Scope 1 Emissions
2022 Communication on Progress
Feralpi Siderurgica
Published date
June 30, 2022
No. of questions
68
CEO Statement
Signed
Governance
Policies and Responsibilities
1. Does the Board / highest governance body or most senior executive of the company:
2. Does the company have a publicly stated commitment regarding the following sustainability topics?
Optional commentANTI CORRUPTION https://www.feralpigroup.com/en/group/governance/anti-corruption HUMAN RIGHTS https://www.feralpigroup.com/sites/default/files/Policy%20Archivio/Human%20Rights%20Policy_Feralpi%20Group_ENG.pdf CODE OF ETHICS https://www.feralpigroup.com/sites/default/files/media/documents/2021-12/Codice%20Etico%20Feralpi%20Group_nov2021_Holding_ENG.pdf3. Does the company have in place a code of conduct regarding each of the following sustainability topics?
Optional commentAll topics are clearly set out in the Code of Ethics (general opening section), where values are highlighted and then each in its specificity within the other chapters.4. Has the company appointed an individual or group responsible for each of the following sustainability topics?
Optional commentIn terms of anti-corruption we have supervisory board for italian plants.5. Does the company have a formal structure(s) (such as a cross-functional committee) to address each of the following sustainability topics?
Optional commentIn terms of anti-corruption we have the supervisory body working with board of auditors and board of directors. For huma rights we do not have a unit responsible of the topic, but sutainability unit is working as ficilitator and awarness.Prevention
6. Does the company have a process or processes to assess risk?
Optional commentwe are working on Feralpi risk assessment , specifically in terms of busniness and in terms of non financial reporting, in order to be compliant with the law., but we don't have a specific unit in cjarge of the topic yet.7. Does the company have a due diligence process through which it identifies, prevents, mitigates, and accounts for actual and potential negative impacts on sustainability topics?
Optional commentIt is a priority and we are planning to develop one in the next years, but still don't know if it would be in the next two years or more.Concerns and grievance mechanisms
8. Are there any processes through which members of the company’s workforce can raise concerns about the company’s conduct related to human rights, labour rights, environment, or anti-corruption?
Optional commentwhistleblowing procedure8.1. Please provide additional detail regarding the process(es) the company has through which members of the company’s workforce can raise concerns about the company’s conduct.
9. Does the company provide or enable access to effective remedy to right holders / stakeholders where it has caused or contributed to the adverse impact?
Optional commentIn terms of labour rights/decent work it would be better to specify which stakeholder tou refer to. in Italy, Germani and France we refer to employees and some suppliers.Lessons
10. How does the company capture lessons regarding each of the following sustainability topics?
Optional commentIn terms of anti-corruption and human rights we do not have any cases .Executive Pay
11. Is executive pay linked to performance on one or more of the following sustainability topics?
Optional commentIn terms of labour rights, human rights and anti-corruption, we are not able to say exactly when we're gonna to introduce it.Board Composition
12. Percentage of individuals within the company’s Board / highest governance body by:
13. Do you produce sustainability reporting according to:
Data Assurance
14. Is the information disclosed in this questionnaire assured by a third-party?
Human Rights
Materiality / Saliency
1. Which of the following has the company identified as material human rights issues connected with its operations and/or value chain, whether based on their salience (i.e., the most severe potential negative impacts on people) or another basis?
Optional commentApart from health and safety and digital security, Feralpi has other issues listed above in its matrix, even if are not material (D&I) or they are included on other wider topic such as human rights, responsible management of supply chain and people empowerment and development.Commitment
2. Does the company have a policy commitment in relation to the following human rights issues?
Optional commenthttps://www.feralpigroup.com/en/group/governance/group-policy2.1. For each human rights policy, is it:
Optional commentIn regards to Europeans plants, human rights are guaranteed by law. In terms of digital security and privacy we abide the European Standards (other international standards are not available).Prevention
3. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following human rights issues?
Optional commentThe identified risks are limited, since Feralpi operates in countries protected by law.4. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this human rights issue?
5. Who receives training for the following human rights issues?
Optional commentIn 2021 a working group on D&I has been trained about gender diversity.6. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following human rights issues?
Response
7. During the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to adverse impact associated with the following human rights issue(s)?
8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the human rights principles, including any challenges faced and actions taken towards prevention and/or remediation.
HUMAN RIGHTS Guiding the modus operandi of all Group companies with regard to equality, human rights and equal opportunities are the Organisational Model drawn up pursuant to Legislative Decree no. 231/2001 in Italy, the German Constitution (art. 1) and the Allgemeines Gleichstellungsgesetz law, transposed within the Group through the Code of Ethics and the new “Diversity & Inclusion” policy, drafted at the end of 2021. From the latest climate survey, Feralpi emerges as a company where the value of inclusion is perceived as strategic and important. Rights protection (73.1%), intergenerational inclusion (66.4%), gender inclusion (66.1%) as well as cultural inclusion (65.6%) are aspects on which Feralpi's work is considered effective. At the same time, 75.3% would recommend the Group to young people, 75.2% to people of different nationalities, and 72.8% to people with different religious denominations. During 2021, it was not deemed necessary to proceed with a specific training activity on the topic of human rights. Instead, it was decided to proceed with internal outreach through ad hoc communications and one-on-one meetings between key function managers and the Sustainability and External Relations unit. Instead, the topic of human rights was given space during training activities aimed at the front line of the Italy Group in the first quarter of 2022. Protection In the workplace, human rights are protected in many ways. The Code of Ethics enshrines the moral and behavioural rules to be adopted in the corporate community. Industry collective bargaining agreements and company supplementary agreements, guaranteed by the free representation of staff at all operating locations, are the basis of the labour relations system. The latter, marked by constant and constructive dialogue between the parties, are based on timely and transparent communication of information that may have direct or indirect influence on employees and aimed at reaching shared understandings between the parties. Collective bargaining agreements cover all staff at the sites located in Italy, Germany and France (96% of the Group) and the quality of industrial relations is subject to the assessment of periodic meetings between the social partners. In Germany, the Works Council is in charge of protecting workers' rights, as well as implementing measures for the inclusion of foreign workers, and promoting the recruitment and integration of workers with disabilities. For this reason, FERALPI STAHL participated in the event “Respect! - No Place for Racism” of IG Metall. Recruitment Feralpi, in the recruitment and selection stages, considers multiple issues related to the proper management of the related process. The same, in addition to taking into account the specific labour market conditions in the various territories where the plants are located, ensures respect for equal opportunity and, more generally, diversity. Employees who are involved in the recruitment and selection process of personnel, whether belonging to HR, Operations or staff entities, must operate while ensuring respect for personal dignity as well as objectively evaluating on the basis of technical and aptitude suitability criteria. The hiring of new resources is tracked and transparent and always contemplates the approval of the various entities of the organisation involved. Remuneration Feralpi's pay structure is composed not only of the basic pay provided for in the national collective bargaining agreement, but also of supplementary agreements that stipulate better conditions for all employees. As for the managerial level, a formalised performance management system (MBO) is in place, based on objective indicators, both quantitative and qualitative. Rights along the supply chain Along the supply chain, the Purchasing Department is directly involved in the protection of human rights, in terms of protection of working relationships between workers and external contractors/subcontractors and with which Feralpi can have direct or indirect commercial relationships. Feralpi's commitment is reflected in the documentary verification of the Contractors/Subcontractors regarding the correct application of the rules in terms of respect for the protection of their workers and in terms of safety in line with the requirements of Legislative Decree 81/2008 at the Italian level: all staff who access the plant must be regularly hired, punctually paid and subject to health surveillance, which determines their suitability for carrying out the related activities. For each contractor, technical and professional requirements are verified by obtaining documentation certifying compliance with contribution obligations (DURC), obligations imposed by the relevant authorities are being met (social security requirements (INPS) and appropriate employee insurance (INAIL)) and suitable third party and public liability insurance policies covering their personnel have been organised. It also checked that all personnel are equipped with suitable PPE and that they are properly trained in terms of both compulsory and specific training if they have to carry out particular activities Access permits are not issued to under-age workers nor to those with employment contracts on secondment or with vouchers, workers with atypical forms of contract such as internships or apprenticeships are also excluded. In addition to these checks, there are documentary checks on any work equipment brought into the plant to verify that such machines, for safety purposes, are in good condition, maintenance and efficiency when they enter the plant. Feralpi also acquires from contractors/subcontractors, a declaration in which they commit to contribute to the reduction of energy consumption and plant environmental impacts by ensuring, on their part, an elimination of waste and malfunctions by using energy efficient and sustainable equipment. If the contractor indicates a need to subcontract, it will be authorised, always in writing, only for specific activities that differ from those carried out by the contractor. Subcontractors will also be subject to the same verification of possession of the technical and professional requirements as above. What was done in 2021? • Drafting and internal dissemination of the Group Policy “Human Rights” • Update Code of Ethics in relation to new policy • Internal outreach activities with key departments What are we going to do in 2022? • Disclosure of the “Human Rights” Policy to all suppliers • Human rights awareness activities along the supply chainLabour
