensuring that the organization is pursuing
best practices. Being a SHE manager does not mean full
responsibility for SHE: the responsibility is distributed
throughout the organization and there is no job position
without a degree of responsibility for SHE. The SHE

Stahl Management teamManager reports to the Local Manager and has the

The Stahl Management team, as of January 2020,

direct support of the Global SHE&PS Manager.

consists of the Stahl CEO, CFO, COO, the director of R&D,
director of Corporate Affairs and the Leather Chemicals

In 2019 Stahl reviewed and implemented new criteria

and Performance Coatings strategic business unit

for reporting and governing SHE and Process Safety.

directors respectively. This team meets monthly and

New KPIs according to industry best practices and criteria

determines the implementation of company strategy

were defined. A systematic reporting system was put inincluding the ESG roadmap.

place in order to analyze key factors on reported eventsand allow management to identify trends and takedecisions based upon objective criteria.

28

ESG 2019 Report | Introduction | Environment | Social |Governance

The Stahl Hazard Identification and Risk Assessment

Zero Discharge of Hazardous Chemicals foundation -Methodology (SHIRAM) was rolled out worldwide

known as ZDHC - committed to eliminating identified

and became Stahl’s standard methodology for risk

substances from the clothing and footwear supply chain.

assessment. This methodology has been designed to

Stahl is an active member of these organizations andfit Stahl’s operations and processes, and to integrate

is involved with them at different levels throughout thebest practices for Risk Assessment and Management.

textile and leather supply chains.

Stahl’s Global Safety Performance and related KPIs
are reported and monitored monthly and annually.
The company tracks progress on safety indicators andreports different categories of injuries and incidents
including lost time injury (LTI), first aid, medical treatment
and irreversible injuries. Each month it reports injuries,“Stahl decided to join the ZDHC program inincidents, audits, training, engineering projects and other2016 because it shared a common goal of

prevention methods both internally and externally. The

achieving a transparent supply chain in

Safety reporting procedure is defined by Stahl’s policy

which stakeholders can take better decisions

on SHE&PS, in which KPIs, criteria and reporting toolson their environmental and social impact.”

are defined.
Ingrid Weijer
ESG Manager

2. Industry governance
QUICK FACTS�	ZDHC Gateway Level 3 conformanceachieved for 1,200 Stahl products�	bluesign® approval for 11 new products�	Introduction of Housekeeping andChemical Management Modules to the
Leather Working Group (LWG) protocol

UNIDO
The mission of the United Nations Industrial Development
Organization (UNIDO) is to promote and accelerate
inclusive and sustainable industrial development (ISID)in developing countries and economies in transition.
UNIDO’s e-learning courses, designed to promote goodpractices and responsible chemical management inleather tanneries, are fully supported by Stahl andare promoted in the areas where it is needed. Stahl’s
sustainability seminars in India are conducted in

The chemical industry is governed by public policies

conjunction with UNIDO and its e-learning courses

like Registration, Evaluation, Authorisation andon safety practices.

Restriction of Chemical substance (REACh) in Europe,or Toxic Substances Control Act (TSCA) in the United

TEGEWA

States, but is also linked to broader regimes that govern

Stahl is a member of TEGEWA (German association ofclimate change, biodiversity, environmental protection

specialty chemicals for textile and leather treatment) ,and prevention of corruption and modern slavery. Stahl isa group of chemical manufacturers supplying the leather,compliant to public policy on chemical substances andtextile and paper industries. TEGEWA’s purpose is toand reports on its ESG activities according to UN Global

identify, review and make recommendations on topics

Compact, GRI and OECD guidelines, among others. The

relevant for the industry. Stahl is an active participant

recently implemented Stahl Modern Slavery policy, forin the group, especially on topics related to chemicals

example, is based on section 54 of the 2015 UK Modern

management and the safety and health of workers who

Slavery Act.

may be handling chemicals in the garment and footwear
supply chain. The public private partnership launched

Aside from public policy directives, Stahl’s end markets

in 2019 to promote safe handling of chemicals in theare also governed by voluntary initiatives (often driven by

Bangladesh tanning district was initiated by TEGEWA

brands and NGOs) that influence industry behavior, likemembers, including Stahl, as well as NGOs and local

the Leather Working Group (a protocol for auditing leather

worker associations.

