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[]
[]
[]
[]
[]
["Participant information"]
["Name of the site",null,null,null,"Aurubis Beerse N.V."]
["Unique identifier provided by the Copper Mark",null,null,null,"P0091"]
["Address",null,null,null,"Nieuwe Dreef 33, Beerse, Antwerpen 2340"]
["Country of operation",null,null,null,"Belgium"]
["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","FM ","10. Working Hours",{"$f":"B96","v":"FM"},"19. Tailings Management",{"$f":"B105","v":"NA"},"28. Indigenous Peoples Rights",{"$f":"B114","v":"NA"}]
["2. Business Integrity",{"$f":"B88","v":"FM"},"11. Remuneration",{"$f":"B97","v":"FM"},"20. Pollution",{"$f":"B106","v":"FM"},"29. Land Acquisition and Resettlement",{"$f":"B115","v":"NA"}]
["3. Stakeholder Engagement","FM","12. Occupational Health and Safety",{"$f":"B98","v":"FM"},"21. Biodiversity and Protected Areas","FM","30. Cultural Heritage","NA"]
["4. Business Partners","FM","13. Employee Grievance Mechanism","FM","22. Mine Closure and Reclamation","NA","31. Due Diligence in Mineral Supply Chains","PM"]
["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",{"$f":"B121","v":"FM"},"2. Risk Identification",{"$f":"B122","v":"FM"},"3. Risk Assessment",{"$f":"B123","v":"NA"},"4. Risk Management",{"$f":"B124","v":"NA"}]
["5. Public Reporting",{"$f":"B125","v":"PM"}]
[]
["Chain of Custody Standard"]
["1. Management System for Material Control",{"$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 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."]
[]
["Award(s)"]
["Valid from",null,"2024-09-16",null,"Valid until","2027-09-15"]
["The Copper Mark"]
["The Nickel Mark"]
["The Zinc Mark"]
[]
["Scope of the assessment"]
["Principle covered metals",null,null,"Copper",null,"Zinc"]
[null,null,null,"Lead",null,"Nickel"]
["Principle covered metal products",null,null,"Copper Anode"]
[null,null,null,"Copper Cathode"]
[]
[null,null,null,"Other:"]
["Other metals in scope",null,null,"Tin"]
[]
[]
[null,null,null,"Other:"]
["Metals in scope of minerals due diligence",null,null,"Copper",null,"Lead"]
[null,null,null,"Zinc",null,"Tin"]
[null,null,null,"Nickel"]
[null,null,null,"Other:"]
["Operating activities",null,null,"Refining"]
[null,null,null,"Roasting / conversion / smelting"]
[null,null,null,"Other:"]
["Infrastructure"]
[null,null,null,"Other:"]
["About the participant",null,null,"Aurubis Beerse N.V. was founded in 1919 as ‘La Metallo-Chimique N.V.’. By 1923 it was processing a wide variety of raw materials ranging from copper trouser-studs to foundry and factory grindings. In the sixties a process was developed to recycle copper, tin and lead out of more complex raw materials. Today, Aurubis excels in recycling and refining non-ferrous materials. \nThe auditee reported 450 permanent employees incl. temporary agency workers and 60 contractors."]
[]
["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 14001","2024-12-01",null,"The assurance / certification was confirmed to be: In conformance\n•\tValid at the time of the review\n•\tNo more than 24 months old and / or plans for reassessment are underway\n•\tIn effect for an additional 12 months and / or plans for reassessment are underway\n•\tCovering the same scope as the Copper Mark Responsible Production Criteria, including operations, locations, and materials\n•\tAccompanied by improvement plans where applicable",null,null,null,"14, 16, 18, 20, 21"]
["ISO 45001","6 April 2025",null,"The assurance / certification was confirmed to be: In conformance\n•\tValid at the time of the review\n•\tNo more than 24 months old and / or plans for reassessment are underway\n•\tIn effect for an additional 12 months and / or plans for reassessment are underway\n•\tCovering the same scope as the Copper Mark Responsible Production Criteria, including operations, locations, and materials\n•\tAccompanied by improvement plans where applicable",null,null,null,12]
[]
["Independent site assessment"]
["Name of lead assessor",null,null,null,"Biljana Vulin-Wunderlich (Criteria 1-30 and 32), Kaido Katalsepp (Criteria 31)"]
["Name of assessment firm",null,null,null,"Arche Advisors"]
["Date(s) of assessment",null,null,null,"18 - 20 June 2024"]
["Assessment period",null,null,null,"01 June 2023 - 31 May 2024"]
["Summary of assessment methodology",null,null,null,"The assessment was conducted in line with all requirements defined in The Copper Mark Assurance Process v.5 dated 19 October 2023, and  ISO 19001:2018 Guidelines for Auditing Management Systems. The assessment activities were risk based with focus on material issues and involved the site tour, interviews, document reviews and cross-referencing information sources to evaluate each criterion. The assessors interviewed 20 employees, including both direct and indirect workers, as well as contractors, 4 work council members, 4 union representatives and 3 external stakeholder representatives. The sampled workers represented various areas, such as production plants, warehouses, services, and administrative roles. "]
["Summary of assessment activities",null,null,null,"Pre-arrival activities: \n- Desktop review of submitted documents and two clarification calls with Aurubis team \n\nOnsite assessment activities:\nThe assessment started with an opening meeting with the site management. The assessors conducted a site tour, management interviews, interviews with workers (employees and contractors) from production and logistics, work council and union representatives, and external stakeholders. Review of evidences related to all requirements was carried out onsite and post-audit. A closing meeting was conducted with the site management at the end of the assessment process. "]
["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","Aurubis Beerse N.V. has a Compliance Management System  (CMS) in place maintained by the Corporate Compliance. The CMS refers to national and international regulations and is documented in the Corporate Compliance Policy covering responsibilities, risk analysis and audits, program, communication and consultation, grievance mechanism, and improvement and monitoring. The Aurubis Compliance Program is based on the Code of Conduct (https://aurubis.com/en/downloads/aurubis-code-of-conduct), the Corporate Compliance Policy and other corporate policies. The Chief Compliance Officer is the central contact person for all compliance-relevant issues and reports directly to the entire Executive Board. At the site level, the Managing Director has the responsibility for implementation of the CMS,  supported by a team of Local Compliance Representatives (LCRs) from the areas of law, sustainability, HR, and risk management to support Corporate Compliance in monitoring and implementing compliance measures, regulations, and training at the site level. External ISO and internal audits are conducted periodically to review fulfillment of legal requirements and internal policies in day-to-day business. This was confirmed through interviews with management; and a review of documents including the compliance policy, relevant job descriptions, the Non Financial Report FY 2022-23 and the Sustainability Report 2023 (https://aurubis.com/en/responsibility/environment-energy-and-climate/reporting-kpis-and-esg-ratings). ",null,null,null,"Data point 1: The company has implemented different policies and procedures that establish the commitment to comply with all applicable laws and regulations, including the Occupational safety/industrial safety law, Labor law/non-discrimination law, Criminal law on corruption/conflicts of interest (see separate policy), EU/US anti-trust law (see separate policies), Business partner selection (separate policy), Foreign trade legislation, Insider law (separate policy), Data privacy law, Accounting law, Tax law, Money laundering (separate policy), Environmental law, Hazardous goods transport law/load restraint law, Regulations in corporate policies and relevant company policies. \nData point 2: Review of the Non-Financial Report FY 2022-23 and the Sustainability Report 2023 reveals the topics identified as material are employee related matters, environmental matters, social matters, Human rights, Anti-corruption and additional material aspects like IT Security. The auditee establishes the commitment to comply with all applicable laws, regulations, and standards of the countries in which they operate. \nData point 3: The auditee maintains a legal matrix including laws and regulations related to environmental, health and safety and labor.   \nData point 4: Records review of procedures and records confirms the auditee maintains a registry of health, safety, and environmental licenses and permits necessary for operation, including legal references, validity periods, renewal timeframes, and current statuses. \nData point 5: Management interviews confirm Local Compliance Representatives have the expertise, accountability and duty to identify, assess, monitor and implement laws and updates in laws in their competencies.   \nData point 6: The auditee has a subscription for legal updates service and external legal advisory.\nData point 7: Review of the audit calendar for 3 years and the audit reports confirm the last ISO 14001 and 45001 audits were conducted on 27 and 28 May 2024. Regular internal audits on QHSE are conducted by the internal auditor team.\nData point 8: Employee interviews confirm they have received legal labor and HSE information during orientation. "]
["2. Business Integrity","FM","Aurubis Beerse N.V. has implemented policies, systems and practices to uphold business integrity, supervised by dedicated Local Compliance Representatives. Based on the Corporate Anti-Corruption Compliance Policy neither corruption nor bribery nor facility payments are tolerated under no circumstances. This applies to company’s own employees and to all business partners. The Group Compliance Policy – Antitrust Law (EU) sets standards for observance of antitrust regulations.  \nBoth compliance systems are reinforced by training programs and an anonymous whistle-blowing hotline. In the reporting period, no complaints regarding business integrity were reported. This was verified through management interviews and a review of documents, including the code of conduct, business partner code of conduct, compliance anti-corruption policy, antitrust policy, and training records. A Group wide campaign has been introduced to promote a speak-up culture. Employees can use the externally managed Whistleblower channel (https://www.ombudservice.de/en/osr-hinweisgeber-formular), implemented in 2022, to report any violations of law or and company policies, or to speak to the Local Compliance Representatives or Worker Committee.",null,"              ",null,"Data point 1: Records review of the Group Compliance Policy - Antitrust Law (EU) (Date: February 1, 2020), Corporate Anti-Corruption Compliance Policy (Date: December 8, 2021), and Code of Conduct (Date: February 2022) reveals the auditee establishes the provisions of countering corruption and bribery, conflict of interest, insider dealing, trade, tax and customs regulations, combating money laundering, proper accounting and documentation, and handling company resources. \nData point 2: Review of the Business Partner Code of Conduct (Date: January 2022) reveals the auditee sets expectations regarding anti-corruption, fair competition, conflicts of interests, money laundering, taxes, fees and royalties and confidential and proprietary information. \nData point 3: Review of training records confirm the auditee provides online training on the Business Integrity to employees during orientation and on annual basis.\nData point 4: Management interview with Local Compliance Representatives confirms the above. \nData point 5: Worker interviews confirm employees are aware of Code of Conduct and Policy on Anti-Corruption. Employees interviewed confirm to receive a copy of the Code of Conduct. Employees can describe the process to report instances of violation of the ethics principles. \nData point 6: The auditee has implemented a grievance mechanism and Whistleblower Hotline available on https://www.ombudservice.de/en/osr-hinweisgeber-formular."]
["3. Stakeholder Engagement","FM","Aurubis Beerse N.V. has implemented a stakeholder engagement policy that establishes the commitment to engage with identified stakeholders. The auditee carries out stakeholder mapping, engagement and communication. Key stakeholders include external stakeholders (such as local and national government bodies such as waste and environmental authorities, international metal associations, NGOs, local fire brigade, local community, suppliers of raw material and suppliers of other products and services) and internal stakeholders (Unions representatives, works council, committee for safety on the work floor). A number of activities are conducted in order to exchange information with stakeholders in different forms of dialogue (in conversations, meetings, at forums and events, and as part of permit processes and environmental impact assessments). There is a complaints mechanism aligned with UN Guiding Principles’ Effectiveness Criteria for Non-Judicial Grievance Mechanisms and available for internal and external stakeholders.\n\nInformation on Whistleblower Hotline and the Reporting and investigation procedure can be downloaded here: \nhttps://www.aurubis.com/en/responsibility/whistleblower-hotline\n\nhttps://www.aurubis.com/en/dam/jcr:f621b24f-856e-4f41-9479-60c393aad7fd/Reporting%20and%20investigation%20procedure%20Whistleblowing_01_2023_EN_US.pdf\n\nThis is confirmed through review of grievance procedure, whistleblower hotline and interviews with management, employees and external stakeholders. The formal grievance process is run by an independent ombudsman and managed by Aurubis corporate. Interviews with external stakeholders from local fire brigade, local environmental authority and neighborhood confirm that the auditee effectively collaborates with local organizations and is responsive and supportive of their needs.\n",null,null,null,"Data point 1: Review of the Sustainability Report 2023 confirms the auditee has established the commitment to engage with identified stakeholders. \nData point 2: Review of Stakeholder Mapping overview confirms, the auditee has mapped stakeholders in its area of influence including local and national government bodies, trade associations, NGOs, local fire brigade, local community, suppliers of raw material and suppliers of other products and services) and internal stakeholders (Unions representatives, works council, committee for safety on the work floor).\nData point 3: The Sustainability Policy (Date: 07 December 2021) indicates \"Health, Well-being, Safety and Environment are an integral part of our strategic objectives and activities. Compliance with laws and regulations is considered as a minimum requirement.... In our projects, we use high technological standards in terms of HWSE and take into account the wellbeing of our employees, the environment and our neighbors, with whom we value a good relationship.\"\nData point 4: Terms of Reference – Communications (Steerco Comms) (not dated) indicates the auditee has a written procedure for communication with stakeholders. \nData point 5: There is a public grievance mechanism available on the company’s website for stakeholders internally and externally to raise concerns of company’s impacts and concerns.\nData point 6: Interviews with external stakeholders (local fire brigade, local environmental authority and neighborhood confirm that the auditee effectively collaborates with local organizations and is responsive and supportive of their needs.\nData point 7: Based on management interview, stakeholders and community engagement and community activities are performed by the department of sustainability, environmental, health and safety. \nData point 8: Stakeholder interviews conducted by the assessors confirmed that the auditee's engagement activities are effective. Stakeholders acknowledged the support and awareness activities implemented by the auditee and confirmed they are aware of the grievance mechanism for reporting complaints and suggestions."]
