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[]
[]
[]
[]
[]
["Participant information"]
["Name of the site",null,null,null,"Aurubis Stolberg GmbH & Co. KG"]
["Unique identifier provided by the Copper Mark",null,null,null,"P0083"]
["Address",null,null,null,"Zweifaller Str. 150, D-52224 Stolberg"]
["Country of operation",null,null,null,"Germany"]
["Name of brands produced at site and corresponding exchanges",null,null,null,"N/A"]
[]
["The Copper Mark Standards Included in the Assessment"]
["Criteria for Responsible Production / Risk Readiness Assessment"]
["Joint Due Diligence Standard for Copper, Lead, Molybdenum, Nickel, and Zinc"]
[]
["Conclusions"]
["Criteria for Responsible Production"]
["1. Legal Compliance",{"$f":"B84","v":"FM"},"10. Working Hours",{"$f":"B93","v":"FM"},"19. Tailings Management",{"$f":"B102","v":"NA"},"28. Indigenous Peoples Rights",{"$f":"B111","v":"NA"}]
["2. Business Integrity",{"$f":"B85","v":"FM"},"11. Remuneration",{"$f":"B94","v":"FM"},"20. Pollution",{"$f":"B103","v":"FM"},"29. Land Acquisition and Resettlement",{"$f":"B112","v":"NA"}]
["3. Stakeholder Engagement","FM","12. Occupational Health and Safety","FM","21. Biodiversity and Protected Areas","FM","30. Cultural Heritage","FM"]
["4. Business Partners","FM","13. Employee Grievance Mechanism","FM","22. Mine Closure and Reclamation","NA","31. Due Diligence in Mineral Supply Chains","FM"]
["5. Child Labor","FM","14. Environmental Risk Management","FM","23. Community Health and Safety","FM","32. Transparency and Disclosure","FM"]
["6. Forced Labor","FM","15. Greenhouse Gas (GHG) Emissions","FM","24. Community Development","FM"]
["7. Freedom of Association and Collective Bargaining","FM","16. Renewable Energy","FM","25.  Artisanal and Small-Scale Mining","NA"]
["8. Discrimination","FM","17. Freshwater Management and Conservation","FM","26. Human Rights","FM"]
["9. Gender Equality","FM","18. Waste Management","FM","27. Security and Human Rights","NA"]
[]
["Joint Due Diligence Standard for Copper, Lead, Molybdenum, Nickel and Zinc"]
["1. Due Diligence Management System",{"$f":"B118","v":"FM"},"2. Risk Identification",{"$f":"B119","v":"FM"},"3. Risk Assessment",{"$f":"B120","v":"FM"},"4. Risk Management",{"$f":"B121","v":"FM"}]
["5. Public Reporting",{"$f":"B122","v":"FM"}]
[]
["Chain of Custody Standard"]
["1. Management System for Material Control",{"$f":"#REF!","v":{"$error":"#REF!"}},"2. Eligible Copper",{"$f":"#REF!","v":{"$error":"#REF!"}},"3. Material Accounting System",{"$f":"#REF!","v":{"$error":"#REF!"}},"4. CoC Transfer Records",{"$f":"#REF!","v":{"$error":"#REF!"}}]
[]
["Key"]
["NA: not applicable",null,"DNM: does not meet",null,"PM: partially meets",null,"FM: fully meets"]
[]
["Statement of Conformance"]
["The site is found to fully meet all applicable criteria"]
[]
["Award(s)"]
["Valid from",null,"19th July 2024 ",null,"Valid until","2027-07-18"]
[]
["Scope of the assessment"]
["Principal covered metals",null,null,"Copper"]
[]
["Principal covered metal products",null,null,"Copper Strip"]
[]
[]
[]
["Other metals in scope"]
[]
[]
[null,null,null,"Other:"]
["Metals in scope of minerals due diligence"]
[]
[]
[null,null,null,"Other: "]
["Operating activities",null,null,"Other"]
[null,null,null,"Recyclng"]
[]
["Infrastructure",null,null,"Roads"]
[]
["About the participant",null,null,"Aurubis Stolberg is part of the Aurubis group and has operated at this site for over 100 years.\nAurubis Stolberg produces high-precision strips and wires made of copper and copper alloys for the world market."]
[]
["Equivalency"]
["Equivalent systems are determined by the Copper Mark to have standards and assurance requirements that are materially comparable in scope and intent to those of the Copper Mark, in accordance with the Copper Mark Recognition Process."]
