Environmental Stewardship & Circularity Documentation & Evidence

• Policy, process document, Environmental Management System (EMS) document, or written comment that explains the company’s approach to waste management in their operations. 

• Report, spreadsheet, or other internal document that shows the breakdown on waste disposal methods for hazardous and non-hazardous waste generated for each year required by the compliance criteria.

• Only for companies that sell food products and/or agriculture companies: Annual report, spreadsheet, or other internal document that shows the breakdown on waste disposal methods for food waste generated for each year required by the compliance criteria.

• Report, spreadsheet, or other internal document that shows the breakdown on waste disposal methods for non-hazardous waste generated in line with ESC1.1.2a through c for each year required by the compliance criteria.

• Report, spreadsheet, or other internal document that shows the breakdown on waste disposal methods for hazardous waste generated in line with ESC1.1.3a through c for each year required by the compliance criteria.

• Hazardous waste manifest or other documentation of hazardous waste required by local legislation.

• Only for companies that sell food products and/or agriculture companies: A report, spreadsheet, or other internal document that shows the breakdown on waste disposal methods for food waste generated in line with ESC1.1.4a through c for each year required by the compliance criteria.

• Report, spreadsheet, or other internal document that shows the breakdown on waste disposal methods, showing that any waste with an unknown destination is categorized as going to landfill.

• Written comment detailing the company’s disposal methods and evidence, such as utility bills, certificates of disposal or recycling.

• Report, spreadsheet, or other internal document that shows the breakdown on waste disposal methods. This includes an overview per facility or there is a documented process to gather and consolidate data per facility.

• Materiality assessment with a written comment on material facilities of the company.

• A list of all facilities owned or controlled by the company.

• Waste management plan (if the company does not track waste from all facilities owned or controlled).

ESC1.2 The company monitors its energy use.

• Policy, process document, Environmental Management System (EMS) document, or written comment that explains the company’s approach to tracking energy consumption in their operations.

• If the company generates their own renewable energy on-site, evidence such as photos of their solar panel installation or copies of installation invoices.

• Report, spreadsheet, or other internal document that shows the breakdown on energy consumption in line with ESC1.2.2a through d for each year required by the compliance criteria. This includes an overview per facility or there is a documented process to gather and consolidate data per facility.

• Materiality assessment with a written comment on material facilities of the company.

• A list of all facilities owned or controlled by the company.

• Energy management plan (if the company does not track energy consumption from all facilities owned or controlled).

ESC1.3 The company monitors its water consumption or withdrawal.

• Policy, process document, Environmental Management System (EMS) document, or written comment that explains the company’s approach to tracking water consumption or withdrawal in their operations.

• An internal document providing a written justification for choosing to measure either water consumption or withdrawal.

• Water risk assessment.

• Report, spreadsheet, or other internal document that shows the breakdown on water consumption or withdrawal in line with ESC1.3.2a through c for each year required by the compliance criteria. This includes an overview per facility or there is a documented process to gather and consolidate data per facility.

• Materiality assessment with a written comment on material facilities of the company.

• A list of all facilities owned or controlled by the company.

• Water management plan (if the company does not track water consumption or withdrawal from all facilities owned or controlled).

ESC1.4 The company identifies its facilities in areas at water risk and monitors their water consumption or withdrawal.

• A list of all facilities owned or controlled by the company and their locations, highlighting facilities in water risk areas, if applicable.

• Evidence of research of all company facilities to identify if any are in high-risk areas, such as government reports, documentation of contact with local authorities, use of a tool, links to relevant studies.

• Report, spreadsheet, or other internal document that shows the breakdown on water consumption or withdrawal in line with ESC1.4.4a and b for each year required by the compliance criteria, highlighting the water usage at facilities in water risk areas.

• Materiality assessment with a written comment on material facilities of the company.

• Water management plan (if the company does not track water consumption or withdrawal from all facilities owned or controlled in areas of physical water risk).

ESC1.5 The company identifies its facilities in or near ecologically sensitive areas, and whether they are negatively affecting these areas.

