Sustainability framework
A central pillar of the internal sustainability work is Trelleborg’s Code of Conduct and a number of Group policies and directives. The Code of Conduct applies to all employees without exception. Training in the content of the Code is mandatory for all employees and is to be refreshed at least every three years.
For the sixth year, Trelleborg is reporting on sustainability in our Annual Report in accordance with the Global Reporting Initiative (GRI Standards Core Guidelines). In addition, the Annual Report for 2023 is adapted to the sustainability reporting rules of the Swedish Annual Accounts Act
Role of the Board of Directors and Group Management
These also show employee representatives with regard to Board members, and responsibility for monitoring, measurement and governance of Trelleborg’s impacts, risks and opportunities. Areas of responsibility for the Board of Directors and Group Management.
The Board of Directors is the highest instance for governance of sustainability matters. The Board approves the outcome of the double materiality assessment including focus areas, targets, Group policies and action plans that are linked to identified material impacts, risks and opportunities. The Board’s Audit Committee also receives
regular updates regarding the work on the Group’s sustainability reporting in the material focus areas that have been identified.
All focus areas identified in the double materiality assessment, whose results are approved by both Group Management and the Board, will be addressed with steering documents: either with Group policies or Group directives. The Board of Directors approves all Group policies. Group Management approves the steering documents that resemble Group policies but do not require Board approval, which in Trelleborg are called Group directives. The governing bodies’ areas of responsibility for material sustainability matters must be clearly reflected in the relevant steering documents.
The Board of Director’s role as the highest body in Trelleborg for governance of sustainability matters has been strengthened in recent years. From 2021, work on sustainability matters at Board level was expanded so that not only the Audit Committee but the entire Board continuously monitors the Group’s performance by reviewing the development of the most significant indicators. This practice has been clearly facilitated as a result of the expansion of the sustainability content in the Group’s interim reports starting in 2022. Additionally, the Board routinely receives examples and case stories from Trelleborg’s ongoing sustainability initiatives.
Sustainability Council
Many of the day-to-day sustainability activities – with particular focus on identifying material sustainability matters and their impacts, risks and opportunities – take place at the Group level via a Sustainability Council, which was convened four times in 2024. Group Management, including the President, serves as a steering committee for the Sustainability Council.
The Sustainability Council contains internal competence for all sustainability matters that have so far been deemed material. Special expertise was engaged in 2024 for a materiality assessment of newer, potentially material sustainability matters, as well as for CSRD reporting issues.
When drafting the Group’s sustainability targets, the Sustainability Council prepares the topics that have been deemed material and forwards proposals for the respective topics to Group Management, which subsequently decides on the proposed targets. Representatives from both Group staff functions and business areas who are on the Sustainability Council are responsible for pursuing issues linked to their areas of expertise.
Operational sustainability work
Operational responsibility for sustainability initiatives, including proposals for relevant targets and actions, is also exercised through a number of existing cross-organizational
groups with dedicated areas of responsibility (see diagram to the right). The cross-organizational groups operate in core areas such as compliance, chemicals and raw materials/circularity, as well as under the framework of the Group’s Excellence activities with continual procedural improvements. All relevant cross-organizational groups are represented on the Sustainability Council.
The Group’s business areas are themselves responsible for many of the operational sustainability activities in the operations. During the year, they routinely present their respective planning and follow-up in the area to Group Management for the fulfillment of the Group’s sustainability targets. In line with this delegated responsibility at the
business area level for achieving sustainability performance as well as data monitoring, sustainability controllers have been appointed in each business area to manage continual planning and follow-up. Each production site already has an environmental coordinator, energy coordinator and occupational health and safety officers.
The sustainability work is further supported by various types of local internal audits in the units, for example, within the framework of the occupational Safety@Work program and, starting in 2025, in the internal control procedures as well.
Skills and expertise in sustainability matters With regard to current and forthcoming EU legislation on sustainability reporting, Trelleborg’s year was dominated by continued implementation of the first generation of double materiality assessment under the legislation for mandatory sustainability reporting CSRD, and by continued development of regulations for the EU Taxonomy. Internal competence in a range of actual or potential material matters such as circularity and biodiversity was deepened during the year.
