11 Upstream-centered Material Topics (ESRS E3, E4, S3)

ESRS Ref: ESRS E3 Water / Sub-topic: Water use (water discharges); ESRS E4 Biodiversity and Ecosystems / Sub-topics: Drivers of biodiversity and ecosystem change; Ecosystem services; ESRS S3 Affected Communities / Sub-topic: Rights of indigenous people

ESRS cross-references: ESRS E1 Climate Change; ESRS E2 Pollution; ESRS S2 Workers in the Value Chain

HorizonNOW 2030: Sustainable procurement; no dedicated Group target (steered through target 1)

This chapter presents several material topics that primarily relate to the upstream part of the value chain: water and marine resources (ESRS E3), biodiversity and ecosystems (ESRS E4), and affected communities (ESRS S3). These topics are grouped together as they all became material through the human rights override in our DMA and occur mainly at tier-n levels of our upstream supply chain.

11.1 Relevance of Topics

The environmental and social relevance of the above listed material topics is primarily linked to the raw materials used in our ink and coating formulations. Water discharges from extraction, land and freshwater use, dependencies on ecosystem services, and impacts on the rights of indigenous communities may arise where those feedstocks (fossil and non-fossil based) are extracted or cultivated. The impacts are attributable to Siegwerk only through these indirect business relationships.

They arise deep in the upstream value chain – typically at tier-n levels, in the extraction and primary processing of oil and gas, mineral and agricultural feedstocks – and not in Siegwerk’s own operations or at direct suppliers. Siegwerk does not operate mines, oil fields or agricultural holdings, and we have no contractual relationship with the sites where these impacts would materialize.

The topics became material through the human rights override we have applied in our DMA. Further details are provided in Chapter 4.1.4. ESRS 1 also allows the use of reasonable and supportable information without undue cost or effort when assessing and reporting on the value chain. We apply that provision here rather than implying a level of insight and control we do not have.

11.2 Policies and Governance

These topics are governed through the same sustainable procurement and human rights due diligence framework described in Chapter 10. The Human Rights Policy and the Business Partner Code of Conduct set expectations on environmental protection and community-related human rights, including respect for the rights of indigenous peoples. Bothare part of supplier onboarding, together with the Siegwerk Sustainability Checklist. Global Purchasing is the operational interface to suppliers, while Global Sustainability and the Human Rights Officer set priorities, guide escalation and ensure legal compliance, including under the German Supply Chain Due Diligence Act.

Implementation runs through SustainUP (Chapter 12.1). No separate governance structure exists for the topics in this chapter, because the risks are identified and addressed through the same supplier processes.

11.3 Metrics, Targets and Actions

We do not set separate metrics or targets for water discharges, land-use change, ecosystem services or the rights of indigenous communities. Entity-specific data at tier-n levels is not obtainable without undue cost or effort, and using proxies would not provide decision-useful information.

What we do steer are the supplier metrics reported in Chapter 10: supplier commitment to the principles of the UN Global Compact under HorizonNOW 2025, and a 95% reduction of high-risk suppliers by 2030 under HorizonNOW 2030. The EcoVadis assessment which the latter target uses as risk rating method includes a Sustainable Procurement theme, which evaluates how our suppliers manage their own supply chains (see Figure 32). It is the closest available lever on the n-tier impacts described here, and actions consist of screening, engagement and targeted programs where severity is highest.

11.4 Progress & Outlook

Progress on these topics follows the maturity of SustainUP. During the reporting period, we continued to roll out supplier expectations, expanded risk-based supplier engagement, and delivered targeted capability building measures. Quantitative progress against the supplier-related metrics is reported in Chapter 10.

Looking ahead, we will continue to prioritize high-risk supply chains and deepen due diligence where potential severity is greatest, while remaining explicit about the limits of our influence beyond direct suppliers. We also expect regulatory developments over the coming years – notably the Corporate Sustainability Due Diligence Directive and the EU Forced Labor Regulation – to improve transparency in deeper supply-chain tiers, since the resulting disclosure pressure will be cumulative across the market rather than dependent on single companies.