manufacturers on environmental stewardship) and the29

ESG 2019 Report | Introduction | Environment | Social |Governance

4. Ethics & Compliance
Memberships towards phasing out restricted substances
As confirmation of its commitment to eliminating thesubstances on acknowledged MRSLs, Stahl has been an

QUICK FACTS

active member of the ZDHC foundation since 2016 and�	Stahl has adopted governance policies
covering health and safety, environment,

has been a bluesign system partner since 2017.
®

human rights in order to mitigate risks linked
to its employees, suppliers and customers�	Codes of Conduct are discussed monthly by
the Management Team meetings and at
QUICK FACTS

quarterly Executive Control Group meetings�	In 2019, the Stahl board comprised of�	Over 1,200 employees received governancecompliance training in 2019

eight directors from five nationalities�	Diversity and inclusion principles
are embedded in our leadershipdevelopment programs

Stahl is committed to the guiding principles of UN Global
Compact, the world’s largest Corporate Sustainability
initiative. The UN guidelines are the foundation of its Code

3. Diversityof Conduct for business partners. With this commitment

Stahl is committed to embedding equality, diversity andthe company confirms its alignment to the universal

inclusion across the organization rather than viewing it

principles of human rights, labour, environment andas an abstract principle. Equal treatment is at the heart ofanticorruption. This also means that activities are also

the organization and we believe this will produce a more

being aligned with the principles of the UN Global

innovative and responsive organization. We also believe

Compact and the 17 Sustainable Development Goals

that there is much more to diversity than age, gender, race

(SDGs).

and cultural background. A diverse workplace allows
employees who offer different ideas and perspectives

As part of the French investment company Wendel,to thrive.

Stahl is subject to French social compliance legislation,
like Sapin II (transparency, anti-corruption and to“Good corporate governancehelps to build an environment oftrust, transparency and accountability
necessary for fostering long-term
investment, financial stability andbusiness integrity, thereby supportingstronger growth and more
inclusive societies.”OECD

modernization of the economy), Duty of Care and theEuropean DIRECTIVE 2014/95/EU disclosure of nonfinancial and diversity information.
Stahl’s vigilance plan corresponds to the French law
2017-399 (March 2017) on Duty of Care. The vigilance
plan identifies and aims to prevent the risk of serious
violations of human rights and fundamental freedoms
as well as harm to human health, safety and theenvironment. Stahl performed a review of the risk

The Stahl board and management teams comprise of men

assessment and control policies within the scope ofand women from diverse backgrounds and many different

Duty of Care. This review covered the risks linked to its

nationalities (Dutch, German, French, Spanish, North

employees, suppliers and customers/external markets

American, Mexican, Indian, Chinese, Italian, Irish, Turkish).

and the company has adopted governance policies
covering health and safety, environment, human rights

Diverse Leadership development
Consistent with our growing leadership talent strategy,
diversity and inclusion principles are also embedded
within our leadership development programs toencourage managers to demonstrate them as partof their leadership behaviour.

30

in order to mitigate the identified risks.

ESG 2019 Report | Introduction | Environment | Social |Governance

5. Stakeholder engagement
Stakeholder engagement means talking and interacting

Transparent communication is used by Stahl to provide

with people and organizations that are directly andinsight into the company for stakeholders. Soliciting

indirectly impacted by Stahl. Understanding their needs

stakeholder feedback also provides Stahl with anenables the company to create a transparent and more

understanding of different perspectives on Stahl’s

resilient supply chain that further reduces its collective

business and the markets it serves. The figure below

environmental and social footprint.

is a snapshot of the steps the company proactively
takes to engage with its stakeholders.

Figure 4: Stakeholder engagement landscape

Stakeholder
Engagement
Academic
institutions

Employees
Government incl.
public authorities

NGOs and
Civil Society

Investors andshareholders

Suppliers

Primary
stakeholders

Industry
associations
and foundations

ConsumerbrandsDistributors
and agents

Customers

Futuregenerations

31

Secondarystakeholders

ESG 2019 Report | Introduction | Environment | Social |Governance

6. Topics that matter
Stahl employs a materiality matrix to ensure it

This approach also ensures that the full scope of its

is reporting on relevant ESG topics. It is based on

activities are taken into account, from operations andrecognized, internationally agreed, guidelines like thesupply chain to interactions with suppliers, customers,

Global Reporting Initiative (GRI). The materiality matrix

consumers, shareholders, government and NGOs.

methodology ensures that the company addresses

In short, the materiality matrix allows the company

material topics for Stahl and its stakeholders.

to identify the ESG topics that matter most.