The expertise of the Board of Directors in the field of sustainability is described on the Board of Directors page. As a whole, Trelleborg’s management can be considered as possessing the competence required to work with the material impacts, risks and opportunities that were identified in the double materiality assessment. The officers responsible for material sustainability matters (climate, circularity, diversity, etc.) report directly to the President, Senior Vice President General Counsel and Senior Vice President Group Communications & Human Resources, respectively.
A new function for technology and innovation – including circularity – was created in 2024 and includes Vice President Technology & Innovation, who reports directly to the President and CEO of Trelleborg, and Director Circularity & Material Innovation.
As mentioned, access during 2024 was available to both external consulting experts and internal cross-organizational teams for updates in specialist fields deemed to have actual or potential materiality.
Sustainability Due Diligence
Due diligence in the area of human rights Ensuring respect for human rights in its own operations is a matter of course for Trelleborg, as described in the Group’s Code of Conduct. The risk of internal shortcomings in this area is generally considered to be limited. Relevant human rights that are followed up with clear Zero breaches targets internally include
freedom of association, no child or forced labor, no human trafficking and no discrimination.
There is zero tolerance for child and forced labor and human trafficking. The 2024 Modern Slavery, Forced Labor, Human Trafficking and Child Labor Statement
describes how Trelleborg addresses these risks in the value chain.
As part of the internal due diligence process in human rights, all units must register identified cases of child or forced labor in the Group-wide reporting system. All reported cases must be investigated. No such cases have been reported in recent years. To monitor human rights in the supply chain, Trelleborg has for many years had an established
procedure for self-assessment based on the company’s Code of Conduct, which a number of suppliers corresponding to 90 percent of the relevant purchasing spend must fill out (Supplier SAQ).
A due diligence framework was created in the supply chain during the year, based on the forthcoming Corporate Sustainability Due Diligence Directive (CSDDD). Going forward, the ambition is to apply the same framework to internal operations as well, which would mean that the business units that are operating in countries where the analysis shows significant risk for crimes against human rights must be proactive in preventing the relevant risks. Additionally, procedures for internal control will be further developed in 2025 and self-assessment forms that contain questions concerning human rights and conditions of employment may potentially be added.
Due diligence in the area of business conduct Due diligence related to business conduct is a well established procedure whose annual local reconciliation takes place mainly at the subsidiaries’ annual general meetings. This procedure is monitored at both the business area level, with the relevant key indicators being reported on a quarterly basis, and at the Group level in conjunction with the annual reporting.
Risk management and internal control over sustainability reporting
The result of the review is regularly reported back to Group Management and the Board in connection with the approval procedures for the preceding year’s Annual Report.
The auditor’s review for 2024 is summarized in an assurance report for sustainability.
Sustainability in internal control
During the year, efforts were strengthened to include sustainability in the responsibility of the Internal Control function, as well as an expansion of this responsibility for the purpose of further strengthening sustainability reporting and its data quality. The approach for the process review is the same as for the other seven processes previously covered by internal control.
The first step in the initiative that was introduced in 2024 is a self-assessment for all reporting units, with questions linked to the following environmental areas: energy and climate, pollution, water, biodiversity, and resource use and circularity including waste.
As a next step in the first half of 2025, sustainability will be integrated into the Internal Control function’s audits of the Group’s units. In addition, the Internal Control function will also include the other ESRS standards in the existing routines in order to increase data quality and ensure that material matters are followed up locally through relevant activities and procedures.
The purpose of the self-assessment is to ensure that all of Trelleborg’s units have procedures and routines in place to guarantee that sustainability data that is reported on a quarterly, semi-annual and annual basis is reliable and relevant. The self-assessment linked to sustainability reporting routines is analogous to the existing internal control procedures and must be filled in at the same frequency as the other self-assessment forms – every quarter. The self-assessments that were submitted on a quarterly basis in 2024 were audited by the Excellence and Sustainability Group function together with the Group’s Internal Control function. The audit indicated a number of deficiencies in reporting procedures for some units, and a dialog was initiated with these in order to discuss actions.
The results of the self-assessments will be presented to the Board’s Audit Committee once a more complete self-assessment procedure is in place.
