6 Pollution (ESRS E2)

ESRS reference: ESRS E2 Pollution / Sub-topics: Pollution of Air; Pollution of Water

ESRS cross-references: ESRS E1 Climate Change; ESRS E3 Water; ESRS E4 Biodiversity and Ecosystems; ESRS S1 Own Workforce; ESRS S3 Affected Communities

HorizonNOW 2030: Sustainable operations, target 3 (VOC emission reduction as part of climate targets)

6.1 Relevance of Topic

Under ESRS E2, the material sub-topics for Siegwerk are pollution of air and pollution of water, covering own operations and the upstream value chain. Downstream air and water pollution IROs were assessed as not material.

For own operations, these sub-topics did not become material through normal quantitative impact scoring, as the scores remained below Siegwerk’s materiality threshold, mainly because likelihood is reduced by regulation, operational controls and monitoring. They were nonetheless classified as material through an override option in Siegwerk’s DMA methodology, specifically for business-characteristic impacts in alignment with ESRS 1 paragraph 43(c). It states that information about impacts and how they are managed through policies and actions may be decision-useful for users of the report irrespective of how effectively the undertaking manages them or how effectively the topics are regulated. VOC emissions from solvent-based production and waterborne discharges from cleaning at water-based sites are inherent to Siegwerk’s business model (with most products being solvent- or water-based).

For upstream, scores were likewise below the threshold. The DMA adjusted result still treats these impacts as material, reflecting connection to human health and an adequate standard of living (including Art. 25 UDHR considerations in the assessment). It should be noted, however, that the impacts often occur at n-tier of Siegwerk’s upstream value chain. Managing this impact therefore is difficult, nonetheless, where possible, conducted through the SustainUP program. Further by ensuring responsible operations we address potential impacts for the communities in proximity to our sites. The remaining chapter therefore focuses on air and water pollution from own operations.

Due to the materiality mechanism specific to the ESRS standards (ESRS 1 paragraph 43(c)) both sub-topics are new material topics. While the sites of course have continued to ensure sustainable operations, centralized data collection and governance have not yet been fully established, which is likely to be reflected in the maturity and comprehensiveness of data presented in the following.

6.2 Metrics and Targets

Pollutants are identified with reference to Annex II of Regulation (EC) No 166/2006 (E-PRTR) and, as applicable, Regulation (EU) 2024/1244 (IEPR), consistent with ESRS E2 guidance on material emissions of pollutants.

6.2.1 Pollution of Air

For air pollution metrics, Siegwerk distinguishes between sites that operate VOC combustion or other abatement systems and sites that do not.

At sites with VOC combustion, quantitative metrics are available. The sites with VOC combustion are Aarberg (Switzerland), Shanghai (China) and Siegburg (Germany). The VOC emissions per site are displayed in Table 14.

in t CO2e	2020	2021	2022	2023	2024	2025
Siegburg
VOC Ethyl Acetate	917	917	917	917	917	208
VOC Toluene	1.535	1.535	1.535	1.535	1.535	54
VOC Ethanol	878	878	878	878	878	144
Shanghai
VOC Ethyl Acetate	459	459	459	459	459	688
VOC Toluene						0
VOC Ethanol	146	146	146	146	146	0
Aarberg
VOC Ethyl Acetate	142	142	142	142	142	0
VOC Toluene	0	0	0	0	0	0
VOC Ethanol	0	0	0	0	0	0

Table 14: Pollutants of Air - VOC emissions

At sites without VOC combustion, continuous quantitative metrics are generally not available. Representative measurements would require closed-room arrangements and exhaust-point setups that are not installed at all locations. Additional periodic measurements would not create a meaningful incremental incentive beyond the VOC minimization practices already required under the Sustainability Policy and local HSE controls. Minimizing VOC emissions is also a health and safety topic, increasing the inherent motivation for good management. The effort of measurement is therefore disproportionate to the value of having the data available.

During the reporting year there were no material accidental pollution incidents for air.

For pollution of air through VOC emissions, Siegwerk has set a reduction target through the reduction of GHG emissions related to VOC emissions from burning. Refer to Chapter 5 for details.

6.2.2 Pollution of Water

Pollution of water is inherent to the business only at sites which produce water-based products and subsequently use water for the cleaning processes, namely Annemasse (France), Bhiwadi (India), Büdingen (Germany), Morganton (USA), Shanghai (China) and Tangerang (Indonesia).

For those sites, there are two general options for wastewater treatment (see Table 15). Either sites have their own wastewater treatment plant, or the wastewater is shipped to an external third party for treatment.

Site	Type of wastewater treatment	In scope of initial analysis
Annemasse [France]	Third party provider	No
Bhiwadi [India]	Own wastewater treatment	Yes
Büdingen [Germany]	Third party provider	No
Morganton [USA]	Own wastewater treatment	No
Shanghai [China]	Own wastewater treatment	Yes
Tangerang [Indonesia]	Own wastewater treatment	Yes

Table 15: Overview of wastewater treatment for sites with water-based production

For sites with both total wastewater volumes and corresponding laboratory results available for the same period, the results show that discharged wastewater remains far below the thresholds mentioned in Annex II of Regulation (EC) No 166/2006 (E-PRTR) and Regulation (EU) 2024/1244 (IEPR), indicating the effectiveness of wastewater treatment.

During the reporting year there were no material accidental pollution incidents for water. Siegwerk has not set quantitative targets for the reduction of water pollution but rather sees it as a basis of operating procedure.

6.3 Policies and Governance

Objectives on reducing VOC emissions and on responsible water management are embedded in Siegwerk’s Sustainability Policy. In addition, strict national and local environmental regulations in the countries where Siegwerk operates provide a binding governance framework for wastewater and air emissions.

Responsibility for the wastewater treatment plants rests with clearly designated site operators, who differ from site to site, but usually sit within Maintenance or HSE. For VOC emissions, the same principle applies; however, the operator role is usually assigned within Supply Chain Management (SCM). HSE provides functional support (standards, guidance, and expertise). This dual approach keeps operational responsibility with those responsible for operating the plant units while ensuring specialist environmental support with HSE.

Waste water and VOC emissions are also part of global HSE audits, ensuring an additional level of governance from a global perspective. See Chapter 12.2 for details.

6.4 Actions

6.4.1 Pollution of Air

Siegwerk follows a multi-tier approach to manage VOCs and thus reduce pollution to air.

First, it focuses on avoiding VOC releases, for example, by closing open vessels and containing solvent handling. This includes designing new installations as closed systems, such as the new production lines for whites in Tangerang and Thailand.

Second, at select sites Siegwerk operates VOC recovery systems such as in Siegburg (Germany) and Shanghai (China) which collect exhaust air and recover VOCs in dedicated abatement systems.

In the reporting year, the following practical projects were approved for continued implementation of the approaches outlined above: a VOC online monitoring system and an update of the exhaust-gas online monitoring system in Shanghai (China).
VOC emission controls are also included in Global HSE audits (see Chapter 12.2).

6.4.2 Pollution of Water

General approach

At sites with a water-based production footprint, the common practice is to operate on-site wastewater treatments so that discharges to the public system meet applicable limits. The solid residues of the wastewater treatment are disposed according to local regulations. Other sites engage specialized external companies to manage wastewater and potential pollutants, as is the case in Annemasse (France). Wastewater management is also reviewed as part of HSE audits. Table 15shows which approach is applied by each site.

All sites consume service water, however, this is non-critical and fed back into the system. In some cases, minor treatment is done beforehand to ensure full compliance.