Impact, risk and opportunity management
E2-1 – Policies related to pollution
The policies described below concern issues related to pollution that results or may result from our own operation or operations in the upstream and downstream value chain. They include preventing and reducing air, water and soil pollution, ensuring the proper handling of hazardous substances and waste, and preventing incidents and emergency situations in connection with mitigating and limiting the impacts on society and the environment.
Environmental and energy management
The group environmental and energy management policy defines binding requirements for managing environmentally relevant activities – including the reduction of emissions to the air, water and soil, the consideration of environmental aspects in the product life cycle and the handling of incidents and emergency situations.
With its environmental and energy policy, thyssenkrupp is pursuing the goal of minimizing negative impacts on the environment – either as the result of the company’s own activities or in part due to the downstream value chain – and using energy and resources as efficiently as possible. To this end, a group policy was developed, which governs the organization and control of the company’s environmental and energy management. This policy defines central structures, responsibilities and minimum standards for internal procedures.
One main element of the policy is the classification of group companies as environmentally relevant or energy-relevant on the basis of objective criteria such as the existence of official environmental requirements or reporting obligations to environmental authorities, external reviews and material energy consumption data. All companies classified as relevant must implement an environmental and/or energy management system in accordance with ISO 14001 and ISO 50001, respectively. According to the group policy, the management systems must cover all environmentally relevant and energy-relevant activities of the respective company.
Pollutant emissions to the air that are a relevant environmental aspect of a business activity must be considered within the context of the environmental and/or energy management system and managed systematically so that negative environmental impacts can be identified, monitored and addressed internally. Moreover, energy management systems serve to record and optimize energy-intensive processes, which are often directly associated with airborne emissions (i.e., from incineration processes), and can thus contribute to mitigating air pollution and its environmental impacts.
Environmental and energy management addresses the downstream value chain by considering the environmental aspects of products and services throughout their life cycle – including use and disposal – from the outset. This requirement is a central feature of thyssenkrupp’s environmental and energy policy. For this reason, environmental and energy-related matters must be considered systematically in the early stages of planning and in the product development process. The goal of this requirement is also to prevent or mitigate those environmental impacts associated with the use of products or services, such as those caused by air pollution that may occur when disposing of products.
At thyssenkrupp, the environment and energy management systems are monitored on the basis of regular management assessments in accordance with ISO 14001 and ISO 50001, respectively. A documented management assessment signed by the executive management is deemed to be verification of implementation. Moreover, environmental and energy-relevant data are recorded and assessed at least once annually in order to gauge the level of performance and continuous improvement of the systems.
Another element of the group environmental and energy management policy is the prevention of and crisis management for incidents and emergency situations. These include events with potentially severe consequences for society and the environment, legal risks or business interruptions, including those affecting thyssenkrupp’s contractual partners. The primary goal is to prevent such incidents and situations by way of early risk detection in conjunction with suitable preventive actions. Should an incident or emergency situation occur nonetheless, the aim is to effectively limit the impacts on society, the environment and operations.
Human rights and environmental due diligence obligations
The policy for human rights and environmental due diligence obligations is anchored in various thyssenkrupp documents such as the principles on human rights and environmental due diligence obligations, the group policy for implementing human rights and environmental due diligence obligations, the Supplier Code of Conduct and the Group Policy Procurement Principles.
Based on the principles of compliance with human rights and environmental due diligence obligations, the group and its upstream value chain undertake to comply with international environmental treaties, especially relating to the control of hazardous substances and the avoidance of transboundary movements of pollutants.
By implementing human rights and environmental due diligence obligations through systematic risk analyses and control measures, thyssenkrupp aims to prevent, mitigate or remedy pollution caused by its own business activities or by activities in the supply chain and to minimize the resulting risks to society and the environment. The basis for this are the groupwide principles in which these obligations are anchored and which are aimed at ensuring compliance with applicable environmental legislation and relevant international treaties such as the Basel, Stockholm and Minamata Conventions. These aim to prevent the transboundary movement of hazardous waste (Basel), the placing on the market and release of persistent organic pollutants (Stockholm) and the release and use of mercury and mercury compounds (Minamata). They establish internationally recognized standards for protecting the environment and health.
In the context of these obligations, both actual and potential adverse environmental impacts – e.g., caused by air pollution, soil contamination or the improper handling of hazardous substances – are considered systematically. Adverse environmental effects that could jeopardize protected legal rights – such as the right to health, food and clean water – must be avoided. Any impacts that actually occur must be mitigated or remedied systematically within the context of corporate responsibility. As an integral part of due diligence obligations, the Supplier Code of Conduct gives substance to these expectations for all thyssenkrupp’s suppliers and their subcontractors by requiring their compliance with international environmental treaties such as the Basel, Stockholm and Minamata Conventions.