["The following equivalent systems were applied:"]
["System","Date of certification / assurance",null,"Review process",null,null,null,"Covered Criteria"]
["ISO 45001","Valid until August 2025",null,null,null,null,null,"CM12"]
["ISO 14001","Valid until August 2025",null,null,null,null,null,"CM14, also relevant to CM17,18,20,21,23"]
[]
["Independent site assessment"]
["Name of lead assessor",null,null,null,"David Shirley & Raj Aseervatham"]
["Name of assessment firm",null,null,null,"Corporate Integrity Ltd"]
["Date(s) of assessment",null,null,null,"On site 11th to 13th June 2024 "]
["Assessment period",null,null,null,"year 2023"]
["Summary of assessment methodology",null,null,null,"The assessment approach is in accordance with Corporate Integrity assessment procedures which include: \n1.\tDocument review (this involves review of policies, procedures, internal and external audit and inspection reports, technical studies and reports, media reports, monitoring and performance data (often viewed on electronic platforms, samples of completed forms, personnel records, and correspondence \n2.\tSite visit planning including Agenda discussions with Copper Mark. This involves identifying focus areas based on risk and identification of stakeholders for interview.\n3.\tSite visit, which includes interviews with senior management, management functions to assess implementation of management systems. These are triangulated through workforce and stakeholder interviews.\n4.\tPreparation of management report"]
["Summary of assessment activities",null,null,null,"The site visit activities involved:\na.\tMeetings at main offices with key functions and management\nb.\tSite walk about all areas of the site, escorted by relevant managers\nc.Tour of communities\nd.\tWorkforce  interviews. 22 workforce members were interviewed representing employees and contractor labour across genders\ne.\tExternal Stakeholder Interviews representing community and regulators. "]
["Summary of findings"]
["Criterion","Rating","Description of system",null,"Identified Gaps (where applicable)",null,"Evidence to support determination"]
["Criteria for Responsible Production / Risk Readiness Assessment"]
["1. Legal Compliance","FM","Much of the sustainability management in Aurubis AG is driven by legal compliance under a heavily regulated German and European legal framework. Aurubis Stolberg has a system in place, designed to ensure legal compliance. This is documented in the corporate Compliance Policy and Compliance Management System and implemented at the local level. \n\nAt Stolberg the system is supported by an online externally serviced platform which provides a register of all legal obligations, with continuous updates and advice bulletins. \n\nThere is an annual declaration from site to head office on compliance status. In 2023 there were no reported legal non-compliances and no litigation cases ",null,null,null,"Key Documents viewed \nRechtsquellen service on screen correspondence\nRisk register\nISO Audit reports \nAnnual declaration to group that they are following legal for financial\nOrganogram showing responsibilities\nRegional Administration inspections – public available\n\nExternal Stakeholder Interviews \nRegulator and insurance representatives confirmed that Aurubis Stolberg is committed to maintaining compliance and is co-operative and responsive."]
["2. Business Integrity","FM","Business integrity is covered in several policies including; Code of Conduct, Business Partner Code of Conduct, Compliance Anti-Corruption Policy and Anti-Trust Policy. The relevant management system is documented in the Compliance Policy and Compliance Management System. There is a dedicated Local Compliance Representative (LCR) at Stolberg, to oversee the compliance programme. There is an annual meeting of all the LCRs.\n\nThere is specific compliance training provided annually through an e-learning platform which is required to be completed by staff in key positions.\n\nFacilitation payments are forbidden under the German Criminal Code.  There were no gifts reported from Stolberg. \n\nThere is an anonymous whistle-blower hot line available advertised on the web site. There were no recorded complaints in 2023.",null," ",null,"Key Documents viewed \nCodes of Conduct\nAnnual report\nBusiness Partner Code of Conduct \nCompliance Anti-Corruption Policy\nAnti-Trust Policy\nCorporate Anti-corruption compliance policy\nConflict of Interest and Anti-corruption procedure\nWhistleblower hot line\nTraining materials records"]
["3. Stakeholder Engagement","FM","The Stolberg operation carries out stakeholder mapping and this is presented in a stakeholder engagement spreadsheet, which links stakeholder types, relevance to Aurubis, the engagement approach. There is evidence of ongoing engagement with a range of stakeholders, including local communities, government bodies, and sector organisations.\n\nThere is an established formal grievance process through the whistleblowing hotline which is communicated on the Aurubis web site.  The process has been reviewed and it is in alignment with the UN Guiding Principles effectiveness Criteria.\n\nNo grievances were reported from external stakeholders in 2023.",null,null,null,"Key Documents viewed \nSustainability Report\nCorporate Social Engagement Policy\nStakeholder engagement map\nGrievance procedure and records\n\nExternal Stakeholder Interviews\nExternal stakeholder interviews indicated that Aurubis engages appropriately with local organisations and is responsive and supportive of local needs. "]