["4. Business Partners","FM","Aurubis Beerse N.V. has a management system in place to promote responsible business practices with business partners including suppliers. All suppliers are required to formally accept the Business Partner Code of Conduct. The auditee has rolled out the Aurubis Business Partner Screening program that is based on OECD guidelines to screen suppliers and contractors before onboarding. The screening process has been implemented to identify, manage, and monitor risks associated with engaging business partners. Prior to contracting and conducting business with a new business partner, suppliers must go through the screening process to be assessed against ESG, Compliance, Financial and Tax risk considerations. The auditee uses a data driven IT tool (BPS tool) to screen new suppliers based on country and sector specific risks including human rights, occupational safety, environmental and business integrity risks. While low-risk suppliers undergo standardized assessments through automated checks and external data sources, suppliers with potential medium, enhanced or high risk score are requested to provide information on their ESG performance through specific questionnaires related to the risk profile. The screening currently applies to contracts above a certain value. \n\nOnce onboarded, suppliers and contractors must follow contract clauses that include Aurubis policies and the Business Partner Code of Conduct which covers ESG requirements. Site management handles day-to-day contractor management, including self-assessments, scoring systems, and annual audits. ",null,null,null,"Data point 1: The Aurubis Business Partner Code of Conduct (Date: January 2022) outlines the requirements regarding labor standards, respect for human rights, health and safety, environmental and climate protection, business integrity and responsible raw material sourcing, as well as reporting procedures and the monitoring of the business partner’s due diligence obligation. It is available to business partners in eleven languages.\nData point 2: The Corporate Responsible Sourcing Policy Version: 1.1 (Date: 01 August 2023) describes the management system for responsible sourcing of material (primary and recycling), goods and services. The Corporate Responsible Sourcing Policy \"summarizes the group Group-wide sourcing rules and ensures a uniform, risk-oriented supplier identity / integrity and supply chain screening process which is based on and aligned with the five-step framework of the OECD Due Diligence Guidance of Minerals from Conflict-Affected and High-Risk-Areas, the Joint Due Diligence Standard for Copper, Lead, Nickel and Zinc of The Copper Mark, the EU Conflict Minerals Regulation 2017/821, the LBMA Responsible Gold and Silver Guidance, the Responsible Minerals Assurance Process (RMAP) Tin and Tantalum Standard, and the German Supply Chain Due Diligence Act.\"\nData point 3: The corporate Business Partner and Supply Chain Screening Process Description (Date: August 2023) indicates that all screening activities are completed in a supporting technology platform, Schumann platform ('BPS Tool').\nData point 4: Management interview confirms the auditee uses a standardized category and country risk methodology (Löning) to identify low, medium, enhanced and high risk suppliers based on category and country risks.    \nData point 5: Based on review of the country risk register (\"Supplier Screening Country Risk 2023_All sites_Rev3) 3833 suppliers have been screened against an overarching country risk methodology (Löning) . \nData point 6: Records review of sampled suppliers confirm the effectiveness of the company risk assessment methodology. \nData point 7: Based on management interview and review of Supplier Self-Assessment Questionnaire, suppliers are requested to provide evidences for ESG performance. "]
["5. Child Labor","FM","The auditee has corporate and site level policies in place prohibiting use of child labor. Corporate policies are included in the Code of Conduct, Business Partner Code of Conduct and Corporate Responsible Sourcing Policy, which follow ILO labor standards. On site level, Aurubis Beerse N.V. sets a minimum age of 18 for all of their operations. Procedures are in place to check employee ages. This was confirmed through management interviews, site observations, and document reviews. No children were identified during the site tour. ",null,null,null,"Data point 1: Based on the Code of Conduct the auditee rejects child labor. \nData point 2: Based on Business Partners Code of Conduct the auditee establishes the prohibition of child labor.\nData point 3: Based on the Corporate Responsible Sourcing Policy \"child labor and the worst forms of child labor are not tolerated by Aurubis in any kind. The age of the employee shall not be less than 15 years or where permitted by applicable local law in accordance with Article 2 (4) and Articles 4 to 8 of Convention No. 138 of the International Labor Organization of 26 June 1973 concerning Minimum Age for Admission of Employment, not less than 14 years.\"\nData point 4: Records review of a Job posting for a student job in maintenance / electrician department confirms the minimum age for applicants is 18 years old.  \nData point 5: During the onsite assessment, no underage employees were found at the facility. \nData point 6: Employee files, which include proof of age documents, were reviewed and confirmed. \nData point 7: Management interviews indicated that the company has an effective system to prevent child labor and has communicated these requirements to their business partners. \nData point 8: Interviews with workers also confirmed that no child labor practices have been observed at the facility."]
["6. Forced Labor","FM","Aurubis Beerse N.V. has a corporate level commitment against forced labor as stated in the Code of Conduct, Business Partner Code of Conduct, and corporate policies, including a commitment to incorporate the United Nations Guiding Principles on Business and Human Rights into working conditions, recruitment, communication, and supply chain management. These policies are implemented at operation site through specific procedures an training on forced labor and hiring practices as well as Code of Conduct trainings for employees and suppliers.  Interviews with workers confirmed that no hiring fees are paid, ID cards are not withheld, movement is not restricted, and workers can refuse dangerous or overtime work. Documents and records also confirmed these practices.\n",null,null,null,"Data point 1: Based on the Code of Conduct \"Aurubis does not tolerate forced labor\". \nData point 2: Based on Business Partners Code of Conduct \"Business partners shall not utilize, be involved in, or obtain an advantage from any forced or compulsory labor. Business partners shall ensure that all work is voluntary.\"\nData point 3: Based on the Corporate Responsible Sourcing Policy, \"Aurubis does not tolerate any forms of forced or compulsory labor in its supply chains, which means work or service which is exacted from any person under the menace of penalty, and for which said person has not offered themself voluntarily.\"\nData point 4: The Corporate Human Rights Policy for Own Business Operation (Date: 01 September 2023) describes the systems and practices Aurubis has in place at corporate and site level to managing human rights risks, including forced labor risks, in own business operations.\nData point 5: Records review of the Collective Bargain Agreement confirms policy is in place that establishes the freely chosen employment, and overtime to be conducted on voluntary basis.  \nData point 6: The observations from the site tour confirm there is no restriction to leave the premises at the time of their work shift.  \nData point 7: Management interview confirms the auditee has established an adequate and effective management system to avoid force labor practices in its operation. Management explains that the requirement of no force labor is established in the Code of Conduct and Business Partner Code of Conduct.  \nData point 8: Review of training records confirms all employees have received the Code of Conduct training in September 2023. \nData point 9: Worker interviews, including those with temporary and contract workers, confirmed that employment at the facility is voluntary. No hiring fees are required, no bonded labor is practiced, and original documents are not surrendered upon hire. Employees can resign without penalty. Employees confirmed they have received a copy of the Code of Conduct and that they have participated in the Code of Conduct training. Workers could explain the grievance procedure. "]