Water management plan of thyssenkrupp Steel Europe AG
A local water management plan at the Duisburg-Nord site of thyssenkrupp Steel Europe AG complements the policy with requirements for wastewater treatment and takes account of possible upstream environmental impacts associated with the cooperation with key water suppliers such as Gelsenwasser AG.
The water management plan of thyssenkrupp Steel Europe AG at the Duisburg-Nord site aims to ensure the efficient use of water and the effective prevention, mitigation and remediation of pollutant emissions into surface waters – especially in connection with industrial wastewater – in order to minimize environmental and health risks. The focus is on protecting water quality, preserving aquatic ecosystems and preventing negative impacts on human health.
Wastewater management by thyssenkrupp Steel Europe AG at the Duisburg-Nord site is based on the principle of minimizing pollutants prior to discharge. Industrial and process wastewater is treated in accordance with the requirements of Germany’s Water Resources Act (WHG), the Water Act of the State of North Rhine-Westphalia (LWG NRW) and official permits. Depending on its type and quality, wastewater is either discharged indirectly via the Emschergenossenschaft or directly into the Rhine.
The water management plan also considers the upstream value chain, especially the cooperation with Gelsenwasser AG as thyssenkrupp’s main water supplier. This organization’s water withdrawals require permits and monitoring and are an element of site-related water management, which aims to ensure the stability of local water resources. As an integrated element of water management, this is intended to contribute to preventing or reducing water-related environmental and health risks, especially in connection with the quality and pollution load of the water that has been used and discharged.
The water management plan aims to continuously improve the efficient use of water and the careful management of this resource. In this connection, the associated management processes and performance indicators are reviewed regularly. A further contribution to the continuous improvement in water use is expected from the dialog with other industrial users of water under the auspices of the Emschergenossenschaft.
E2-2 – Actions and resources related to pollution
The following disclosures describe the actions taken by thyssenkrupp and the resources made available to implement the policies for preventing, mitigating and remedying pollution that are described in subsection “E2-1.”
Environmental and energy management
In order to implement the group environmental and energy management policy, the environmentally relevant and energy-relevant thyssenkrupp companies operate decentralized management systems in accordance with ISO 14001 and ISO 50001, respectively. These systems serve to manage environmentally relevant activities and improve the environmental performance and energy efficiency of processes and products.
One example of this in the Steel Europe segment is the integrated approach to air pollution control, soil protection and noise reduction. Production plants are equipped with waste gas purification systems controlled by a digital emission monitoring system. The data measured by this system are transmitted to the responsible authorities. To protect the soil, environmentally relevant aspects are already considered in the planning phase for new plants, as envisaged by statutory requirements. The soil protection measures are complemented by plant technology solutions and internal procedures for the responsible handling of potentially hazardous substances. Certain areas of the Duisburg site are vacant or covered with vegetation and must be maintained in accordance with environmental aspects with the aim of preserving soil function and preventing or mitigating erosion, compaction or pollution. Decommissioned landfills are renatured with the aim of improving soil quality, while greened earthen walls serve to control both emissions and noise.
The other thyssenkrupp businesses also implement actions to prevent and mitigate air and soil emissions as part of the environmental and energy management system. Activated carbon filters can be installed in metal-forming pressing processes to capture oil mists and the resulting decomposition products; in pickling units, alkaline air scrubbers are used to reduce acid and pickling vapors. At relevant sites, emissions are also being reduced by the increased use of electric-powered mobile machinery such as diggers and transport vehicles, which avoid the emission of exhaust gases caused by the combustion of fossil fuels. In addition, fabric filter systems can be installed in metallurgical flame-cutting units to reduce emissions. As prescribed by the authorities, the emissions from combined heat and power plants are measured regularly to monitor compliance with the relevant thresholds. In addition, waste gas treatment processes can be used to reduce emissions.
Moreover, certain technical and organizational measures serve specifically to protect the soil. These measures include systems that comply with Germany’s Ordinance on Installations for Handling Substances Hazardous to Water (AwSV) such as gas stations or oil storage depots designed to prevent fuel-contaminated water from entering the soil or sewage system. Moreover, paved surfaces with separators are deployed at washing stations to mitigate the risk that any fuel adhering to the object being washed enters the ground. In addition, the proper collection of waste in labeled containers – coupled with proper disposal – is intended to prevent waste from entering the environment. Alarm and contingency plans are also available, which are supported by the site fire department and are intended to facilitate a rapid response in the event of an incident.
The examples outlined above are operational environmental and energy management actions that are implemented decentrally and adapted to the situation at the respective site. At the policy level, the central actions are the classification of thyssenkrupp companies as environmentally relevant or energy-relevant and the obligatory introduction of corresponding management systems. No further policy steps are planned at present.