Commitment
1. Does the company have a policy commitment in relation to the following labour rights principles?
Optional commentPolicy Human Rights Policy HSE (2020) for the plants Feralpi Siderurgica and Acciaierie di Calvisano1.1. For each labour rights policy, is it:
Optional commentLabour rights commitment is included in the HR Policy.Prevention
2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following labour rights issues?
Optional commentWorking conditions: Other - The engagement is managed by the traid unions directly3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this labour rights issue?
Optional commentWorking conditions: Collective actions4. Who receives training for the following labour rights issues?
Optional commentIn the question is not specified if we refer to 2021 or in general. for this reason, in terms of occupational safety and health, we select "all employees". Otherwise, if the question is referring to 2021 only, we would flag "select employees".5. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following labour rights issues?
Optional commentEach plants has its monitoring process, but some of them without goals and targets.Performance
6. What is the percentage of employees covered under collective bargaining agreements?
7. What is the percentage of employees in a trade union or other workers' organization?
8. In the course of the reporting period, what was the percentage of women in:
9. What was the average ratio of the basic salary and remuneration of women to men (comparing jobs of equal value) during the reporting period?
Optional commentThe percentage refers to employees and managers of Feralpi Holding. In NFD 2021 we report the figure of each plant that has more than 6 woman (to avoid privacy matters).10. In the course of the reporting period, how frequently were workers injured (injuries per hour worked)?
11. In the course of the reporting period, what was the company’s incident rate?
Optional commentRate of Injury= (number injuries/hours worked)*1.000.000Response and Reporting
12. In the course of the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to the adverse impact associated with the following labour rights issues?
13. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the labour rights principles, including any challenges faced and actions taken towards prevention and/or remediation.
Safety culture Feralpi adopts a prevention strategy to identify and define investments and policies for employee safety, and to reinforce awareness with ongoing training and activities to raise awareness among all collaborators. In fact, health and safety training activities continued in 2021 for all new additions and proposed training updates on equipment use, working at heights and in confined spaces, first aid, defibrillator use, and fire fighting. In FERALPI STAHL, ad hoc training courses were promoted for managers and employees through digitalisation of training documents, in line with what was awarded in 2020 “Clever Fox” (Schlauer Fuchs). Training and education of all former Fer-Par personnel on the use of the new shaping equipment was also promoted both at the shaping equipment suppliers' training centers and at Presider's Borgaro Torinese and Maclodio plants and later at the Nave plant through on-the-job training. The I am Safety campaign In 2021, the I am Safety initiative was presented at Feralpi Siderurgica, designed to engage Safety Tutors and all workers in developing proactive safety conduct. The project's operational activities were subsequently postponed pending the identification of an optimal characterisation in the context of the Group's safety culture and awareness training project under development and intended to touch - in stages - all Group companies, involving within each personnel at all levels, starting with Management. For the implementation of this comprehensive project, the company with whose cooperation the training programme will be conducted has been selected and identified, the first assessment activities of which will take place in the parent company in the first quarter of 2022. It remains established practice to listen to and talk with workers, supervisors and workers' safety representatives on a daily basis. Interventions in establishments to protect safety and the worker In parallel with the awareness and training actions, Feralpi continuously carries out improvement actions in all plants with a view to prevention and safety protection. In the area of prevention, during 2021, work was carried out at the Feralpi Siderurgica plant related to improved vehicular traffic management, with changes to horizontal and vertical signs, the implementation of speed bumps and new safety signs. Also with the aim of minimising residual risks related to vehicular handling, action was also taken on the in-house vehicle fleet, continuing with the upgrading of the forklift fleet, taking the opportunity to flank environmental improvements by encouraging the use of electric-only forklifts. At FERALPI STAHL, work has also been done on standardising and expanding factory signage with regard to warning, obligation and prohibition signs. Since mid-July 2021, all FERALPI STAHL buildings in Riesa have been gradually retrofitted with new signage, with the aim of simplifying and supplementing the safety signs previously installed at the entrances to the various areas. The signals have a reflective property so that they can be easily recognised even in low light and from long distances. The project on reporting is based on the provisions in accordance with the new definition of minimum standards for IPR on site. The plant was therefore divided into protection zones corresponding to the hazard potential of individual areas. Minimum PPE provisions exist for each protection zone. The colour used for the background of the new signs corresponds to the respective protection zone. As was the case last year, FERALPI STAHL won an award in 2021 for its culture of prevention, thanks to its ongoing commitment to occupational safety and health protection. In addition to training trainees in safety days, the reasons for the award also include the constant analysis of possible hazards, workplace accidents and potential accidents, and the derivation of preventive measures. Certification projects for complex lines at the Feralpi Siderurgica plant continued, with preliminary work on Rolling Mill 2 and in the continuous casting cooling plate area and hot charge of billets at the Rolling Mill 1 furnace, and marking related to the scrap sorting plant complex was obtained. Similarly, projects related to the configuration of hardware and software systems of segregations and access to production facilities continued. On the subject of optimising work at height, new anchor points, new lifelines and new metal platforms have been installed at Feralpi Siderurgica to carry out specific maintenance activities. Three new hoists, a motorized reel for crane rope replacement were also installed, and the automatic electrode screwing system was further evolved. The year 2021 also saw the redevelopment project of the Nave plant, Presider's new production unit. This project included the complete renovation of the span of the building occupied by the production facilities, with the installation of new production equipment that allowed operations to start in September. The work involved the complete resurfacing of the interior flooring, restoration of masonry works, resurfacing of horizontal and vertical signage, construction of new technological systems and installation of new lifting equipment. At the Arlenico plant, work to eliminate man-machine interference inside the rolling mill was carried out during 2021. In particular, the semi-product storage areas and the control and packaging area were secured: this has been done through the implementation of physical barriers preventing free access and the drafting of procedures regulating access. It then began with the installation of safety keys and PLC safety of the latter areas. The work will be completed during 2022, directing the plant toward certification of the overall plant's compliance with the Machinery Directive. At the plant located in Calvisano, new plant operations were planned and carried out in 2021 aimed at making significant improvements in the safety of equipment and facilities in several areas of the plant, including the new unified control room for EAF and LF plants, equipped with a specifically designed control console and equipped with high-definition, wide-view monitors. The intervention has significantly improved safety management, both through the adoption of modern devices with high standards of functional safety and improved control of process steps. The inert gas ladle inflow system was also implemented, which significantly reduced the frequency of operator interventions in risky areas. Regarding work at height, a new jib crane has been installed, making maintenance work at the Continuous Casting safer, and new lifelines have been constructed, for safety in work operations. Finally, an upgrade of the fire detection system was carried out, including control in new areas and new sirens for evacuation signal. Also in Calvisano, projects were also started on plant systems to obtain certification of compliance with the Machinery Directive by leveraging actions to segregate dangerous areas and managing the logic of the entrances with safety keys and safety PLCs. What was done in 2021? • Feralpi Siderurgica: improvement of vehicular traffic and fleet management | Certification of complex lines | Interventions for work at height • FERALPI STAHL: Introduction of minimum PPE standards | Training of all managers responsible for personnel on “Creating a culture of responsibility” | Standardisation and expansion