Signatory Name: Visy Industries

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1 Signatory Name: Visy Industries The question numbers in this report refer to the numbers in the report template. t all questions are displayed in this report. Status: Complete The content in this APC Annual Report is hereby endorsed by the Chief Executive Officer, or equivalent officer of the organisation Industry sector (please select 1 only): Brand Owner / Wholesaler / Retailer Packaging Manufacturer Waste Management Other - Commercial Organisation Community Group Industry Association Government Raw Material Supplier Other: Please indicate your organisation's reporting period: Financial Year: 1 July June 2015 Calendar Year: 1 January December 2015 Was your action plan extended or updated to cover the APC transitional year (01/07/ /06/2016)?

2 Goal 1: Design KPI 1: % of signatories with documented policies and procedures for evaluating and procuring packaging using the SPGs or equivalent. 9. Does your company have documented policies and procedures for evaluating and procuring packaging using the SPGs or equivalent? 10. Of the types of packaging existing at the beginning of the reporting period, what percentage had been reviewed using the Sustainable Packaging Guidelines (SPG) by the end of the reporting period? 1 Have any new types of packaging been introduced during the reporting period? 12. Provide details of policies and procedures Visy Pulp & Paper Fibre Procurement Statement Visy Environmental Policy 100 % If yes, of the new types of packaging introduced during the reporting period, what percentage have been reviewed using the Sustainable Packaging Guidelines (SPG) by the end of the reporting 100 % 13. Please indicate your progress this year towards achieving your annual targets and milestones for KPI Action : Educate all staff involved in the design & development of new packaging of the associated environmental and social impacts. Target : Relevant staff able to identify associated impacts Action : Provide all design & development staff with the Visy Sustainable Packaging Design Guide Target : All relevant staff have access to the guide Action : Incorporate environmental ad social criteria into the development process of new packaging Target : Where required, designers are completing detailed checklist Ongoing. Visy packaging is always designed to be "fit for purpose" considering customer and consumer specifications. Being both a resource recovery company and packaging manufacturers, Visy' s packaging formats are designed to maximise the recovery potential of the kerbside recycling system and we work with our customers to produce packaging which avoids material incompatibility issues. Understanding these environmental and social impacts is part of the on the job training of design & development staff. Market category forums and new product development teams regularly meet to discuss & review packaging formats with a view to limit environmental & social impacts. Completed. Market category forums and new product development teams regularly meet to discuss & review packaging formats with a view to limit environmental & social impacts The design process has many inputs - one of which is clearly sustainability driven. However Visy believes that it is a better organisational fit to drive outcomes from a customer and commercial perspective rather than a checklist. As such Visy will not be progressing with this target.

3 Action : Designers and development staff have access to tools/checklists to assess environmental impacts of packaging Target : Where required, designers are completing detailed checklist Action : Develop formal process for working with customers to address environmental performance of new products Target : Formal process developed following Year One scoping Action : Review and revise, if required the Visy Sustainable Packaging Design Guide Target : Guide accounts for all designers or tailored to suit. Action : Develop integrated reporting process Target : Reporting number of designs assessed - automated where possible Action : Produce and implement New Product Design Procedure as part of HSE MS Target : Formal procedure as part of HSE MS Completed Ongoing. Through the Visy Insights & Innovation team, Visy is working across a number of projects with customers to investigate new technologies or materials to improve the environmental performance of packaging. A formal process for these partnerships is yet to be developed and is usually considered on a case by case basis Completed. There is no further development planned for this Action The design review process is a continual one based on technology and Visy/Customer interaction. Visy is not driving this target and will not be implementing this action/target. Completed. Sustainable Packaging Guidelines have been developed which are the base Principles of Visy's design process and cusomer promise. Visy uses these to induct and maintain awareness in design teams Action : Gap analysis of sites compliance with procedure above Target : Understanding site compliance Action : Use internal forums (digital) to allow designers to share sustainability information Target : Designers sharing knowledge across divisions A Gap analysis was not completed. Visy will not be proceeding with this Action/Target Ongoing. Internal newsletters coverings, ideas, product updates, R&D developments etc aid in the development of knowledge transfer. Following a trial period of an interactive communication network utilising Google+, the Visy Insights & Innovation team have now developed category groups - cross divisional which has allowed open dicussion on a market category level. This has allowed designers, sales reps, account managers, R&D specialists etc an open forum both interactively via online discussion and face-to-face. 14. Describe any constraints or opportunities that affected performance under this KPI Visy packaging is always designed to be 'fit for purpose" considering customer and consumer specifications and material efficiency of the pact. being a resource recovery company as well as a packaging manufactures, Visy' s packaging formats are designed to maximise the recovery potential through commercial and kerbside recycling systems and we work with our customers to produce packaging that avoids incompatibility issues. Understanding these environmental and social impacts is part of the on the job training of design and development staff.