["4. Business Partners","FM","There is a group wide programme for screening and due diligence of suppliers and contractors. All suppliers are subject to the Aurubis Business Partner Screening process. Larger and group wide supply contracts are screened by the corporate team. Locally the procurement team contracts and manages mainly local service contracts. \n\nAll Stolberg suppliers are registered in the system and have been evaluated with this tool. The ultimate responsibility for implementation lies with the Corporate Compliance department but there is significant input from the local procurement team. Oversight is provided by the Board, who determine actions required for high risk and critical business partners.\n\nAll such business partners are initially subjected to an Aurubis configured software Third Party Compliance screening process covering 25 questions. This identifies risks through a traffic light system. Yellow and Red rated companies are subjected to further due diligence depending on the outcome of the initial screening. \n\nAll contractors at site are subject to Stolberg’s contract general terms and condition, which includes commitments to Aurubis Code of Conduct and to human rights related conditions.",null,null,null,"Key Documents viewed \nBusiness Partner Code of Conduct\nBusiness Partner Supply Chain Screening Process\nCorporate Responsible Sourcing Policy General Terms and Conditions of Purchase\nContract template\nHuman Rights commitment"]
["5. Child Labor","FM","Child labour policies are included in the Code of Conduct and the Business Partner Code of Conduct, both of which also include commitments to ILO labour Standards. Child Labour is also covered under German Law in the German Youth Employment Protection Act (section 5 Prohibition of Employment of Children).\n\nRisk of workers under 18 being employed at the Stolberg site appears low. All employees are checked at onboarding through an applicant management system which requires proof through social security and health insurance documentation.  During the site walk abouts there was no visible evidence of underage employment on the sites. ",null,null,null,"Key Documents viewed \nCode of Conduct \nBusiness Partner Code of Conduct \nHuman Rights commitment\n\nSite Observations\nDuring the site walk abouts there was no visible evidence of underage employment on the sites"]
["6. Forced Labor","FM","Forced labour policies are included in the Code of Conduct and the Business Partner Code of Conduct, these also include commitments to ILO labour Standards. A formal commitment which is a supplement to the Code of Conduct was developed and signed off by the Executive Board Chairman and published in March 2023. \n\nThe policy has been rolled-out to the Stolberg site through related training programmes. Training courses through interactive e-learning tools ‘Together with Respect’ and \"Unconscious Bias\" have been developed and are compulsory for all Aurubis AG employees worldwide. The ‘Together with Respect’ course was rolled-out to both the ‘white collar’ and ‘blue collar’ workers at the Stolberg site during 2023. \n\nAurubis publishes a Declaration on Modern Slavery and Declaration on Human Trafficking in accordance with the UK Modern Slavery Act 2015 on behalf of Aurubis Group companies. ",null,null,null,"Key Documents viewed \nCode of Conduct \nBusiness Partner Code of Conduct \nHuman Rights commitment\nUnconscious Bias Training\nModern Slavery declaration\n\nWorker Interviews \nAll workers expressed awareness of the Code of Conduct and confirmed that they receive the unconscious bias training\nSite Observations\nNo obvious signs of forced labour were observed on site."]
["7. Freedom of Association and Collective Bargaining","FM","The right to freedom of association and the right to collective bargaining are required by policy in the Code of Conduct and the Business Partner Code of Conduct. This is also required in German Law in the Works Constitution Act and the Speakers’ Committee Act.\n\nAll members of the Aurubis Stolberg workforce come under a collective bargaining agreement of the Metal Workers Union. This is the agreement that drives the basis for remuneration, working hours and other workplace conditions. \n\nApproximately 90% of Aurubis workers at Stolberg operations are members of the union, but all workers including contract workers are provided with working conditions determined by the collective bargaining agreement. \n\nAll Stolberg employees are represented by a Works Council. There is one full time member of Works Council and 8 other members all elected by the workforce. ",null,null,null,"Key Documents viewed \nCode of Conduct \nBusiness Partner Code of Conduct \nIG Metals Union Collective bargaining agreement\nExamples of signed agreements \n\nManagement interviews \nThe appointed chairman of the Works Council confirmed that there were regular meetings held and that all agreements were signed by him and the head of Human resources, although most issues were resolved informally. He commented that there is a high level of responsiveness of management to Works Council requests and talked about ‘working together rather than against each other’. He said that the Union conducts an on-line survey to determine what workforce members want from the union\n\nWorker Interviews\nWorkers were all aware of the Works Council and talked favourably about the support they got through it. They also confirmed the responsiveness of management to worker requests (some slower than others) "]
["8. Discrimination","FM","Discrimination and harassment policies are included in the Code of Conduct and the Business Partner Code of Conduct. These also include commitments to ILO labour Standards.  A formal commitment which is a supplement to the Code of Conduct was developed and signed off by the Executive Board Chairman and published in March 2023. \n\nThe policy has been rolled-out to the Stolberg site through related training programmes. Training courses through interactive e-learning tools ‘Together with Respect’ and \"Unconscious Bias\" have been developed and are compulsory for all Aurubis AG employees worldwide. The ‘Together with Respect’ course was rolled-out to both the ‘white collar’ and ‘blue collar’ workers at the site during 2023. \n\nNo related grievances were received in 2023.",null,null,null,"Key Documents viewed \nCodes of Conduct\nHuman Rights commitment\nUnconscious Bias Training\nAurubis Germany Discrimination Policy\nInformation for the Employees of Aurubis Stolberg to the General Equal Treatment Act (AGG)\n\nWorker Interviews\nThe workforce interviews confirmed that training had been received. All interviewees also indicated that discrimination was not encountered in their workplace.  "]
