2024


Non-financial
Performance
Declaration
Printed on Clairbook 1.5 Extra White paper - Cover 240 gsm - Inside pages 100 gsm

With the exception of the cover photo (Western Capercaillie - Tetrao urogallus), all the wildlife
photos contained in this report were taken in the Vosges Mountains.
FOREWORD
This document sets out the way in which the Exacompta Clairefontaine
Group takes account of the social and environmental impacts of its
activities.

This statement of non-financial performance (Déclaration de
Performance Extra-Financière or DPEF in French) is an integral
part of the management report. The reporting period covers the year
2024 (1 January to 31 December), during which the Group generated
consolidated revenue of €831,274,000.

Aside from the exceptions specified below, all of the Group’s activities
are covered in this document. The environmental information contained
in this statement covers 98.5% of the workforce in the target scope, and
99.7% for employee information. We have specifically focused on paper
production activities, which account for the majority of the Group’s
environmental impact. Some historical data (energy/air emissions/
water) has been corrected following the detection of errors.

Due to an organisational change, information relating to Quo Vadis
Canada could not be collected.
Papeterie du Coutal, which ceased production during 2024, and
Digital Valley Portugal, which provides IT services, are not included in
this statement of non-financial performance.

In 2024, the Group acquired Flock One, a company specialising in
flocking for decorative and technical applications. Data relating to this
site will be included in next year’s publication.

The Group encourages measures designed to promote responsible food
choices, prevent food insecurity and improve animal welfare, although
it does not exercise direct responsibilities in these areas. These issues
are therefore excluded from this report.

Exacompta Clairefontaine encourages its subsidiaries to promote
physical exercise and sport.

With regard to support for the French army reserve and the promotion
of links between the nation and the armed forces, in accordance with
Article L. 3142-89 of the French Labour Code, employees who are part
of the army or national police reserves are granted unpaid leave of at
least ten days per year.
In France, in companies with more than 11 employees, the social and
economic committee (SEC) is the staff representative body.
For a number of years, dialogue with social partners, in particular trade
union representatives, has enabled the conclusion and implementation
of collective agreements in order to ensure the continuation of good
working conditions and equal treatment.
At 31 December 2024, 157 agreements in force were recorded relating
to issues including salary, working hours, health scheme funding and
professional gender equality.

Site managers are responsible for implementing Group policy to ensure
that their activities guarantee employee health and safety, help preserve
the environment and promote regional development.

Preserving biodiversity in all its forms is a major challenge and plays a
key role in many areas, including:
- supplies (food, fresh water, building materials, biomass fuel,
pharmaceuticals, etc.);
- regulation (climate, erosion, diseases, pollination, etc.);
- cultural activities (leisure and tourism, inspiration, education, ethical
and spiritual values).

As a user of these services, the Exacompta Clairefontaine Group is
committed to preserving biodiversity. Various actions in this area are
presented in this report.
CONTENTS
THE GROUP’S PRODUCTS 4
GROUP PRESENTATION 5
Principal business activities 5
Markets 6
Industrial assets 7
Commercial assets 7
Environmental assets 8
A long-term policy 9

ENVIRONMENTAL INFORMATION 10
Investing to limit our environmental impact 11
Financial provisions and guarantees 13
Raw materials 13
“Waste” management 15
Combating food waste 16
Energy consumption 16
Fuels 17
Electricity 18
Use of renewable energy 19
Atmospheric emissions 19
Greenhouse gases 19
Other atmospheric emissions 20
Water consumption 21
Discharge of wastewater 21
Soil management 22
Agricultural recycling of sewage sludge 22
Soil management at Group sites 23
Environmental impact 23
Noise and other types of pollution 23
The effects of climate change 24
Biodiversity 24

EMPLOYEE INFORMATION 27
The Group’s human capital 28
Skills development 28
Equal opportunities and diversity 29
Employee health and safety 30
Preventive measures 30
Industrial accidents and occupational illnesses 31

REGIONAL INVOLVEMENT 32
Impact on the local economy 33
Tax policy 33
Fair practices 33
Procurement and subcontracting 34
Product safety 34
Partnerships 34
Human rights and educational initiatives 35

SUMMARY OF THE MAIN ISSUES 38

VERIFICATION REPORT 40

3
THE GROUP’S PRODUCTS
PRINTING AND WRITING PAPERS




SCHOOL STATIONERY ENVELOPES




PRODUCTS LINKED
FILING ITEMS TO THE ANNUAL CYCLE




FINE ARTS DIGITAL PRODUCTS




4
GROUP PRESENTATION
The Exacompta Clairefontaine Group engages in both the production
and processing of paper, enabling it to control the quality of its
products at each stage of the manufacturing process.
Its guiding principle is “make what you sell and sell what you make”.
Apart from a few exceptions, the Group does not engage in resale or
contract manufacturing.
Its strength lies in its reliance on iconic brands to win the loyalty of
consumers and businesses through the Group’s quality policy.


PRINCIPAL BUSINESS ACTIVITIES
PRINTING AND WRITING PAPERS
Papeteries de Clairefontaine have manufactured printing and
writing papers since 1858. With five machines operated across four
sites, the Group produced over 286,000 tonnes in 2024 (gross tonnage)
and 281,000 tonnes in 2023. The qualitative positioning of these
papers intended for office use, printing, the manufacture of stationery
and filing items is overwhelmingly high-end.


Since 2008, the consumption of paper and stationery
has fallen due to the development of digital methods for
recording and transferring data, as well as environmental
campaigning.



The main raw materials used by Clairefontaine, Mandeure and
Schut consist of virgin or recycled pulp sourced on the world
market. For its part, Everbal employs technology that enables it to
produce on average 100 kg of paper from 106 kg of waste paper.


The Group’s papers compete with those produced by the
large manufacturers who also produce their own pulp.
These manufacturers have a structural advantage in
terms of cost price and are not affected by fluctuations in
commercial pulp prices.



STATIONERY
Production began in the late nineteenth century at the
Papeteries de Clairefontaine site and in 1930 at Exacompta.
This activity accounts for over 62% of the combined revenue
of the business sectors, making it a European leader in this field.

5
Notebooks, notepads, prints, envelopes, registers and diaries - over
the past 30 years production has been extended to include filing items,
fine art and craft accessories and calendars. The Group’s expertise
also facilitates a service offering in printing.
In 2014, the Group began diversifying its offer through the development
of digital photos and associated services through the acquisition
of Photoweb, Invaders Corp (Lalalab) and, most recently, Fizzer.
It became a major player in the wrapping paper segment with the
purchase of Eurowrap in 2019. In 2022, the Group strengthened
its foothold in the crafts sector by acquiring a controlling interest
in The Clay and Paint Factory, a Belgian manufacturer of paints,
dyes, varnishes and modelling clays.


A significant proportion of stationery purchases are
seasonal, resulting in variable costs for workshops and
overstock that is costly in terms of space and cash flow.



MARKETS
The Exacompta Clairefontaine Group’s customers include paper
resellers, printers and processing firms, office suppliers, retailers
and supermarkets. These marketing operations are confined to the
papers and stationery produced by the Group. With the exception
of the digital photos department and Papier Tigre (purchased in
2023), the Group does not sell directly to end customers.