4 Goal 2: Recycling KPI 3: % signatories applying on-site recovery systems for used packaging. 15. Do you have on-site recovery systems for recycling used packaging? at all facilities/ sites at some, but not all facilities/ sites 16. Please indicate your progress this year towards achieving your annual targets and milestones for KPI 3 Action : Continue to improve on-site recovery systems for recycling at Visy of used packaging and office products Target : Minimum standard met at all sites Recycling programs are installed at all Visy sites according to the Visy Green Office Guidelines which outline the requirements for office recycling and waste management All of Visy's packaging operations have on-site recovery systems for the collection of waste packaging materials such as trimmings and rejects during manufacture. 2. Action : Continue to improve on-site recovery systems for recycling production wastes Target : Recycling of key material wastes at Visy Visy continues to implement a number of projects and initiatives that reduce waste to landfill and recycling existing production waste Action : Work with Visy Recycling to assess recyclability of customers production and packaging wastes Target : Formal procedure/service explored Action : Review 2008 Sustainable Sourcing Policy Target : Sustainable Source Policy revised and signed by COO Action : Improve consumer and customer recycling knowledge Target : Defined education strategy revised to account for key packaging customers Action : Work with key customers and Covenant to improve away from home recycling Target : Defined strategy to progress public place and other away from home recycling strategies Complete. Visy offers this service through a waste audit conducted by Visy Recycling. While no formal process exists, customers may request an audit through their state contacts. Completed. further action required. Managing the impact of our supply chain is identified in Visy's Corporate Environment Policy and responsibility is assigned to the Divisional Purchasing Teams. Visy's key raw materials are fibre, aluminium and plastic and we are focused on obtaining these from sustainable post consumer and industrial sources. Visy certifies its fibre supply chain to FSC and PEFC. We're focused on promoting the rigour we place around fibre sourcing and the products we produce; whether it's through increased certification and further labelling or branding. Visy Recycling Education Centres are now open in Victoria, New South Wales & Queensland offering tours and presentations about our packaging closed loop. The programs are offered to schools, community groups and businesses within our local council partners. Ongoing discussions with local councils and key customers for strategies to improve public place recycling.