• Evidence of research to identify if any of the company's manufacturing or production facilities are in ecologically sensitive areas, such as government reports, documentation of contact with local authorities, use of a tool, links to relevant studies.

• Records of an impact assessment, detailing the methodology, that identifies the facility's most significant impacts on biodiversity.

• A list of all manufacturing and production facilities owned or controlled by the company and their locations, highlighting facilities in or near ecologically sensitive areas, if applicable.

• The date in the impact assessment document, confirming it was completed within the last 36 months.

ESC1.6 The company monitors the animal welfare conditions in its operations.

• Document, such as internal organizational chart, or written comment from the company with an overview of the company’s operations that are relevant to the production and/or sale of animal products.

• Formal report or process document that shows the indicators that the company uses to monitor animal welfare conditions covering ESC1.6.1a through c.

• Tracking spreadsheet or other internal database that shows the data the company has collected animal welfare data for each year required by the compliance criteria.

• Internal or external facing document (e.g., report), that shows an annual aggregate summary of the animal welfare conditions.

• Document, such as internal organizational chart, or written comment from the company with an overview of the company’s operations that are relevant to the production and/or sale of animal products.

• Formal report or process document that shows the indicators that the company uses to monitor animal welfare conditions covering ESC1.6.1a through c.

• Tracking spreadsheet or other internal database that shows the data the company has collected animal welfare data in the past fiscal year for Year 0, or all years since the previous certification.

• Internal or external facing document (e.g., report), that shows an annual aggregate summary of the animal welfare conditions.

• An internal document identifying applicable animal welfare laws and records demonstrating compliance such as permits, policies, or internal audit reports.

ESC1.7 The company conducts an assessment to identify actual and potential environmental impacts connected to its operations and value chain.

• A report or document that lists and prioritizes environmental issues. Includes a methodology section aligned with the compliance criteria. It does not have to be publicly shared, and can be completed in-house or by a third party.

• Records of impact assessment, for instance:

  • Environmental performance data

  • Stakeholder engagement (documentation of meetings, surveys, and conversations with stakeholders)

  • Impacts register (e.g., spreadsheet or database listing the company's impacts on nature, such as wastewater discharge, land use change).

  • Internal/external impact assessment tools (e.g., spatial maps, industry guidance)

  • Third-party assessments and reports

  • Reports from working groups of industry associations the company is part of

  • A report or internal document that lists and prioritizes environmental issues. Includes a methodology section aligned with the compliance criteria.

  • The date in the assessment document, confirming it was completed or updated in the last 36 months.

  • A written explanation for why water, biodiversity, or waste were not deemed material, supported by credible scientific evidence. The explanation letter signed by the highest governing body or highest governing body meeting minutes. The minutes include an approval of the written explanation by the highest governing body.

  • A written note or section in the internal assessment document referring to the potential impacts from the Risk Tool.

ESC1.8 The company publicly shares its material environmental issues.

• Link to the company’s website or annual impact report, where a materiality matrix of identified material (environmental) issues (as per PSG2.3) are publicly available.

• A link to the company's webpage or report where the methodology used in the assessment is publicly shared.

ESC 2.1 The company has a strategy to address its actual and potential negative environmental impacts.

• A strategy document that addresses material negative environmental impacts in direct operations and the value chain, and describes how the company will address each impact.

• The strategy or a related implementation plan that includes ESC2.1.2a through g.

• Evidence to verify that the company’s environmental strategy is approved by the executive team or highest governing body. This may include meeting minutes or a signature on the strategy.  

• The date in the strategy document, confirming it was adopted or reviewed in the last twelve months.

• Meeting minutes confirming the highest governing body reviewed or adopted the strategy in the last twelve months at the time of submitting it for the audit.

ESC 2.2 The company has a biodiversity transition plan to halt and reverse biodiversity loss caused by its operations and value chain.

• A biodiversity transition plan that includes ESC2.2.1a through d.

• Action plans or projects from working groups of industry associations the company is part of.

• The biodiversity transition plan that includes ESC2.2.2a through c.

