Safety, Health & Environment (SHE)

Zotefoams considers that the management of SHE matters forms a key element of effective governance. Separate policies relating to SHE are in place. The Company is certified to accredited standard ISO 45001:2018 for Health and Safety, following a migration from OHSAS 18001:2007, and ISO 14001:2015, the International Standard for Environmental Management Systems, and is regularly audited by certification bodies to ensure that the Company complies with those standards. Following an integrated surveillance audit carried out in 2021, Zotefoams UK was granted ongoing certification. The auditor commended the progress and maturity of the management systems, the high degree of executive oversight and the high level of focus on safety engagement. The Company is also certified to accredited standard ISO 9001: Quality Management.

The Board has ultimate responsibility for SHE policy and performance and receives quarterly reports on Group SHE issues. The Board has set a very low risk appetite for health and safety matters. Annual performance objectives are agreed by the Board and performance against these is monitored as part of its quarterly reporting programme. RIDDORs (lost time accidents reportable under the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013) are recorded immediately and are subject to a thorough root cause analysis reviewed by the Board, with appropriate follow-up actions agreed with management. Additionally, the Board has a detailed review of SHE performance, targets, metrics and approach through monthly updates.

The Group CEO is directly responsible to the Board for SHE performance. Group committees on SHE normally meet once per quarter to consider all SHE matters and are overseen by steering committees, chaired by the Group CEO (or appropriate responsible person in subsidiary companies). The steering committees consider overall performance and the impact of current and impending legislation.

On joining the Group, all employees receive induction training on SHE matters, including the Group’s SHE policies, and refresher training is provided, as appropriate, to ensure employees remain abreast of and familiar with SHE matters. Employees are made aware that each and every one of them has a part to play in ensuring the safety of themselves and their colleagues at work. Employees are encouraged to report to their managers any unsafe, or potentially unsafe, acts or conditions. Senior managers are responsible for ensuring that SHE policies are implemented in their areas, that their teams are informed of the departmental SHE requirements and that employees receive and understand training on environmental issues and safe working practices. Regular audits are conducted to ensure policy and procedure implementation is appropriate.

The Group takes the reporting of all SHE incidents very seriously and requires employees to report all incidents, including any near misses, as well as damage to plant or equipment which has not resulted in personal injury. The Group considers the reporting of near misses to be as equally important as actual incidents, since it raises situations to management that could cause, or might have caused, harm. It then ensures appropriate corrective action can be taken to eliminate or minimise the risk. The Group also ensures that appropriate safety practices are included in standard operating procedures to reduce the risk of SHE incidents occurring.

Few controlled substances are used in the manufacture of our foams, but where they are, the Group has established procedures, in which the relevant employees are trained, to ensure that the storage and handling of such substances are safe and in accordance with regulatory requirements. The manufacturing process involves manual handling and processing of materials. When new or altered equipment or materials are introduced, and at regular periods thereafter, the risks to the processes are assessed and improvements made wherever possible, such as to the design of the equipment, to reduce or eliminate the risks identified.

The most strictly controlled parts of the Group’s sites are where high-pressure gas is used. The high-pressure autoclaves are subject to the Pressure Systems Safety Regulations 2000 in the UK, OSHA (Occupational Safety and Health Administration) in the USA and the Journal of Laws of the Republic of Poland, Dz. U. 2022 poz. 68. Tightly defined procedures and operational controls are in place to manage the safety of these pressure systems. Fail-safe mechanisms, known as pressure relief valves and bursting discs (which act like fuses in an electrical system), are included in the design of the pressure systems which, when triggered, allow safe depressurisation of sections of the system and prevent any further risks. Operation of these fail-safe mechanisms releases harmless nitrogen gas into the atmosphere. The air we breathe is composed of 78% nitrogen.

All SHE incidents are investigated by appropriate levels of management to ascertain the root cause of the incident and, wherever possible, working practices and procedures are improved to minimise the risk of recurrence. In 2021, there were no prosecutions, fines or enforcement actions taken as a result of non-compliance with SHE legislation (2020: none).