Figure 5: Materiality matrix

Economic
topicsEnvironmental
topicsSocialtopicsOther
topicsHigh

Occupational
health and safety

Effluent
and waste

EnergyWater andeffluent
Materials
Training andeducation
Diversity andequal opportunity

MediumImportance to stakeholders

EmissionsCustomer healthand safety

Environmental
compliance

Employment
Economic
performance

Local
communities
Socioeconomics
compliance
Anti-corruption
Non-discrimination
Procurement
practices

Other
topicsLow

Marketpresence

Low

Medium

Impact on Stahl Group

32

High

ESG 2019 Report | Introduction | Environment | Social | Governance

GRI table / ESG data
The below table indexes the Stahl ESG Report 2019 against the GRI (Global Reporting Initiative)
reporting guidelines and the UN Global Compact (UNGC). The ESG data in this reporthas been prepared in accordance with GRI G4 (core), based on self-declaration.

Disclosure Number

33

What to report?

Disclosed information

Source of evidence

102-14

A statement from the most senior decision-maker of the organization (such as CEO, chair, or equivalent senior position)
about the relevance of sustainability to the organization and its strategy for addressing sustainability.

“Message from the CEO” in the 2016, 2017, 2018 and 2019 Stahl ESG/Sustainability Reports, referring to our goal oftransparency and our strategy to achieve it. This strategy is frequently communicated to the press and in publications.

https://www.stahl.com/corporateresponsibility/policies-statementsreports/reports

102-1

Name of the organization.

Stahl Holdings B.V.

https://www.stahl.com

102-2a) A description of the organization’s activities.
b) Primary brands, products, and services, including an explanation of any products or services that arebanned in certain markets.

a) To manufacture, sell and trade in chemical products like processing chemicals and finishing products for the leather
tanning industry, and performance specialty coatings and polymers for industrial coatings markets. The company also
provides services to these markets parallel to its commercial activities.
b) Stahl uses two primary brands (Stahl and PielColor®) to promote its products and services, and there are many
product trademarks used within the portfolio (eg: PolyMatte®, Stahl EasyWhite Tan™, Catalix®, DryFast, Stahl EVO®,
Stahl Neo®, PielColor® Magic Line). See the Stahl Compliance Report for our guidelines and restrictions on trading incertain countries (secion: Sanctions and embargoes).

Compliance report

102-3

Location of the organization’s headquarters.

Stahl Holdings B.V., Sluisweg 10, 5145 PE Waalwijk , Netherlands, +31 416 689 111

https://www.stahl.com/global-contacts

102-4

Number of countries where the organization operates, and the names of countries where it has significant operations and/orthat are relevant to the topics covered in the report.

We have manufacturing sites, labs and offices in 24 countries and are active (through ie buying & selling)in over 70 countries. The most important* countries are Argentina, Bangladesh, Brazil, China, Colombia, France,
Germany, India, Indonesia, Italy, Japan, Mexico, Netherlands, Pakistan, Singapore, Spain, Turkey and the USA.
*Most important means where we do most business, especially the contact with clients,
as well as the manufacturing of our products.

https://www.stahl.com/global-contacts

102-5

Nature of ownership and legal form.

Stahl’s majority shareholder is the private equity Wendel Group (67.5% of shares).
Other minority shareholders include Clariant and BASF.

https://www.wendelgroup.com/en/company/stahl

102-6Markets served, including:
1. Geographic locations where products and services are offered;
2. Sectors served;
3. Types of customers and beneficiaries.

Automotive, Footwear, Apparel & Accessories, Architectural & Interior Design, Home furnishing,Industrial Application and Leisure & Lifestyle.

https://www.stahl.com

102-7

Scale of the organization, including:
1. Total number of employees;
2. Total number of operations;
3. Net sales (for private sector organizations) or net revenues (for public sector organizations);
4. Total capitalization (for private sector organizations) broken down in terms of debtand equity;
5. Quantity of products or services provided.

As of 31/12/2019: 1826,6 FTEs, 11 manufacturing sites, approximately 5,000 products. Net sales 2019: EUR 809 Million.
Stahl Lux 2 SA (holding company) total equity is reported at EUR 174.3 Million, total liabilities EUR 800.408 Million.