Risk management in sustainability reporting
Over time, it has become apparent that the overall Enterprise Risk Management (ERM)-based risk management initiatives in Trelleborg must be supplemented to fulfill the increasingly specific requirements for sustainability reporting. This will be further accentuated when EU legislation for sustainability reporting is introduced starting with the 2025 fiscal year.
To meet its own need – as well as those of its stakeholders – for a comprehensive sustainability risk analysis, Trelleborg has already been working with various approaches and frameworks:
» A continued Group-wide focus on ERM to analyze and cover classic Group-wide risk, based on respective weighing of outcome and likelihood.
» During the year, the financial risks that emerged in the double materiality assessment were also integrated into the ERM framework.
» As of 2024, the sustainability analysis has been further supplemented by a sustainability risk assessment as part of the annually updated double materiality assessment.
» Starting in 2024, the established ERM framework for climate-related physical risks has been supplemented with climate-related transition risks.
» For Trelleborg’s specific analysis of climate-related risks and opportunities under the guidelines in the Task Force on Climate-related Financial Disclosures (TCFD) framework.
The climate scenarios used by Trelleborg are:
- that society succeeds with the transition and keeping global warming below 2 °C, and
- that society does not succeed with the transition and global warming is as high as 4 °C.
Stakeholder engagement
The stakeholders that are directly affected or may be negatively impacted by operations comprise a key group, and from this perspective employees who are affected by or at risk of occupational injuries and ill health should be highlighted, as should workers in the value chain who may potentially be working under some type of unsatisfactory working conditions.
A growing area in the dialog surrounding Trelleborg’s sustainability performance is questions and surveys from customers, in many cases forwarded by third-party companies and organizations. Investors and shareholders continue to show an interest in Trelleborg’s sustainability profile and the level of engagement from this stakeholder group with regards to questions and surveys remains high. Trelleborg answers a number of comprehensive sustainability surveys from established platforms, such as CDP and EcoVadis, to evaluate the company’s own and its suppliers’ performance in the sustainability area.
The social interest to preserve the environment in the immediate physical vicinity of Trelleborg’s units is monitored on a general level by several stakeholder segments that are included in the Society group: authorities through, for example, permits or regulations, environmental and sustainability organizations with various specialized focus areas, as well as researchers and students specializing in the environment or sustainability. All neighbors to Trelleborg’s facilities, who could at least potentially experience the negative impacts of being located close to a manufacturing plant, are another such central stakeholder.
Stakeholder engagement
Our stakeholders are showing engagement for Trelleborg’s initiatives in social and environmental issues, as well as interest in how the Group is pursuing its sustainability initiatives. Stakeholder dialog is a powerful tool that provides an understanding of the impact of the operations and how Trelleborg can manage it.
An overall aim of Trelleborg’s annual reporting of sustainability matters is to provide all stakeholders with an accurate overview of the Group’s activities, results/performance and commitments in the ESG areas of the environment and issues of social responsibility including health and safety, as well as business conduct and sustainability governance issues. Generally, sustainability matters have clearly received more space in the Group’s interim reporting, and the dialog during the year has also primarily been marked by work focused on climate, circularity and social sustainability and some work on Board and compensation matters.
The direct dialog with stakeholders is managed primarily by the respective functions in the Group (Investor Relations, logistics, and communication, for example) and locally within the business areas, where stakeholder expectations and questions can be managed proactively while feedback is facilitated. This dialog is characterized by transparent and reliable communication in accordance with the principles in Trelleborg’s Code of Conduct. Different stakeholders may have different focus areas and various interests related to sustainability, which makes it important for Trelleborg to learn about and account for viewpoints from all groups. Questions from dialog sessions, which are held both locally and centrally, are addressed in the Group’s Sustainability Council (read more on page 119), where they are integrated into the double materiality assessment process. The results are presented, and then adopted, by Group Management and the Board of Directors.
Trelleborg and the value chain
customer requirements for critical applications in demanding environments. The core of Trelleborg’s solutions is expertise in materials technology and in-depth knowledge of customer applications.
Sustainability Contacts
Contact our sustainability team: sustainability@trelleborg.com
For Product inquiries or related matters, please go to: Contact us

Johan Wijk