To maintain operations in the workshops whilst meeting
customer requirements, it is necessary to manufacture an
increasing number of product references, Cost-effective
production series are decreasing, leading to an increase in
the cost price.



With regard to businesses and consumers, the Group prioritises the
sale of products bearing its own brands, of which the best known
cover multiple product categories such as:
• Clairefontaine - papers, notebooks, envelopes, fine art
accessories;
• Exacompta - accounting ledgers and snap-out sets, diaries,
filing items.
Similarly, the Quo Vadis range of diaries and the Rhodia range of
notepads are increasingly extensive.




6
INDUSTRIAL ASSETS
Quality is the backbone of the Group’s paper production business
and the factor that guarantees the long-term viability of its products,
whether unprocessed paper sold in reels or reams or paper transformed
into stationery at its own workshops with the same high standards.

Over the last three years, the Group invested an average of €44 million
per year (i.e. 5% of consolidated revenue) in the development and/
or renewal of its production, processing and distribution equipment.

In France, the Group is committed to developing the skills of its
workforce by allocating at least 1% of payroll to continuous training.

Its research and development policy has a specific focus on the
uniformity, brightness and coating of paper used for printing or
specialty packaging. Multiple tests are carried out each year on our
five machines. The use of recycled fibres is a priority. The Group is also
engaged in the development of new ranges of paper.

For stationery items, Claircell Ingénierie develops special processing
equipment, while our designers create innovative products. Finally,
the Photoweb laboratory has cutting-edge customised digital
applications.


COMMERCIAL ASSETS
Consumers are loyal to the Group’s brands, which are a mark of the
high quality of the products on which they appear. Communication
campaigns further promote brand awareness.

The Group operates sales networks dedicated exclusively to the sale
of stationery and papers to supermarkets and stationery stores. The
departments have sales delegates for visiting key accounts.

Exacompta Clairefontaine also has an online store, Exaclair Shop,
dedicated to listed resellers.




7
The Group has six high-performance logistics platforms supporting
delivery to its customers throughout Western Europe:
• Vémars (northern Paris) - Exacompta,
• Ottmarsheim (Alsace) - Clairefontaine Rhodia,
• Etival-Clairefontaine (Vosges) - Papeteries de Clairefontaine,
• Carquefou (Loire-Atlantique) - Quo Vadis,
• Wizernes (Pas-de-Calais) - Papeteries Sill for distribution to
supermarkets and hypermarkets,
• Autrèche (Indre-et-Loire) - Cogir for shipping products to cafés,
hotels and restaurants.


ENVIRONMENTAL ASSETS
Special attention is paid to protecting the environment. In addition to
compliance with regulatory obligations, a number of Group sites have
obtained environmental certification:
• FSC® and PEFC: chain of custody for the use of cellulose fibres
from responsibly managed forests and controlled sources;
• Blue Angel: use of recycled plastic or fibrous materials limiting
the use of dangerous substances;
• European Ecolabel: limiting water and atmospheric emissions
in production, restricting the use of dangerous substances and
greater energy efficiency;
• Imprim’Vert ®, ISO 14001, ISO 50001: implementation of a
structure to improve environmental and energy performance at
Group locations.

Number of certified sites by standard

PEFC 31

FSC® 29

ANGE BLEU 13
ISO 14001 8
IMPRIM’VERT®
3
ECOLABEL
EUROPEEN 3

ISO 50001 3

0 5 10 15 20 25 30 35




A number of costs borne by the Group have a negative
impact on it vis-à-vis its European competitors. For
example, for 2024 Papeteries de Clairefontaine paid
almost €2 million to the extended producer responsibility
(EPR) scheme as a seller of graphic paper on the market.
This mandatory contribution does not exist in any other
European country and foreign producers selling in France
pass the cost on to distributors.


8
A LONG-TERM POLICY
Etablissements Charles Nusse SA holds more than 80% of the capital
of Exacompta Clairefontaine. The family holding company manages
and controls the Group, enabling it to set a consistent long-term policy.

In a capital-intensive industry, the Group posts around three quarters
of its consolidated earnings to reserves. Despite having a satisfactory
cash flow situation, major internal and external investments are
financed by long-term loans.

Exacompta Clairefontaine has a policy of fully owning all its subsidiaries,
whether direct or indirect, in order to avoid the involvement of minority
interests.

The Group is decentralised, with its five departments run by managers
who share the same values and are capable of making quick decisions
in line with the global policy.
With more than 165 years of history, the decisions taken thus far
are testimony to the relevance of its strategic guidelines, which take
particular account of its social and environmental responsibilities.

However, this does not stop the Exacompta Clairefontaine Group from
approaching the issues described below as challenges to be met in
order to safeguard its long-term viability:
• consumer trends and the increasing importance of digital
technology,
• sustainable forest management, in terms of the sustainable use
of resources, the preservation of biodiversity and support for
local communities,
• the significant amount of energy consumed by paper production
operations at a time when energy and climate transition is
becoming increasingly important,
• decarbonising industry as part of the European Union’s “Fit for
55” plan, which aims to reduce greenhouse gas emissions by at
least 55% by 2030 compared to 1990 levels,
• the need to control water consumption and improve wastewater
quality,
• safeguarding employee health and safety,
• as well as the management and development of their skills.

These priorities have been identified by looking at:
• industry studies,
• benchmark studies conducted on identified best practices,
• industry questionnaires prepared by stakeholders (in particular
the WWF),
• the support of an independent expert.



9
ENVIRONMENTAL
INFORMATION




Wild Boar - Sus scrofa

10
INVESTING
TO LIMIT OUR
ENVIRONMENTAL IMPACT
Each year, the Group invests in improving the environmental performance
of its plants and supports initiatives designed to reduce their impact on
the environment. In 2024, the Group’s main environmental investments
amounted to €2,401,000 (€3,947,000 in 2023). Over the last three years,
the proportion of expenditure allocated to energy-saving measures has
increased sharply. It represented 43% of the total investment in 2024
(67% in 2023). This highlights the Group’s commitment to reducing its
greenhouse gas emissions in order to protect the climate.

Breakdown of investments per topic
(€000) 2024 2023 2022
3 000

2 500

2 000

1 500
1 030
1 000
698

500
267
169 196
27 11
0 3 8 0

Energy, air Waste Soil Waste Landscape Industrial Water Noise,
and climate water management and biodiversity risks consumption odours,
vibrations



2024 case studies:
• energy savings and reduction of atmospheric emissions
- Papeteries de Clairefontaine: continuation of work on the new
biomass boiler, creation of a low-temperature heating system,
replacement of insulation panels on the roof of the paper machine
dryer hoods, replacement of windows;
- Cogir, Ernst Stadelmann, Papeteries de Clairefontaine,
Exacompta, Falken, Quo Vadis, Exaclair Limited: replacement
of old-generation lighting with LED lighting;
- Exacompta, Madly: investment in new, more energy-efficient
compressors;
- Papeteries Sill: insulation work;
- Lavigne: installation of charging stations for electric vehicles;
• wastewater treatment and reduction of pollution risks
- Papeteries de Clairefontaine: installation of a retention system
for firefighting water on the waste paper recycling platform,
replacement of an inflatable shut-off device in a pipe to stop leaks
in the event of accidental spillage;
11
• waste management
- Exacompta: purchase of a machine to unwind the ends of reels
of paper and make better use of materials, reduction in packaging
quantities through the acquisition of a strapping machine;
- Manuclass: purchase of a baling press to recycle label backing
paper (glassine);
- Papeteries de Clairefontaine: purchase of additional waste bins;
- Madly: reduction in ink waste through the installation of an ink
station, purchase of a bagging machine to reduce packaging
waste;