["9. Gender Equality","FM","Gender equality requirement is included in the Code of Conduct.   \n\nThe policy has been rolled-out to the Stolberg site through related training programmes. Training courses through interactive e-learning tools ‘Together with Respect’ and \"Unconscious Bias\" have been developed and are compulsory for all Aurubis AG employees worldwide. The ‘Together with Respect’ course was rolled-out to both the ‘white collar’ and ‘blue collar’ workers at the site during 2023. \n\nEqual pay for women is already a part of the agreed tariff system through the collective bargaining agreement process, which defines wages on merit and defined grades. \n\nWhile no specific targets are set, there are campaigns to encourage women to join the apprenticeship scheme. At group level the Women 4 Metals initiative is active with a committee set up for this. At Stolberg there is a Girls for Metal day where external women are invited to see what opportunities exist. \n\nNo related grievances were reported for Stolberg site in 2023.",null,null,null,"Key Documents viewed \nCodes of Conduct\nCollective Bargaining agreement\nUnconscious Bias Training\nWomen 4 Metals structure\n\nWorker Interviews \nWomen interviewed indicated that they were comfortable with working conditions and did not experience specific gender related bias, although they recognize they are working in a male dominated working environment. They pointed out that currently there were no specific facilities for women such as shower rooms but understood that this was due to the small % of women in the workforce. This has been raised and is a factor in current Works Council requests for a worker specific facility (rest and recreation area, changing and shower rooms etc.)."]
["10. Working Hours","FM","Policy wording on working hours is included in the Code of Conduct and the Business Partners Code of Conduct. The working hours are controlled through German Law and through the Collective Bargaining Agreement. The German legal working week is 48hrs and the Collective Bargaining Agreement average working week for Aurubis Stolberg is 35 hrs. Work hours above this average are done on a voluntary basis. \n\nStolberg operates a 3x8 shift system which includes a 30min break so shift time is calculated at 7.5 hours. There is a shift rota which operates over a 9-week period and the average working week over this period is 35hrs.  Overtime is flexible and voluntary.\n\nThe time management system Veda is used to track working hours through a clock in/clock out system. There are various reports and warnings for monitoring including violations of rest periods. ",null,null,null,"Key Documents viewed \nCode of Conduct\nCompany agreement on time account regulations\nCollective Bargaining agreement\n\nWorker Interviews \nInterviews with Works Council members and with individual employees indicated that working hour limits were being adhered to and that they were satisfied with the holiday entitlement."]
["11. Remuneration","FM","Policy wording on remuneration is included in the Code of Conduct and the Business Partners Code of Conduct.  Remuneration levels for blue and white collar workers are based on a tariff agreement in the collective bargaining agreement and within this tariff system individual remuneration packages are based on an objective evaluation scoring system. This is all agreed through the Works Council. The remuneration of the lowest pay group at Aurubis Stolberg is above the German minimum/living wage. There is also a range of other employment benefits.\n\nRemuneration tariffs and benefits for various work placements are set in the Collective Bargaining Agreement, which is based on the standards for the Metals Industry in Germany.",null,null,null,"Key Documents viewed \nJob description plus tables showing evaluation scores\nCollective bargaining agreed tariffs\n\nWorker Interviews \nAll interviewees responded that they are satisfied with their wage and benefits packages."]
["12. Occupational Health and Safety","FM","\"There is evidence of the current ISO45001 certificate which expires on 2025-08-18 and the most recent certification report (2023) raised no non-conformances or observations.\n\nThere is a strong focus on safety at the site triggered partly by a fatality last year at the Aurubis Hamburg operation which prompted a global review of safety. A recent third-party risk based gap assessment at Stolberg highlighted a number of opportunities for improving safety management in four key risk areas. Stolberg is now in the process of implementing improved safety practices in these areas.\n\nWhile there is a range of occupational exposures, exposure levels are monitored and found to be below Occupational Exposure Limits. \t",null,null,null,"Key Documents viewed \nISO 45001 report and certificate\ndds + risk review and recommendations\nExposure monitoring records\n\nWorker Interviews \nThe site layout is quite constricted by available space, so hazards and personnel are often in close proximity. During the site visit we saw evidence of appropriate signage and wearing of PPE.\n\nExternal Stakeholder Interviews\nThe Employers Liability Insurance representative said that the quality of safety at Stolberg in his view has improved and that he recognises that the site is on a continuous improvement journey. He confirmed that he sees all accident reports and that he visits the site 2 to 4 times per year also provides safety leadership training at the site.\n\nSite Observations\nAll personnel interviewed talked of management taking health and safety seriously at the operation and indicated that they felt they were provided with a safe place of work. Housekeeping appeared good."]