["7. Freedom of Association and Collective Bargaining","FM","Aurubis Beerse N.V. has a corporate level policy for freedom of association and collective bargaining. They are documented in the Code of Conduct and the Business Partner Code of Conduct and are aligned with ILO Conventions and the Belgian law. There are two unions on site. Additionally, a legally required works council is established through social elections that takes place every 4 years. All employees are covered by a Collective Bargaining Agreement (CBA) negotiated every two years. Interviews with representatives of both unions and with works council show there is a constructive relationship and open communication with management representatives. Meetings with management and with workers take place regularly and ad-hoc whenever needed. Results of meetings are documented and communicated to workforce either verbally, via screens in the canteens or on notice boards in the production area. Both union representatives and works councils confirm they are able to actively conduct their representation business with affiliates. However, some important management decisions are perceived as not being made quickly enough which has been noted as an opportunity for improvement. \n\n",null,null,null,"Data point 1: Based on the Code of Conduct, Aurubis commits to the core labor standards of the ILO, and OECD Guidelines for Multinational Enterprises. It is stated that \"Aurubis recognizes its employees' right to form, join, and be involved in unions and employee representative bodies within the context of national laws, collective wage agreements, and local customs.\" \nData point 2: Based on management interview workers can freely elect their union representatives. Last elections were on 14-16 May, 2024. \nData point 3: Review of CBA (valid until December 2024) confirms all employees are covered by the CBA where workers rights and obligations are defined. All employees have access to the content of the CBA.\nData point 4: Review of minutes of meeting with management confirm there are regular meetings of management and union / worker representative and they are all documented (Minutes of Action and Decision logs January, March, April, May 2024 with decisions, actions defined, timeline and comments). \nData point 5: Interview with union representatives and works council confirm the auditee does not restrict access to or interfere with employees’ efforts to organize or bargain collectively.\nData point 6: According to the interview with the workers they know who union representatives and works council are and what their role is. They are able to join a union without restriction, penalty or discrimination by the employer. \n"]
["8. Discrimination","FM","Aurubis has discrimination and harassment policies that are included in the Code of Conduct and the Business Partner Code of Conduct, and a corporate level Diversity Commitment. The company also has a public commitment to integrate the UN Guiding Principles into working conditions, recruitment, communications, leadership and business partners.\nAurubis Beerse N.V. implements these commitments through communication of Code of Conduct, trainings and awareness building campaigns. \nSystems and practices are in place to protect employees, including temporary agency workers and contractors, against discrimination and harassment when it comes to hiring, compensation, promotion or in interaction with others. Workers reported a generally harmonious and non-discriminatory working environment, with no grievances related to discrimination or harassment during the assessment period. \nThis is confirmed by a review of documents, training records, interviews with workers and their representatives, interviews with external stakeholders, interviews with management, and site observations.",null,null,null,"Data point 1: Based on Code of Conduct, Aurubis commits to the Ten Principles of the United Nations Global Compact which includes human rights and the core labor standards of the ILO. \nData point 2: Based on Business Partners Code of Conduct the auditee establishes the prohibition of discrimination and harassment. \nData point 3: Aurubis Human Rights Commitment (Date: March 2021) indicates that Aurubis follows the United Nations Guiding Principles on Business and Human Rights in accordance with the \"Protect, Respect and Remedy\" framework. \nData point 4: The Aurubis Diversity Commitment (Date: February 2023) supplements the topics covered in the Code of Conduct. It is stated that Aurubis is committed to the diversity of its employees. \"We aim to create a working environment free of discrimination, fear, and inhumane conditions.\" Every person at Aurubis should be able to live up to their full potential \"at our sites, with direct business partners and along the entire supply chain.\"  \nData point 5: A review of job advertisements confirms no personal characteristics are required for recruitment and hiring.\nData point 6: The job application process ensures equal opportunity for all applicants.\nData point 7: The grievance communication channel for internal and external stakeholders is publicly available on the company’s website and posted in various facility areas.\nData point 8: A wage compensation analysis confirms equal pay based on seniority, technical background, knowledge, and experience, with salaries agreed upon with unions and established in the Collective Bargaining Agreements.\nData point 9: Training on the prohibition of discrimination is provided during orientation and annually, as outlined in the Code of Conduct.\nData point 10: Management interviews confirm an effective process to prevent discrimination.\nData point 11: Employee interviews confirm no experiences of discrimination and awareness of discrimination policies, procedures, and grievance mechanisms.\n"]
["9. Gender Equality","FM","Aurubis Beerse N.V. has a corporate level policy on gender equality as part of the Code of Conduct and a formal commitment to integrate the UN Guiding Principles into working conditions, recruitment, communications, leadership and business partners. Additionally, the Aurubis Diversity Commitment supplements the topics covered in the Code of Conduct, with four central approaches to diversity: respect diversity both inside and outside of Aurubis, advocate for employee participation by every individual and at all levels, reject all forms of discrimination, all employees to contribute to a positive climate of diversity, appreciation and openness. \nProcedures and practices are in place to implement the commitments at site level, such as measures to contribute to corporate gender equality targets (e.g. increasing the proportion of female managers). For the Group as a whole, a target of 30% and 25% respectively has been set for the first and second management levels by the end of the 2025/26 fiscal year. Neither target has yet been met, with 26% in the first management level and 18% in the second management level. Concrete measures were launched to help meet these targets and continually improve Aurubis as a diverse company. The CBA ensures equal wages, benefits, bonus and promotion regardless of gender. Pregnant women are not employed in certain areas due to risks from lead and heat. \nAurubis Beerse N.V. participates in the Women4Metals initiative that focuses on increasing the visibility of women in the metal industry and attracting more women to the field. All employees can join the monthly Women4Metals lunch sessions. \nInterviews with women workers indicated they are comfortable with working conditions and do not experience gender-related bias. This was confirmed through interviews with management and workers, and a review of documents including the CBA, sustainability KPI update, human rights commitment, and maternity protection risk analysis.",null,null,null,"Data point 1: The Aurubis Code of Conduct includes a commitment to gender equality. \nData point 2: The Aurubis Diversity Commitment (Date: February 2023) supplements the topics covered in the Code of Conduct. It is stated that Aurubis is committed to the diversity of its employees.\nData point 3: Based on the review of the Pay Gap Report 2019-2021 pay gap evaluation on country level is conducted biennially (last one for 2022-2023), including a breakdown of workforce by gender, education, positions, seniority. Companies not compliant with the policy of equal pay for equal work have to implement a corrective action plan to eliminate the inequalities. \nData point 4: Disclosure of compensation of Executive Board and earning trends for employees in Aurubis Annual Report FY 2022_23 \nData point 5: Employee interviews confirm that they have been trained in the Code of Conduct and Diversity Policy."]
