2020 Sustainability Report

Why Environmental Management Systems Matter

Following environmental laws and regulations applicable to our business is an integral part of Greif’s ongoing operations. Our environmental management systems and collaborative relationships with regulators enable us to proactively and efficiently demonstrate to our stakeholders our deep understanding of the complex regulatory environment we are subject to, while illustrating our ability to consistently meet them.

Governance

Since 2011, Greif has used our proprietary Compliance Management System (CMS) to track and monitor our compliance with certain laws and regulations, including environmental compliance related to facility emissions, energy, water and waste. Our Environmental Health and Safety (EHS) Team, led by our Vice President of EHS and Operations for North America, with support from the Senior Environmental Manager, the Environmental Specialist, and the EHS Director and regional managers that support Greif’s four operating regions, administer the CMS. Two dedicated EHS professionals manage environmental compliance within our Paper Packaging and Services (PPS) operations.

Greif is a diverse, complex global manufacturer subject to a wide range of EHS regulations that may impact our organization in different ways. Across our organization, we use a variety of tools and processes to appropriately manage geographic and business-specific needs, however, all of our global environmental management systems are administered under a consistent set of principles. All Greif facilities have an environmental management system that is supported by a compliance management software. All required compliance tasks are linked to an escalation process to ensure they are fully and accurately completed on time. Escalations can go as high as our CEO, if necessary. Audits are performed to confirm that work is completed and facilities remain in compliance with all required regulations.

In 2020, Greif completed the integration of CMS into all legacy Caraustar sites, making CMS accessible to all Greif facilities worldwide. Both legacy Caraustar and Greif facilities in North America supplement their compliance management systems through Dakota, an advanced EHS compliance and risk management software that tracks new and upcoming regulations applicable to each facility’s unique profile. Greif supplements our use of Dakota by conducting third-party audits to determine additional facility-specific tasks that may support better environmental risk management. Third-party physical audits were paused in 2020 due to the COVID-19 pandemic and are planned to resume in 2022, but virtual audits were conducted. Greif was not subject to any fines of material significance to the organization in 2020.

Greif has used CMS to collect and track waste data since 2018. In 2020, we improved our ability to view and manage waste data in CMS by enabling monthly access to data. This allows each of our facilities to gain insights into data more quickly and implement programs throughout the year. Please visit the Waste section of our report for more information on our waste management efforts.

Greif’s New Chemical Request and Equipment Pre-Acceptance processes continued in 2020, ensuring that no new potentially hazardous chemicals were introduced to our operations and that all new equipment met our environmental, quality, health and safety standards for equipment prior to being approved for purchase and installation. In 2020, we completed our efforts to record all capital projects in our Global Industrial Packaging (GIP) North America business. In PPS 124 new Chemical Requests were conducted in 2020. We also continued our Management of Change (MOC) process in GIP North America to assess potential commercial, EHS, plant, quality and regulatory impacts of manufacturing or materials changes. In 2020, we completed 53 MOC reviews at our GIP North America facilities and our 13 mills in our PPS business.

Greif provides regular Environmental Management System (EMS) training throughout the year. This includes training on our EMS as well as training directed by our EMS. For example, our PPS business conducted 11 training events on the aspects and the use of our EMS in 2020. A total of 166 compliance training events were directed by our EMS in 2020. These compliance training events included:

• Universal Waste Annual Refresher Training
• SPCC Annual Refresher Training
• Stormwater Annual Refresher Training
• Hazardous Waste and Emergency Refresher Training
• DOT Hazmat Shipping 3-year training
• Asbestos Awareness Program Refresher Training
• Annual RCRA Hazardous Waste Refresher Training
• Landfill Solid Waste Annual Refresher Training

In addition to our systems and processes, individual Greif production facilities manage quality, safety and environmental standards through certifications such as OHSAS, ISO, FSSC and SQF. Our PPS operations maintain ABI, FSC, OSHA, PEFC, SFI and PEFC certifications. Globally, 14 sites have achieved ISO 14001 certification.