NaDiVeG compliance table

NaDiVeG compliance table: Disclosures pursuant to section 267a UGB

Issue		Concept description		Risks for external stakeholders and environment		Risks for Lenzing		Due diligence/measures for handling risks		Results
Respect for human rights		Policy on Human Rights and Labor Standards Code of Conduct FSC^® certification Better Growth Strategy Sustainability Policy		Risks of non-compliance with human rights might affect employees of suppliers – especially in forestry Health and safety risks for the supply chain Risks of discrimination		Legal and compliance risk Fines Lawsuits Reputation loss		Whistleblower System Works council Supplier assessment to mitigate supply chain risks Policy on Human Rights and Labor Standards		No cases of human rights abuses. 100 percent of the total workforce is represented by local unions or works councils (voluntary basis). No strikes at any Lenzing production facility in 2023. Own workforce Workers in the value chain
Combating of corruption and bribery		Code of Conduct Whistleblower Directive Anti-Bribery and Corruption Directive		Supply chain risk for Lenzing’s customers Risks concerning corruption and bribery may affect the societies of countries where Lenzing operates in a negative way.		Legal and compliance risk Business damage Reputation loss Fines Lawsuits		Whistleblowing System Compliance trainings Enforcement Reporting to the audit committee of the supervisory board twice a year Supplier assessment to mitigate supply chain risks		No cases of corruption in 2023 No significant fines or non-monetary sanctions were imposed as a result of legal infringements or breaches of regulations in 2023. Business conduct Affected communities
Diversity		Better Growth Strategy Policy on Human Rights and Labor Standards Code of Conduct		Discrimination of gender, cultural background, age and further diversity aspects Mental health risks for employees		Compliance risk Reputation loss		Grievance mechanism through works council Diversity concept		Own workforce Business conduct
Social (employees)		Better Growth Strategy Sustainability Strategy Sustainability Policy Works council / trade union at all sites Policy for Safety, Health and Environment Life-long learning program Whistleblower Directive Global Equity, Diversity and Inclusion Policy		Safety and health risks for employees and supervised workers Negative effects on employee development, communities and value chain partners Risk of infectious disease		Reputation loss Negative impact on employer branding Difficult recruitment High employee turnover Loss of know-how and lack of competence Lawsuits		Whistleblower System SHEARS platform Safety trainings Health infrastructure at all sites Specific regional events for employees Work Councils/ Trade Unions		Five sites audited by Higg FSLM: good results Own workforce Business conduct
Social (society)		Compliance with applicable laws Sustainability Strategy (focus area community wellbeing) Sustainability Policy Whistleblower Directive		Health and safety risks for local communities Environmental risks Supply chain risks for Lenzing’s downstream customers Violation of human and indigenous rights such as displacement or suppression of freedom of speech through the value chain Communities around production sites or their food and water resources can negatively affected		Reputation loss Lawsuits Business damage		Whistleblower System Community activities at production sites		No significant fines or non-monetary sanctions were imposed as a result of legal infringements or breaches of regulations in 2023. Business conduct Affected communities Workers in the value chain
Environment		Sustainability Strategy Sustainability Policy Policy for Safety, Health and Environment Policy for Wood and Pulp Sourcing of certified or controlled wood Bioenergy Policy Group sustainability targets Science-based targets ISO management systems Enterprise Excellence (EPEX)		Risks of negative effects on the ecological systems of forests of suppliers and water bodies Risks of high contribution to climate change through own emissions to air Risks of substance leakage		Lack of availability of wood due to climate change Any climate-related disruption in one of the production sites will influence the business model and its success Reputation loss Lawsuits Business damage Regulatory risks (increased costs for CO₂-emissions, stronger regulations concerning environmental laws)		Afforestation project starting in 2018 Higg FEM 3.0 Supplier assessment to mitigate supply chain risks Lenzing Enterprise Excellence Program for continuous improvement (EPEX) Applying voluntary benchmarks, such as the EU Ecolabel Management of climate-related risks and opportunities (TCFD) Reporting on CDP Climate, Forests and Water Roadmaps of group level and of site level targets Science-based targets 2050: net-zero GHG emissions by 2050 2030: absolute GHG emissions reductions in scope 1 and 2 by 42 percent and in scope 3 by 25 percent		Ranked second in Canopy’s Hot Button Report Higg FEM results better than industry average CDP ‘Triple A’ rating Environmental management system according to ISO 14001:2015 Certificates: ISO 14001:2015, ISO 9001:2015 and ISO 45001 EcoVadis Platinum status SAC Higg MSI: better scores for Lenzing’s products compared to industry average (e.g. TENCEL™ Lyocell) Lenzing contributing to leading multi-stakeholder initiatives (SAC, ZDHC, EU-BAT) Business conduct Affected communities

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