["10. Working Hours","FM","Aurubis has a policy on working hours included in the Code of Conduct and the Business Partners Code of Conduct in line with Belgian law and ILO Conventions. \nAurubis Beerse N.V. has a system to manage working hours, including overtime, breaks, rest days, and a time-tracking system. They follow the Collective Bargaining Agreement and Work Regulation for shift scheduling. There is a full continual shift regime in place with 36, 37,5, 39 or  40 regular hours/ week depending of department and shift. Overtime limits are also set by law and CBA, not to exceed an average of 38 hours weekly in a year. Overtime is limited to a certain number of hours and is voluntary. Hours are monitored through a time management system. \nDocument review and management interview confirm a management system is in place to ensuring employees' regular and overtime hours stay within legal limits, not exceeding sixty hours per week.\nEmployees confirmed their working hours, overtime, breaks, and rest days, and none worked more than 60 hours in a week. These practices where verified through interviews with management, union representatives, and workers, as well as a review of documents, including the Code of Conduct, attendance reports, and communications on working hours.\n",null,null,null,"Data point 1: The Code of Conduct and Business Partner Code of Conduct include a commitment to the core labor standards of the ILO and OECD Guidelines for Multinational Enterprises. \nData point 2: Review of Work Regulations (Date: 12 July 2013) confirms the working hours, including overtime, breaks, rest days, and a time-tracking system are defined in the Working Regulation that has been approved by the union and government.\nData point 3: Management and worker interview confirm the Work Regulation is communicated on intranet and every new employee receives a hard copy of it.\nData point 4: Document review and management interview confirm a management system is in place to ensuring employees' regular and overtime hours stay within legal limits, not exceeding sixty hours per week.\nData point 5: This has been confirmed by workers interviewed. "]
["11. Remuneration","FM","The auditee has a corporate level policy on compensation as part of the Code of Conduct and the Business Partners Code of Conduct, with a commitment to applicable national laws and the core labor standards of the ILO Conventions. At site level, minimum wages are defined in the sector CBA.  \nThe Group conducted a salary benchmark assessment against the metals sector to ensure competitive salaries, and demonstrates they are paying within the 75-90% range. Employees earn above the legal minimum wage and receive overtime pay and premiums based on their activities and shifts. Annual pay increase is index based and depends on seniority. This was confirmed through management interview and review of documents including the minimum wage comparison report, workers’ wages, and sustainability KPI updates.\n",null,null,null,"Data point 1: The Code of Conduct and Business Partner Code of Conduct include a commitment to the core labor standards of the ILO and OECD Guidelines for Multinational Enterprises. \nData point 2: Review of CBA and Work Regulations (Date: 12 July 2013) confirms remuneration is defined in the CBA and Work Regulation Article 13 and 14. Workers are paid with a half-monthly advance. This advance is calculated the 16th of the month or next working day due to weekend or public holiday and payment is scheduled no later than 3 working days later.\nData point 3: Review of wage pay scale (Date: May 2023) reveals minimum wags per wage group are updated annually. \nData point 4: Management interview confirm the auditee pays more than the industrial average. No specific % of over payment is available as this depends on function. Average shift premium is paid for early (5%) and late (10%) shift, while the premium for night shift (20%) is above average. "]
["12. Occupational Health and Safety","FM","The assessment confirmed Aurubis Beerse N.V. has a valid ISO 45001 certificate.",null,null,null,"Criteria 12 was deemed to be equivalent based on ISO 45001 certification. This is verified through review of the Certificate of Approval for ISO 45001:2018. The scope of this approval is applicable to:\nAdvanced recycling & refining of multi-metals. Production of non-ferrous metal products and minerals. Expiry date: 6 April 2025. Certificate identity number: 10437326"]
["13. Employee Grievance Mechanisms","FM","Policy wording on grievance mechanism is included in the Code of Conduct and the Business Partners Code of Conduct. Aurubis has a whistleblower hotline available on the company’s website that is aligned with the UN Guiding Principles’ Effectiveness Criteria for Non-Judicial Grievance Mechanisms. The whistleblower hotline is available for internal and external stakeholders and is run by an independent ombudsman and managed by Aurubis corporate. \n\nWhistleblower Hotline:\nhttps://www.aurubis.com/en/responsibility/whistleblower-hotline\n\nhttps://www.aurubis.com/en/dam/jcr:f621b24f-856e-4f41-9479-60c393aad7fd/Reporting%20and%20investigation%20procedure%20Whistleblowing_01_2023_EN_US.pdf\n\nAt Aurubis Beerse N.V., workers can also report grievances, including anonymously, or seek advice through one of the nominated internal confidential advisors, external prevention advisors specialized in psychosocial issues at work, works councils, a member of the Safety at Workplace Council, or directly with direct supervisor or human resources. A corresponding Speak up information campaign and trainings have been rolled out. \nThis is confirmed through review of grievance procedure, whistleblower hotline policy and interviews with management, union representatives, works councils and employees. \nBased on records review and interviews, the auditee has a process in place to document and handle grievances through different channels. Consequently, grievance records are maintained by different functions including worker representatives. This makes it difficult to analyze trends and is therefore noted as an opportunity for improvement. \n\n",null,null,null,"Data point 1: Based on the Code of Conduct and Business Partner Code of Conduct employees, business partners, and other third parties are encouraged to confidentially and anonymously report indications of possible legal violations, violations of the Code of Conduct or other activities that could harm the company either through the Group-wide whistleblower hotline, or through the reporting mechanism in place at the sites. \nData point 2: Based on the Code of Conduct, all grievances reported through the hotline are investigated. \nData point 3: In the Aurubis Human Rights Commitment (Date: March 2021) the following is stated: \"We call on all employees to report justified suspicion of discrimination or other human rights violations to their supervisors, the management of the company in question, the employee representatives, the responsible HR departments, the chief compliance officer, or our whistleblower hotline. We also expect our business partners to inform us immediately about justified suspicion of human rights violations in connection with our business activities. Anyone can report these types of violations confidentially and anonymously via the Compliance Portal, also known as the whistleblower hotline, which is publicly accessible on our website. Every report is investigated. There are no disadvantages for a whistleblower who makes a report.\"\nData point 4: On the company website, there is a contact information to file a grievance or complain.\nData point 5: Interview with HR management, union representatives and works council confirm all grievances reported are managed systematically. "]
["14. Environmental Risk Management","FM","The assessment confirmed Aurubis Beerse N.V. has a valid ISO 14001 certificate.",null,null,null,"Criteria 14 was deemed to be equivalent based on ISO 14001 certification. This is verified through review of the Certificate of Approval for ISO 14001:2015. The scope of this approval is applicable to:\nAdvanced recycling & refining of multi-metals. Production of non-ferrous metal products and minerals. Expiry date:1 December 2024; Certificate identity number: 10424028"]
["15. Greenhouse Gas (GHG) Emissions","FM","Greenhouse Gas Emissions are reported at corporate level through the Carbon Disclosure Project. Aurubis reports emissions using the GHG Protocol and 3rd party audits in accordance with the European Emissions Trading Scheme. \nBased on the Sustainability Report 2023, Aurubis has committed to reducing Scope 1 and 2 emissions by 50% and Scope 3 emissions by 24% 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. \n\nAurubis Beerse N.V. share of Group emissions is 6% 2018. The corporate commitments are supported by a decarbonization roadmap and projects like renewable energy initiatives. In this context, the auditee submits reports on long-term decarbonization measures (e.g. green energy, using hydrogen) to Belgium governmental bodies. The auditee is undertaking studies to identify potentials for reduce CO2 with existing systems. Focus is on improvement on Scope 2 emissions. Optimization of existing systems and purchasing green energy would allow reaching the target of  the 50% CO2 reduction. Since 2023, every project has to be screened and approved if there is an impact on CO2 emissions. \n\nThis was confirmed through management interviews and document reviews.\nMore information on corporate level initiatives is available in the TCFD Report 2022/23:  \nhttps://www.aurubis.de/aurubis-com/en/responsibility/environment-energy-and-climate/reporting-kpis-and-esg-ratings\n",null,null,null,"Data point 1: Based on review of disclosed reports, Aurubis publishes a Non-Financial Report for the Group within the Annual Report and release a Sustainability Report guided by the standards of the Global Reporting Initiative (GRI) every two years. In the years without a Sustainability Report, the KPIs are updated and released separately in consolidated form.\nData point 2: According to the Sustainability Report 2023 and the TCFD Report 2022/23 Aurubis  collect, analyze and publicly report CO2 or CO2 equivalent emissions according to an internationally recognized protocol. Reduction targets have been set on either an absolute or intensity basis and monitor progress over time.\nData point 3: This was confirmed through management interview. "]
["16. Energy Consumption","FM","The assessment confirmed Aurubis Beerse N.V. has a valid ISO 14001 certificate.",null,null,null,"Criteria 14 was deemed to be equivalent based on ISO 14001 certification. This is verified through review of the Certificate of Approval  for ISO 14001:2015. The scope of this approval is applicable to:\nAdvanced recycling & refining of multi-metals. Production of non-ferrous metal products and minerals. Expiry date: 1 December 2024. Certificate identity number: 10424028. The auditee has also a valid ISO 50001 certification."]