["13. Employee Grievance Mechanisms","FM","There is a formal grievance line, the Whistleblowing line, the procedure for which is provided in the Compliance Policy. The line is run by an independent ombudsman and is available to all stakeholders (internal and external). The process was reviewed, and it is in alignment with the UN Guiding Principles effectiveness Criteria. The contact point for the whistleblowing hotline is on the publicly available Aurubis web site. \n\nThere is an independent service available called Employee Assistance Program (EAP Assist). This external organization offers a channel that employees and family can call 24/7 to raise concerns, such as difficulties/problems at work.\n\nOther lines for workers to raise any concerns are to line management, to Human Resources or through the Works Council.  . \n\nThere was one reported grievance case during 2023, which was filed via anonymous letter to the managing director and board. The investigation is still in progress.  ",null,null,null,"Key Documents viewed \nPolicies\nCompliance Policy with whistle-blower process\nEAP presentation and web site\nInduction training\n\nWorker Interviews\nWorkers interviewed were aware of the grievance processes available to them. Most indicated that they would report to their boss, HR or the Works Council if they wanted to complain or raise an issue. "]
["14. Environmental Risk Management","FM","We saw evidence of the current ISO14001 certificate which expires on 2025-08-18.The most recent audit was conducted in Nov 2023 and there were no non-conformances raised. \nThe housekeeping at the site was to a high standard which is indicative of good environmental management.",null,null,null,"Key Documents viewed \nISO 14001 reports\nISO14001 Certificate"]
["15. Greenhouse Gas (GHG) Emissions","FM","Scope 1 emissions are quantified, third party verified and reported using methodology of the European Union emissions Trading System (EUETS) GHG Protocol. Aurubis also reports Greenhouse Gas Emissions through the Carbon Disclosure Project. The Scope 2 emissions are reported on the basis of a market-based approach which considers grid factors in the indirect energy mix. \n\nAurubis group wide has made a commitment to 50% reduction of Scope 1 & 2 emissions and 24% reduction of Scope 3 emissions by 2030 based on a 2018 baseline. These targets are validated by the Science Based Targets Initiative (SBTi).  Aurubis is also a signatory to the Business Ambition for 1.5⁰C. Aurubis has also produced a TCFD report, which summarises climate related risks (including for Germany) and carbon reduction projects past and planned (including for Germany).\n\nAurubis Stolberg has in place a decarbonization road map, a key basis for which is to convert current natural gas usage to electrical and then transition to a renewables power purchase agreement for scope 2.",null,null,null,"Key Documents viewed \nISO50001 report\nCDP Climate Change questionnaire\nDecarbonisation Road Map"]
["16. Energy Consumption","FM","Aurubis Stolberg has an energy management system certified to ISO50000. The most recent audit and report in 2023 raised no non-conformances. We saw evidence of the current certificate which expires in 2025-08-18.\n\nTotal energy consumed and energy efficiency per tonne of production is quantified. \n\nThere is a detailed energy review report for years 2022 -2023, which demonstrates an active energy efficiency and carbon reduction programme with several prioritised programmes in place.  ",null,null,null,"Key Documents viewed \nISO50001 report\nISO5001 Certificate\nEnergy review report"]
["17. Freshwater Management and Conservation","FM","Stolberg water management system is covered by the ISO14001 EMS which is audited annually. Aurubis Stolberg is not in a water constrained area, so water supply risks are low. \n\nThe water supply and water balance circuit is shared with the adjacent Prym operation (There is a historical context as this was originally all one company). Make up water is taken from the adjacent river under an extract permit. There is zero discharge back to the river. All process water effluents go to a WWTP operated by Prym. Some water is recirculated, and any discharges are made into the municipal wastewater system. The system is balanced through a closed reservoir.  All surface water at the site is collected in a closed drain system and passed through a separator prior to discharge into the reservoir. \n\nThe whole valley was severely affected by a heavy rainfall flood in 2022, which caused the plant to shut down. Flood control measures have subsequently been put in place.",null,null,null,"Key Documents viewed \nISO14001 report\nWater balance diagram"]
["18. Waste Management","FM","Waste management is heavily regulated and is also covered and audited under the ISO14001 system.\n\nAll waste streams are measured and monitored. Performance monitoring also includes an efficiency KPI (waste per tonne of product), and this is used as a basis for identifying waste reduction opportunities. Most waste streams are identified for re-use or recycling and go to specialist companies as ‘secondary raw material’ so there is limited opportunity for further reduction.",null,null,null,"Key Documents viewed \nISO 14001 report\nWaste stream spread sheet\nWaste efficiency data\n\nSite Observations\nWaste was clearly seen to be segregated and stored on site"]
["19. Tailings Management","NA"]
["20. Pollution","FM","Pollution control is  is managed through by ISO14001. There are no emissions of heavy metals. All emissions are regulated by the setting of emission limits, and these are monitored and signed off by the regulators. There have been no exceedances recorded in recent years. Pollution controls include bag filters on the foundry extract fans. \n\nThere is an historic ground water contamination issue. There is a remediation plan in place to contain and clean this, comprising three extraction wells which pump water through an oily water separator and discharged under permit. ",null,null,null,"Key Documents viewed \nISO14001 Report\nMonitoring results\nRegulators sign off documentation\nGround water discharge permits\n\nExternal Stakeholder Interviews \nCommunity and regulator feedback for Stolberg were positive in relation to pollution issues."]