102-8

Total number of employees by employment contract (permanent and temporary), by gender.
Total number of employees by employment contract (permanent and temporary), by region.
Total number of employees by employment type (full-time and part-time), by gender.
Whether a significant portion of the organization’s activities are performed by workers who are not employees.
If applicable, a description of the nature and scale of work performed by workers who are not employees. Any significant
variations in the numbers reported in Disclosures 102-8-a, 102-8-b, and 102-8-c (such as seasonal variations in the tourism
or agricultural industries).
An explanation of how the data have been compiled, including any assumptions made.

As of December 31, 2019, the total number of employees (headcount) at 2019 year-end was 1847 which is a decrease of
150 employees compared to the end of 2018. Stahl had 1973 FTE’s in 2018 and 1827 in 2019, an decrease of 146 FTE’s.
87.6% of Stahl’s employees are on permanent contracts. Its workforce is 76% male and 24% female.
Total Full Time Employees (FTE) leaving (dismissals and resignations) during 2019 were 259 and 114 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 theytake place. The turnover rate in 2018 was 8.71% (in 2018 it was 10.58%).

https://www.wendelgroup.com
Registration Document

102-41

Percentage of total employees covered by collective bargaining agreements.

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 supervisionfrom headquarters but are also centrally coordinated, to ensure Stahl remains competitive in the respective markets.

https://www.wendelgroup.com
Registration Document

102-9

A description of the organization’s supply chain, including its main elements as they relate to the organization’s activities,
primary brands, products, and services.

Stahl manufactures its products at its own manufacturing sites around the world or at outsourced locations via service
agreements. Its suppliers are also chemical companies, and include most of the the major global chemical corporations.
Clients that use our products are typically leather tanneries and converters of textiles and other synthetic materials.

102-10Significant changes to the organization’s size, structure, ownership, or supply chain, including:
1. Changes in the location of, or changes in, operations, including facility openings, closings, and expansions;2. Changes in the share capital structure and other capital formation, maintenance, and alteration operations(for private sector organizations);
3. Changes in the location of suppliers, the structure of the supply chain, or relationships with suppliers,
including selection and termination.

None

ESG 2019 Report | Introduction | Environment | Social | Governance102-11

Whether and how the organization applies the Precautionary Principle or approach.

While Stahl has not expressly formalized an approach to the Precautionary Principle, the company is effectively applying
the principle with its proactive approach to transparency and sustainability. As an example, Stahl is actively eliminating
several chemcial substances from its product lines which are not yet regulated by law, but that we believe could be
potential risks in the future. Stahl is also active in promoting transparency throughout its customers’ supply chains, viainitiatives that bring different players from the supply chain together to discuss and decide on environmental issues.

102-12A list of externally-developed economic, environmental and social charters, principles,or other initiatives to which the organization subscribes, or which it endorses.

In the Sustainability Report we refer to UN Global Compact and UN 17 SDGs per chapter, where applicable. Where
applicable, we promote and use the OECD guidelines, for instance for our transfer pricing policy.

102-13102-45A list of the main memberships of industry or other associations, and national orinternational advocacy organizations.

A list of all entities included in the organization’s consolidated financial statements
or equivalent documents.
Whether any entity included in the organization’s consolidated financial statements
or equivalent documents is not covered by the report.

Solidaridad, The Zero Discharge of Hazardous Chemicals Foundation (ZDHC), bluesign® system partner,
The Leather Working Group, TEGEWA, University of North Hampton and Wageningen University

Partnerships:
https://www.stahl.com/corporateresponsibility/partnership/partners
Memberships:
https://www.stahl.com/corporateresponsibility/partnership/memberships
Universities:
https://www.stahl.com/corporateresponsibility/partnership/universities