Health and safety

The COVID-19 pandemic remains a threat and continuing to protect the health of all Group employees is paramount. Throughout the year, Zotefoams maintained a range of anti-COVID measures designed to mitigate the risk of transmission. These continue to apply in all locations in addition to any governmental restrictions in force. Health surveillance programmes also provide at-risk employees Group-wide with medical monitoring and support to ensure that work-related medical conditions are identified and addressed promptly through the appropriate referral to medical specialists. The change in work/life balance imposed by the pandemic has also been recognised and a number of wellbeing initiatives have been launched in response. Further details are provided in our People section on page 70 of our 2021 Annual Report.

Fostering a safety culture has a positive impact on risk and performance. Management focus remains on developing safety leadership, using various engagement methods to increase Group-wide awareness of hazard identification and control, as detailed in the case study below.

One of our core priorities in 2021 was to review the risk assessment process around our equipment to ensure that machinery was engineered in a way that minimises the risk of injuries to operators, regardless of levels of skills and experience. All new capital investment projects have been and are currently subject to a design stage occupational health and safety risk assessment.

Health and Safety performance

The primary metric used to monitor the number of reportable lost time injuries is RIDDOR. In 2021, we are very pleased to report that there were no RIDDOR incidents across the Group (2020: 1). The Group has not experienced any fatality amongst staff or contractors as a consequence of a work-related incident.

The Group also uses metrics devised by the United States Department of Labor to measure staff absences resulting from workplace incidents and accidents. This allows comparison with a large, relevant peer group and also provides an established methodology with which we can benchmark our performance annually. In 2021, there was a slight decrease in Days Away From Work (DAFW) and a slight increase in Days Away Restricted or Transferred (DART). To combat this in 2022, we will continue the programme of increasing risk and hazard awareness, which is also linked to the continuation of expanding the new safety engagement process. In both cases, the metrics are compared with the latest benchmark data for Rubber and Plastics Processors. Good performance against this benchmark was noted in both 2020 and 2021.

(latest published figures)

Environmental performance

An increase in Group energy usage of 5,479 MWh mainly arose through increased output levels in our main USA site (up by 2,741 MWh) and commencement of production in Poland (up by 1,477 MWh). The main reason for this increase was increased activity at these sites.

There were no significant environmental incidents during the year (2020: none). Previous years have been analysed against an internal categorisation introduced in 2018, guided by the Environmental reporting guidelines at

Level 1 – Reported to Environment Agency (e.g. polluting incident)

Level 2 – Reported to local authority (e.g. waste concerns)

Level 3 – Internal report only (e.g. small granule spills)

SHE: Key metrics

Group: Reportable lost time injuries01146
Internally recorded environmental incidents     
Level 100000
Level 200000
Company metrics     
Energy usage (MWh)49,43348,40544,57052,22549,085
Energy consumption (kWh/kg)9.22* 9.89*11.60*11.03*11.05
Group metrics     
Energy usage (MWh)68,21962,74056,45363,46955,354

*   Calculation shown as mix-neutral assessment of energy usage per kg of polymer processed.

In 2021, no incidents were reported at Level 1 or 2, meaning no significant impact to the environment. The Company ensures that all reports are taken seriously and investigated and that the responses given are appropriate to their level of impact or potential impact. Nineteen internally reported Level 3 incidents (2020: 24) relating to minor machine oil spills, plastic granule spills and thermal oil spills were recorded during the year. The incidents are captured by daily inspections and actioned as required. The decrease is attributed to a significant increase in safety observations, employee education and early-stage implementation of the 5S method to reduce waste and increase productivity.

At our site in Kentucky, USA we suffered an equipment failure in our silencer system which regulates noise from part of our process. A replacement system was installed quickly to allow our processes to restart and noise to be managed. Although this new system meets all environmental and local requirements for noise, there was a noticeable change from the previous system. Our team in Kentucky has liaised with the local mayor, residents and authorities and we have commissioned the design of a bespoke silencer system to further reduce local noise emissions.

This is expected to be implemented in H1 2022.

