Impact, risk and opportunity management
E3-1 – Policies related to water and marine resources
The policies presented below in connection with this disclosure requirement address matters relating to water in the company’s own operations, including the procurement and use of water, wastewater treatment as an element of sustainable water use and the prevention or mitigation of water pollution. The water management plan at the Duisburg-Nord site includes, in particular, a closed loop for process water and multistage wastewater treatment. Marine resources are not an explicit component of these policies, but are not explicitly excluded either.
The systematic inclusion of water-related aspects in product and service design is currently not part of the policies discussed in connection with this disclosure requirement. However, topics like these are addressed individually in other group policies such as the environmental and energy policy or product life cycle management policy. There is currently no separate group policy on integrating water-related requirements in product and service design.
Human rights and environmental due diligence obligations, which cover thyssenkrupp’s own operations and those of its direct and indirect suppliers, require the avoidance of excessive water consumption, also in water risk regions. At present, there is no explicit inclusion of downstream stages in the value chain.
There are currently no sites in areas of high water stress that are not covered by a corresponding policy. There are no separate corporate policies specifically for these regions. However, the due diligence obligations and business continuity management apply groupwide and also cover sites in water risk regions.
There is currently no specific corporate policy on protecting the marine ecosystem.
Human rights and environmental due diligence obligations
In the context of human rights and environmental due diligence obligations, thyssenkrupp considers the potential negative impacts on water resources and aquatic ecosystems, including those that could result from excessive water consumption or from disproportionate water withdrawals in the context of the company’s own business activities. The use of large quantities of water – especially at sites in regions at risk from water stress – may result in the overexploitation of local resources, intensify conflicts between user groups and have a negative impact on the resilience of water-dependent ecosystems. In addition, the restricted availability of water may endanger the security of supply to neighboring communities – for example, in respect of their access to drinking water, agricultural use and other material provisioning services. Moreover, excessive water withdrawals harbor the risk of hydrological imbalances, the loss of habitat and long-term disruptions to environmental functions.
One goal of these due diligence obligations is to avoid excessive interventions in natural water resources, maintain the ecological integrity of water resources and ensure that there is no risk to the long-term availability of water for the environment and society. In order to prevent, mitigate and remedy such impacts, thyssenkrupp’s group policy obliges all its own establishments to comply with water-related environmental requirements, both national and international. At the same time, the water-related aspects described are integrated in the company’s risk management systems, which have the goal of prevention, remedial action and the continuous monitoring of effectiveness.
Further information on human rights and environmental due diligence obligations can be found in subsection “E2-1.”
Business continuity management
With its groupwide business continuity management, thyssenkrupp takes a preventive approach to ensure that defined actions can be implemented to restart operations as quickly as possible in the event of failure or damage – for example, in the case of water-dependent processes such as the use of waterways for transport and logistics. The goal is to identify relevant risks at an early stage and to effectively mitigate their impacts should they arise. In this context, risks are considered that could restrict the availability of water – for example, as the result of local water scarcity or technical failure of the water supply infrastructure. These may impair the function of water-dependent processes and result in the disruption of production activities in regions at risk from water stress.
In order to effectively manage business continuity, all group companies are required to prepare a business continuity plan (BCP) in accordance with a groupwide procedure. Any existing plans must comply with the minimum standards specified in this procedure. The management of the group companies appoint members of their operational management teams to hold responsibility for this and require that their respective BCPs are reviewed and updated if necessary.
Water management plan of thyssenkrupp Steel Europe AG
At the Duisburg-Nord site, thyssenkrupp Steel Europe AG has implemented a water management plan aimed at ensuring the efficient use of water and at preventing, mitigating and remedying any potential negative impacts on aquatic ecosystems and society that might be caused by pollution due to industrial wastewater discharges. The water management plan is based on the requirements contained in permits in accordance with water regulations and includes quality-controlled processes for wastewater treatment prior to discharge into the Rhine.
The concept applies specifically at the Duisburg-Nord site. Developed in close consultation with the relevant authorities and water institutes, it takes account of technical conditions at the site and regional requirements relating to the water infrastructure. The focus is on protecting aquatic habitats and avoiding potential risks to the environment and human health due to pollution.
Further information on the water management plan can be found in subsection “E2-1.”
E3-2 – Actions and resources related to water and marine resources
The following disclosures describe the actions taken by thyssenkrupp and the resources made available to implement the policies described in subsection “E3-1” concerning the sustainable procurement and use of water, the treatment of wastewater in the context of sustainable water use and the prevention and mitigation of water pollution.
Human rights and environmental due diligence obligations
In the context of its human rights and environmental due diligence obligations, thyssenkrupp systematically identifies and assesses potential adverse impacts on society and the environment, including water resources and aquatic ecosystems, that could be caused by the company’s own operations. The assessment is performed on the basis of defined risk criteria and uses a standardized risk identification process.
If risks are identified, priority should be given to initiating preventive actions. In the event of incidents with relevant impacts, mitigation and clean-up actions must be implemented. Depending on the type of impact, suitable remedial action must also be initiated. It must be implemented on the basis of internal regulations that are applicable groupwide. Further information on human rights and environmental due diligence obligations can be found in subsection “E2-2.”
Business continuity management
The business continuity plan is the central instrument of business continuity management. Development of the plan requires the identification of site-related critical resources such as equipment, consumables (including water) and essential services, the limited supply of which could impair business processes. As a way of hedging supply risks, the process requires thyssenkrupp group companies to perform preventive risk assessments, also for water-dependent processes.
If these site-specific assessments reveal the high criticality of water-dependent processes, suitable mitigation actions must be implemented. These include alternative supply strategies such as an emergency water supply, hedging clauses in contracts with external water suppliers, investment in production technologies that use less water, and technical and organizational efficiency measures to reduce water consumption. These actions should be implemented on a risk basis at sites with identified water-related risks, such as increased water stress.
The risk analysis and the development of a business continuity plan are the central measures in managing business continuity. No further policy steps are planned at present.
Water management plan
The water management plan of thyssenkrupp Steel Europe AG at the Duisburg-Nord site includes measures to reduce freshwater consumption, cut wastewater volumes, treat wastewater and monitor wastewater quality. In particular, the closed loop for process water serves to reduce freshwater and wastewater volumes. Multistage purification processes are used to treat wastewater before it is transferred for discharge. Wastewater quality should be monitored by regular analysis in the context of thyssenkrupp’s own monitoring measures and testing by the authorities. Further information on the water management plan can be found in subsection “E2-2.”