Europe and Africa: Stahl Chemical Industries BV GMBH (in liquidation), Stahl France SAS, Stahl Chemicals Germany
GmbH, Stahl Italy SRL, Stahl Lux 2 SA, Stahl Group SA (98.01%), Stahl Netherlands B.V., Stahl International B.V.,
Stahl Europe B.V., Stahl Treasury B.V., Stahl Holdings B.V., Stahl International Specialties Development B.V., Stahl Europe
Application PC B.V., Stahl International Polymer Development B.V., Stahl International Compounding B.V., Stahl Parent
B.V., Stahl Iberica SL, Stahl Investment Spain SL, Pielcolor SL, Stahl Performance Powder Coatings SL (84.0%), Stahl
Switzerland GmbH, Stahl Kimya Sanayi ve Ticaret Ltd Sirketi, Stahl UK Ltd, Stahl Africa Chemicals Plc (in liquidation)
North America: Stahl de México, S.A. de C.V., Stahl (USA) Inc., Stahl LLC
South America: Stahl Chemicals Srl, Stahl Brasil SA, Productos Stahl de Colombia SA, Pielcolor Uruguay SA(in liquidation), Lidertime SA (in liquidation), Stahl Uruguay SA, Stahl Argentina SRL
Asia: Stahl Coatings and Fine Chemicals (Suzhou) Co. Ltd, Stahl Leather Chemicals HK Limited (in liquidation),
Stahl India Pte Ltd, PT Stahl Chemicals Indonesia, Stahl Japan Ltd, Stahl Korea Ltd, Stahl Pakistan (private) Ltd,
Pielcolor Trading (Suzhou) Co. Ltd, Stahl Asia Pacific Pte Ltd, Stahl Taiwan Ltd, Stahl (Thailand) Ltd
Clients: The content is mainly focused on our clients and we aim to give them a very good overview of our company, ourvalues and our performance.
Shareholder: Through Wendel audits (by Deloitte) we are challenged to enhance the reporting for our shareholder,
including the stringent French law requirements, such as Duty of Care and Sapin II.

102-46

An explanation of the process for defining the report content and the topic Boundaries.
An explanation of how the organization has implemented the Reporting Principles fordefining report content.

NGOs and universities: Through our memberships, partnerships and co-operation with NGOs and universities
we learn their wishes with regards to strategic topics, transparency and reporting requirements.

https://www.wendelgroup.com
Registration Document

Other stakeholders: Through stakeholder engagement we enhance our reporting by means of the materiality matrix.
We have published a materiality matrix since 2018, which was based on internal feedback on what topics matter (x-axis).
For our stakeholders (y-axis), we investigated the materiality matrix that was available. We plotted the 33 GRI topics in amatrix. We show the topics that matter (medium and high) in our matrix.
All 33 GRI topics:
Economic: Economic Performance, Market Presence, Indirect Economic Impacts, Procurement Practices,
Anti-corruption, Anti-competitive Behavior.

102-47A list of the material topics identified in the process for defining report content.

Environmental: Materials, Energy, Water and effluents, Biodiversity, Emissions, Effluents and Waste,
Environmental Compliance, Supplier Environmental Assessment.
Social: Employment, Labour/Management Relations, Occupational Health and Safety, Training and Education,
Diversity and Equal Opportunity, Non-discrimination, Freedom of Association and Collective Bargaining, Child Labour,
Forced or Compulsory Labour, Security Practices, Rights of Indigenous Peoples, Human Rights Assessment,
Local Communities, Supplier Social Assessment , Public Policy, Customer Health and Safety, Marketing and Labeling,
Customer Privacy, Socioeconomic Compliance.

34

102-48The effect of any restatements of information given in previous reports, and the reasons for such restatements.

In case of a restatements in the ESG report linked to enviromental data reported, we clearly explain what and why.

102-49Significant changes from previous reporting periods in the list of material topics and topic Boundaries.

No significant changes, since we published the matrix in 2018.

102-40A list of stakeholder groups engaged by the organization.

Customers, owners/shareholders, NGOs, brands, suppliers, employees.

102-42The basis for identifying and selecting stakeholders with whom to engage.

Size, influence, frequency of engagement.

https://www.stahl.com/corporateresponsibility/policies-statements-reports/
reports

https://www.stahl.com/corporateresponsibility/stakeholders

ESG 2019 Report | Introduction | Environment | Social | GovernanceOur corporate strategy includes interacting with our stakeholders so we can better understand their perspectives andpriorities when it comes to our company and the industries and markets in which we operate. Stakeholder engagement
is central to our aim of creating a transparent supply chain that reduces our collective environmental footprint andincludes transparent communications and continuous assessments of our operations with and by our partners.

102-43The organization’s approach to stakeholder engagement, including frequency of engagement by type and by stakeholder group,
and an indication of whether any of the engagement was undertaken specifically as part of the report preparation process.

How we define our stakeholders
Our stakeholders include employees, customers, governments, NGOs, industry associations, universities,
communities and media. We are in constant contact with all these stakeholders about industry developments,
our activities and services and other important topics, such as our Materiality Matrix.

https://www.stahl.com/corporateresponsibility/stakeholders

How we involve our stakeholders
We expect every Stahl location and business to engage with its stakeholders. These stakeholders are defined as people
and organizations that may be affected by our actions, goals and policies, and which may impact us in the same way.
We engage with them on an ongoing basis, and the following table provides a snapshot of the steps we take to form
and maintain productive relationships with our key stakeholder groups.