["17. Freshwater Management and Conservation","FM","Policy wording on water management is included in corporate and site level policies and procedures, such as Code of Conduct, Business Partner Code of Conduct. There is corporate level commitment for reducing water consumption and continuously improving the water quality in the sphere of influence.\nKPIs and targets are systematically reported through the sustainability report, CDP Water Security  and other initiatives.  \nAurubis Beerse N.V. has implemented these commitments through a ISO 14001:2015 based water management system based on a site specific water-use impact assessment in collaboration with relevant stakeholders. While meeting legal and other requirements regarding water efficiency, consumption and use is a minimum requirement, the auditee follows European and Flemish initiatives that encourage companies to use water sustainably, as e.g. Green deal for improving water quality, Blue deal regarding how to guard against water scarcity, environmental permits regarding systematically reducing groundwater consumption, capture water capture ban due to low water level or presence of blue-green algae.\nAurubis Beerse N.V. has processes in place to ensure that water at the site is adequately pre-treated, controlled and purified so that it complies with all legal and internal provisions. This process applies to the entire water system at Aurubis Beerse: groundwater wells, capture canal water, acid waste water streams (acid water electrolysis, lab, nickel department, etc.), and Wastewater treatment plant. Water consumption limits are set by the authorities, with annual reporting obligations, in addition to internal monthly monitoring against KPIs. Currently, no targets for reduction are set. However, a feasibility study has been commissioned to evaluate the potential for use of more rain water. The auditee has a rain water basin for 15,000 m3 rain water and has recently added a new basin for another 15,000 m3 rain water. A water treatment plant before discharging in to the river is used for heavy metals, with ongoing preparations for upcoming regulations. \nWithin the reporting period there were no exceedances in water quality discharges, all of which were reported and no action or fine was required from the authorities.\nThis was confirmed through interviews with management, site observations, and a review of documents including the water management procedure, code of conduct, and environmental policy declaration.",null,null,null,"Data point 1: Based on review of the Corporate Environmental Policy (Date: 01 January 2023) there is a Group wide environmental management system in accordance with EMAS and ISO 14001 implemented at site level in collaboration with local environmental officers and the managing director .   \nData point 2: Based on review of \"Aurubis AG CDP Water Security\" report 2022 there is a corporate level commitment to improve water security. \nData point 3: Review of Water Management Policy for Aurubis Beerse N.V. (Date: 01 December 2022) caring about water is an essential part of its sustainability policy. \nData point 4: Review of procedure \"Environment - Compliance with environmental legislation and statutory environmental obligations\" (Date: 01 June 2023) confirms a process is in place to systematically monitor environmental legislation and keep it up to date. \nData point 5: Management interview confirms the above. "]
["18. Waste Management","FM","The assessment confirmed Aurubis Beerse N.V. has a valid ISO 14001:2015 certificate that covers waste management. Certificate expiry date: 1 December 2024. Certificate identity number: 10424028. \n",null,null,null,"Data point 1: Criteria 18 is covered by ISO 14001:2015 certification. This is verified through review of the Certificate of Approval for ISO 14001:2015. The scope of this approval is applicable to:\nAdvanced recycling & refining of multi-metals. Production of non-ferrous metal products and minerals. Expiry date: 1 December 2024. Certificate identity number: 10424028. The environmental management system of the site is audited annually.   \nData point 2: Review of procedure \"Environment - Compliance with environmental legislation and statutory environmental obligations\" (Date: 01 June 2023) confirms a process is in place to systematically monitor environmental legislation and keep it up to date. Legislation on waste management is part of it. \nData point 3: Based on management interview the auditee is legally required to report monthly and annually on ingoing and outgoing wastes. \nData point 4: Review of the list of waste codes shows the waste that the site is authorized to process. "]
["19. Tailings Management","NA","Not applicable to non-mining operations.",null,null,null,"Data point 1: Based on the auditor's observations and gathered contextual information, there is no evidence of mining operations. Therefore, criteria 19 review is not applicable."]
["20. Pollution","FM","The assessment confirmed Aurubis Beerse N.V. has a valid ISO 14001:2015 certificate covering pollution. Certificate expiry date: 1 December 2024. Certificate identity number: 10424028. There are annual audits of the environmental management system and the scope include pollution. The site has no open environmental issues. \n\nObligations to manage pollution (water, air emissions and immissions, noise, waste, periodic soil and groundwater investigations) are regulated by the Belgian law. The site has processes in place to carry out measurements, evaluate the results obtained and take measures if exceedances are observed. \n\nNoise and dust are the main concerns for the surrounding community, and initiatives are in place to mitigate these impacts. This was confirmed through management and stakeholder interviews and a review of documents, including the environmental policy, procedures, ISO 14001 certification, and corporate environmental policy.\n\nBased on management interview, the site has a historic issue related to soil sanitation. The soil investigation is completed and a 6-year project plan is in place to implement the remediation. ",null,null,null,"Data point 1: Review of procedure \"Environment - Compliance with environmental legislation and statutory environmental obligations\" (Date: 01 June 2023) confirms a process is in place to systematically monitor environmental legislation and keep it up to date. Legislation on waste management is part of it. \nData point 2: Criteria 20 is covered by ISO 14001:2015 certification. This is verified through review of the Certificate of Approval for ISO 14001:2015. The scope of this approval is applicable to:\nAdvanced recycling & refining of multi-metals. Production of non-ferrous metal products and minerals. Expiry date: 1 December 2024. Certificate identity number: 10424028. The environmental management system of the site is audited annually.  \nData point 3: Report review of last audit (Date: 27 May 2024) reveals that pollution is within the audit scope. There are no open environmental issues. \nData point 4: Records review confirm the auditee has procedures in place to manage pollution in line with legal requirements  (water, air emissions and immissions, noise, waste, periodic soil and groundwater investigations). \nData point 5: Based on management interview, Aurubis Beerse N.V. has a historic issue related to soil sanitation. The remediation process started with a soil investigation and the auditee is now seeking quotes for the implementation of the remediation process. \n"]
["21. Biodiversity and Protected Areas","FM","The assessment confirmed Aurubis Beerse N.V. has a valid ISO 14001:2015 certificate covering pollution. Certificate expiry date: 1 December 2024. Certificate identity number: 10424028. There are annual audits of the environmental management system and the scope includes biodiversity. One of the action plans for 2024 is the improvement of biodiversity. \n\nAurubis Beerse N.V. sold a nature reserve to the authorities 20 years ago with the obligation to look after the frogs and salamanders. In order to maintain the operating license, which must be renewed every 20 to 30 years, the auditee must comply with the mentioned obligation. To this end, it works together with the Flemish Agency for Renaturation (ANB) and Agency for nature and forest (Department of Flemish ministry of Environment). The agencies take plant samples every 3 years. Renaturation projects are then implemented, which are financed by the auditee. \n\nThis was confirmed through interviews with management, and a review of documents including the corporate policy on environmental protection, the ISO 14001 certification, and the Aurubis non-financial report.",null,null,null,"Data point 1: Review of procedure \"Environment - Compliance with environmental legislation and statutory environmental obligations\" (Date: 01 June 2023) confirms a process is in place to systematically monitor environmental legislation and keep it up to date. Legislation on waste management is part of it. \nData point 2: Criteria 20 is covered by ISO 14001:2015 certification. This is verified through review of the Certificate of Approval for ISO 14001:2015. The scope of this approval is applicable to:\nAdvanced recycling & refining of multi-metals. Production of non-ferrous metal products and minerals. Expiry date: 1 December 2024. Certificate identity number: 10424028. The environmental management system of the site is audited annually.  \nData point 3: Report review of last audit (Date: 27 May 2024) reveals that biodiversity is within the audit scope. \nData point 4: Management interview confirms the auditee is involved in a renaturation project in cooperation with governmental agencies. "]
["22. Mine Closure and Reclamation","NA","Not applicable to non-mining operations.",null,null,null,"Data point 1: Based on the auditor's observations and gathered contextual information, there is no evidence of mining operations. Therefore, criteria 22 review is not applicable."]