• water consumption
- Madly: the acquisition of a bagging machine also reduces water
consumption for cleaning;
- Everbal: installation of a filtration system for water reuse on the
flotation unit;
- Photoweb: development of an inkjet photo printing machine
that reduces water consumption by 40%;
- Quo Vadis: intervention by a diver to maintain fire water reserves
and thus avoid draining the tanks;

• landscape and biodiversity
- Papeteries de Clairefontaine: landscaping of green spaces
following the redesign of the main entrance to the site;
- Lavigne: purchase of trees from forests managed according to
the principles of continuous cover mixed forestry;

• industrial risks
- Papeteries de Clairefontaine: installation of a flexible fire
water supply system for the waste paper recycling platform;
- Lavigne: installation of fire-resistant partitions and doors for the
room housing a new digital printing machine;
- Papeterie de Mandeure, Falken, Papeteries Sill: purchase of
equipment to enhance fire protection at the sites.




Papeteries de Clairefontaine – Installation of a retention system for firefighting water

12
FINANCIAL PROVISIONS AND
GUARANTEES
The French law of 23 October 2023 on green industry did away with the
obligation for facilities covered by the directive on industrial emissions
to set up financial guarantees to ensure plant safety if operations
are discontinued. Papeteries de Clairefontaine and Papeterie de
Mandeure are therefore no longer impacted by this requirement.



RAW MATERIALS
The papers produced by the Group are primarily composed of
cellulose fibres. The virgin pulp we use is produced from timber
originating from responsibly managed forests and controlled sources.
This policy is principally aimed at protecting biodiversity, ensuring
the health and vitality of forests and preserving their socio-economic
function. Recycled fibres are also used to produce certain papers,
which Everbal has made a speciality.


The Group has obtained FSC® and PEFC
certification for its chain of custody in order
10-31-714

Promouvoir la gestion
durable de la forêt


to guarantee the traceability of fibre sources. www.pefc-france.org




PAPER MILLS (excluding Everbal): Purchase 100%
certified virgin fibre pulp.
2025 → Situation at 31/12/2024: 94.5%
goal


In 2024, the consumption of virgin and recycled pulp fibre from
production sites amounted to 203,046 tonnes (206,057 tonnes in
2023). These paper mills filter their process water in order to recycle as
much of these fibres as possible.




Types of fibres used in Recycled Virgin
paper production fibres fibres
29% 71%




13
Paper production also requires the use of starches, mineral fillers
and various additives, which provide the colouring and commercial
properties (e.g. printing, writing) that are expected of our manufactured
products.
Retention agents are also used to improve the binding of additives to
the fibres and thus reduce additive consumption.

A proportion of these papers are then used by the Group’s processing
factories, where they are combined with other materials - card,
greyboard, metal parts (eyelets, binder mechanisms, etc.), glues and
inks - to make thousands of different types of exercise books, note
pads, notebooks, diaries and filing items.

The Group also uses plastics, to which great attention is paid. By way
of example, in 2024 Ernst Stadelmann consumed 1,177 tonnes of
polystyrene (PS) and polypropylene (PP) granules (1,276 tonnes in
2023) for manufacturing office equipment (drawer units, letter trays,
etc.). Recycled granules accounted for 64% of supplies (62% in 2023),
thereby reducing the company’s environmental footprint.

Besides the important role it plays in ensuring customer satisfaction,
quality control also provides a number of environmental benefits.
Checking products at all stages of the production process allows us to
identify quality issues at an early stage, avoid excessive consumption
of raw materials and limit the amount of waste.


Main raw materials (excluding packaging)
used by the production sites
(tonnes)

2024 2023 2022
160 000
144 642
140 000
120 000
100 761
100 000
80 000
58 404
60 000 52 927


40 000
20 000
6 864 5 764
0
Virgin Recycled Paper/ Chemicals Plastics Metal
fibres fibres cardboard




* Not all raw materials have been included due to differences in the unit of measurement (per
unit, per m, per m²). Purchased finished items, generally multi-material, are not taken into
account.


14
“WASTE” MANAGEMENT
The circular economy is a production and consumption model that
involves sharing, reusing, repairing, renovating and recycling existing
products and materials for as long as possible.
When a product reaches the end of its life, if it cannot be repaired, its
components can be reintegrated into the economy through recycling.
This reduces raw material use and related waste.

The paper industry is one of the drivers of the circular economy and its
principles are applied by the Group. A large portion of the paper scrap
collected by the processing plants is sent to the Everbal plant, which
specialises in producing recycled paper.

To optimise recycling, a platform for preparing recovered paper was
set up in 2023 at the Papeteries de Clairefontaine plant.




Papeteries de Clairefontaine – Platform for preparing paper for recycling



By sorting other types of waste (plastic, metal, etc.), the Group
promotes the recycling of these materials by specialised firms.

Sludge emanating from the paper mill water treatment plants is used
for farming purposes whether or not it is subject to composting or
methanisation operations. When collected waste cannot be recycled,
it is sent to an energy recovery facility. As a last resort, waste products
that cannot be reused are sent to specialised treatment centres for
disposal. Our staff are regularly made aware of the importance of
sorting waste in order to optimise our performance.




15
In 2024, a total of 34,859 tonnes of waste was generated by the Group’s
activities, compared to 32,792 tonnes in 2023, the majority of which
was recovered.


Waste - Breakdown per category

Wood SIW**
Metals 3% Other
2% 3% 1%
Recoverable
plastics
2%




Paper/cardboard
Sewage 41%
sludge
35%



OIW*
13%



* OIW: Ordinary industrial waste (non-recyclable)
** SIW: Special industrial waste (e.g. chemical residues)




COMBATING FOOD WASTE
Few Group companies have a collective catering service.
Employees who eat lunch on site are personally responsible for their
food. Some companies occasionally hire catering services offering
daily delivery of meals prepared in individual portions. In both cases,
the risk of food waste is extremely low.




ENERGY CONSUMPTION
The paper production process is relatively energy-intensive:
• fuel used to produce the steam required to dry paper,
• electricity used in fibre refining, the pumping of liquids and the
operation of machinery.


Energy price fluctuations may have a significant impact on
the cost price.




16
Paper mills have therefore long been taking steps to limit energy
consumption (insulation of dryer hoods, using heat recovery for
heating process water and premises, installing variable speed drives
on engines, etc.).

The processing sites are also working on these issues by purchasing
more energy-efficient equipment or by seeking ways to optimise the
lighting and heating of premises.

The energy management systems implemented by Papeteries de
Clairefontaine, Everbal and Falken are ISO 50001 certified.


FUELS
In 2024, paper mill fixed installations used 99% of the fuel consumed
by the Group.

Natural gas is the primary fuel consumed by our facilities. It is the fossil
fuel that emits the least amount of pollutants during combustion.

With its two biomass boilers, Everbal now only uses heavy oil when
the main boilers are undergoing maintenance.

For its part, the Papeteries de Clairefontaine thermal power plant
operates on the basis of co-generation, enabling the simultaneous
generation of steam and electricity. For this purpose, the plant is fitted
with one gas turbine and two steam turbines. A biomass boiler was
installed in 2023 to decarbonise part of the site’s steam and electricity
production. Commissioning is scheduled for May 2025.




Papeteries de Clairefontaine – Biomass boiler




17
Average specific fuel consumption of paper mills
(NCV kWh/tonne of gross paper production)
2 062
2 000 1 774 1 855 1 805

1 500

1 000

500

0
2024 2023 2022 2016
Benchmark year




PAPER MILLS: Reduce the fuel consumption of fixed
installations by 20% compared to 2016.
2025 → Situation at 31/12/2024: -14%
goal



ELECTRICITY
Four Group sites produce electricity (Exaclair Limited, Schut Papier,
Ernst Stadelmann and Papeteries de Clairefontaine).
As such, most of the electricity consumed comes from the national
power grid.
The Group’s paper mills use up around 87% of all the electricity
consumed by the Group.


Average specific electricity consumption of paper mills
(kWh/tonne of gross paper production)
613
600 529 538 534


400

200

0
2024 2023 2022 2016
Benchmark year




PAPER MILLS: Reduce electricity consumption by 20%
compared to 2016.
2025 → Situation at 31/12/2024: -13.8%
goal

18
USE OF RENEWABLE ENERGY
The Group uses renewable energy whenever possible in order to
reduce the environmental impact of its activities, particularly with
regard to climate change.
For this it uses:
• two biomass boilers (Everbal),
• the heat produced by an external biomass boiler (Ernst
Stadelmann),
• geothermics (Photoweb),
• one hydroelectric turbine (Papeteries de Clairefontaine),
• solar panels (Exaclair Limited, Schut, Ernst Stadelmann).




ATMOSPHERIC EMISSIONS
GREENHOUSE GASES
CARBON DIOXIDE (CO2)
Only the Group’s three paper mills in France are subject to the
European Union Emissions Trading System (EU ETS).


Total CO2 emissions declared Average emissions
as part of the EU ETS framework (kg CO2/tonne of gross paper
(tonnes of CO2) production)

82 019 350
90 000 78 330 291
80 000 74 230 300 260 268
70 000 250
60 000
200
50 000
40 000 150
30 000 100
20 000
50
10 000
0 0
2024 2023* 2022* 2024 2023* 2022*

* Increase in emissions due to longer running time of Papeteries de Clairefontaine gas turbine.




The free allowances of CO2 received by the Group were
reduced from 74,155 tonnes in 2013 to 57,767 tonnes in
2024. The missing allowances corresponding to actual
emissions are purchased on the European exchange
market. Trading at €4/tonne in December 2016, CO2 reached
an all-time high in February 2023, passing the €100/tonne
mark.

19
One of the Exacompta Clairefontaine Group’s objectives is to reduce
its CO2 emissions from fossil fuels by investing in renewable energy
and taking action to limit energy consumption.
It should also be noted that Papeteries de Clairefontaine sends a
portion of the smoke generated by its boilers to a precipitated calcium
carbonate (PCC) production facility. The CO2 required to manufacture
this mineral filler is captured directly in the exhaust fumes. In 2024,
11,465 tonnes of CO2 was consumed during the process and not
emitted into the atmosphere (9,891 tonnes in 2023).


MAIN CO2 EMITTERS
Direct CO2 emissions from fixed sources (in particular steam-
generating combustion systems, heating of buildings and electricity
production), mobile sources (handling equipment, company vehicles,
trucks controlled by Group companies), as well as indirect emissions
relating to mains electricity consumption, were taken into account.
Due to lack of data, emissions generated by the transportation of raw
materials and finished products and by employee travel could not be
assessed.
Across this scope, fixed combustion installations are the main CO2
emitters.



OTHER GREENHOUSE GASES
Owing to refrigerant leaks in their air-conditioning systems, four sites
were responsible for releasing 31 kg of fluorinated gases into the
atmosphere in 2024 (191 kg in 2023). The other Group companies did
not identify any such leaks or were unable to obtain precise data on
the matter.


OTHER ATMOSPHERIC EMISSIONS
Only the Group’s three paper mills in France are required to regularly
measure emissions from their boilers.

Other atmospheric emissions from paper mills
(tonnes)
2024 2023 2022
50

40 37,4


30

20
11,6
10
1,1 2,0
0
NOx CO SOx Dust/particles
nitrogen oxides Carbon Sulphur
Monoxide oxides


20
WATER CONSUMPTION
Water is indispensable to the paper industry and it is essential that
the supply of this resource is sustainable. Accordingly, the Exacompta
Clairefontaine Group makes every effort to preserve the water supply
and reduce its consumption.
The paper mills are the Group’s biggest consumers of water. They
collectively account for over 92% of surface water and groundwater
use, including drinking water. However, the vast majority of extracted
water is returned to the natural environment after treatment.
The Group’s plants have never been affected by water restrictions,
except for paper mills during severe droughts, without any impact on
their production levels.


Average water consumption at the Group’s paper mills
(m3/tonne of gross paper production)

15,4
16
11,8 11,4 11,5
12

8

4

0
2024 2023 2022 2016
Benchmark year




PAPER MILLS: Reduce water consumption by 20%
compared to 2016.
2025 → Situation at 31/12/2024: -23.3%
goal



DISCHARGE OF WASTEWATER
The Group’s paper mills are equipped with wastewater treatment
plants enabling them to limit the amount of pollutants discharged
into the natural environment.
They are the only sites that measure wastewater quality on a very
regular basis, either daily or continuously for certain parameters.
As the Group’s other entities consume only a very small quantity of
water, they are connected to municipal wastewater treatment plants
or treat their effluent as special industrial waste.


21
Paper mill emissions
Volumes of discharged Discharge of COD*
wastewater (kg COD/tonne of gross paper
(m3/tonne of gross paper production)
production)

12,0 10,5 1,2
9,6 9,6
10,0 1,0
0,78 0,76
8,0 0,8 0,65
6,0 0,6

4,0 0,4

2,0 0,2
0,0 0,0
2024 2023 2022 2024 2023 2022

* COD: Chemical Oxygen Demand




Papeteries de Clairefontaine – Sewage sludge handling



SOIL MANAGEMENT
AGRICULTURAL RECYCLING
OF SEWAGE SLUDGE
The sludge generated by the treatment of effluent produced during
the paper production process is generally directly reused in farming or
previously converted into standardised compost (French standard NF
U44-095). Papeterie de Mandeure and Papeteries de Clairefontaine
also use methanisation.
Paper mill sludge contains elements that have agronomic value
which means that it can be used as a partial substitute for traditional
chemical fertilisers.

22
The sludge is mostly recycled in agriculture as:
• organic soil amendment: rich in cellulose fibres, this type of
sludge has a beneficial effect on soil structure;
• calcium soil amendment: one application provides on average
a little over 2.5 tonnes of lime per hectare.

The concentration of metal trace elements (MTE) and trace organic
compounds (TOC) in the sludge are well below the limits set by the
regulation.


SOIL MANAGEMENT AT GROUP SITES
The average rate of soil sealing at the Group’s industrial sites is around
45%. These sealed surfaces include the buildings, thoroughfares and
car parks. Open spaces consist of green areas, lagoon-type areas and
land reserves.

Regulations require that all potentially hazardous products or waste
at these sites be stored on retention shelving so that any spills can be
contained, thereby reducing the risk of soil pollution. No soil pollution
surveys have had to be carried out on operational Group facilities
since 2003.




ENVIRONMENTAL IMPACT
No significant environmental incidents occurred in 2024.




NOISE AND OTHER
TYPES OF POLLUTION
Plant operations are conducted within closed buildings, thus limiting
noise disturbance for local residents. In addition, some sites are fitted
with noise reduction systems (silencers and soundproof booths for
high-noise machine sections).

Given that the paper mills have their own water treatment plants,
unpleasant smells may very occasionally arise in the nearby areas.

Night lighting on Group sites is limited to facilities involving work in
shifts (morning, afternoon, night). Unused areas are not lit. In these
factories, exterior lighting is maintained to reduce the risk of accidents,
in thoroughfares and car parks in particular.


23
THE EFFECTS OF
CLIMATE CHANGE
For the time being, the consequences of climate change have not had
a material impact on the activities of the Exacompta Clairefontaine
Group. However, the paper industry may be impacted by this
phenomenon on multiple levels.

Prolonged periods of drought have tended to be more
frequent and more severe over recent years. Water usage
restrictions may limit paper mill production capacity.



During low-water periods, i.e. when a water stream is at its
lowest level, the self-purification capacity of the natural
environment is weaker. During this period, any malfunction
at wastewater treatment works may result in a discharge
having a harmful impact on aquatic fauna and flora.



A number of the raw materials used by paper mills are
sourced from the agricultural sector, such as starches
from wheat, corn and potatoes. Climate disturbances may
impact the availability of these resources, a significant
proportion of which is used in human and animal foods.




BIODIVERSITY
The Exacompta Clairefontaine Group sponsors various initiatives in
favour of biodiversity.

CONSERVATOIRE D’ESPACES
NATURELS DE LORRAINE
Papeteries de Clairefontaine and the
Conservatoire d’Espaces Naturels de
Lorraine wildlife trust entered into a
management agreement with a farmer
in 2005. This agreement relates to the
preservation, on the land belonging to
the company, of hay meadows inhabited
by a butterfly (Dusky Large Blue) included
on the French list of protected insect
species. Due to the presence of habitats
and species of European Community
Mating of Dusky
interest, this nature reserve was made Large Blue
into a Natura2000 site. (Phengaris nausithous)

24
OBSERVATOIRE DES CARNIVORES SAUVAGES
Since 2022, the Exacompta Clairefontaine Group
has been providing financial support to the
Observatoire des Carnivores Sauvages (OCS),
a charity engaged in the study and protection of
wild carnivores in eastern France. Three species in
particular are under surveillance: lynxes, wolves
and European wildcats.




© Alain LAURENT

OCS – Eurasian lynx (Lynx lynx)



GROUPE D’ETUDE RAPACES VOSGES
Since 2022, funding has also been provided to
the Groupe d’Etude Rapaces Vosges (GERV),
which studies, monitors and protects two
iconic species: the Peregrine Falcon and the
Great Horned Owl, both of which are relatively
vulnerable in the Vosges department.




GERV - Release of a Eurasian Eagle Owl (Bubo bubo)
following care provided by the GORNA association

25
VOSGES FOREST
The Exacompta Clairefontaine Group owns
and maintains around 290 hectares of
woodland in the Vosges.

These forests are certified and managed in accordance with PEFC
standards with help from the Forêt d’ici de l’Est forestry cooperative.

Consideration is being given to ways of developing biodiversity in
these areas dedicated to forestry production. In 2024, the Group
commissioned studies to establish Potential Biodiversity Indices (PBI)
for two forest areas.
The results are expected in the first half of 2025.

The PBI is an assessment tool developed to assess a forest stand’s
capacity to support rich and varied biodiversity. It does not directly
measure the biodiversity present, but rather the conditions favourable
to its presence.

The PBI is based on the observation of 25 easily identifiable field
indicators, including:
• tree species diversity,
• the presence of dead wood,
• cavity trees or large-diameter trees,
• vegetation stratification,
• the presence of water, forest edges or senescence islands.

Each of these elements is an indicator of a structure or microhabitat
favourable to different species (mammals, birds, insects, fungi, etc.).
The higher the number and quality of these indicators, the stronger
the index, reflecting a high potential for biodiversity.




Cavity tree - Black woodpecker (Dryocopus martius) building its nest in a beech tree

26
EMPLOYEE
INFORMATION




Red squirrel - Sciurus vulgaris

27
THE GROUP’S HUMAN CAPITAL
At the end of 2024, Exacompta Clairefontaine employed some 3,400
people, 73% of whom were based in France.
Based on the available data, 41% of employees are
female and 59% are male. The vast majority of employees
(93%) held permanent employment contracts.
With regard to staff turnover, most departures were related to
contract expiration (58%), reflecting the seasonal nature of part of
the Group’s activities. The use of fixed-term or temporary workers
at certain times allows the Group to cope with fluctuations in its
manufacturing business, in preparation for the start of the school
year, the manufacture of products linked to the annual cycle (diaries,
calendars, etc.) or festival or holiday periods (photo books).


Breakdown of workforce by age group
< 25 years old
6%
55% of the employees
25-44 years old included in the study were
39% over 44 years old. However,
numerous business activities require
knowledge and expertise that
> 44 years old must be handed down before older
55% generations retire.




SKILLS DEVELOPMENT
In response to an ever-changing market and new technologies, the
Group’s companies must be flexible in order to adapt quickly to
demand. This means supporting and anticipating the transformation
of business activities and the way in which work is structured.

As such, the human resources teams and business line managers
work closely together and are committed to ensuring that employees’
skills match the companies’ requirements on a continuous basis.
Once these requirements have been identified, training programmes
are prepared and carried out.

Within this fluid environment, the acknowledgement and transfer of
expertise is essential and proper planning for retirement is paramount.
In order to achieve this, the Group’s companies encourage employees
to formalise recognition of their specific or transferable skills through
professional qualification certificates.

Some companies also operate a mentor system in order to transfer
the know-how of experienced staff members before they retire and to
promote staff versatility.

28
In 2024, the companies included in the study delivered a total of
23,220 hours of training (26,918 hours in 2023), either in-house or
through certified training organisations, at a total cost of €1,716,000
(€1,106,000 in 2023).

Breakdown of total hours of training received,
by professional category

2024 2023 2022
70 %

60 %

50 % 47 %



40 %

30 %
20 %
20 % 16 %


10 % 9% 9%



0%
Managers and TSE* Employees Manual Travelling sales
engineers workers representatives
* Technical and supervisory employees




PAPER MILLS: Achieve an employment rate of
managers and technical and supervisory employees
of at least 35%
2025 → Situation at 31/12/2024: 30.1%
goal




EQUAL OPPORTUNITIES
AND DIVERSITY
Equal opportunities, non-discrimination and diversity are fundamental
values which the Exacompta Clairefontaine Group is committed to
upholding.
Gender and ethnicity play no part in recruitment and career
development, as the Group gives precedence to skills and professional
merit.
Occupational training is a major lever for eliminating inequalities in
the career paths of men and women.
The Group also employs people with disabilities (at least 135 at the
end of 2024), adapting workstations as necessary.


29
EMPLOYEE HEALTH
AND SAFETY
PREVENTIVE MEASURES
Another of the Group’s concerns is ensuring optimum working
conditions in order to guarantee employee health and safety.
With this in mind, all production and logistics sites have a safety officer.

Action plans based on occupational risk analysis are implemented in
order to eliminate risks or mitigate those that cannot be completely
avoided.

In 2024, €1,400,000 was invested to improve employee safety
(€2,810,000 in 2023).
An overview of the measures taken is presented below:

• reducing the risk of musculoskeletal disorders (MSD)
- Manuclass: replacement of a manual unloading mat with an
automated conveyor belt at a wrapping machine, addition
of an automatic labelling machine to a folder manufacturing
machine;
- Madly: Installation of an automatic taping machine to reduce
manual handling when closing boxes;
- Papeterie de Mandeure: study and work on the winder to
reduce vibrations transmitted to the whole body;
- Exaclair UK, Papeteries de Clairefontaine: purchase of
ergonomic office equipment;
- Papeteries Sill, Papeteries de Clairefontaine: floor
refurbishment to limit shocks and vibrations when operating
handling equipment;

• improving the thermal environment of buildings
- Exaclair UK: installation of a high-speed sectional door to
reduce door opening times during the cold season;

• work equipment safety and improvements
- Manuclass: addition of protective covers and light curtains to
prevent access to hazardous areas of machines, replacement of
a folding machine;
- Everbal: hiring of a fixed-term employee to develop safety
training procedures;
- Quo Vadis: installation of a steam extraction system at a pad
printing machine;
- Papeteries de Clairefontaine: purchase of 6 temporary lifelines
to secure work at height;


30
• support for handling tasks and reduction in load carrying
- Quo Vadis: purchase of an exoskeleton to assist with lifting loads;

- Papeteries de Clairefontaine, Madly, Papeteries Sill,Quo
Vadis, Papeterie de Mandeure: purchase of handling equipment
and machinery to provide support for handling tasks;

- Papeterie de Mandeure:
modification of the winder and
purchase of a motorised pusher
to reduce manual handling of
reels;

- Papeteries de Clairefontaine:
automation of stacking
and palletising on a ream
production line.




INDUSTRIAL ACCIDENTS
AND OCCUPATIONAL ILLNESSES
In the companies reviewed, 6,179 days were lost due to industrial
accidents (including commuting accidents) in 2024, compared to
4,584 in 2023.
2024 2023 2022
Industrial accident
Number of lost time industrial accidents per 23.8 30.2 24.6
1,000,000 hours worked
Severity rate
Number of working days lost 1.2 0.9 0.8
per 1,000 hours worked


At the Group’s French sites, 16 occupational illnesses were recognised
in 2024 (11 in 2023).

The Exacompta Clairefontaine Group continuously enhances its
health and safety policy in order to work towards achieving the lowest
possible accident rate.



GROUP: Achieve a frequency rate lower than 15.
→ Situation at 31/12/2024: 23.8
2025
goal



31
REGIONAL
INVOLVEMENT




Common buzzard - Buteo buteo

32
IMPACT ON THE LOCAL
ECONOMY
All Exacompta Clairefontaine subsidiaries play a vital role in their local
economies, both as employers and in terms of their commitment and
contribution to local communities. 73% of the Group’s employees
work in France. Recruitment is typically drawn from people living in the
vicinity of factories and other operational centres, but a wider scope is
also applied for specific skills.
For example, Papeteries de Clairefontaine has been present in
the village of Etival-Clairefontaine (Vosges) since 1858 and employs
around 550 people. Over time, close bonds have been formed with the
surrounding cities and villages.
Over the past thirty years, the Group’s growth has in part been due to
acquisitions of other companies. They are most often kept in the same
location with a focus on specialising in their core profession. As such,
in 2024 in France, 88% of employees worked at sites located outside
the greater Paris region.
Since its inception, the Group’s majority shareholders have been
members of the same family. The Group also comprises a number of
sixth or even seventh-generation employees. The tradition of going to
work in the same factory as one’s parents is still alive today.




TAX POLICY
The Group has little exposure to tax evasion risk due to its structure.
None of the Group entities are located in a ‘tax haven’.
All French companies except Flock One, purchased in 2024, are
consolidated for tax purposes with intercompany transactions
eliminated for such purposes.
Risks related to proceedings, tax audits and litigation are presented in
the Group management report.
Tax returns, the payment of taxes and duties and accounting records
are prepared and submitted in each country in which the subsidiaries
are established.
Transactions involving foreign subsidiaries are carried out in
accordance with the OECD principles on transfer pricing.




FAIR PRACTICES
The prevention of active and passive corruption and money laundering
is a key concern of senior management. A code of conduct was
circulated to all Group employees in 2017. This code specifically meets
the requirements of the 8 November 2016 French Sapin II law for the
prevention and detection of corruption and influence peddling and is
available on the Group’s website.

33
PROCUREMENT AND
SUBCONTRACTING
Exacompta Clairefontaine is a French group with a European mindset.
Social and environmental issues are taken into account through the
certifications required by our customers or as part of the Group’s QSE
policy.
Fibrous raw material suppliers (pulp and paper) generally have FSC®,
PEFC or Blue Angel certification. Printing suppliers are generally
Imprim’Vert ® certified.
For a supplier or product to be selected, it must be deemed
environmentally friendly. Supporting documentation may be requested
and checked, particularly in the case of products carrying European
Ecolabel certification.
The Group seldom subcontracts and, when it does, subcontractors are
mainly locally based. The operations concerned may also be performed
in-house.



PRODUCT SAFETY
The health and safety of our consumers is paramount. Some product
lines must comply with standards and regulations regarding toy safety
or hygienic requirements for materials and packaging in contact with
food. All products in the Avenue Mandarine range bear CE marking
for toys. Safety data sheets are also available for products that require
them.
The European General Product Safety Regulation (GPSR) came into
force on 13 December 2024. A product placed on the market must be
“safe”. Under normal or reasonably foreseeable conditions of use, it
must present no risk or only minimal risks compatible with the product’s
use and considered acceptable while ensuring a high level of consumer
protection. Prior to being placed on the market, each product must
undergo a risk and safety assessment.




PARTNERSHIPS
The Group is strongly committed to encouraging young people to
practice sport. Each discipline conveys values of respect, dynamism,
performance, ambition and equality, which contribute to children’s
development.
Exacompta Clairefontaine sponsors a number of French youth teams
practising various sports, including football, basketball, rugby, handball,
hockey and cycling.
In addition to supporting amateur and leisure sports, Clairefontaine
Rhodia is also the main sponsor of boys’ and girls’ youth teams (aged
7-19) for a number of highly respected French football clubs.

34
The young talents of Olympique Lyonnais and Le Havre football clubs


The Group supports Olympique Lyonnais, Le Havre AC, FC Nantes,
SM Caen, Sochaux-Montbéliard Football Club, AJ Auxerre and PSG
Handball.
The Group also supports cultural activities, including festivals and a
range of other projects through sponsorship. Group companies are
committed to the local communities of their employees.


HUMAN RIGHTS AND
EDUCATIONAL INITIATIVES
The Exacompta Clairefontaine Group is particularly attentive to
compliance with human rights and fundamental principles and rights
at work.

Education is the central pillar on which Group initiatives in support
of these principles are based. Exacompta Clairefontaine is committed
to helping children to successfully complete their education and has
set up a number of projects to promote education and raise public
awareness of children’s rights.


SUPPORT FOR FRANCE PARRAINAGES
A partnership to support isolated and
vulnerable children in France.
Since 2021, Clairefontaine Rhodia has worked
alongside France Parrainages to promote the
development of local sponsorship in France.
As a corporate sponsor, the company provides
ongoing financial support to the association (€120,000 as of end-2024),
thereby helping to strengthen its work with vulnerable children. In
addition to this support, the Avenue Mandarine brand actively promotes
the association’s values by including its logo and an information flyer in
all its game boxes, thereby raising awareness among its customers of
the importance of sponsorship and child protection.

35
In 2024, this partnership was expanded with a new joint project:
the creation of an alphabet book on ‘Living Better Together’, which will
be made available to schools throughout France.
“The best way I’ve found to keep my inner child alive is by connecting and
sharing with children. France Parrainages offers such valuable support,
especially for those in need, that we’re happy to be able to help them.”
Rhyzlène Nusse, Creative and Communications Director.



SUPPORT FOR HANDICAP INTERNATIONAL
In 2021, Clairefontaine Rhodia decided to
start providing ongoing support to Handicap
International. €350,000 was donated to the
NGO between 2021 and 2024.
Handicap International works in Tunisia, among other countries,
to ensure a better future for children with autism. Autism spectrum
disorders affect children from an early age in the areas of social
interaction, communication and behaviour. Attending a mainstream
school, finding a job and interacting with others in everyday life are all
opportunities that are reduced if an early diagnosis (before the age of
3) is not made. Through early identification of autism and appropriate
care, Handicap International’s teams help improve children’s social
functioning to give them the best chance of success and even a fully
independent life.
In 2024, as a result of Handicap International’s work in Tunisia:
• 2,300 Tunisian children received an early diagnosis from
professionals whose skills were strengthened;
• 410 children with autism spectrum disorders received appropriate
support from these same professionals.




© Virna Marchesin / HI



Handicap International has created the first public centre for the care
of autistic children in Tunis, and two similar projects are underway in
Medenine and Jendouba.

36
The association trains professionals (general practitioners,
paediatricians, educational psychologists, etc.), thereby promoting
better identification and care for children with autism. It also raises
awareness among parents about the signs of autism so that they can
take action as soon as they appear.
The organisation also promotes the sharing of best practices through a
national forum in Tunis that brings together all professionals involved
in diagnosis.


COMBATING BULLYING AT SCHOOL
Since 2019, Clairefontaine has been committed to raising awareness
among young people about bullying at school. This scourge sadly
affects a large number of students in France and worldwide. This form
of violence, which can be physical, verbal or psychological, can have
serious consequences for victims’ mental and/or physical health.

This commitment was stepped up in 2022 with the launch of a major
speaking-out campaign on social media: #HashtagRouge.

In 2023, support was provided to the Agir pour Devenir association,
with Sylvain Dhugues acting as ambassador for our campaign against
bullying. As a former victim of bullying due to his obesity, Sylvain has
given talks in schools across France to raise awareness among young
people about the effects of bullying, obesity and the importance of
physical activity. He also shares advice on Instagram for young victims
and their parents.

In 2024, Clairefontaine collaborated with the French Ministry of
Education to produce a poster on bullying in schools for primary
school children. Developed and designed by experts on the subject
within the ministry, the poster’s graphic design and editorial content
address the issue of bullying in schools in a way that is not anxiety-
provoking. Available to teachers upon request via the Clairefontaine
Rhodia website, the poster can be used in the classroom to discuss
bullying at school and raise awareness of the issue among children
from an early age.




37
SUMMARY OF THE
MAIN ISSUES




Red fox - Vulpes vulpes

38
Outcome
2025
Issue Policy Indicator at 2024
goals
year-end



Purchase of FSC- and
Sustainable forest Purchase rate of
PEFC-certified virgin 100% 94.5%
management certified fibres
pulp




Fuel consumption 20%
(NCV kWh/tonne reduction -14%
of gross paper production) versus 2016
Research into
sources of energy
Control of energy
savings and
consumption
implementation of
action plans Electricity 20%
consumption reduction -13.8%
(kWh/tonne
of gross paper production)
versus 2016



Research into
sources of water Water 20%
Preservation of consumption
savings and reduction -23.3%
water resources (m3/tonne
implementation of of gross paper production)
versus 2016
action plans



Application of Industrial
the occupational accident
Preservation of
risk assessment frequency rate
employee health < 15 23.8
document, Number of lost time
and safety
implementation of industrial accidents per
action plans 1,000,000 hours worked




Identification of
Employment
existing skills to
rate of
Employee skills be maintained
managers and
development and and new skills to ≥ 35% 30.1%
technical and
management be developed,
supervisory
implementation of
employees
action plans



Coverage rate
- environmental indicators: 100%
- employment indicators: 99.7%




39
VERIFICATION REPORT
ON THE STATEMENT OF
NON-FINANCIAL PERFORMANCE
The statement of non-financial performance under review relates to the
fiscal year ended 31 December 2024.

To the Shareholders’ Meeting,
In our capacity as an independent third-party body (“third party”),
accredited by Cofrac Inspection for validation/verification activities under
number 3-1877 (the scope of which may be consulted at www.cofrac.
fr), we have carried out work with the aim of formulating a reasoned
opinion expressing a conclusion of moderate assurance on the historical
information (observed or extrapolated) in the statement of non-financial
performance prepared in accordance with the entity’s procedures
(hereinafter the “Procedures”) for the fiscal year ended 31 December
2024 (hereinafter the “Information” and the “Statement” respectively),
as presented in the Group management report in accordance with the
statutory and regulatory provisions of Articles L. 225-102-1, R. 225-105 and
R. 225-105-1 of the French Commercial Code.

CONCLUSION
On the basis of our work, as described in the section entitled “Nature
and scope of the assignment”, and the information we obtained, we
have identified no material misstatements liable to call into question the
compliance of the consolidated statement of non-financial performance
with the applicable regulatory provisions and the fact that the Information,
taken as a whole, is presented fairly in accordance with the Procedures.

OBSERVATIONS
Without calling into question the conclusion expressed above and in
accordance with the provisions of Article A. 225-3 of the French Commercial
Code, we hereby issue the following comments:
• We encourage you to continue strengthening the internal control
system relating to the collection and validation of information reported
by the Group’s entities.
• It would be worthwhile to expand the scope covered by certain
indicators in order to improve their representativeness.
• Finally, we note the absence of a key performance indicator on the
social pillar.

PREPARATION OF THE STATEMENT
OF NON-FINANCIAL PERFORMANCE
The lack of a generally accepted and commonly used framework or
established practices on which the Information can be evaluated and
measured allows for the use of different, but acceptable, measurement
techniques that may affect comparability across entities and over time.


40
Therefore, the Information should be read and understood with reference
to the Procedures, the material provisions of which are presented in the
Statement.


LIMITATIONS INHERENT IN
THE PREPARATION OF INFORMATION
The Information may be subject to a degree of uncertainty inherent to
the current state of scientific or economic knowledge and the quality
of the external data used. Some information may be affected by the
methodologies, assumptions and/or estimates applied during its
preparation and presented in the Statement.


RESPONSIBILITY OF THE ENTITY
Management is responsible for:
• selecting or establishing appropriate criteria for the preparation of the
Information;
• preparing a Statement in accordance with statutory and regulatory
provisions, including the presentation of the business model, a
description of the principal non-financial risks and a presentation of
the policies applied with regard to those risks and the outcomes of
these policies, including key performance indicators;
• preparing the Statement using the entity’s Procedures as set out above;
and
• implementing the internal control procedures it deems necessary
to ensure that the Information is free from material misstatement,
whether due to fraud or error.

The Statement was prepared by the Board of Directors.


RESPONSIBILITY OF THE INDEPENDENT
THIRD-PARTY BODY
It is our responsibility, on the basis of our work, to formulate a reasoned
opinion expressing a conclusion of moderate assurance on:
• the compliance of the Statement with the provisions of Article R. 225-
105 of the French Commercial Code;
• the fair presentation of the historical information (observed or
extrapolated) provided pursuant to Article R. 225-105 I (3) and II of the
French Commercial Code, i.e. the outcomes of policies, including key
performance indicators, and measures relating to the main risks.
As it is our responsibility to form an independent conclusion on the
Information as prepared by management, we are not permitted to be
involved in the preparation of this Information, as this could compromise
our independence.
We are not responsible for issuing an opinion on:
• the entity’s compliance with other applicable statutory and
regulatory provisions;
• compliance of products and services with applicable regulations.


41
APPLICABLE REGULATIONS
AND PROFESSIONAL STANDARDS
We conducted the work described below in accordance with the
provisions of Articles A. 225-1 et seq. of the French Commercial Code, the
professional guidance issued by the French Institute of Statutory Auditors
(Compagnie Nationale des Commissaires aux Comptes, CNCC) relating to
this work, particularly the CNCC’s technical opinion (work of the statutory
auditors - work of the independent third-party body (OTI) - statement of
non-financial performance), in lieu of an audit programme.

INDEPENDENCE AND QUALITY CONTROL
Our independence is defined by Article L. 822-11 of the French Commercial
Code and the French Code of Ethics for Statutory Auditors. Furthermore,
we have implemented a quality control system comprising documented
policies and procedures designed to ensure compliance with applicable
laws and regulations, ethical rules and the professional guidance issued
by the French Institute of Statutory Auditors relating to this assignment.

MEANS AND RESOURCES
Our work was carried out by three people between February and April
2025 over a total procedure time of around three weeks.

We consulted our experts in sustainable development and corporate
social responsibility to assist us in the conduct of our work. We conducted
around ten interviews with the persons responsible for preparing the
Statement, including representatives of senior management and the
following departments: administration, finance, risk management,
compliance, human resources, health and safety, environment and
procurement.

NATURE AND SCOPE OF THE ASSIGNMENT
We planned and carried out our work taking into account the risks of
material misstatements in the Information.

We believe that the procedures followed in exercise of our professional
judgement allow us to express a moderate level of assurance:
• we reviewed the activities of the entity and all entities within the
scope of consolidation, as well as the presentation of the principal
risks;
• we assessed the appropriateness of the Procedures in terms
of their relevance, completeness, reliability, neutrality and
understandability, taking industry best practices into consideration
as applicable;


42
• we verified that the Statement covers each category of information
required under Article L. 225-102-1 III of the French Commercial
Code relating to social and environmental issues and includes,
where applicable, an explanation of the reasons for the absence
of information required under paragraph 2 of Article L. 225-102-1
III of said Code;
• we verified that the Statement includes the information required
by Article R. 225-105 II of said Code, where such information is
relevant to the principal risks;
• we verified that the Statement presents the business model and
a description of the principal risks related to the activity of all the
entities included in the scope of consolidation, including, where
relevant and proportionate, the risks generated by its business
relations, products or services, as well as the policies, actions and
outcomes including key performance indicators related to the
principal risks;
• where applicable, we verified that the Statement includes a clear
and reasoned explanation of the reasons for the absence of a
policy on one or more of these risks in accordance with Section I of
Article R. 225-105 of the French Commercial Code;
• we consulted documentary sources and conducted interviews in
order to:
- assess the selection and validation process for the principal
risks as well as the consistency of the outcomes, including the
key performance indicators applied, with regard to the principal
risks and policies presented, and
- corroborate the qualitative information (actions and outcomes)
that we considered to be the most important, as presented in
Appendix 1.
• we verified that the Statement covers the consolidated scope, i.e.
all entities within the scope of consolidation in accordance with
Article L. 233-16 of the French Commercial Code;
• we obtained an understanding of internal control and risk
management procedures the entity has put in place and we
assessed the data collection process aimed at ensuring the
completeness and fair presentation of the Information;
• for the key performance indicators and other quantitative
results that we considered most important, as presented in
Appendix 1, we implemented:
- analytical procedures involving verification of the proper
consolidation of the data collected as well as the consistency
of changes in said data;
- detailed checks by means of sample tests or other methods
of selection, in which we verified the correct application of the
definitions and procedures and compared the data provided
with the supporting documentation. This verification work
was carried out on a selection of contributing entities and
covers between 16.3% and 27.8% of the consolidated data
selected for these tests;
• we assessed the consistency the Statement as a whole in light of our
knowledge of all the entities included in the scope of consolidation.


43
The procedures performed in the context of a moderate assurance
assignment are less extensive than those required for a reasonable
assurance assignment carried out in accordance with the professional
guidance issued by the French Institute of Statutory Auditors; a higher
level of assurance would have required more extensive audit work.


Niort, 25 April 2025


THE INDEPENDENT THIRD-PARTY BODY
GROUPE Y Audit




Christophe Poissonnet
Partner, Sustainable Development Department




44
Appendix 1: Contributing entities


Test coverage Average
Indicators Section of contributing
Issue rate (based on coverage
selected entities
headcount) rate


Employment rate
Employee skills of
Papeteries de
development managers and
Clairefontaine, 27.75%
and technical and
Publiday, Photoweb
management supervisory
employees 27.75%


Preservation of Papeteries de
Industrial accident
employee health Clairefontaine, 27.75%
frequency rate
and safety Publiday, Photoweb


Volume (in m3) of Papeteries de
Preservation of water Clairefontaine,
20.04%
water resources consumed per Papeterie de
tonne of paper Mandeure

Papeteries de
Fuel Clairefontaine,
23.35%
consumption Papeterie de
Control of Mandeure, Everbal
energy 20.75%
consumption Papeteries de
Electricity Clairefontaine,
23.35%
consumption Papeterie de
Mandeure, Everbal

Sustainable Share of recycled
Papeteries de
forest fibres in total 16.27%
Clairefontaine
management paper production

Papeteries de
Amounts donated
Donations & Clairefontaine and
and partnerships 20.23% 20.23%
partnerships Clairefontaine
announced
Rhodia




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