102-44

Key topics and concerns that have been raised through stakeholder engagement, including:
1. How the organization has responded to those key topics and concerns, including through its reporting;
2. The stakeholder groups that raised each of the key topics and concerns.

No significant new topics have been raised during 2019.
Proactively we engaged with the Leiden University in the Netherlands, who investigate how well our policy and strategy
fits the ESG and CRS agenda of the major influential brands and companies. Their recommendation may include key
topics and concerns.

102-50

Reporting period for the information provided.

January 1, 2019 up to and including 31 December, 2019.

102-51

If applicable, the date of the most recent previous report.

March 2020 (Sustainability report 2019).

102-52

Reporting cycle.

The Stahl Sustainability Report is published each year in March.

https://www.stahl.com/corporateresponsibility/policies-statementsreports/reports

102-53The contact point for questions regarding the report or its contents.

See back of the Sustainabilty report & on the website per relevant article or item

https://www.stahl.com/corporateresponsibility/policies-statementsreports/reports

102-54The claim made by the organization, if it has prepared a report in accordance with the GRI Standards, either:
1. ‘This report has been prepared in accordance with the GRI Standards: Core option’;2. ‘This report has been prepared in accordance with the GRI Standards: Comprehensive option’.

‘This report has been prepared, whenever possible, in accordance with the GRI Standards: Core option’;102-55The GRI content index, which specifies each of the GRI Standards used and lists all disclosures included in the report.
For each disclosure, the content index shall include:
1. The number of the disclosure (for disclosures covered by the GRI Standards);
2. The page number(s) or URL(s) where the information can be found, either within the report or in other published materials;
3. If applicable, and where permitted, the reason(s) for omission when a required disclosure cannot be made.

See (a) first column GRI reference numbers and (b) last column the links to documents where available or the source of
the information.

102-56

A description of the organization’s policy and current practice with regard to seeking external assurance for the report.
If the report has been externally assured:
1. A reference to the external assurance report, statements, or opinions. If not included in the assurance report accompanying
the sustainability report, a description of what has and what has not been assured and on what basis, including theassurance standards used, the level of assurance obtained, and any limitations of the assurance process;2. The relationship between the organization and the assurance provider;
3. Whether and how the highest governance body or senior executives are involved in seeking external assurance
for the organization’s sustainability report.

The KPIs reported in the Responsible Operations section of this report have been audited and approved by anindependent third party (Deloitte). The Sustainability report as a whole has not been assured by a third party.

The Stahl Board, its highest governance body, consists of members from its shareholders Wendel, BASF, Stahl plus two
independent members. The Stahl board meets five times per year and schedules additional conference calls to discuss
any pertinent company matters, like the latest financial results.

102-18Governance structure of the organization, including committees of the highest governance body.
Committees responsible for decision-making on economic, environmental, and social topics.

Stahl Board 2019
Huub van Beijeren (Stahl CEO)
Frank Sonnemans (Stahl CFO)
Félicie Thion de la Chaume (Wendel)
Jérome Michiels (Wendel)
Claude Ehlinger (Wendel)
Bruno Fritsch (Wendel)
Anup Kothari (BASF)
Etienne Boris (Independent)
Piet van der Slikke (Independent)
The Stahl Management team, as of January 2020, consists of the Stahl CEO, CFO, COO, the director of R&D, director of
Corporate Affairs and the Leather Chemicals and Performance Coatings strategic business unit directors respectively.
This team meets monthly and determines the implementation of company strategy.
A wider governance body, called the Executive Control Group, includes Stahl Management team members as well assite managers, regional general managers, executives from the strategic business units, and marketing, communications,
ESG, IT, legal & compliance, finance and SHE representatives. The Executive Control Group meets on a quarterly basis
and reviews YTD (year to date) performance KPIs and decides on tactics for the upcoming business cycles.

35

https://www.stahl.com/corporateresponsibility/stakeholders/engagement-feedback

https://www.stahl.com/corporateresponsibility/policies-statementsreports/reports

ESG 2019 Report | Introduction | Environment | Social | Governance102-16

A description of the organization’s values, principles, standards, and norms of behavior.