of reporting at the plant related to warning signs and indicators • Presider: Nave site redevelopment | On-the-job training • Arlenico: safety interventions • Acciaierie di Calvisano: plant interventions aimed at making significant improvements to the safety of equipment and facilities What will be done in 2022? • Group assessment, starting with Feralpi Siderurgica, aimed at defining the contents of the project for the overall enhancement of the safety culture to be followed by the various training phases. Continuation in complex plant certification processes. • FERALPI STAHL: Introduction of a health and safety mentor (“Bella Steel”) who informs employees about proper conduct and the use of PPE | Introduction of new certified workwear | Analysis of the existing transportation system and implementation of a new and updated solution | Introduction of an e-learning campaign to digitalise training courses for outside companies, visitors and their own employees • Arlenico: completion of mill safety works. Preparation of management system for future safety certification • Acciaierie di Calvisano: continuation in complex plant certification processes | preparation for future safety certification HUMAN RIGHTS Guiding the modus operandi of all Group companies with regard to equality, human rights and equal opportunities are the Organisational Model drawn up pursuant to Legislative Decree no. 231/2001 in Italy, the German Constitution (art. 1) and the Allgemeines Gleichstellungsgesetz law, transposed within the Group through the Code of Ethics and the new “Diversity & Inclusion” policy, drafted at the end of 2021. From the latest climate survey, Feralpi emerges as a company where the value of inclusion is perceived as strategic and important. Rights protection (73.1%), intergenerational inclusion (66.4%), gender inclusion (66.1%) as well as cultural inclusion (65.6%) are aspects on which Feralpi's work is considered effective. At the same time, 75.3% would recommend the Group to young people, 75.2% to people of different nationalities, and 72.8% to people with different religious denominations. During 2021, it was not deemed necessary to proceed with a specific training activity on the topic of human rights. Instead, it was decided to proceed with internal outreach through ad hoc communications and one-on-one meetings between key function managers and the Sustainability and External Relations unit. Instead, the topic of human rights was given space during training activities aimed at the front line of the Italy Group in the first quarter of 2022. Protection In the workplace, human rights are protected in many ways. The Code of Ethics enshrines the moral and behavioural rules to be adopted in the corporate community. Industry collective bargaining agreements and company supplementary agreements, guaranteed by the free representation of staff at all operating locations, are the basis of the labour relations system. The latter, marked by constant and constructive dialogue between the parties, are based on timely and transparent communication of information that may have direct or indirect influence on employees and aimed at reaching shared understandings between the parties. Collective bargaining agreements cover all staff at the sites located in Italy, Germany and France (96% of the Group) and the quality of industrial relations is subject to the assessment of periodic meetings between the social partners. In Germany, the Works Council is in charge of protecting workers' rights, as well as implementing measures for the inclusion of foreign workers, and promoting the recruitment and integration of workers with disabilities. For this reason, FERALPI STAHL participated in the event “Respect! - No Place for Racism” of IG Metall. Recruitment Feralpi, in the recruitment and selection stages, considers multiple issues related to the proper management of the related process. The same, in addition to taking into account the specific labour market conditions in the various territories where the plants are located, ensures respect for equal opportunity and, more generally, diversity. Employees who are involved in the recruitment and selection process of personnel, whether belonging to HR, Operations or staff entities, must operate while ensuring respect for personal dignity as well as objectively evaluating on the basis of technical and aptitude suitability criteria. The hiring of new resources is tracked and transparent and always contemplates the approval of the various entities of the organisation involved. Remuneration Feralpi's pay structure is composed not only of the basic pay provided for in the national collective bargaining agreement, but also of supplementary agreements that stipulate better conditions for all employees. As for the managerial level, a formalised performance management system (MBO) is in place, based on objective indicators, both quantitative and qualitative. Rights along the supply chain Along the supply chain, the Purchasing Department is directly involved in the protection of human rights, in terms of protection of working relationships between workers and external contractors/subcontractors and with which Feralpi can have direct or indirect commercial relationships. Feralpi's commitment is reflected in the documentary verification of the Contractors/Subcontractors regarding the correct application of the rules in terms of respect for the protection of their workers and in terms of safety in line with the requirements of Legislative Decree 81/2008 at the Italian level: all staff who access the plant must be regularly hired, punctually paid and subject to health surveillance, which determines their suitability for carrying out the related activities. For each contractor, technical and professional requirements are verified by obtaining documentation certifying compliance with contribution obligations (DURC), obligations imposed by the relevant authorities are being met (social security requirements (INPS) and appropriate employee insurance (INAIL)) and suitable third party and public liability insurance policies covering their personnel have been organised. It also checked that all personnel are equipped with suitable PPE and that they are properly trained in terms of both compulsory and specific training if they have to carry out particular activities Access permits are not issued to under-age workers nor to those with employment contracts on secondment or with vouchers, workers with atypical forms of contract such as internships or apprenticeships are also excluded. In addition to these checks, there are documentary checks on any work equipment brought into the plant to verify that such machines, for safety purposes, are in good condition, maintenance and efficiency when they enter the plant. Feralpi also acquires from contractors/subcontractors, a declaration in which they commit to contribute to the reduction of energy consumption and plant environmental impacts by ensuring, on their part, an elimination of waste and malfunctions by using energy efficient and sustainable equipment. If the contractor indicates a need to subcontract, it will be authorised, always in writing, only for specific activities that differ from those carried out by the contractor. Subcontractors will also be subject to the same verification of possession of the technical and professional requirements as above. What was done in 2021? • Drafting and internal dissemination of the Group Policy “Human Rights” • Update Code of Ethics in relation to new policy • Internal outreach activities with key departments What are we going to do in 2022? • Disclosure of the “Human Rights” Policy to all suppliers • Human rights awareness activities along the supply chainEnvironment
Commitment
1. Does the company have a formal policy on the following environmental topics?
Optional commentwe have several environmental policies for each plants. We don't have a Group policy.1.1. For each environmental policy, is it:
Prevention
2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following environmental issues?
3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with these environmental topics?
4. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following environmental topics?
5. In the course of the reporting period, has the company been involved in providing or enabling remedy for any actual impacts associated with the following environmental issue(s)?
Optional commentAny impact associated with the following environmental issue is occured.Climate Action
6. What were the company’s gross global greenhouse gas emissions for the reporting period?
Scope 2 Emissions
Scope 3 Emissions
Optional commentScope 1 Emissions: full Scope 2 Emissions: full Scope 3 Emissions: partial - Categorie included: Upstream trasportation and distribution for scrap, employee commuting, downstream transportation and distribution for products7. What percentage of the company's revenue was invested in R&D of low-carbon products/services during this reporting period?
8. Has the organization acted to support climate change adaptation and resilience?
Energy / Resource Use
9. Please report the company's renewable energy consumption as a percentage of total energy consumption in the reporting period.
Optional commentthe value is 0.03% Data is reffering to self production only. The % of electrical energy from renewable sources is not included.Technology
10. What percent of the company's revenue came from environmentally friendly products / services during this reporting period?
Sector-specific Questions
11. Which sector(s) does the company operate in? If diversified, choose top 3 by revenue.
Sector-specific: Water
12. Please provide details regarding the company's water withdrawal and consumption (own operations) during the reporting period.