["23. Community Health and Safety","FM","Policy wording on Community Health and Safety is included in the Code of Conduct and other corporate and site level policies. Aurubis has a commitment to plan facilities carefully, operate them in accordance with their permit, and service them regularly.  \nAt Aurubis Beerse N.V. this commitment has been implemented by a management system to avoid, minimize, reduce and compensate for adverse impacts on community health and safety, in partnership with local authorities and local community.\nProcesses and systems are in place to systematically manage community health and safety, focusing on atmospheric emissions and noise pollution as the top risks. Emission levels are strictly regulated to protect public health, with no exceedances reported in 2023/24.\nThe site has emergency response arrangements in place, including regular drills with local fire departments and major exercises involving external services and stakeholders. This was confirmed through interviews with management and local stakeholders, including community members, government officials, and the fire department, as well as a review of documents like the ISO 45001 certification report, communication plan, and occupational health and safety plan.\n\n ",null,null,null,"Data point 1: Based on Aurubis Code of Conduct a management system has been implemented to avoid, minimize, reduce and compensate for adverse project-related impacts on community health and safety, in partnership with local community. \nData point 2: Stakeholder interview with representatives of local fire department, local environmental department and community member confirm that the auditee has robust systems and practices in place to manage Community Health and Safety effectively. "]
["24. Community Development","FM","At corporate level, Aurubis has a policy on social engagement that is included in the Code of Conduct. The company is committed to be a responsible partner to employees, suppliers, customers, and neighbors, contributing to a livable environment for future generations. Social initiatives usually involve donations or sponsorships, with projects selected based on set criteria. The projects have three focuses: knowledge, environment, and participation and they are placed under the slogan, “together we care”.\n\nAt Aurubis Beerse N.V. these commitments are implemented through engagement with a range of stakeholders including local community, residents, members of civil society and local schools. The auditee engages in social support for vulnerable people in the neighborhood (e.g. accommodation for refugees from Ukraine, sponsorship of a local non-profit organization that set up a unique fitness concept for people with physical disabilities, knowledge building in local schools).\nInterviews with stakeholders indicate a positive relationship and responsiveness to comments and requests.\nThis was confirmed through interviews with management, interviews with stakeholders from the community, and a review of documents including the projects list, sponsorships, the corporate sponsoring policy, and Aurubis sustainability KPIs.\n",null,null,null,"Data point 1: Aurubis has a policy on social engagement that is included in the Code of Conduct.\nData point 2: Records review of article (published on Aurubis website on 09 Sept 2023) reveals the auditee is sponsor and strategic partner of the local non-profit organization 'To Walk Again'  that set up a unique fitness concept for people with physical disabilities.\nData point 3: Interview with stakeholders from local community and fire brigade reveal there is a positive relationship and the auditee is responsive to requests and comments. \n\n"]
["25. Artisanal and Small-Scale Mining","NA","The site assessment confirmed there is no ASM in the area of influence. ",null,null,null,"Data point 1: Based on the auditor's observations and gathered contextual information, there is no evidence of ASM operations in the company's area of influence. The auditee does not source external material from either ASM or LSM operations. Therefore, criteria 25 review is not applicable."]
["26. Human Rights","FM","Aurubis has publicly committed to following the UN Guiding Principles and the UN Global Compact at the corporate level. These commitments are documented in different policies and codes, such as the Code of Conduct, Business Partner Code of Conduct, Corporate Responsible Sourcing Policy, the Human Rights Commitment and the Human Rights Policy for Own Business Operation that describes systems and practices in place at corporate and site level to managing human rights risks in own operations and supply chains. The central units for human rights risk management in the Group are the Human Rights Committee (HRC) and the Supply Chain Committee (SCC). They fulfil the function of the Human Rights Officer of Aurubis Group in the own business operations and in the supply chain. At site level, the Managing Director and the Aurubis Group functions are responsible for compliance with the provisions of the policy. The auditee has provided evidence for robust systems and practices in place to control human rights issues in the workplace and for conducting due diligence in the supply chain. No human rights-related grievances were reported during the assessment period. This was confirmed through management and worker interviews and document reviews. \n\nhttps://www.aurubis.com/en/responsibility/people/human-rights-and-labor-standards\n",null,null,null,"Data point 1: Aurubis Human Rights Commitment (Date: March 2021) indicates that Aurubis follows the United Nations Guiding Principles on Business and Human Rights in accordance with the \"Protect, Respect and Remedy\" framework. \nData point 2: The Corporate Human Rights Policy for Own Business Operation (Date: 01 September 2023) describes the systems and practices Aurubis has in place at corporate and site level to managing human rights risks in own business operations. It is stated that site management as well as the respective Group functions at Group level, are responsible for conducting an annual and ad-hoc risk analysis (as required), develop and implement preventive and remedial actions and develop KPIs to measure effectiveness in collaboration with sites, Group functions and Human Rights Committee. The central units for human rights risk management in the Group are the Human Rights Committee (HRC) and the Supply Chain Committee (SCC). They fulfil the function of the Human Rights Officer of Aurubis Group in the own business operations and in the supply chain. The HRC is formed at Group level by the Sustainability, Compliance and Human Resources functions and report to the Executive Board. The HRC meets at least once a year. Its responsibilities include drafting and updating the human rights policy for the own business operations, coordination and oversight of annual analysis, assessment and prioritization of risks at all sites, and communication with the Group. The mandate of the Compliance and HR group functions within the HRC is primarily an advisory function, however, management of human rights grievance mechanism is overseen by Compliance, while Human Resources is significantly involved in providing specific training on  human rights and risk management. \nData point 3: Review of Aurubis AG Policy Statement on Respecting Human Rights and Environmental Obligations in accordance with Section 6 (2) of the German Supply Chain Due Diligence Act confirms public commitment to respecting human rights and environmental obligations.\nData point 4: Aurubis Modern Slavery and Human Trafficking Statement 2022 is publicly communicated. \nData point 5: Review of site level policies, procedures and training and grievance records confirm auditee has implemented a robust system to manage human rights risks in own business and in the supply chain.  \nData point 6: This has been confirmed in management and worker interviews. "]
["27. Security and Human Rights","NA","Not applicable to non-mining operations.",null,null,null,"Data point 1: Based on research review, onsite observation and management interviews there is no mining operation in place. Therefore, criteria 27 review is not applicable."]
["28. Indigenous Peoples Rights","NA","The site assessment confirmed there are no indigenous peoples in the area of influence.\n",null,null,null,"Data point 1: According to the research review, onsite observation, and interviews, the auditor concludes that there are no indigenous people in the area of influence. Therefore, criteria 28 review is not applicable."]
["29. Land Acquisition and Resettlement","NA","The site assessment confirmed there is no land acquisition and resettlement current or planned.",null,null,null,"Data point 1: Based on research review, onsite observation and management interviews the auditee owns the land where it currently operates. The company has no land acquisition and resettlement plans. \nData point 2: External stakeholders and community members interviewed confirm that they are not aware of a conflict raised due to land acquisition negotiations and settlements by the company. Therefore, criteria 29 review is not applicable."]
["30. Cultural Heritage","NA","The site assessment confirmed there is no cultural heritage in the area of influence.",null,null,null,"Data point 1: Based on research review, onsite observation and management interviews there is no cultural heritage in the auditee's area of influence. Therefore, criteria 30 review is not applicable."]
["31. Due Diligence in Mineral Supply Chains","PM","Please refer to the JDD assessment for details.",null,null,null,"Auditor considers the company's Step 5 report covers the requriements of the Standard; however, there is a finding for continual improvement because the Step 5 report is not site specific nor does it provide site specific information."]
["32. Transparency and Disclosure ","FM","At the corporate level, Aurubis includes a Non-Financial Report in its Annual Report and releases a GRI-standard Sustainability Report every two years. In years without a Sustainability Report, updated KPIs are released separately in a consolidated format. Current reports include\nNon-Financial Report 2022/23\nAurubis Sustainability KPI Update 2022/23\nEnvironmental Report and EMAS Environmental Statement 2024 (German only, English version to follow)\nTask Force on Climate-Related Financial Disclosures (TCFD)-Report 2022/23\nReport on Equality and Equal Pay for FY 2022/23\nCDP Climate Change Questionnaire 2023 \nCDP Water Security Questionnaire 2023\nAurubis Modern Slavery and Human Trafficking Statement\nCDP Water Security Questionnaire (EN)\nAll reports can be downloaded here:\nhttps://www.aurubis.de/aurubis-com/en/responsibility/environment-energy-and-climate/reporting-kpis-and-esg-ratings",null,null,null,"Data point 1: Public disclosure of ESG performance is available on https://www.aurubis.de/aurubis-com/en/responsibility/environment-energy-and-climate/reporting-kpis-and-esg-ratings.\n"]
[]
["Joint Due Diligence Standard for Copper, Lead, Molybdenum, Nickel and Zinc"]
["1. Due Diligence Management System","FM","Aurubis has a very straight-forward Copper supply chain. There is 1 supplier of Copper Cement which is originating from 2 zinc smelters in Europe. Both smelters have signed a Letter of Commitment to become Zinc Mark Certified.\nThere are 506 suppliers for recycled material originating from 69 countries.\nDue diligence in mineral supply chains is handled primarily at corporate headquarters, with local team supporting the implementation on site.\nThe Corporate Responsible Sourcing Policy, V1.1, August 2023 is publicly available at https://www.aurubis.com/en/responsibility/responsible-business-activities/responsible-supply-chain.\n\nDirect link to policy: https://www.aurubis.com/dam/jcr:83be7fa4-15fe-49ea-97d8-649b8942aef4/official_RSP_2023_update%20(002).pdf\n\nThere is a system of transparency and controls in place.\nAurubis works with suppliers to gather and collect necessary information and build capacity where appropriate. \nThe due diligence management system includes a process for continuous improvement of due diligence implementation over time.",null,null,null,"The Corporate Responsible Sourcing Policy, V1.1, August 2023, Management review records, Org Chart, Grievance Mechanism and Procedure, Job descriptions, Training records, Internal audit report, Procedure \"Organization and Quality control of Incoming Materials\", Procedure \"Material unloading\", Procedure \"Stock Management of Raw Materials”, Procedure \"Quality Evaluation of Materials by visual inspection and evaluation\", KYC files, Communication records (internal and external)"]
["2. Risk Identification","FM","The auditee's process to collect, review, and retain information for red flags identification is \nappropriate.\nFor risk identification the auditee has implemented several procedures, including KYC, Red Flags identification process, Grievance Mechanism etc.\nAurubis is utilizing TDI's (The Dragonfly Initiative) CAHRA Index. This index categorizes countries based on their likelihood of aligning with the OECD definition of a CAHRA, assessing them as high, moderate, or low risk. ",null,null,null,"CAHRAs identification procedure, KYC files, Grievance Procedure, Records of sanctions and adverse media check, Management meeting records"]
["3. Risk Assessment","NA","No Red Flags identified during the assessment period",null,"N/A",null,"N/A"]
["4. Risk Management","NA","No Red Flags identified during the assessment period",null,"N/A",null,"N/A"]
["5. Public Reporting","PM","The auditee has a process to annually report on its due diligence. Report for 2022/2023 is published at: https://www.aurubis.com/en/responsibility/responsible-business-activities/responsible-supply-chain confirms the auditee annually reports information on supply chain due diligence.\nReport includes a description of the management system designed and implemented for implementing the company’s policy and a system of control and transparency designed and implemented to collect and retain information necessary for red flags identification.\nThe report does not provide site specific information.\nA summary of the methodology adopted and the results of the red flags review process obtained during the assessment period was not included in the sites step 5 report.\n",null,"The report does not provide site specific information.\nA summary of the methodology adopted and the results of the red flags review process obtained during the assessment period was not included in the sites step 5 report.\n",null,"Record review of 2022/2023 report\nhttps://www.aurubis.com/en/responsibility/responsible-business-activities/responsible-supply-chain"]
[]
["Identified Gaps and Improvement Activities (for criteria determined to be does not meet or partially meets)"]
["Criterion","Rating","Identified gaps",null,null,null,"Site response (optional)"]
["5. Public Reporting","PM","The report does not provide site specific information.\nA summary of the methodology adopted and the results of the red flags review process obtained during the assessment period was not included in the sites step 5 report.\n"]

{"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"]