["21. Biodiversity and Protected Areas","FM","Due to the relatively low footprint of the Stolberg operations no impact on biodiversity has been identified. There is a requirement that for any new development an evaluation is required, and this considers biodiversity impacts. The most recent development was the introduction of LPG storage. The evaluation for this concluded that while there are areas of interest close to the operation there is no expected impact. ",null,null,null,"Key Documents viewed \nApplication for LPG plant biodiversity evaluation"]
["22. Mine Closure and Reclamation","NA"]
["23. Community Health and Safety","FM","Policy and management related to community health and safety is achieved through the environmental management system and the legal compliance system, which involve significant engagement with relevant regulators and through the stakeholder engagement programme.\n\nAs discussed under CM20 Pollution the impact footprint of this operation is relatively small. There are no known community health and safety risks associated with the operation and there have been no related community complaints.\n\nThe site is on a busy road and there is a project with local industry and the municipality to improve safety, although this is a general local issue not attributed to Aurubis. ",null,null,null,"Key Documents viewed \nISO14001 Report\nMonitoring results\nRegulators sign off documentation\n\nExternal Stakeholder Interviews \nThe mayor who represents the community, spoke highly of the relationship with Aurubis and their engagement with the community. He said that there had never been a problem with Aurubis during his tenure (5 years). His main interest on health was the promotion of health and welfare in the community and he confirmed that Aurubis were active in this area."]
["24. Community Development","FM","This topic is driven by the Group Social engagement Policy. The Stolberg facility is hosted within a mature economy, where basic public needs such as housing, education, clean water, food and employment are largely met.  As such there is minimal imbalance between the general community and the Stolberg facility and its employees that would lead to social risk and require direct investment.  As such the company is involved in voluntary initiatives with the community has a charitable giving program rather than a socio-economic development strategy. \n\nRecords provided by Stolberg indicate small contributions/sponsorships in 2023 for a range of local activities",null,null,null,"Key Documents viewed \nGroup Social engagement Policy\nSummary of community expenditure in 2023\nTogether towards a sustainable future\nCommitment to Clever Mobile project\n\nExternal Stakeholder Interviews \nThe mayor who represents the community, spoke highly of the relationship with Aurubis and their engagement with the community. He said that there had never been a problem with Aurubis during his tenure (5 years). He confirmed that Aurubis were actively involved and responsive in the community."]
["25. Artisanal and Small-Scale Mining","NA"]
["26. Human Rights","FM","Aurubis has publicly committed to following the UN Guiding Principles and the UN Global Compact. The requirements for these are reflected in the Code of Conduct and the Business Partner Code of Conduct, with specific language relating to human rights in the workplace and in the supply chain. \n\nWhile human rights related risks are not specifically mentioned in the corporate or site level risk evaluations, there is evidence that management arrangements exist for control of specific human rights issues in the workplace (see observations for CM5 to CM13 above) and that due diligence is carried in the supply chain (see CM4 and CM31 above).\n\nGrievance procedures are in place to collect human rights related grievances and non were recorded in 2023.",null,null,null,"Key Documents viewed \nCode of Conduct\nBusiness Partner Code of Conduct\nHuman Rights Commitment"]
["27. Security and Human Rights","NA"]
["28. Indigenous Peoples Rights","NA"]
["29. Land Acquisition and Resettlement","NA"]
["30. Cultural Heritage","FM","Stolberg is considered to be a copper town and its culture and history were built around this. So, the Stolberg plant is considered part of the culture in this respect. In terms of the operational impact on cultural heritage this is considered not to be a risk.\n\nStolberg has made some small contributions to the local museum, which catalogues the copper history in the region.",null,null,null,"Key Documents viewed \nPhotographs of local museum copper industry displays"]
["31. Due Diligence in Mineral Supply Chains","FM","see under JDD below",null,null,null,"\"Key Documents viewed \nBusiness Partner Code of Conduct\nBusiness Partner Supply Chain Screening Process - selected evidence on on-line end to end business partner screening process. \nCorporate Responsible Sourcing Policy General Terms and Conditions of Purchase\nOverview direct metal suppliers to Aurubis Stolberg - Status of business partner screening\"\t\t"]