• Evidence to verify that the company’s biodiversity transition plan is approved by the executive team or highest governing body. This may include meeting minutes or a signature on the plan.  

• The biodiversity transition plan.

• The date in the biodiversity transition plan, confirming it was adopted or reviewed in the last twelve months. 

ESC 2.3 The company has a water stewardship strategy that limits water use in its operations and value chain to within sustainable thresholds.

• A water stewardship strategy that includes ESC2.3.1a through d.

• Action plans or projects from working groups of industry associations the company is part of.

• Documentation of identification of contextual data, such as:

  • Records of contact with the local authority 

  • Analysis of water risk

• Records of scientific resources or expert advice

• The water stewardship strategy.

• Evidence to verify that the company’s water stewardship strategy is approved by the executive team or highest governing body. This may include meeting minutes or a signature on the strategy.  

• The date in the water stewardship strategy, confirming it was adopted or reviewed in the last twelve months.

• Meeting minutes confirming the highest governing body reviewed or adopted the strategy in the last twelve months.

ESC 2.4 The company’s policies and procedures address its material environmental impact areas.

• A policy or procedure document for each material environmental impact area.

• The policy or procedure documents, showing that their scope matches the nature and relevance of the material environmental impact area.

ESC 2.5 Workers in relevant roles receive the guidance they need to implement the environmental policies and procedures.

• Training materials, guidance documents, or tools provided to workers in relevant roles.

• Records of training attendance, communication to relevant roles.

• Job descriptions, team/function strategy documents, organizations charts to confirm relevant roles.

• Interviews with workers that received guidance.

• Training materials, guidance, or tools that are tailored to specific roles or departments.

• Interviews with workers that received guidance.

ESC2.6 The company assesses the potential negative environmental impacts related to potential organizational clients and projects, and takes necessary mitigation actions.

• A documented process for assessing the potential negative environmental impacts of working with clients and projects.

• Client selection or screening policy with environmental criteria. 

• Project and client selection or screening tool.

• The process document that includes mitigation actions.

• Annual records of the process to determine the three most material potential clients and projects, which may include a reference to timesheets, billing reports, revenue reports, income statements, impact assessments.

• Annual records of the outcomes of the assessment, such as meeting minutes, consultations, risk matrix, internal reports.

• Records of mitigation actions taken and an evaluation of their effectiveness.

ESC2.7 The company assesses the potential negative environmental impacts of investments, and takes necessary mitigation actions.

• A documented process for assessing the potential negative environmental impacts of potential investments.

• Client selection or screening policy with environmental criteria. 

• Project and client selection or screening tool.

• The process document that includes mitigation actions.

• Annual records of the process to determine the three most material potential investments, which may include a reference to investment statements, portfolio tracking tools, impact assessments.

• Annual records of the outcomes of the assessment, such as meeting minutes, consultations, risk matrix, internal reports.

• Records of mitigation actions taken and an evaluation of their effectiveness.

ESC3.1 The company monitors its material inflow.

• An annual overview of material inflow indicators, separated by products and packaging, e.g., internal spreadsheets, procurement platforms, databases.

• Sustainability certifications or third-party assessments for renewable input materials.

ESC3.2 The company reduces its use of virgin non-renewable materials.

• An annual overview of material inflow indicators, separated by products and packaging, e.g., internal spreadsheets, procurement platforms, databases, that confirms ESC3.2.1 a and b.

ESC3.3 The company’s product development incorporates circularity principles.

• Written confirmation of the chosen sub-requirement options (ESC3.3a through d).

• In case there are legal barriers to adopt circular design principles: links to the respective regulations or health and safety standards.

• Product specification sheets.

• A document that explains how the product design follows the priority order of the waste hierarchy, such as product development documentation, policy or other internal document.

• Records demonstrating an increase in the percentage of indicators or the addition of a new, higher-hierarchy option.

• Records showing a change from the "end-of-life recirculation" option to one of the higher-hierarchy options.

• If the company has multiple products in its portfolio:

  • Records of the percentage, by weight, of products and packaging separately that do not fit any of the four options, if applicable.