Water withdrawal (volume of water in megaliters):
Water consumption (volume of water in megaliters):
Optional commentWater is not a material topic for Feralpi, so it is not included in the report.13. Please provide details about the company’s water intensity of products in regions with high or extremely high water stress.
Optional commentwater is not a material topic, so it is not included in the report.Sector-specific: Forest, biodiversity, and land use
14. Please report the number and area (in hectares) of sites owned, leased, or managed by the company in or adjacent to protected areas and/or key biodiversity areas (KBA).
Optional commentBiodiversity/Forest and Land use are not material topic for Feralpi.15. What area (in hectares) of natural ecosystems was converted during the reporting period in areas owned, leased, or managed by the company?
16. Is the company supporting or implementing project(s) focused on ecosystem restoration and protection?
Sector-specific: Waste
18. Please report the company's total weight of waste generated in metric tonnes during the reporting period.
19. Please report the percentage of the company's waste that was hazardous waste (i.e., hazardous waste ratio) during the reporting period.
Optional commentThe percentuage is not in the Non Financial Declaration, but data in absolut terms are there and they are certificated by third part.20. Please report the company's estimated metric tonnes of single-use plastic consumed wherever material along the value chain during the reporting period.
Overall Environment
21. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the environment principles, including any challenges faced and actions taken towards prevention and/or remediation.
Environment: toward decarbonisation through efficiency, circularity and cutting-edge technology The steel industry is called upon to pursue both efficiency and rational use of resources to modernise processes. Feralpi Group has embraced the challenges of decarbonisation, engaging in the process of ecological and energy transition towards models with a lower impact. Emission reduction and adaptation to climate change In accordance with European targets to achieve carbon neutrality, Feralpi has defined a five-year Group climate strategy in 2021 that sees a CO2 reduction target of more than 90,000 t/y (when fully operational), investments in the range of Euro 100 million, and more than 118 MW of installed power from renewable energy with the goal of cover 20% of the energy consumption of the Group's Italian companies. The pillars of Feralpi's climate strategy 1. REDUCTION OF CO2 EMISSIONS 2. INVESTMENTS IN DECARBONISATION PROJECTS 3. DEVELOPMENT RENEWABLE ENERGY The main actions implemented over the short term are: - advanced energy monitoring; - enhancement of energy efficiency interventions, with strengthening of economic sustainability by obtaining white certificates; - Advanced Control systems for optimising billet preheating furnaces; - research alternative materials to the fossil source; - accounting of CO2 emissions in line with the methodology and guidelines of ISO 14064 and ISO 14067 by integrating risk management related to the application of Emission Trading; - plant investments aimed at reducing direct emissions; - investment in renewable energy production facilities In implementing the strategy, in 2021, Feralpi worked on optimising all technical plant aspects in terms of efficiency and energy consumption reduction. As the commitment continued to circular actions for the valorisation of production residues from steel cycle or other cycles. In terms of measurement and monitoring, Feralpi Siderurgica in 2021 worked on establishing a model for measuring indirect CO2 emissions (Scope 3 or Category 3+4+5+6 of ISO 14064-1). With this work, it was possible to define targeted efficiency actions and environmentally sustainable solutions for the Lonato plant and eventually for all plants. Work is also underway to optimise the energy management system with a new energy consumption monitoring platform. During 2021, it was not deemed necessary to conduct an economic-financial assessment of the impacts related to climate change: the reduction of CO2 is a commitment that Feralpi consciously chooses to pursue in order to increase its market competitiveness and thus its long-term sustainability. This is the reason why the decarbonisation strategy and related targets are an integral part of the business plan. Measures to reduce direct greenhouse gas emissions and other air emissions With the aim of reducing direct emissions, decarbonising and making the steelmaking process more sustainable, Feralpi is committed to the increasing use of alternative materials to coal in its production process. Research and development projects aimed at replacing coal within production are a key investment in achieving the goals. Thus, the OnlyPlastic project continued in 2021 with polymer injection tests from different points in the Feralpi Siderurgica electric furnace. Projects for the reuse of recoverable materials of alternative origin to fossil and polymeric materials were then initiated. Feasibility studies and pilot testing campaigns - which will be completed in 2022 - have been initiated to recover the metal fraction from metal oxides for use in EAF and for obtaining ferro alloys. Also in 2022, the use of alternative materials to the coal and polymer used in testing will be tested Following a study on the characterisation of the emissive effluent from the mill and an initial testing phase, Feralpi will proceed with the implementation of a pilot system to capture CO2 through algae cultivation in 2022. Also from a technological and circular perspective, there are other actions planned for 2022 to reduce emissions: 1) Carrying out feasibility studies for using green hydrogen instead of other fossil fuels. 2) Implementation of a slag composition survey system in EAF and steel level measurement. 3) Pilot test with rapid sludge drying system for material recovery oxides. In Riesa, emission reduction projects were implemented in 2021, such as a new extraction hood in the slag area with direct integration into the dedusting system. In this way, diffuse dust emissions released after slag extraction from the electric furnace and subsequent bed cleaning can be extracted even more directly and efficiently, avoiding fugitive emissions. The exhaust airflow of the extraction system is integrated into the existing dust removal system. In addition, there are plans to expand the slag area and cover and close the crane track in the fall works, which means an almost complete closure of the scrap processing sector. Regarding noise emission reduction, the renovation and maintenance of the roof hood of the furnace area (existing secondary extraction above the electric furnace) is scheduled for 2022. This is assumed to reduce noise emissions by 3dB. Lastly, FERALPI STAHL, following work at the Riesa plant that involved covering a natural area site between the company parking lot and residential buildings, is implementing as required at the regulatory level a compensation measure with the planting of 3,000 shrubs and 20 larger trees. This includes the investment for the new rolling mill in ESF Elbe-Stahlwerke Feralpi GmbH (refer to the chapter “Feralpi's Background and Strategy”), which involves 100% direct charging with inductive heating, with no direct CO2 emissions. FERALPI'S COMMITMENT TO REDUCING DIRECT EMISSIONS What was done in 2021? • Feralpi Siderurgica - testing of polymers instead of coal for foaming slag in the smelting phase | Implementation of oximo moving head burner for EAF process efficiency and flue gas reduction | Implementation of ladle reheating station with recuperative burners for energy recovery emission reduction • Presider - feasibility study for welding fume extraction systems • FERALPI STAHL - installation of air pre-heaters on horizontal ladle furnaces | Initiation of compensation actions What are we going to do in 2022? • Feralpi Siderurgica - replacement of methane billet heater, with electric inductors • Presider - installation of welding fume extraction systems • Arlenico - implementation of software to manage furnace combustion • FERALPI STAHL - implementation of a new stabilisation system, a slag relief system, a digital tundish temperature measurement system, and slag passage relief from ladle to tundish. Installation of a new fume hood in the slag shed area, a new roof hood for the smelting plant, and additional roofing of the scrap processing area. • Acciaierie di Calvisano: use of polymers to replace hard coal in the smelting phase Energy efficiency measures Feralpi Group, in order to achieve its 2030 CO2 emission reduction target, has planned process energy efficiency actions in EAF so as to reduce power consumption, process time and an improvement in metal yield. Parallel to this is also the development of actions leading to the generation of electricity from renewable sources to cover a substantial share of the energy consumed by the plant and the development of energy recovery methods. As part of its plan to reduce electricity consumption, Feralpi thus worked on improving the efficiency of the compressed air distribution network and generation in the compressor station, using cutting-edge technology that uses artificial intelligence and machine learning. This renovation, which began in 2020 and was carried out with the collaboration of Enel X, resulted in an increase in the efficiency of the main hall from 0.130 kWhe/Nm³ to 0.120 kWhe/Nm³ (+7.7%) in 2021, saving nearly 560 MWhe (105 toe). Further replacement of existing compressors with new, more efficient machines will be considered in 2022. In terms of efficiency and decreasing gas consumption, two regenerative heat recovery burners have been installed now in 2019, resulting in 2021 energy savings of 20 toe. A structural modification to the burners was carried out in December 2021, allowing further energy efficiency, as well as optimisation of metal yield and a reduction in emissions. In 2021, more than 8,000 MWht were recovered from EAF furnace flue gas line and more than 7,200 MWht were utilised in addition to the generation of cooling energy from heat recovery, which saw the production of nearly 220 MWhf against the utilisation of 840 MWht. Upcoming evaluations are underway regarding thermal recovery from furnace flue gas at Rolling Mill 2, the possibility of thermal recovery from the entire EAF Feralpi Siderurgica furnace flue gas line, and expansion of the existing TLF network. At the same time, with a view to energy efficiency, a new EAF scorification door was implemented in the Feralpi Siderurgica plant, limiting the entry of false air into the furnace and also reducing the emission of fumes. The introduction of an induction furnace in Rolling Mill 1 and a turboexpander in the methane reduction station is being evaluated. In Acciaierie di Calvisano, the optimisation path for compressed air production has been started, which will be completed in 2022 with the replacement of the last old generation machine with estimated savings of about 240,000 Kw/h per year, and which will be accompanied by the systematisation of leak detection on the network to avoid energy waste. In addition, extraordinary maintenance of the office building will be carried out in 2022, improving its energy performance by two categories. In Feralpi Siderurgica, underground compressed air storage is being soon evaluated. In ESF Elbe-Stahlwerke Feralpi GmbH, it is still undergoing optimisation. Leak detection has been ongoing since 2020, when an optimised concept was developed for the compressed air generation systems of the steel mill and rolling mill, with which 1,850 MWh/year of electricity and more than 1,000 MWh/year of heat can be saved. At ESF Elbe-Stahlwerke Feralpi GmbH, with the installation of the combustion air pre-heater in the horizontal ladle furnaces, it was possible to reduce natural gas consumption (by 765 MWh or 7%) and associated CO2 emissions in 2021, just as it was possible to reduce this consumption (by 1,240 MWh or 0.8%) with the replacement of the air pre-heater on the reheating furnace in the rolling mill. With the aim of continuing to reduce energy consumption and increase energy efficiency, the replacement of the steel mill and rolling mill compressor plants, which is estimated to result in savings of 1,850,000 kWh per year, and Tempcore pumps, which will result in estimated energy savings of 141,000 kWh per year, have been planned at Stahl for 2023. Analyses are also underway for the use of hydrogen in the heating furnace of the rolling mill. FERALPI'S COMMITMENT TO ENERGY EFFICIENCY AND REDUCING EMISSIONS FROM ELECTRICITY What was done in 2021? • Feralpi Siderurgica: start-up of compressor room with new higher efficiency machines | Replacement of metal halide lamps with LED lamps (75% light fixtures replaced) | Heat recovery from EAF furnace fume line | Generation of cooling energy from heat recovery | Optimisation of combustion control system of Mill 2 furnace and of regenerative ladle horizontal heating burners | Implementation of new scorification door in EAF for EAF process efficiency | Internal awareness campaign related to actions to be performed to reduce consumption. • Acciaierie di Calvisano: optimisation in compressed air generation. • Arlenico: replacement of metal hydride lamps with energy-saving LED lamps (70% of replacement carried out) • Nuova Defim: replacement of a chiller in Anzano with a state-of-the-art one • FERALPI STAHL (Riesa site): replacement of metal halide lamps with LED lamps (expected savings 100,000 kWh/a) What are we going to do in 2022? • Feralpi Siderurgica: completion of lamp replacement | Optimisation of horizontal ladle heating burners | Training courses for employees on energy consumption • Arlenico: replacement of office heating boilers with new generation regenerative boilers | replacement of old lamps with energy-saving LED lamps • Nuova Defim: replacement of a chiller in Alzate | complete replacement of the power factor correction plant in Anzano del Parco • FERALPI STAHL: Commissioning of a billet welder in the rolling mill | improvement of the availability of the waste heat utilisation system in the electric furnace to increase steam production | Structural improvement of the roof hood in the slag room and direct integration into the collection line for dust removal | Roofing of the furnace area | Replacement of 5 speed-controlled pumps | construction at the Riesa plant of a scrap preparation hall • Acciaierie di Calvisano: replacement of the last old generation air machine Measures to support renewable energy The share of electricity from renewable sources can be estimated at around 3.93%for the main supplier in Italy and around 13.9% for Germany. The percentage of renewables for the main Italian supplier is low, primarily due to the composition of the portfolio, which is largely focused on industrial customers working in the B2B rather than B2C segments, and with volumes still low for small/retail customers. The penetration of certification mechanisms such as the Guarantees of Origin (GO) market, in fact, is progressively moving up the supply chain, starting with B2C supplies, but has not yet had a significant impact on B2B. To date, the measures implemented by Feralpi to support the deployment of renewable energy at the forefront relate to the establishment of local plants at individual establishments. Examples are the Feralpi Siderurgica 625.14 kWp photovoltaic plant with which nearly 500 MWhe will be produced in 2021 or the 347 kWp photovoltaic plant in Presider, Pomezia, which covers the plant's entire production and generates an energy surplus that is sold to the Distributor. In 2021, as part of increasing efforts, feasibility studies were carried out to expand the Siderurgica photovoltaic park on multiple plant roofs to increase the producible power by an additional 3,000 kWp. And at the same time feasibility studies for revamping current photovoltaic park, as well as initiating projects that enable the Group to invest directly in major photovoltaic fields in Italy over the next 5 years. Feralpi's commitment to reduce CO2 emissions thus finds its grounding in a new company for the implementation of photovoltaic parks aimed at reducing dependence on non-renewable energy sources and capable of leading to savings of more than 90,000 t of CO2 per year when fully operational, equivalent to about 128,571 equivalent trees planted. Feralpi Power On S.r.l., the Feralpi Group's new renewable energy company, will incorporate the plant-owning SPVs and manage their respective Power Purchasing Agreements (PPAs). The project involves the development of ground-mounted photovoltaic fields across the country and installation on Group properties (roofs and land). When fully operational, the installed capacity will be 118 megawatts, with an average annual energy production of about 200,000 MWh (estimated lifetime production 5.9 million MWh). On the sidelines of this major investment, the Ecoeternit company is developing a preliminary technical and economic feasibility study aimed at building a photovoltaic field on the final cover of the landfill. On the one hand, the intervention would allow for the use of an otherwise unused/unusable surface area, and on the other hand, it would reduce the surface area directly exposed to weathering (particularly rainfall), resulting in increased guarantees of minimising the risk of seepage that would generate leachate. An additional advantage is the possibility of securing 20- to 30-year cash flows that would help cover the landfill post-management costs (lasting 30 years). The characteristics of the project are still being studied: the maximum area potentially affected by the intervention is about 40,000 square meters, with a maximum capacity of about 3 MW and an annual production of 3.5 million kWh/year, against an investment of Euro 2.5 to 3 million. The (eventual) implementation timeline is expected from 2026 (upon completion of landfill closure operations). Parallel to renewable energy, strong attention is increasingly being paid to the topic of hydrogen, especially by Saxon Minister for Energy and Climate Protection Wolfram Günther, which sees green electricity as the basis for business survival in Saxony - home to FERALPI STAHL. For energy-intensive industries, such as steel, green hydrogen, i.e. produced with renewable energy, offers enormous opportunities, and for this reason Saxony has defined its strategy in this regard. In this context, FERALPI STAHL together with other companies such as Wacker Chemie in Nünchritz, Mannesmann Röhrenwerke, and Schmiedewerke Gröditz have joined together in early 2022 in the Industriebogen energy network, with the goal of making hydrogen usable as an energy carrier. FERALPI'S COMMITMENT TO RENEWABLE ENERGY What was done in 2021? • Initiating activities to establish photovoltaic park and drafting first roadmap • Feralpi Siderurgica: Feasibility studies for photovoltaic park expansion and revamping • Ecoeternit: Preliminary feasibility study for a photovoltaic field What are we going to do in 2022? ● Establishment of new company for renewable energy development engaged in the development of photovoltaic parks to which is added an activity to evaluate additional alternative energy sources, such as biomethane production ● Feralpi Siderurgica - Design and implementation of expansion and revamping of photovoltaic plants ● Presider and Presider Armatures: feasibility studies for photovoltaic system installation ● FERALPI STAHL - Assessing the best option for green energy supply | Joining Industriebogen for the promotion of green hydrogen Measures for the development of sustainable mobility Sustainable mobility is also an area of action for the Group, although it is not of particular relevance to date in terms of impact with respect to production activities. Despite this, the Group has chosen to pursue actions aimed at developing increasingly sustainable mobility. In terms of logistics, Feralpi has included among its goals a growth in rail transport, as opposed to wheeled transport, especially with a view to internationalisation and market expansion. The investment in the construction of a second rolling mill at the Riesa plant will also go some way toward supporting this goal, as the steel mill generates a lot of local traffic both incoming and outgoing, even though the plant is equipped with numerous sidings. While incoming is due to the fact that not all scrap yards have a junction (70% of scrap is delivered by truck and only 30% by rail), outgoing improves the situation but many steel billets currently go from Riesa to Italy for further processing because the steel mill can produce more billets than can be processed locally. A second rolling mill will therefore result in more on-site production and less traffic. This process could be further improved with a dedicated freight train running regularly between Riesa and Lonato del Garda: although in the face of objective difficulties stated by the railways on trains running from one shipper to one consignee or due to track shortages, negotiations with a private rail operator are underway. Specifically at Feralpi Logistik GmbH, the Group's only logistics company, the issue of sustainable mobility is experienced with great attention: all vehicles in the fleet are no more than 4 years old and all trailers are no more than 10 years old, and the most modern trailers use liftable technology, which allows significantly lower fuel consumption. As of 2018, all vehicles in the fleet are minimum EURO 6 or better, and every new purchase is always aimed at lower impact. By 2021, 12 vehicles were replaced, which is estimated to bring an 8% reduction in specific diesel consumption in terms of kilometers driven, based on the average specific diesel consumption in 2016-2018. With further modernisation of the fleet, a further 8% reduction is expected by 2030. At the level of internal plant mobility, work was carried out at Presider in 2021 to make the company's fleet more efficient (from diesel-powered to fully electric vehicles). Nuova Defim, with the purchase in 2021 of new 5- and 3.5-ton forklifts to replace the last diesel-powered ones used on the yards with new high-efficiency electric ones, has improved its efficiency by 35%, resulting in zero emissions. On the same line, Arlenico has replaced a diesel-powered wire rod handling forklift with an electric one, and in 2022 another diesel-powered forklift in maintenance will be replaced with an electric one. In Germany, gradually, the cars in use by the company will be replaced with electric cars. Electric car charging stations reserved only for employees and guests are available at the Feralpi Holding building, Feralpi Siderurgica technical offices, Acciaierie di Calvisano. At the Riesa office, these stations are also open to the public and can be used by everyone. Finally, in Presider - for the Borgaro Torinese plant only - the figure of the Mobility Manager has been defined and a home-to-work travel plan set up, in line with Interministerial Decree no. 179 of 12 May 2021 aimed at enabling the structural and permanent reduction of the environmental impact resulting from private vehicular traffic in urban and metropolitan areas, promoting new interventions to reorganise mobility demand. FERALPI'S COMMITMENT TO SUSTAINABLE MOBILITY What was done in 2021? ● Presider - corporate fleet efficiency | start-up of Mobility Management activities and first draft of PSCL (Home-Work Commute Plan) for Borgaro Torinese | Establishment of a Mobility Manager ● Nuova Defim - Purchase of new electric forklifts ● Feralpi Logistik - replacement of 12 vehicles (diesel consumption: 8% reduction) What are we going to do in 2022? ● Presider Armatures - corporate fleet efficiency ● Presider - official presentation to the competent bodies of the PSCL and program start-up for the Borgaro Torinese plant ● Feralpi Logistik: additional tractor units of only are planned to be replaced by 2023. Circularity as a sustainable management model Feralpi organises processes and facilities to minimise production residues, landfilling and raw material handling, investing in its replacement and circularity. Materials used for steel production include scrap, additives, lime, ferro alloys, and refractories. Added to these are oxygen and inert gases. Some of these materials, for example scrap, are 100% materials recovered from other supply chains. Others, such as lime and refractories, have percentage of recycled matter (2% and 5%, respectively). The recycled share of additives (amounting to 18% in 2021) refers to filler coals, swellers, desulfurisers, deoxidisers, recarburisers and filler polymers. Use of recovered materials from other production cycles as raw material Feralpi's production process is circular by nature: its circularity consists in producing steel from scrap, thus avoiding the release of waste into the environment and reducing the consumption of natural raw materials that would otherwise be needed. Ferrous scrap - the most important raw material for Feralpi - of different origins and compositions, can be considered as waste or non-waste, according to so-called “End of Waste” EU Regulation 333/2011, and hence be reused. The steel produced by Feralpi consists of 93% recycled material: the figure has been subjected to validation, by a third party, with positive results to the verifications of the percentage content of recycled material of origin according to the UNI EN ISO 14021 standard. In fact, the steelmaking process is constantly evolving. The Group applies innovative solutions that aim to reuse waste materials also from other supply chains, such as the valorisation of plastic waste, which is too often dispersed in the environment and slow to decay. Feralpi Group - in collaboration with partners I.Blu (IREN Group), Tenova and Euromec - now produces steel through the inclusion of technopolymers within the melting process of the electric furnace, replacing coal and its derivatives. The polymers - sourced only from plastic packaging from separate waste collection - are subjected to sophisticated sorting and classification processes at modern, qualified industrial plants and then to technological treatment for recycling. Such processes transform treated plastic materials into new “circular raw materials” that comply with regulations and quality standards, becoming important resources for various industrial applications. Feralpi, after several years of testing, can now inject BLUAIR material into the electric arc furnace during scrap melting. In 2022, the use of polymers or other recovered materials in the electric furnace will be expanded: in fact, there are plans to test the use of alternative materials, as well as new polymers, to further replace the hard coal used in the steelmaking stages. This method is considered the most appropriate for containing effects on the environment. Gaseous residues, resulting from the reaction that takes place following the blowing of the material into the steel and slag bath, can be destroyed at high temperature in the flue gas duct of the plant, which is specifically designed for this purpose already for conventional production. Laboratory studies and industrial tests conducted have shown that the injection of such plastic-derived polymers inside the electric arc furnace does not cause undesirable emissions compared to conventional production; thus, this action cannot be considered “dangerous” or “harmful.” FERALPI'S COMMITMENT TO THE VALORISATION OF RESIDUES FROM OTHER VALUE CHAINS What was done in 2021? ● Feralpi Siderurgica - tests of using polymers from recovered plastics instead of anthracite for foaming slag | Completion of district heating to surrounding community of Lonato del Garda for energy recovery from EAF flue gas to obtain energy for civil heating | Process optimisation related to using spent refractory bricks instead of lime What are we going to do in 2022? ● Feralpi Siderurgica - increase scrap cleaning by an additional 10%. ● Feralpi Siderurgica - testing the use of alternative materials and new polymers ● Acciaierie di Calvisano - tests of the use of recycled polymers in the furnace as a substitute for coal and consolidation of use ● FERALPI STAHL - increase the percentage of dolomite substitutes (to date 16%) Valorisation of production residues within the production cycle or externally Recovery and reuse of spent refractories in the production cycle in the place of raw materials Spent refractory materials coming from the ladle are returned to the production cycle, as partial raw material substitutes. The raw material to be replaced is calcic lime and dolomite lime (“CaO cubes” and “40% CaO”) to be used as a slagging agent in the EAF (electric-arc furnace). Their reuse in the furnace does not entail any negative impact on the environment or human health. Recovery of dust and fumes to reduce the demand for mineral zinc The metal zinc contained in the dust resulting from flue gas removal in the smelting process is mostly recovered at external plants in replacement of natural mineral. The dust produced by the ferro alloy plant are fed directly into the production cycle, the amount of which equals that of the materials from which dust originates. Recovery of mill scale, to replace iron ore in the construction supply chain Rolling scale is recovered for external use. Green iron is the by-product obtained from the rolling scale that is sold to plants for the production of ballasts and concrete. Recovery of non-ferrous metals from scrap sorting The residual fraction produced by the scrap selection plant is sent to external plants for the recovery through mechanical sorting of non-ferrous metals (such as aluminium, brass and copper). Sludge recovery The project involves the construction of a system for drying sludge, a residue from water treatments, which will allow the production of a residue with lower moisture content and therefore more suitable for recovery in construction. The project is for future application. Slag recovery to replace materials of natural origin in the construction industry Slag from the steel cycle can be black and white. The recovery of the black slag and related processing are outsourced to external companies, which then handle related marketing. Specifically at the Lonato del Garda plant, the contracted company converts the slag into a commercial by-product called “Greenstone”, which is used in the construction industry to replace materials of natural origin. All Greenstone by-products have obtained the CE 2+ marking, according to UNI EN specifications. In addition, the black slag recovered at the Lonato plant has an EPD® (Environmental Product Declaration). The EPD is based on the application of the Life Cycle Assessment method (LCA regulated by ISO 14040 and 14044), which quantifies the environmental performance of a product during the various stages of its life cycle. Also at the Calvisano plant, the black slag waste is recovered for the production of products certified according to the 2+ system. The black slag produced by Feralpi Siderurgica in 2021 was sent for total recovery. In 2021, the recovery of white slag continued, enabling its partial use in the field of building construction: the share of white slag sent for recovery reached 40% (8% 2020) of all white slag produced. Heat recovery for clean energy generation Heat is recovered from the cooling water systems of the Feralpi Siderurgica and the Riesa steel mills, preventing it from being released into the atmosphere. The flue gas recovery system at ESF Elbe-Stahlwerke Feralpi GmbH generates up to 30 t/h of steam that is partly conveyed by the Riesa town utility company (Stadtwerke Riesa - SWR) directly to Goodyear Dunlop Tires and partly used to generate electricity through an Organic Rankine Cycle (ORC) turbine. Waste heat from the compressor stations is used to heat and supply hot water to the technical administration offices. Feralpi Siderurgica, through heat recovery, has instead built a plant that interfaces directly with the smelting furnace flue gas cooling system, allowing it to heat the hydraulic distribution circuit over around one kilometre and delivering 4 MWt at an operating temperature of 90°C. The recovered heat has been used to heat the buildings inside the plant since 2018. Since 2019, public buildings and some residential buildings in town have been heated with the steel mill heat, thanks to the collaboration with the local government. In 2021, a number of activities were carried out at the Lonato plant that resulted in an increase in the number of Lonato utilities connected to the grid for an increase in energy delivered to the city of 620 MWht (total almost 3,500 MWht) and the related removal of methane gas plants. District heating: ● energy recovered from the EAF in 2021: almost 8,000 MWht; ● energy used by the various utilities in 2021: over 7,000 MWht; ● network performance: 88% (12% average dispersion); ● energy sold to Lonato: over 3,400 MWht (over 50% of the total used); ● primary energy from fossil sources not used: almost 6,000 MWht; ● missed consumption of methane gas: over 600,000 Sm³; ● normalised energy savings: over 600 TOE; District cooling ● thermal energy used by the absorber in summer 2021: 840 MWht; ● cooling energy produced by the absorber in summer 2020: 220 MWht; ● Average COP: 0.26; ● electricity not consumed for cooling energy production with compression chillers: nearly 45 MWhe; ● normalised energy saving: 8 TOE. Evaluation of a possible extension of the district heating network beyond Lonato is underway. FERALPI'S COMMITMENT TO THE RECOVERY AND REUSE OF PRODUCTION RESIDUES What was done in 2021? ● Feralpi Siderurgica - expanded white slag recovery path | Increased district heating users | reduced water waste with optimised tower water make-up system ● Acciaierie di Calvisano - started white slag recovery process ● FERALPI STAHL - recovery of residual iron from ladle slag for reuse in EAF | Partial reuse of furnace slag, ladle slag and dust What are we going to do in 2022? ● Feralpi Siderurgica - treatment and recovery in the production cycle of scrap processing ends, which are now sent for external recovery | Increased white slag recovery | Realisation of sludge drying system | Use of induction system for billet heating | Feasibility study to improve separation and reuse of non-ferrous metals ● Acciaierie di Calvisano - Allocate all slag (black and white) for reuse ● FERALPI STAHL - increase the percentage of dolomite substitutes (to date 16%) and in the medium term internal recycling of white slag (reuse in electric furnace) | Extensive use of EAF slag as recycled construction material for high internal construction activity | Treatment of excavated soil and concrete for reuse as recycling materialAnti-corruption
Commitment
1. Does the company have an anti-corruption compliance programme?
Optional commentThe management of anti-corruption offences is in the 231 Model (Italian law similar to Sarbanes - Oxley Act) for Italian plants2. Does your company have policies and recommendations for employees on how to act in case of doubt and/or in situations that may represent a conflict of interest, e.g. with regard to gifts and hospitality, donations, sponsorship, or interactions with public officials?
Optional commentCode of Ethics - https://www.feralpigroup.com/sites/default/files/media/documents/2021-12/Codice%20Etico%20Feralpi%20Group_nov2021_Holding_ENG.pdf In addition we have: Donorship and sponsorship Policy https://www.feralpigroup.com/sites/default/files/Policy%20Archivio/Policy_Management%20of%20social%2C%20cultural%20and%20philantropic%20initiatives.pdf Antitrust Manual (not public) 231 Procedures: management of sponsorship and donation; management of inspection conducted by public administration officials; managing access to subsidies public contribution; managing gift and entertrainement expenses (not public)Prevention
3. Who receives training on anti-corruption and integrity?
Optional commentExpecially commercial employees3.1. How often is such training provided?
4. Does the company monitor its anti-corruption compliance programme?
Response and Reporting
5. Please report the company's total number and nature of incidents of corruption during the reporting year.
6. Within the reporting period, what measures has the company taken to address suspected incidents of corruption independently or in response to a dispute or investigation by a government regulator?
7. Does your company engage in Collective Action against corruption?
Optional comment"Corruption" is not a material topic8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the anti-corruption principle, including any challenges faced and actions taken towards prevention and/or remediation.
Organisational model and management systems With the aim of taking into account the issue of sustainable development - and thus its risks and opportunities - and lowering it into all business processes to achieve the goals of the business plan, there is in Feralpi an organisational and corporate governance model capable of assigning specific tasks and responsibilities to the main corporate governance bodies. Code of Ethics During 2021, Feralpi Holding's Code of Ethics was updated, following the process of updating the Organisation, Management and Control Model pursuant to Legislative Decree 231/2001 and the drafting of the Group's new human rights policy. The Code of Ethics is the charter of rights and duties of the entire Group in which the ethical and social responsibilities of the company - internally and externally - and the values it adopts are defined. Management Model For each company in the Group there is a specific Organisation, Management and Control Model (OMCM) pursuant to article 6 of Legislative Decree 231/2001, as amended and supplemented: a document approved by the Board of Directors, containing general principles and specific rules aimed at ensuring conditions of transparency and fairness among all those who work within it and on its behalf. The OMCM allows individual companies to prevent and counteract the commission of predicate offences thanks to the correct planning of activities, a system of self-control and constant supervisory action on the areas of activity and enables individual companies to take prompt action to prevent and combat the commission of offences through constant supervisory action on the areas of activity at risk carried out by the Supervisory Body. During 2021, the Models of Siderurgica and Holding were updated to comply with recent regulatory changes that have occurred regarding the introduction of new predicate offenses. This will be followed in 2022 by Acciaierie di Calvisano, Caleotto, and Arlenico, and then all the others. Companies operating in Germany are regulated by the Business Establishment Act (BetrVG), which provides the right to participate in decision-making through the works council. In this model of corporate governance, employees and works councils are involved, at the same time exercising control and having information, consultation and veto rights. In addition, Feralpi has concluded collective agreements with the IG Metall union in Germany. Antitrust Manual Feralpi has drawn up an Antitrust Manual, accompanied by an operational handbook containing all the principles and guidelines for the personnel who maintain relations with third parties on behalf of the Group companies. The antitrust programme is updated and implemented every two years. In view of the risks found and the management methods in place, it is not considered necessary today to envisage further internal actions to increase awareness of this issue, in addition to the planned annual training session and audit with the staff most exposed to risk: in 2022, when the manual and operational vademecum are renewed, training for managers is planned. Non-Italian Group companies regularly comply with the regulations in force in their countries and also join Feralpi Group compliance by adopting the same principles and values. In Germany, ESF Elbe-Stahlwerke Feralpi GmbH is an active participant in the Wirtschaftsvereinigung Stahl, the national federation of German steel companies through which all aspects related to fair competition are identified and handled, in full compliance with all related guidelines and regulations. In the three-year period 2019-2021, there are no facts or sanctions in this regard. Supervisory Body (SB) The Board of Directors appoints the Supervisory Body - a collegial body composed of two or three members, among whom the Chair is appointed - from which it in turn receives reports of critical issues coming from it, in compliance with the Management and Control Model drawn up in accordance with Legislative Decree 231/2001. At Acciaierie di Calvisano and in Nuova Defim the Supervisory Body, unlike in the other plants, is a single-member body. Nine Supervisory Bodies (SBs) are operational at 31 December 2021, in Feralpi Holding, Feralpi Siderurgica, Acciaierie di Calvisano, Nuova Defim, Fer-Par, Presider, MPL, Caleotto and Arlenico, respectively. The holding company's Supervisory Body operates in collaboration with the supervisory bodies of all Italian Group companies. For the Group’s foreign companies, no Supervisory Bodies are put in place, since the Model 231 is not applicable, and the monitoring system is entrusted to the national law system and the competent authorities to whom the complaints are reported. No reports of violations of the organisational model or of the Code of Ethics were received during the period considered. Whistleblowing All Italian Group companies with Model 231 in place have a special procedure for handling whistleblowing. During 2021, internal communication was promoted among the corporate population of Feralpi Holding, Feralpi Siderurgica and Acciaierie di Calvisano, in line with some updates related to the 231 Management Model, with the aim of promoting this procedure, explaining conditions and then giving visibility of the different communication channels. Other Group companies will be informed jointly with the organisational model update programme. At Feralpi Stahl, given a more complex national regulatory environment, a process for whistleblowing has not yet been established. Although Germany has signed the main conventions in the field of anti-corruption, it has not fully ratified them, leaving some regulatory gaps on very relevant profiles including, precisely, the protection of the Whistleblower. The protection of whistleblower workers is contained in a plurality of laws, such as freedom of conscience, freedom of expression and information, and the general right of action. During 2021, no reports were received by the Supervisory Bodies. Managing and combating corruption The Group combats all forms of malfeasance and prevents corruption crimes in full compliance with applicable laws and national regulations. The commitment at Group level is grounded in the Group’s Code of Ethics, which also refers to potential risk due to corruption, stressing principles of Transparency, Truth and Honesty and appropriate conduct in relationships with government departments. Specifically in the Italian context, in relation to the crimes of Corruption towards the Public Administration and Corruption between private individuals, Italian companies (excluding Ecoeternit) find references in the Model relating to Legislative Decree 231/2001. The methods for managing sensitive activities and the related responsibilities are described in various procedures and refer in terms of reporting to the Supervisory Bodies of each company. Ecoeternit, in line with its size and specific characteristics, operates in synergy with the information defined at Group level. There is also an internal procedure that governs relations with the Public Administration: regulation applied, for example, by assigning powers to delegate, sign and access accounts to specific executive roles only, and for specific transactions. Companies that participate in public tenders indirectly provide specific training for commercial personnel to prevent acts of corruption between private parties. Companies operating in Germany follow the requirements of the German legislation, which requires them to provide detailed information to the State on specific aspects potentially connected to corruption and money laundering risks, which are then checked and verified. The double-checking principle is also applied, whereby several members of company staff cross-check information. What is expressed in the Code of Ethics and Management and Control Model 231/2001, as well as what is required for companies participating in public contracts and what is imposed by Italian and German regulations, are fundamental and sufficient for optimal management by the Feralpi Group. This approach is also the key to fighting corruption in terms of the supply chain: the Group's suppliers are in fact invited to accept the Code of Ethics and the values expressed therein. Privacy Management Feralpi Group constantly monitors regulatory and enforcement practice developments in the area of personal data protection with the goal of implementing adjustment actions that lead to continuous improvement of the personal data protection system. In addition, based on the company's level of exposure, to the risks of loss of confidentiality, integrity and privacy of personal data, all Feralpi Group companies implement appropriate technical and organisational security measures to strengthen the protection of processed personal data, in accordance with the principle of accountability. In the year just ended, dialogue continued between the Group's various sectors and with production facilities in Italy and Germany, in order to maintain the focus on data protection and security issues. Increasing digitalisation, which has accelerated in all sectors partly as a result of the pandemic, has led to an increase in the risk associated with cyber threats. As of today, in fact, an increasing number of threats in the “cyber” sphere resulting from the evolution and growing complexity of information systems and greater vulnerability of applications and ICT infrastructures also requires entities such as Feralpi to equip themselves with systems and procedures capable of guaranteeing high levels of security in the processing of data and information inside and outside the organisation. The measures are aimed at protecting privacy and data security of customers and suppliers, including their employees, on the one hand, and data protection of workers on the other. As a result of the growing demand for reliability and compliance with specific requirements by Feralpi Group's largest customers, new business models that have created an context in which data and information are widely shared and interconnected, as well as the sophistication, speed and impact of cyber attacks, the level of risk management complexity has increased, with negative consequences on two fronts: privacy and security. The Group takes all the necessary precautions to minimise the risks inherent in the services it offers, implementing and adopting the best security standards and also turning its attention to the market to identify the appropriate tools to protect the technological structure in order to ensure confidentiality, integrity and availability of the company's information assets. The year 2021 was focused for Feralpi on the consolidation of security and data protection policies with specific reference to cybersecurity, which resulted in a roadmap and the preparation of policies on secure data deletion and decommissioning of equipment, management of update patches for system security, and a mapping of the group's IT infrastructure, a process necessary to lead in 2022 to the definition of an updated and more resilient organisational model for information security. In order to best safeguard and protect the data and information it handles, Feralpi Group has carried out all the activities required by the European Regulation 679/2016 (GDPR). Since 2018, in compliance with the regulatory framework defined by the European Regulation 2016/679 (GDPR - General Data Protection Regulation), Feralpi has a Group DPO (Data Protection Officer), with the main role of guidance, coordination and liaison with the individual legal entities. In Germany, the specifics of the German framework have led to the identification of an on-site DPO, who works in close coordination with the Group DPO. As a testament to the Group's commitment to safeguarding data and information, during 2021, no complaints were received regarding customer privacy breaches or data loss. During 2021, there were no data breach incidents, unlike in 2020, when there was one incident, which caused no major consequences. A request for the exercise of rights was received from a data subject, which was handled according to current regulations.