External values: Stahl is committed to the highest standards of social and environmental responsibility and ethicalconduct as described in the Code of Conduct. Stahl requires its business partners to comply with the same or at least
equal ethical standards and operate in accordance with the principles in this Code of Conduct (‘Code’) and in fullcompliance with all applicable laws and regulations. Stahl expects suppliers and/or business partners to use aproactive approach in establishing and maintaining the standards set forth in the Code and conduct themselves withresponsibility and integrity. The business partner states to agree to the conditions in the Code and acknowledges thatany deviations found can have an adverse effect on the relation with Stahl including an immediate discontinuation of thebusiness relationship. The business partner commits, in signing the Code, to all applicable legislation and regulations.
The Code therefore forms an integral part of the agreement between the business partner and Stahl. To verify
compliance with the Code, Stahl shall consult with the business partner from time to time. Stahl has the right tospeak and to train employees of the business partner directly in order to fully comply with the Code. If this is deemed
appropriate, Stahl can request that an audit can be conducted by a third party to be appointed by Stahl. The business
partner states to fully cooperate in this investigation. Stahl expects his business partner to comply with the UN Global
Compact Guiding Principles in the areas of human rights, labour, the environment and anti-corruption and wishes toemphasize the following specific areas of interest.
Internal values: The Code of Conduct sets out Stahl general business principles that apply to all employees and all its
subsidiary companies. Integrity is essential in establishing and maintaining our reputation and providing our quality
services to our customers. Our objective is to preserve continuity of the company by maintaining a strong financial basis.
This implies balancing long and short term interests, with due care and respect for our customers, employees,
shareholders and other business relationships. Should employees have any concern about what conduct would beappropriate (as laid down in our Whistle Blower policy), they should promptly raise that concern with the Compliance
Officer. Any concern so raised is addressed with discretion and respect.

36

2 Codes of Conduct (for Business
Partners and for Employees).
See also Stahl Compliance report.

ESG 2019 Report | Introduction | Environment | Social | GovernanceBusiness partner
Code of conduct
March 2020
1. Introduction

2. Ethical behaviour & integrity

Stahl is committed to the highest standards of social

Laws and regulationand environmental responsibility and ethical conduct

The business partner operates in full compliance withas described in the Stahl Parent B.V. (“Stahl”) Code ofinternational, national and domestic laws and regulations

Conduct. Stahl requires its business partners to comply

applicable to their business operations, and to obtain allwith or demonstrate equivalent policies and standards

necessary permits.

and to operate in accordance with the principles in thisCode of Conduct (‘Code’) and in full compliance with all

Business integrity

applicable laws and regulations.

The business partner shall not engage in any form ofcorruption, extortion, embezzlement, or bribery to obtain

Stahl expects suppliers and/or business partners toan unfair or improper advantage. The business partner

use a proactive approach in establishing and maintaining

shall abide by all applicable anti-corruption laws andthe standards set forth in this Code and to conduct

regulations of the countries in which it operates including

themselves with responsibility and integrity. The businessall applicable international anti-corruption conventions.

partner is obliged to agree to the conditions in this Codeand acknowledge that any deviations found can have an

Free and fair competition

adverse effect on the relationship with Stahl, including an

Stahl behaves openly and fairly in the marketplace.

immediate discontinuation of the business relationship.

The business partner must value free and fair

The business partner commits, upon signing this Code,competition throughout the world and comply

to all applicable legislation and regulations. This Codewith anti-trust and competition laws.

therefore forms an integral part of the agreement
between the business partner and Stahl.

Confidentiality
The business partner protects all confidential information

To verify compliance with the Code, Stahl shall consult

provided by STAHL and its respective business partners.

periodically with the business partner either directlyor through independent verification systems such as

Protection of Intellectual Property

Ecovadis. Stahl has the right to speak with and train

The business partner shall respect intellectual property

business partner employees directly in order to fullyrights and safeguard customer information. The businesscomply with the Code.

partner shall manage technology and know-how in amanner that protects intellectual property rights.

