Zero audit non-confor­mities

Legal basis

The EU Corporate Sustainability Due Diligence Directive (CSDDD) aims to ensure that companies assume greater responsibility for upholding human rights and environmental standards throughout their global supply chains.

The CSDDD was published in the Official Journal of the European Union in July 2024 and will enter into force in 2025. EU member states now have until 2026 to transpose its provisions into national legislation. The CSDDD’s scope will extend gradually to companies of different sizes and will cover companies based in the EU as well as non-EU companies that operate on the European market. Companies covered by the CSDDD will be required to fulfill due diligence obligations throughout their supply chains in order to identify, prevent and remedy risks and violations of human rights and environmental standards. Key topics include forced labor, child labor, environmental pollution and breaches of labor rights. It aims to create a level playing field for all enterprises while requiring companies to assume greater responsibility for their social and environmental impacts. Companies now have an obligation to conduct risk analyses, implement preventive measures and set up complaint mechanisms. They must also produce regular reports on their due diligence obligations and make these reports publicly available. The German Supply Chain Due Diligence Act (LkSG) entered into force in January 2023 and currently requires large companies to review their global supply chains for human rights and environmental violations.

About the Aluminium Stewardship Initiative (ASI)

Established in 2012, the Aluminium Stewardship Initiative (ASI) is a global, multi-stakeholder, non-profit organization that defines common standards and issues corresponding certifications. By defining globally applicable standards and developing a certification system, the ASI promotes the responsible aluminium production, procurement and supply chains. AMAG is a founding member of ASI and has been closely involved in its development.

The ASI Performance Standard defines environmental, social and governance principles and criteria, which address a broad range of sustainability issues in the aluminium value chain. Companies certified in line with the ASI Performance standard produce aluminium in accordance with the ASI standards and its criteria, which cover the environment, social affairs and business ethics.

The ASI Chain of Custody (CoC) standard builds on the ASI Performance standard. It sets out requirements for creating a chain of custody for materials, reaching from mining, bauxite production and recycling and to processing and finishing products. As an ASI CoC-certified company, AMAG is entitled to sell ASI-certified aluminium proportionate to its procurement of ASI-certified input materials.  These input materials include used scrap (i.e. scrap materials following use by consumers) as well as ASI-certified primary aluminium and rolled bars, which are subject to stringent criteria in relation to the environment, social affairs and business ethics.

Responsible corporate governance

The AMAG Group has maintained a strong focus on responsible and resource-efficient aluminium production for many years. AMAG is conscious of its specific responsibilities to its employees and business partners, to society, to its shareholders and investors and to government institutions, and is well prepared to cope with legislative developments. Observing and upholding human rights and ethical, social and environmental standards, both within the company and throughout the supply chain, is a core element of responsible corporate governance. As a signatory to the UN Global Compact (UNGC), AMAG is committed to promoting the ten principles of the UNGC in the areas of labor standards, human rights, environmental protection and anti-corruption along with sustainable, responsible business management.

Treating all stakeholders with integrity, showing respect and appreciation for people and the environment and ensuring fair competition are of the utmost importance to the company. These high standards are also reflected in the AMAG Code of Conduct, the AMAG Human Rights Code and the ESG Requirements for AMAG Suppliers, as well as internal guidelines and procedures. AMAG expects its suppliers and business partners to observe and actively promote these same high standards.

Due diligence obligations and supply chain responsibility at AMAG

AMAG has already been indirectly affected by the German Supply Chain Act (LkSG) through requirements imposed by its customers. In light of this, AMAG’s Sustainability, Law and Purchasing departments have critically evaluated - and, where necessary, expanded - AMAG’s sustainable procurement management activities and associated documentation (the Responsible Procurement Management Procedure, procurement guidelines, supplier requirements and general purchasing conditions). AMAG will implement the additional requirements arising from the CSDDD in the course of its transposition in national legislation. AMAG implemented key aspects - such as assessments based on environmental and social criteria, and criteria regarding key suppliers’ corporate governance activities - in the course of securing ASI Performance certification in 2018, and has continuously developed its measures ever since.

Responsible procurement management

AMAG employs a systematic approach to responsible procurement management throughout the supply chain in order to prevent and remedy human rights violations and negative environmental impacts as effectively as possible. Purchasing departments within the AMAG Group scrutinize all major new and existing suppliers (of scrap, primary metal, rolling slab, alloying metals, dross and energy) regarding their respect for human rights. The supplier assessment comprises four areas. The overall assessment is a risk classification, which determines appropriate measures. The first of the four areas is confirmation that the supplier meets AMAG’s ESG requirements. The second is determining the risks arising from the origins of the supplier’s materials. The remaining assessment areas concern certifications and focus questions, including in relation to goods’ origins, supply chain management and reporting of ESG-related data.If a supplier is placed in the “high risk” category, risk mitigation measures are drawn up and monitored to ensure their efficacy.

AMAG Compliance Line

A comprehensive compliance system ensures that potential misconduct is identified and prevented or brought to an end, thereby protecting the company and its stakeholders. The AMAG Compliance Line offers an anonymous means of reporting such misconduct and related concerns.It is a system comprising several reporting channels and is open to AMAG’s employees and business partners as well as members of the public. After a report is received via the confidential mailbox, the whistleblower receives information about the how their tip-off being investigated.