Specific Energy Consumption (SEC) – UK

In October 2009, the Company entered into a Climate Change Levy (CCL) agreement which involves meeting specific targets to reduce energy consumption. Provided the Company meets the requirements of the CCL agreement, it receives a rebate on its electricity bills and is also exempt from the Carbon Reduction Commitment Scheme.

The Company measures energy efficiency by taking energy consumption and dividing it by the amount of material (in kg) that passes through high-pressure autoclaves. The increase in production of our High-Performance Products (HPP) foams, which generally require more processing energy than polyolefin foams, prompted us to update these metrics to be product-mix neutral in 2018. In 2021, our adjusted energy efficiency measure Specific Energy Consumption (SEC) has decreased to 9.22 kWh/kg (2020: 9.89 kWh/kg), the lowest recorded since 2015. In 2019, the Company completed its second assessment under the Energy Saving Opportunity Scheme (ESOS) and remained compliant in 2021.

The SEC value has been reported in the 2021 Annual Report as a mix-adjusted value since 2018 to reflect the growth of Footwear and to show the energy efficiency improvements made.

In order to benefit from a CCL exemption, the Company has entered into Climate Change Agreements (CCAs) as set out by the Department for Business, Energy and Industrial Strategy. A CCA is a voluntary scheme setting targets to increase energy efficiency and reduce carbon dioxide (CO2) emissions. For the plastics sector, the scheme is run by BPF Energy Limited, to which unadjusted SEC figures are reported quarterly. The scheme will run up to 2025.

Carbon emissions globally

Zotefoams products are used in applications globally to improve people’s lives and reduce energy consumption, primarily through insulation and weight reduction. The processes we employ to create these foams allow us to use less raw material and produce lighter foams than competitive processes, both of which are beneficial for carbon reduction. In making these foams, energy (both gas and electricity) is the main source of carbon emissions from our facilities.

The efficiency with which we use energy to process polymer is measured by the weighted specific energy consumption. In 2021, our UK site, which processed approximately 80% of Group polymer by tonnage during the year, reduced the weighted specific energy consumption by almost 7%. Overall carbon emissions for 2021 were 14,210 metric tonnes (2020: 14,542 metric tonnes), with the main changes being due to the change in the conversion factor for electricity to CO2 as UK generation switches from coal to renewables and nuclear.

In 2021, 97.7% (2020: 93.2%) of the Group’s carbon emissions arose from our use of electricity and gas, primarily in processing polymer but with some use in facility heating and cooling. Direct carbon emissions from other sources were minimal (2.3% of Group emissions) as we do not operate our own fleet of vehicles.

The methodology we have used is in accordance with the guidance published by the Department for Environment, Food and Rural Affairs in June 2013. We have only included emissions for which we are directly responsible. We have not included emissions for activities over which we have no direct control. For example, we have included business mileage on a Company van and mileage claimed by employees in the UK, but not other forms of business travel, such as travel made by employees elsewhere in the Group or travel using public transport or air travel.

We are committed to using renewable electricity where feasible. Our UK site switched supply during 2021 and is now supplied with 100% REGO electricity, with our Poland site switching to renewable electricity from the start of 2022.


Group: carbon emissions (CO2 tonnes)






Scope 1 Emissions (direct emissions from our operations which includes fuel)






Scope 2 Emissions (indirect emissions, primarily electricity)












Carbon emissions (kg) per material gassed (kg)






Water and waste

While none of our sites are located in regions where water is scarce, we recognise that usage of water is a key environmental metric supporting our sustainability proposition. The amount of waste produced is a key target updated in 2021 to minimise our impact on the environment and forms part of our corporate objectives. Water usage decreased by 2% across the Group in 2021. Our water consumption is metered and we have specific programmes to improve efficiency and reduce water usage. The main water usage is at our UK site, the largest of our manufacturing sites, where we implemented specific initiatives to prevent leaks and minimise water usage, including relining our water storage pit.

Total waste across the Group was 3,124 tonnes for the year with more than 856 tonnes being recycled. At our main site in the UK, we continue to work with partners who sort our waste, recycle significant portions and recover energy through incineration. The quantity quoted as recycled is known to be understated as our partner for non-foam waste is currently unable to report this reliably, therefore we have not reported this as recycled. During 2021, we further developed outlets for our foam scrap, the majority of which is now re-purposed into turf-underlay and blocks of particle foam.