When appropriate, Stahl can request an audit be
conducted by a third party to be appointed by Stahl.
The Code obliges the business partner to fully cooperate

3. Environment

in this investigation. Stahl expects its business partners

Stahl is committed to protecting the environment,

to comply with the UN Global Compact Guiding Principles

and environmental responsibility is at the core of(see annex) on human rights, labour, the environment andhow we operate. The business partner shall develop,

anti-corruption and emphasizes the following specificimplement, and maintain environmentally responsible

areas of interest.

business practices. The business partner shall respect
the environment and comply with all (supra) national
environmental, health and safety legislation and

37

ESG 2019 Report | Introduction | Environment | Social | Governanceregulations. The business partner shall conduct its

legislation and regulations applying to child labour in line

business processes in such a manner that compliancewith Convention 138 (Minimum Age) and Convention 182

is guaranteed. On top of legislative requirements,(Worst forms of Child Labour) of the International Labour

Stahl also encourges its business partners to support

Organisation. The business partner shall not use workand promote good practices and high standards ofthat is performed involuntarily under threat of penalty.

environmental stewardship, in order to collectively
reduce environmental footprints, fight climate change

Health and safety

and achieve more transparency in our supply chains.

The business partner shall implement strict policies
with the aim of creating an incident and injury freework environment. At all levels, the business partner

4. Social

will play an active role in identifying and rectifying

Human rights

unsafe (health) situations.

The business partner shall conduct their activities in amanner that respects human rights as per The United
Nations Universal Declaration of Human Rights.

5. GovernanceThe business partner’s highest governance body (e.g.

Discrimination

the board of directors) is ultimately responsible for

The business partner shall unconditionally respectadherence to this Code and for compliance to relevant

all anti-discrimination conditions in (supra) national

governance codes and guidelines. This body should also

legislation and regulations.

be transparent about the corporate governance structureof their organization and provide, when needed, soundModern slavery

reasons for any non-compliance to this Code (using theModern slavery, or any form of forced or compulsory‘comply or explain’ principle).

labour, is a violation of human rights. Stahl takes a strong
stance against modern slavery and works to ensure highlabour rights standards. Stahl condemns any form of“G overnance is the systems and processes thatmodern slavery and child labour, and shall not participate

ensure the overall effectiveness of an entity –in the trafficking, recruitment, or receipt of any persons,whether a business, government or multilateralby means of threat or abuse of power. Stahl allows

institution.” – United Nations

employees to resign from their position at any time.
By behaving ethically and honestly with all its partners,“G ood corporate governance helps to build

Stahl is committed to ensuring that modern slavery does

an environment of trust, transparency andnot occur elsewhere and strives only to do business withaccountability necessary for fostering long-term

organizations who uphold similar principles.

investment, financial stability and businessintegrity, thereby supporting stronger growth

Working hours

and more inclusive societies.” – OECD

The business partner shall not force their employees towork excessive hours and shall comply with all (supra)
national legislation and regulations concerning labour

6. Grievances & whistleblower policy

and labour conditions. In case employees are asked to

Grievances and/or suspicion of non-compliance to thiswork overtime, their extra work is compensated in line

code can be expressed through Stahl’s whistleblower

with local legislation.

communications line: communications@stahl.com

Child and forced labour
The business partner shall respect all (supra) national

38

ESG 2019 Report | Introduction | Environment | Social | GovernanceSignature for complianceBusiness partner CoC

Organization:
Name:
Title:
Place and date:
Signature:

Annex: Un global compact 10 principles
Stahl expects its business partner to comply with the UN Global Compact Guiding 10 Principles in the areas of humanrights, labour, the environment and anti-corruption and wishes to emphasize the following specific areas of interest.

Ten principles of the UN Global Compact in the areas of Human Rights, Labour,
Environment and Anti-Corruption
Principle 1: 	Support and respect the protection ofinternationally proclaimed human rights.
Principle 2: 	Ensure that business practices are notcomplicit in human rights abuses.
Principle 3: 	Uphold the freedom of association andthe effective recognition of the right tocollective bargaining.
Principle 4: 	Eliminate all forms of forced and compulsory labour.
Principle 5:

Abolish child labour.

Principle 6: 	Eliminate discrimination in employment and occupation.
Principle 7: 	Adopt a precautionary approach to environmental challenges.
Principle 8:

Conduct environmentally responsible activities.

Principle 9: 	Encourage the development and diffusion of environmentally friendly technologies.
Principle 10:39Fight corruption in all its forms including extortion and bribery.

ESG 2019 Report | Introduction | Environment | Social | Governance40

stahl.com
Please do not hesitate to contact the ESG team if
you have any questions or remarks about this report.
Stahl Holdings B.V.
Sluisweg 10 | 5145 PE Waalwijk | Netherlands+31 416 689 111 | communications@stahl.com

41