In the energy management area, the GEEP has been created as an instrument to define targets for reducing energy consumption and consolidate actions to optimize processes, utilize waste heat and modernize technical installations. In the 2024 / 2025 reporting year, around 162 GWh were saved by GEEP, which is equivalent to the avoidance of around 75 kt CO2e. Further efficiency gains of at least 110 GWh are planned for fiscal year 2025 / 2026. Improving energy efficiency may not only contribute to mitigating GHG gases but also cut emissions of airborne pollutants such as nitrogen oxides, sulfur dioxide and particulate matter in relation to fossil fuels.
Human rights and environmental due diligence obligations
For the implementation of human rights and environmental due diligence obligations, thyssenkrupp has established a process that considers both its own business activities and those of its direct and indirect suppliers. The main tool for this is the risk analysis – both annual and ad hoc – that is performed using a standardized process. The risk assessment for our own company is based on a structured self-disclosure process. In the analysis of the supply chain, external risk indices, geographical and industry-specific factors and additional findings (e.g., from audits) are used to identify site- and supplier-specific risks. An ad hoc analysis must be performed if justified reports are received of risks at indirect suppliers.
If the risk analysis identifies human rights or environmental risks, appropriate preventive action must be initiated. This ranges from the contractual specification of training and awareness actions through to auditing and certification. The appropriate preventive action is selected on a risk basis from a groupwide catalog. The effectiveness of the actions must also be documented and reviewed regularly.
In the event of actual or imminent violations, remedial action must be taken without delay. Such action includes supplier declarations, action plans and – in the case of severe or non-remediable violations – the phased termination of a business relationship. However, priority is given to the principle of enablement over termination. This means that a business relationship should only be terminated if less severe remedies are not effective or not available. Remedial action must always be documented and monitored.
The process to implement human rights and environmental due diligence obligations is anchored in thyssenkrupp’s governance structure. Reports received via channels such as the whistleblower system are recorded and assessed systematically; if necessary, they are included in the risk analysis.
At the policy level, the central action in implementing human rights and environmental due diligence obligations is regular risk analysis, coupled with the initiation of needs-based preventive, mitigating and remedial action. No further policy steps are planned at present.
Water management plan of thyssenkrupp Steel Europe AG
The water management plan of thyssenkrupp Steel Europe AG at the Duisburg-Nord site includes measures aimed at avoiding or reducing the discharge of pollutants into surface waters and the associated environmental and health risks. The measures can be divided into three main categories:
Technical and operational measures to avoid and treat wastewater
The focus is on closed water circulation systems in which process waster is reused, thus reducing the volume of wastewater. As a rule, this not only cuts the volume of water discharged but also, depending on the composition and level of treatment, the impact on the receiving waters. The wastewater from production processes goes through a multistage treatment process to improve its quality. Depending on its type and composition, the treated wastewater is either discharged indirectly via the Emschergenossenschaft or, after appropriate treatment, directly into the Rhine. The discharge points are also subject to continuous monitoring by the company; in addition, the authorities perform regular controls.
In addition, existing site installations are being optimized by way of technical modernization in order to improve wastewater quality. Moreover, the water management plan in accordance with water regulations specifies that the site’s sewers are inspected regularly by specialist companies. Any findings must be documented so that the sewers can be remediated if necessary. The goal is to identify and remedy any leaks, the ingress of water from other sources or potential backwater effects at an early stage to support the treatment and discharge of the wastewater in accordance with regulations and reduce the risk of unintentional contamination.
The company’s own polder system, which protects vulnerable installations such as the hot strip mill against increased groundwater levels, forms part of the overall water management concept and contributes indirectly to stabilizing the drainage and wastewater systems. This reduces potential backwater effects and infrastructure-related risks in connection with wastewater discharges. As a result, it is also possible to reduce the risks of an unintentional build-up of backwater, leaks and overflows, which may also cause a discharge of contaminated water.
Technical safeguards and organizational measures
The water protection system at the Duisburg-Nord site ensures the safe handling of substances that are hazardous to water quality through the use of technical safeguards such as collection basins, double-walled plant components and systematic leak testing. In addition, all employees who work with such substances receive regular training in accordance with statutory requirements. The goal is to foster safe and environmentally compatible behavior in day-to-day operations, minimize potential sources of error and enable appropriate reactions in the event of an incident.
Risk assessment and collaborations
As a further risk prevention measure, the water management plan also specifies the regular assessment of potential risks from flooding and intense rain events on the basis of official hazard maps and in collaboration with the Emschergenossenschaft. These assessments are intended to avoid overloading the drainage system and prevent the associated risks of unintentional wastewater discharges. In addition, regular dialog with other commercial water consumers within the Emschergenossenschaft is aimed at supporting the resource-efficient use of water. This dialog aims to develop joint solutions for the efficient use of available water resources, such as restricting wastewater volumes and potential contamination.
The actions described are the operational elements of the water management plan and are implemented as part of the water protection system at the Duisburg-Nord site. At the aggregated level, they also serve as the policy implementation action. No further policy actions are planned at present.