Sustainability · Standards

We act responsibly

The strategies, codes, and policies that govern how the Elemental Group — and Elemental North America within it — operate.

01 · Our approach

Corporate governance built on transparency and due diligence

We conduct our business in compliance with applicable laws, the principles of social coexistence, and established customs in the countries where the Group’s companies are based. The Code of Ethics is the key document guiding all employees and associates in daily operations.

The Group’s corporate governance is based on the principles of transparency and due diligence — reflected in internal regulations (policies, procedures, and strategies) and an appropriate management and supervisory structure with assigned responsibilities across areas and positions.

02 · Strategies

Three cross-cutting strategies

S.01HR

Human Resources Management Strategy

At Elemental Group, we strive to create safe and stable workplaces. As an international organisation, we consider ourselves an important part of the communities in which our companies operate.

S.02ESG

ESG Strategy

Considering climate challenges, EU and global regulations, stakeholder requirements, and market trends, we treat ESG management as an urgent strategic priority — managing environmental and social issues based on policies and management systems.

S.03Environment

Environmental Management Strategy

The Group's activities are part of global efforts to protect the climate and support sustainable development. We actively participate in saving the planet and improving the lives of communities, implementing the goals set by the United Nations in the field of environmental protection.

03 · Policies and procedures

Seven policies covering ethics, safety, and supply chain

P.01Policy

Anti-Corruption Policy

Ensures a fair and transparent model of activities across the Elemental Group — guaranteeing trust, security, free competition, and value for all stakeholders.

P.02Policy

Anti-Mobbing Policy

Builds an organizational culture based on mutual respect. Employees are educated on what mobbing and discrimination are, how to respond, and who to contact — with actions detailed in the Policy.

P.03Policy

Occupational Health & Safety (OSH) Policy

A commitment to maintaining a safe, healthy, and friendly working environment for all employees and associates — with continuous improvement, hazard identification, and regular training.

P.04Policy

Human Resources Management (HR) Policy

Presents the principles and regulations governing HR across the Group — based on trust in people, common goals, and mutual respect, supporting the sustainable development principle.

P.05Policy

Whistleblowing Procedure

Encourages internal and external stakeholders to report situations contrary to our Code of Ethics, policies, and procedures — helping prevent and detect irregularities.

P.06Policy

Supplier Code of Conduct

Elemental Group is a global organization playing a role in the fight against climate change. Our suppliers commit to the same responsibility standards across the recycling and refining chain.

P.07Policy

Supply Chain Management Policy

In accordance with international laws and ethical standards — including human rights, environmental protection, health, personal safety, and sustainable development — we embed responsible business practices across the entire supply chain.

Full policy texts, translations, and the Group’s Code of Ethics are published centrally by the Elemental Group.

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