In 2022, we will embark on a number of longer-term initiatives to reduce our waste, in particular the waste that cannot be recycled. This includes investment in machinery to improve our circularity by allowing scrap polymer from our process to be re-incorporated as the base material in the manufacture of our foam products.

Water and waste: Global

Water consumption (000m3)




UK site




USA site




Other sites




Global consumption




Waste recycled (tonnes)



The quantity quoted as recycled is understated as our partner for non-foam waste is currently unable to report this.

Total Waste (tonnes)




Key sustainability targets

Our sustainability targets focus on the reduction of our Scope 1 and 2 carbon emissions.

In parallel with these specific Scope 1 and 2 targets, we have calculated the carbon cost of a representative selection of our foams (referred to as “carbon accounting”) and ReZorce® mono-material barrier packaging technology. We are utilising this information internally and working with selected customers to assess how this can be used constructively to make objective decisions to steer our own business and guide our customers in choosing the optimal material solutions for their applications. We are also developing Life Cycle Assessments (LCA) for our products in use, giving us visibility of Scope 3 emissions on a case study basis.

TARGET 1: Improve purchase-to-product (mass balance) of AZOTE® polyolefin foam products. We purchase more polymer than we sell as foam, with losses in the current manufacturing process. This is waste material and waste energy which, with some investment, can be reduced. By the end of 2026, we plan to have halved the polymer purchased that is not in the product (internal waste and oversized materials). To support this, in 2022, we will financially and operationally plan the investments required to achieve our 2026 target. Additionally, we aim to implement improvements to reduce the polymer waste rate during manufacture and are targeting a 2.5% waste reduction for 2022. Targets and achievements for intermediate years will be published on our website.

TARGET 2: Re-purpose polymer waste, that cannot be prevented, from our UK manufacturing process. Inherent to achieving longevity and light weight in our foams is a manufacturing step, known as crosslinking, which modifies the polymer. Crosslinking is not practically reversable and therefore utilising this modified polymer to manufacture foams requires different techniques than when dealing with unmodified polymer. As we develop these techniques, we are able to re-incorporate this modified polymer in the manufacture of certain products.

By the end of 2022, we plan to:

  • Have developed AZOTE products that will allow us to re-incorporate into our foams 50% of solid polymer waste produced at our UK site
  • Find applications that reuse 90% of all AZOTE foam waste produced at the UK site.

TARGET 3: Zotefoams products have historically been designed to use less material and last longer. We will further develop our product portfolio by designing and developing new products which offer our customers more sustainable solutions. By the end of 2026, 5% of our revenue will be generated from new products designed and developed, after 2022, for use-phase resource efficiency. Targets and achievements for intermediate years will be published on our website.

TARGET 4: We continually strive to reduce the energy consumed in the manufacture of our products. As we produce greater quantities of products across multiple manufacturing sites, the energy we consume increases. Additionally, certain products we develop which offer greater use-phase resource efficiencies can require greater energy per unit volume to manufacture. Setting a target which both accommodates growth and reflects the changing product mix is difficult, but we have committed that by 2026 we will reduce the energy consumed per unit of revenue by 10%. Details of this target and projected progress is provided below.

We acknowledge that external factors, such as inflation leading to higher prices and foreign exchange rates impacting profit, will have an influence on the achievement of Target 4. We have chosen an energy per unit of revenue metric because our strategy of mix enrichment favours HPP products, which generally require more energy to manufacture. Following that strategy results in higher energy usage being reported. However, these products offer benefits in terms of reduction or avoidance of energy consumption in the use-phase (a concept defined by SASB as a product that through its use can be shown to improve energy efficiency, eliminate or lower greenhouse gas (GHG) emissions, reduce raw materials consumption, increase product longevity, and/or reduce water consumption) which are not reflected in the figures we report.

We strive to reduce the energy used in our manufacturing process and seek a metric that demonstrates this. We have agreed that energy per unit of revenue gives sufficient weight to HPP products (which tend to have a higher selling price) and is an appropriate measure.

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