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 Senior Vice President of Global Operations, with support from the Senior Environmental Manager, the Environmental Specialist, 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, global manufacturer, and due to its global footprint and various production processes, it is 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 our global environmental management systems are administered under a consistent set of principles. Audits are performed by internal and external parties regularly to confirm that facilities remain in compliance with all required regulations.

In 2021, Greif launched an environmental audit program across our Europe, Middle East and Africa (EMEA) facilities conducted by third parties. On-site external audits were completed for 28 European facilities in 2021. In the first half of 2022, we will expand the audits to 18 EMEA facilities outside of Europe.

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 internal and third-party audits to determine additional facility-specific tasks that may support better environmental risk management. This year, we conducted in-house audits quarterly for all Greif Paper Packaging & Services (PPS) facilities. We also conducted regular internal audits for Global Industrial Packaging (GIP) business. Third-party physical audits were paused in 2020 and 2021 due to the COVID-19 pandemic and are planned to resume in 2022; however, we conducted virtual audits in the interim. Greif was not subject to any fines of material significance.

All GIP sites have completed environmental risk assessments. In 2022, PPS will be performing a global risk assessment to evaluate environmental risk across all facilities. To improve this process, we began developing a standardized tool to assess environmental risk for all locations. This new process will be implemented in 2022 and will help us identify the best path forward to remain compliant with regulations and improve environmental performance.

In addition to the risk assessment, we plan to introduce a maintenance program in 2022 to advance the longevity of our regenerative thermal oxidizers that control VOC emissions at 10 of our steel drum sites across North America. Continuing our shift to a corporate-driven management system, we will be working with a third-party partner to implement and manage the new devices. Our third-party partners will assist us in assuring that our regenerative thermal oxidizers are maintained in compliance with all relevant regulations and avoiding or solving any maintenance-related issues.

Greif’s New Chemical Request and Equipment Pre-Acceptance Review processes continued in 2021. In addition, we developed a safety and environmental review process that requires corporate review when a facility requests to purchase or process a new chemical product at our Delta locations. The chemical undergoes an environmental review conducted by our corporate environmental specialist and a safety review performed by the regional safety officer. Once both reviews are complete, results are shared with the senior environmental manager and the director of EHS for approval. If approved by both parties, we can begin the process of onboarding the chemical. This process ensures that potentially hazardous chemicals are not introduced into our operations without understanding any potential impacts and determining the appropriate mitigating actions.

In our PPS business, we implemented a new project development checklist. When a mill has a new capital project, the project manager must fill out the checklist form disclosing the impacts the project may have on the environment. The comprehensive checklist includes factors such as compliance, changes in emissions and wastewater management. Once completed, our EHS professionals review it to confirm whether the project can move forward. The implementation of the checklist ensures that all new equipment meets our environmental, quality, health and safety standards for equipment prior to being approved for purchase and installation.

In 2021, we completed our efforts to record all capital projects in our GIP North America (NA) business. We also continued our Management of Change (MOC) process in GIP NA to assess potential commercial, EHS, plant, quality and regulatory impacts of manufacturing or materials changes. In 2021, we completed 20 MOC reviews at our GIP NA facilities. In PPS 31 new Chemical Requests were conducted in 2021.

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 team. For example, our PPS business conducted 8 training events on the aspects and use of our EMS in 2021. Approximately 178 compliance training events were directed by our EMS team to North American PPS and GIP sites in 2021, and all EMEA sites also received compliance training. These compliance training events included: