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SAPPI LIMITED

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The representation of Black people, particularly Black women, in management and all levels of<br />

employment within the company is a focus within the organization, driven by employment equity targets<br />

set in each occupational category. Skills development initiatives, particularly programs aimed at<br />

improving management and leadership skills, are geared to meet these targets. Where practical, we<br />

purchase goods and services from Black-owned businesses and seek opportunities to develop future<br />

Black vendors. We are committed to the support of our Project Grow, which is an initiative with local<br />

communities using their land for plantations while training them in the core principles of forestry<br />

management. This is achieved through financial and technical input, as well as by providing a secure<br />

market during the start-up phase of these small tree farming enterprises. This initiative has been<br />

extended to encourage aspirant tree farmers who wish to undertake forestry activities on a larger scale<br />

consistent with the government’s strategy of promoting forestry as a means of sustainable livelihood in<br />

rural areas. We have a number of enterprise development initiatives and have established programs to<br />

train new entrepreneurs. These initiatives involve the transfer of business skills, technical assistance,<br />

financial support and preferential payment terms to assist new enterprises to enter the market. We have<br />

a history of investment in the communities in which we operate. Initiatives to promote education, health<br />

and welfare, arts and culture, and rural and community development, amongst others, are regularly<br />

undertaken.<br />

The South African constitution guarantees ownership rights of assets, and it is the stated intent of<br />

the constitution that transfer of ownership will occur at market prices. It should be noted that BEE equity<br />

participation need not necessarily occur at the corporate level, and can be effected at divisional,<br />

business unit or lower levels. Because the BEE Act sets forth a framework for plans rather than specific<br />

requirements or goals, it is not possible to predict whether or how our business or assets may be<br />

impacted.<br />

For further information, see ‘‘Item 4—Information on the Company—History and Development of<br />

the Company’’ and ‘‘Item 3—Key Information—Risk Factors’’.<br />

Environmental Matters<br />

We operate in an industry subject to extensive environmental regulations. Typically, we do not<br />

separately account for environmental operating expenses but do not anticipate any material<br />

expenditures related to such matters. We do separately account for environmental capital expenditures.<br />

See note 32 to our Group Annual Financial Statements included elsewhere in this Annual Report for a<br />

discussion of these matters.<br />

For further information, see ‘‘Item 4—Information on the Company—Environmental and Safety<br />

Matters’’.<br />

Operating Results<br />

Financial Condition and Results of Operations<br />

The operations of the Group are organized into the following three reportable segments: (for a more<br />

detailed description of the operations of the Group, see ‘‘Item 4—Information on the Company—<br />

Business Overview’’):<br />

Sappi Fine Paper North America<br />

Sappi Fine Paper Europe<br />

Sappi Southern Africa<br />

The Sappi Fine Paper business comprises the two reportable segments, Sappi Fine Paper North<br />

America and Sappi Fine Paper Europe.<br />

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