5 17. Describe any constraints or opportunities that affected performance under this KPI All of Visy's packaging operations have on-site recovery systems for the collection of waste packaging materials such as trimmings and rejects during manufacture. For example : - PET and Plastics rejects and trimmings are collected for regrind an reused. - Paper and cardboard trimmings and waste are recovered and sent to our recycled paper mills for fibre feedstock - Waste aluminium is collected and sent to aluminium processors for recycling as are steel offcuts and trimmings from our food can operations. Visy recycled board grades are made of Visy recycled paper liners. Visy's recycled paper mills are FSC Recycled certified. As a result. Visy Board's corrugated cardboard products offer an excellent environmental impact solution. Visy established Australia's first 100% recycled plastics plan which uses FDA approved recycling processes for the manufacture of recycled food grade PET and the manufacture of recycled HDPE. KPI 4: Signatories implement formal policy of buying products made from recycled packaging. 18. Does your company have a formal policy of buying products made from recycled packaging? Please explain why not Managing the impact of our supply chain is identified in Visy's Corporate Environmental Policy. Visy does not have a prescribed policy for Buy Recycled, however through the supplier quantification review process and through formal supplier reviews, Visy reviews its critical suppliers on it's sustainability focus and regularly receives sustainability updates. As a recycling company, Visy has processed over 2 million tonnes of resources from Australian and New Zealand kerbside and commercial recycling in 2014/15. This includes 5 million tonnes of waste paper and cardboard used as a major feedstock for our six recycled paper mills. 19. Is this policy actively used? 20. Please indicate your progress this year towards achieving your annual targets and milestones for KPI 4 targets in Action Plan N/A 2 Describe any constraints or opportunities that affected performance under this KPI Visy's programs aims to maximise packaging recyclability and increase the recycled content of our products. At the time of writing this annual report, no formal Buy Recycled policy is planned for implementation. Visy supports the APC's target for brand owners to continually review their packaging (both new and current) and supplies information & data that supports the reporting of recycled content in brand owners packaging.

6 Goal 3: Product Stewardship KPI 6: % signatories with formal processes to work collaboratively on packaging design and / or recycling. 22. Does your company have formal processes in place for collaborating with other companies or organisations on improved packaging designs and/or recycling which aims to reduce or eliminate waste? Provide details of policies and procedures (including names of policies/ procedures) Visy has an embedded innovation process with its customers. The Insights & Innovation group is charged with developing new products & processes with internal business units and customers. A good example of this supplier/customer innovation collaboration is the increased use of recycled PET in PET bottles. Visy is also developing applications for rhdpe packaging products for a variety of applications including milk, cream, vinegar & juice up to 50%. rplastics branding & marketing give brand owners a competitive advantage - the opportunity to tell a much better packaging sustainability story to their customers. 23. Please indicate your progress this year towards achieving your annual targets and milestones for KPI Action : Continue to review and develop our Action Plan annually to account for customer expectations and requirements. Target : Action Plan is targeted to key customers Action : Continue to increase the number of suppliers Target : Major material suppliers completed survey and Code of Conduct Action : Review supplier assessment process to ensure high risk suppliers are captured Target : Major material and potential high risk suppliers completed survey and signed Code of Conduct Action : Continue to identify product certification opportunities Target : All opportunities evaluated Action : Develop Product Stewardship Procedures as part of HSE MS Target : Formal procedures aligned with APC requirements Action : Gap Analysis of sites compliance with procedure above Target : Gap Analysis complete The Action Plan is to be kept as it until the next formal stage of the APC is decided. In terms of both supplier sustainability and assessment we regularly monitor and assess our key materials through our customer review process. t completed. Visy will continue to drive the highest level of commercial and technical expectations of all our key suppliers. Completed. The appropriate certification opportunities were identified and pursued. Visy's six Australian recycled paper mills are FSC Recycled Certified. Plasterboard liner from the Visy Paper Coolaroo site, is also FSC Mix Certified. Visy Pulp and Paper Tumut which produces Kraft paper is 70% PEFC Certified and FSC (FSC-C) responsible wood fibre. Further certification opportunities will be investigated as they arise. A restructure of the National Environment Team moved focus away from developing the HSE MS towards ensuring compliance with existing standards. t conducted due to change in HSE standard

7 Action : Explore opportunities for resource efficiency across the Visy Group Target : Resource efficiency procedures implemented Action : Continue to improve the capacity of reporting programs and scorecards Target : New environment scorecard implemented Action : Educate staff on key strategies to minimise waste Target : Develop and run "Waste t" program Resource efficiency is the backbone of Visy operations. Visy Environment Policy contains a commitment to use natural resources responsibly. Visy produced approx. 50% of its energy needs from renewable sources. Since Visy has reduced its greenhouse gas emissions per energy consumed by 18%. Visy uses a number of alternative water sources (i.e desalination and recycled water) These alternative water sources have increased from 183,935 KL (3.7% of total water consumption) in FY09 to 1,164,721 KL (16.5% of total water consumption) in FY15. Completed & implemented. Visy has continued to work on improving internal HSE reporting and to ensure systems are capable of meeting all external reporting requirements such as NGERs and NPI. Completed. Educational programs are ongoing 24. Describe any constraints or opportunities that affected performance under this KPI Within our packaging divisions, Visy regularly works with customers to improve the design and/or recyclability of our packaging products. While no formal process is in place, it is an inherent part of our customer relationships and is approached in most contracts and supply agreements. Visy's Recycling division relies on appropriated material collection or sorting. Contamination of non-recyclable materials decreases the efficiency or our Materials Recycling Facilities (MRF's). As such, Visy's packaging formats are designed to maximise the recovery potential of the commercial and kerbside recycling system and we work with our customers to produce packaging with avoids material incompatibility issues. Understanding these environmental and social impacts is part of the on the job training of design and product development staff. Visy also works closely with major customers in providing innovative product designs that utilise emerging technologies in materials, design and sustainable packaging. The feasibility of such products always considers the recyclability and recoverability of a material and design through our existing recycling infrastructure. KPI 7: % signatories showing other Product Stewardship outcomes. 25. Please indicate your progress this year towards achieving your annual targets and milestones for KPI 7 Action : Use internal forums (digital) to inform customer facing staff of product stewardship issues Target : Increase usage and access to forum This program has developed into open market category discussion groups using a mixture of Google+ communities as well as formal market category forums where product stewardship issues are amongst standard discussion items. Cross divisional in nature, the forums provide an opportunity to enhance specific learnings in this area and to apply such learnings to business oriented outcomes. Projects formed out of these groups are aligned to Visy and specific customer goals.

8 Action : Develop Product Stewardship communications plan Target : Plan developed and implemented Action : Develop Product Stewardship Procedures as part of HSE MS Target : Formal procedures aligned with APC requirements Action : Reward & recognise efforts to improve packaging Target : Include Product Stewardship at least 1 recognition per year Action : Introduce Product Stewardship lead environment indicator Target : Lead indicator measured on scorecard A formal Product Stewardship did not proceed. Instead the HSE Standard 12 which incorporates product stewardship with an emphasis on EMS, site environmental risk management and lifecycle environmental management procedure was implemented. Completed. HSE Standard 12 is now broader than product stewardship and deals with EMS site environmental risk management and lifecycle environmental management. Decision made not to proceed with this Action/Target Implemented & completed. Lead indicator developed for environmental systems and performance. 26. Since the beginning of the reporting period, has your company had any other outcomes related to product stewardship? If yes, please give examples of other product stewardship outcomes 27. Describe any constraints or opportunities that affected performance under this KPI Visy is a member of the Sustainable Agriculture Initiative (SAI) Platform which is a cross industry approach to a more sustainable supply chain. Its membership is committed to supporting the development of sustainable agriculture - its sole agenda is to improve the sustainability of agriclture and productivity. Visy is in a unique position to provide support and leadership in the areas of recycling and packaging. Visy is a Foundation Member of the Retail & Supplier Roundtable - Sustainability Council. The vision of the Sustainability Council is to lead consumer goods industry collaboration on documenting and promoting consistent sustainability practices and continuous improvement across the supply chain. Visy uses a number of alternative water sources (i.e. desalination and also recycled water). These alternative water sources have increased from KL (3.7% of total water consumption) in FY09 to 1,164,721 KL (16.5% of total water consumption) in FY15. This has reduced our impact on fresh water sources. Visy s primary energy consumption* increased in 2014/2015 by 0.82% over the previous year (*Primary energy consumption includes all fuels (Scope 1 renewable and fossil) used by Visy and all energy as steam or electricity (Scope 2) purchased by Visy but excludes steam and electricity used by sites that were generated by Visy sites). Visy has consistently increased the amount of energy from renewable sources (including wood waste, black liquor from kraft paper production, biomass-paper waste, and bio-gas and bio-fuels derived from production processes) over the past five years. In Visy produced approx. 50% of its energy needs from renewable sources. Since Visy has reduced its greenhouse gas emissions per energy consumed by 18%. In Visy generated 995,103 GJ of electricity within its operations (an almost 5% increase on FY14) and through this reduced our use of electricity from the national grid.

9 KPI 8: Reductions in packaging items in the litter stream. 28. Please indicate your progress this year towards achieving your annual targets and milestones for KPI Action : Improved broader staff awareness of the strategies to reduce the incidence of Visy's packaging becoming litter Target : Run internal litter education program Action : Encourage staff to participate in Clean Up Australia Day Target : Communications program around litter Action : Ensure litter management is adequately address in housekeeping checklists Target : Adequate litter management on site Ongoing. Visy-wide Toolbox Talks on Litter and Stormwater management mandated across all sites. t considered for reporting period due to other business priorities Ongoing. Visy-wide Toolbox Talks on Litter and Stormwater management mandated across all sites. 29. Describe any constraints or opportunities that affected performance under this KPI Visy works with customers to design packaging formats which minimise littering by avoiding unnecessary removable items. However the nature of away from home consumption requires packaging systems to often contain removable pieces such as foldable forks or spoons, and ultimately littering is a personal decision. Effective away from home recycling systems and community education have been shown to reduce littering and Visy has supported the promotion of these goals through our involvement with local councils.

10 Your Experiences This section lets you share with us any achievements, good news stories and areas of difficulties in making progress against your plan and the Covenant goals and KPIs. 30. Key achievements or good news stories In Visy has processed over two million tonnes of resources from Australian and New Zealand kerbside and commercial recycling. This includes 5 million tonnes of waste paper and cardboard used as a major feedstock for our six recycled paper mills, Visy's Council and Commercial co-mingled collection services recover mainly HDPE, PET, Glass, Aluminium, Steel and Fibre. Recyclable waste materials from Fibre and PET businesses are put back through the recycling/manufacture process and eventually reused in new packaging products. 3 Areas of difficulties in making progress against your plan, Covenant goals or KPIs We firmly believe that Visy's core business principles strongly support the goals of the Covenant however we realise that many of the Actions in our Plan required the implementation of separate business processes above these already effective systems. Visy's approach to the goals of the Covenant should instead be through the delivery of mainstream strategies that build on our existing culture of lowest cost that continue to drive sustainabiity through commercial initiatives. Visy has strongly supported the Australian Packaging Covenant and supports a broad whole of lifecycle approach to sustainable packaging, not solely recovery focused policy. We also continue to support greater domestic remanufacturing of products from recyclates, to deliver national benefits including manufacturing jobs and investment as well as emissions reduction. A culture of innovation and our unique service model through the life-cycle of packaging has made Visy a leader in its field. We can help our customers design innovative new packaging, create it, assist with manufacture, transport product to customers or end consumers, provide expert branding and promotions, then...collect it all back again to be recycled into new packaging. Our APC Action Plan and thus this Annual Report apply to Visy's Packaging operations in Australia only, Visy Pulp and Paper, Visy Recycling, Visy Logistics and our offshore operations fall outside the scope of the APC. However Visy Recycling is core to Visy's approach to resource recovery and is included within the plan to Recycling Key Performance Indicators. Visy realises that our APC Action Plan as it currently stands is what we intended to do at the time that it was submitted - the majority of KPI's have already been achieved. However the reality is that VIsy works very closely with our customers to help them meet their APC KPIs. Visy is driving sustainable packaging and is a clear leader in the field but we also recognise that the agenda is set by our customers.

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