  • Records showing that the entire product portfolio was measured across the four options.

  • The records of the percentage of single-use products and packaging by weight.

• Records showing the reduction in the percentage of single-use products or packaging.

• Records of the percentage of products and packaging designed for durability, repairability, or reusability.

• Internal document detailing how the product or packaging design enables durability, repairability or reusability.

• Records of product testing for durability.

• Records of memberships of related (international) pacts, collective action or partnerships with expert organizations to address aspects of circularity outlined in the sub-requirement (e.g., Ellen MacArthur Foundation).

• Third party-assessments, e.g., Crade-to-Cradle.

• Records of the percentage of products and packaging designed for disassembly, remanufacturing, or refurbishment.

• Internal document detailing how the product or packaging design enables disassembly or remanufacturing or refurbishment.

• Records of the percentage of products and packaging designed for recycling or recirculation by the biological cycle.

• Records of consideration of product design compatible with existing recycling systems, such as meeting minutes, product design documentation, internal reports.

• An internal document explaining how the product or packaging design exceeds standard practice for recycling or recirculation by the biological cycle.

ESC3.4 The company understands the recovery infrastructure available where it sells its products.

• An analysis document of available recovery infrastructure for products and material packaging that meets ESC3.4.1a through d. It may be supported by other reference materials such as data from municipalities and waste management companies, sales reports, records of engagement.

• A methodology note or section in the analysis about how the company defined its material products and packaging.

• A methodology note or section in the analysis.

• The date in the recovery infrastructure analysis document, confirming it was completed or updated in the last 36 months.

• Records showing an increased extent of coverage in each subsequent analysis.

ESC3.5 The company takes steps to increase the recovery of its products and packaging after their end-of-life.

• Records of actions or programs to improve infrastructure for product or packaging recovery. For instance:

  • Contracts detailing contributions to an Extended Producer Responsibility (EPR) scheme

  • Partnership agreements with relevant stakeholders such as waste management companies, municipalities, or non-profit organizations

• Records of multi-stakeholder collaborations through alliances

• Records showing these actions or programs were introduced in the two countries with the largest end-user sales

• Sales dashboard or report.

• Records demonstrating an increase in the scale of existing programs or the introduction of new ones.

ESC4.1 The company implements actions to prevent or mitigate its actual and potential negative environmental impacts.

• Records of the actions taken, individually or collectively, and their demonstrable output or results.

• Internal and public commitments. Progress or impact reports, scorecards.

• Records of the actions taken and their demonstrable output or results.  

• Records of impact data or metrics.

• Records confirming the actions are related to the company's operations or value chain.

ESC4.2 The company makes progress on its environmental strategy and evaluates its effectiveness.

• The company's environmental strategy.

• Records of the actions taken, individually or collectively, and their demonstrable output or results.

• Internal and public commitments. Progress or impact reports, scorecards.

• A report or meeting minutes detailing the evaluation of the effectiveness of the environmental strategy. 

• Records of internal and/or external (i.e., expert) consultations, research, emerging guidance by third party organizations.

• Records of the company prioritized avoiding and reducing negative environmental impacts while progressing its environmental strategy.

• Records of updates to the environmental strategy.

• Links to any public ratings of the company's environmental strategy by expert organizations, such as the World Benchmarking Alliance.

• Meeting minutes or a formal letter confirming the results of the evaluation were shared with the highest governing body or executive team.

• A report or meeting minutes detailing the evaluation of the effectiveness of the environmental strategy. 

• Records of updates to the environmental strategy.

• The environmental strategy document showing targets and indicators for preventing or mitigating negative environmental impacts in the value chain.

ESC4.3 The company makes progress on its biodiversity transition plan and evaluates its effectiveness.

• The company's biodiversity transition plan.

• Records of the actions taken, individually or collectively, and their demonstrable output or results.

• Internal and public commitments. Progress or impact reports, scorecards.

• A written note or section in the biodiversity transition plan detailing how it is aligned with the mitigation hierarchy for biodiversity.