["32. Transparency and Disclosure ","FM","Aurubis Stolberg reporting is incorporated into the corporate reporting programme. There are several public reports covering ESG performance reporting including:\n•\tSince 2002 and annual Environmental Report \n•\tSince 2003 every two years a Sustainability report according to GRI. KPI updates are annual\n•\tSince 2015 CDP participation and report\n•\tSince 2017 an annual Non-financial report, which incorporates the Step 5 reporting.\n•\tTCFD report ",null,null,null,"Annual Environmental Report 2022 \nSustainability report according to GRI. \nKPI updates 2022\nCDP participation and report 2022\nNon-financial report, which incorporates the Step 5 reporting 2022\nTCFD report"]
[]
["Joint Due Diligence Standard for Copper, Lead, Molybdenum, Nickel and Zinc"]
["1. Due Diligence Management System","FM","There is a group wide governance structure for responsible sourcing. There is evidence both at corporate and site level of responsible sourcing being an integral part of business management. Resources provided by the company to support the implementation of the policy and management system are appropriate and proportional to its size, location and circumstances. The company's senior management ensures continual improvement of the management system. The due diligence management system includes a process for continuous improvement.  Supplier engagement activities are undertaken by the company to support suppliers in building capacity on the company's policy and its practical application.",null,null,null,"Key Documents viewed \nBusiness Partner Code of Conduct\nBusiness Partner Supply Chain Screening Process - selected evidence on on-line end to end business partner screening process. \nCorporate Responsible Sourcing Policy General Terms and Conditions of Purchase\nOverview direct metal suppliers to Aurubis Stolberg - Status of business partner screening"]
["2. Risk Identification","FM","The information collected by the company is sufficient to identify red flags. The Business Partner Screening Tool facilitates several essential steps, including intake and risk profiling, risk assessment, control assessment, findings management, and continuous monitoring. To minimize the risk of manual errors, an interface has been integrated between the SAP system and the Business Partner Screening Tool. Being a fabricator Aurubis Stolberg does not source direct primary materials but does source via smelters and recyclers and through traders and the Aurubis group responsible sourcing system identifies these and applies risk identification and management. The company makes reasonable efforts to identify potential red flag locations of material origin and transit and/or supplier red flags in these upstream supply chains. ",null,null,null,"See above"]
["3. Risk Assessment","FM","There is evidence of risk management plans for Aurubis suppliers. There is evidence of ongoing engagement with Stolberg suppliers.",null,null,null,"See above"]
["4. Risk Management","FM","There is evidence of risk management plans for Aurubis suppliers. There is evidence of ongoing engagement with Stolberg suppliers.",null,null,null,"See above"]
["5. Public Reporting","FM","Aurubis reports publicly in accordance with Step 5 requirements in the 2023 Sustainability Report. https://www.aurubis.com/en/responsibility/environment-energy-and-climate/reporting-kpis-and-esg-ratings",null,null,null,"See above"]

{"sheet":"Dropdownlists","index":1,"n_rows":48,"n_cols":16,"rows_kept":48,"cut":false,"hidden":true,"merged":[]}
["Standards","Performance Determination","Statement of Conformance","Award","Principle covered metals","Other metals","Metals in scope of mineral due diligence","All products","Principle covered metal products - copper","Principle covered metal products - lead","Principle covered metal products - nickel","Principle covered metal products - zinc","Principle covered metal products - moly","Operating activities","Infrastructure","Equivalency"]
["Criteria for Responsible Production / Risk Readiness Assessment","NA","The site is found to fully meet all applicable criteria","The Copper Mark","Copper","Antimony","Antimony","Copper Concentrate","Copper Concentrate","Lead Concentrate","Nickel Concentrate","Zinc concentrate","Unroasted Molybdenite Concentrate","Mining","Roads","ASI Performance Standard"]
["Joint Due Diligence Standard for Copper, Lead, Molybdenum, Nickel, and Zinc","DNM","The site is found to fully or partially meet all applicable criteria, and has committed to continuous improvement to fully meet all applicable criteria within the time prescribed by the Assurance Process.","The Molybdenum Mark","Lead","Bismuth ","Bismuth ","Copper Anode","Copper Anode","Lead Bullion","Nickel Matte","Waelz oxide/Crude Zinc Oxide","Pure Molybdenum DiSulfide Lubricant Grade Molybdenum","Concentrating","Rails","ICMM Performance Expectations"]
["Chain of Custody Standard","PM","The site is found to miss some or all applicable criteria, but has committed to continuous improvement to fully meet all applicable criteria within the time prescribed by the Assurance Process.","The Nickel Mark","Molybdenum","Cadmium","Cadmium","Copper Cathode","Copper Cathode","Lead Alloy","Nickel Mixed Sulphide / hydroxide","Special high grade zinc","Roasted Molybdenite Concentrate / Roasted Molybdenum Concentrate/ Technical Grade Molybdenum Oxide in Powder or Briquettes","Blending","Ports","IFC Performance Standards"]
[null,"FM","The site is found to miss some or all applicable criteria, and has not committed to continuous improvement to fully meet all applicable criteria within the times prescribed by the Assurance Process.","The Zinc Mark","Nickel","Cobalt","Cobalt","Copper Wire","Copper Wire","Lead Ingot","Ni chemical","Zinc alloys","Ferromolybdenum","Electrowinning and solvent extraction","Other","IRMA Standard for Responsible Mining"]
[null,null,null,"Chain of Custody","Zinc","Gallium","Copper","Copper Wire Rod","Copper Wire Rod",null,"Ni metall","Zinc oxide","Chemical Grade Molybdenum Products (Ammonium Heptamolybdate, Ammonium Octamolybdate, Ammonium Dimolybdate, Calcined Pure Molybdic Oxide, Sublimed Pure Molybdic Oxide, Sodium Molybdate)","Roasting / conversion / smelting",null,"ISO 14001"]
[null,null,null,null,null,"Germanium","Gallium","Xopper Rod","Xopper Rod",null,"Nickel Oxide sinter","Zinc sulfate","Pure molybdenum metal in Powder or Briquette form","Refining",null,"ISO 45001"]
[null,null,null,null,null,"Gold","Germanium","Copper Bar","Copper Bar",null,"Ferronickel","Other zinc compounds",null,"Manufacturing",null,"LBMA Responsible Gold Guidance"]
[null,null,null,null,null,"Indium","Gold","Copper ections","Copper ections",null,"Nickel pig iron","Zinc sheet",null,"Recyclng",null,"LBMA Responsible Silver Guidance"]
[null,null,null,null,null,"Iridium","Indium","Copper Plate","Copper Plate",null,"NiSO4","Zinc die castings",null,"Other",null,"MAC Toward Sustainable Mining"]
[null,null,null,null,null,"Iron","Iridium","Copper Sheet","Copper Sheet",null,null,"Sulfuric acid"]
[null,null,null,null,null,"Osmium","Iron","Copper Strip","Copper Strip",null,null,"Lead"]
[null,null,null,null,null,"Palladium","Lead","Copper Tube","Copper Tube",null,null,"Silver"]
[null,null,null,null,null,"Platinum","Molybdenum","Lead Concentrate",null,null,null,"Cadmium"]
[null,null,null,null,null,"Rhenium","Nickel","Lead Bullion",null,null,null,"Copper-cementate"]
[null,null,null,null,null,"Rhodium","Osmium","Lead Alloy",null,null,null,"Indium"]
[null,null,null,null,null,"Ruthenium","Palladium","Lead Ingot",null,null,null,"Germanium"]
[null,null,null,null,null,"Selenium","Platinum","Unroasted Molybdenite Concentrate"]
[null,null,null,null,null,"Silver","Rhenium","Pure Molybdenum DiSulfide Lubricant Grade Molybdenum"]
[null,null,null,null,null,"Tellurium","Rhodium","Roasted Molybdenite Concentrate / Roasted Molybdenum Concentrate/ Technical Grade Molybdenum Oxide in Powder or Briquettes"]
[null,null,null,null,null,"Tin","Ruthenium","Ferromolybdenum"]
[null,null,null,null,null,"Tungsten","Selenium","Chemical Grade Molybdenum Products (Ammonium Heptamolybdate, Ammonium Octamolybdate, Ammonium Dimolybdate, Calcined Pure Molybdic Oxide, Sublimed Pure Molybdic Oxide, Sodium Molybdate)"]
[null,null,null,null,null,"Other","Silver","Pure molybdenum metal in Powder or Briquette form"]
[null,null,null,null,null,null,"Tellurium","Nickel Concentrate"]
[null,null,null,null,null,null,"Tin","Nickel Matte"]
[null,null,null,null,null,null,"Tungsten","Nickel Mixed Sulphide / hydroxide"]
[null,null,null,null,null,null,"Zinc","Ni chemical"]
[null,null,null,null,null,null,"Other","Ni metall"]
[null,null,null,null,null,null,null,"Nickel Oxide sinter"]
[null,null,null,null,null,null,null,"Ferronickel"]
[null,null,null,null,null,null,null,"Nickel pig iron"]
[null,null,null,null,null,null,null,"NiSO4"]
[null,null,null,null,null,null,null,"Zinc concentrate"]
[null,null,null,null,null,null,null,"Waelz oxide/Crude Zinc Oxide"]
[null,null,null,null,null,null,null,"Special high grade zinc"]
[null,null,null,null,null,null,null,"Zinc alloys"]
[null,null,null,null,null,null,null,"Zinc oxide"]
[null,null,null,null,null,null,null,"Zinc sulfate"]
[null,null,null,null,null,null,null,"Other zinc compounds"]
[null,null,null,null,null,null,null,"Zinc sheet"]
[null,null,null,null,null,null,null,"Zinc die castings"]
[null,null,null,null,null,null,null,"Sulfuric acid"]
[null,null,null,null,null,null,null,"Lead"]
[null,null,null,null,null,null,null,"Silver"]
[null,null,null,null,null,null,null,"Cadmium"]
[null,null,null,null,null,null,null,"Copper-cementate"]
[null,null,null,null,null,null,null,"Indium"]
[null,null,null,null,null,null,null,"Germanium"]