• A report or meeting minutes detailing the evaluation of the effectiveness of the biodiversity transition plan. 

• Records of internal and/or external (i.e., expert) consultations, research, emerging guidance by third party organizations.

• Records of updates to the biodiversity transition plan.

• Meeting minutes or a formal letter confirming the results of the evaluation were shared with the highest governing body or executive team.

• Links to any public ratings of the company's environmental strategy by expert organizations, such as the World Benchmarking Alliance.

• The biodiversity plan showing targets and indicators for the value chain.

ESC4.4 The company makes progress on its water stewardship strategy and evaluates its effectiveness.

• The water stewardship strategy.

• Records of the actions taken, individually or collectively, and their demonstrable output or results.

• Internal and public commitments. Progress or impact reports, scorecards.

• A report or meeting minutes detailing the evaluation of the effectiveness of the water stewardship strategy.

• Records of internal and/or external (i.e., expert) consultations, meeting minutes, research, emerging guidance by third party organizations.

• Records of updates to the water stewardship strategy.

• Links to any public ratings of the company's environmental strategy by expert organizations, such as the World Benchmarking Alliance.

• Meeting minutes or a formal letter confirming the results of the evaluation were shared with the highest governing body or executive team.

• A report or meeting minutes detailing the evaluation of the effectiveness of the water stewardship strategy.

• The water stewardship strategy showing targets and indicators for the value chain.

ESC4.5 The company publicly shares the effectiveness of its environmental strategy.

• A link to the company's webpage with the public report on environmental strategies, which may be an integrated annual report or standalone sustainability report.

• The date in the report confirms that it was updated within the last 36 months.

• A link to the company's webpage with the public report on environmental strategies.

ESC5.1 The company considers actual and potential environmental impacts in its procurement decisions.

• Annual records of the process to determine the five most material procurement decisions, which may include a reference to spend reports, invoices, purchase orders, impact assessments.

ESC5.2 The company considers actual and potential environmental impacts in its procurement decisions

• Annual records of the process to determine the five most material procurement decisions, which may include a reference to spend reports, invoices, purchase orders, impact assessments.

ESC5.3 The company works with suppliers to prevent or mitigate their most material environmental impacts

• A list of prioritized suppliers and a document outlining the criteria used for prioritization.

• Evidence of a process for prioritizing suppliers based on actual and potential negative impact.

• Documentation of agreed targets with prioritized suppliers and records of annual progress monitoring (e.g., slides or meeting minutes of annual business reviews indicating the list of attendees, supplier scorecards, performance reports).

• Records of projects of related working groups in industry associations or multi-stakeholder collaborations (i.e., collective action).

ESC5.4 The company has a time-bound plan to trace the origin and potential environmental impacts of its high-risk raw materials.

• Impacts assessment under ESC1.7.

• A list of high-risk raw materials.

• A traceability plan.

• Third-party certifications, a supply chain traceability report, legal compliance documents.

• Records of projects of related working groups in industry associations or multi-stakeholder collaborations (i.e., collective action).

• A calculation and documentation showing the proportion of traceable high-risk raw materials.

• Breakdown of raw materials by location.

ESC5.5 The company sources deforestation-free raw materials.

• Third-party certifications, supply chain traceability reports, legal compliance documents, geospatial data, satellite imagery.

• Zero deforestation or no-conversion policy.

• Impacts assessment under ESC1.7.

• A list of high-risk raw materials linked to deforestation.

ESC5.6 The company traces more high-risk raw materials to their origin.

• Records showing an increase in the proportion of traceable high-risk raw materials, such as third-party certifications, supply chain traceability reports, legal compliance documents, geospatial data, satellite imagery.

• A list of high-risk raw materials.

• A traceability plan.

ESC5.7 The company works with suppliers to address environmental impacts related to high-risk raw materials.

• Documentation of agreed targets with prioritized suppliers and records of annual progress monitoring (e.g., slides or meeting minutes of annual business reviews indicating the list of attendees, supplier scorecards, performance reports).

• A list of high-risk raw materials.

• A traceability plan.