About This Report

1. The chart indicates which facilities were included in the scope of the sustainable development data. Only data from these facilities are included in this section, which may therefore show inconsistencies with the annual report covering all facilities. Please revert to Trade Register filing dated March 10, 2022 for a full list of group companies of the AMG Group.
2. Sales, administrative, and smaller engineering sites with estimated data.

The reporting boundaries have changed since 2020 to include AMG Lithium located in Frankfurt, Germany. The thirty-four locations reporting in 2021 (in which AMG has a 51% or greater stockholding) are detailed in the Locations of Operations. AMG uses actual data for all facilities within the reporting boundary except for sales and administrative offices and some smaller engineering sites (typically with less than 10 employees or with environmental impacts <1% in all aspects) which have been determined to be non-material to the report, and therefore estimated data has been used for these locations in 2021. Facilities that were in the ramp-up phase of commissioning during the reporting period are excluded from the reporting boundaries. Those sites utilizing estimated data are indicated in the Locations of Operations table.

AMG reporting locations include mining, manufacturing, sales, and administrative offices in fourteen countries across five continents. This report covers AMG’s three operating segments: AMG Clean Energy Materials, AMG Critical Minerals, and AMG Critical Materials Technologies, which report their full year performance at the end of the fourth quarter, with, in some cases, estimated data provided for the final month of the year. Due to reorganization and reporting structure changes, we are reporting consolidated data at the AMG Group level only.

AMG endorses and supports the definition of corporate social responsibility as set by the World Business Council for Sustainable Development: “…the continuing commitment by business to behave ethically and contribute to economic development while improving the quality of life of the workforce and their families as well as of the local community and society at large.” For AMG and its affiliated companies, this definition translates into four main sustainable development objectives that the Company has formulated in line with its financial objectives, technological capabilities, and its leading position in the global metallurgical industry. These objectives are to:

• Provide safe working conditions for our employees and be responsible stewards of the environment.
• Meet or exceed regulatory standards by engaging in ethical business practices.
• Be a valued member of the local economy, community, and society by contributing to solutions to address some of the fundamental environmental and social challenges facing society today.
• Target industrial activities which either contribute to the reduction of greenhouse gas levels through the circular economy or by arriving at technologies which enable our business partners to reduce greenhouse gas levels and quantify the success of these endeavors.

AMG’s Supervisory Board and Management Board are guided by these objectives when defining and implementing the Company’s strategic objectives.

The Management Board members are collectively responsible for building a culture within AMG focused on long-term value creation. Each Management Board member has the responsibility to serve the best interests of the Company and its stakeholders.

The Supervisory Board oversees the Management Board’s implementation of the long-term value-creation strategy of AMG. The Supervisory Board regularly discusses the strategy, implementation of the strategy, and principal risks associated with the strategy.

The Vice President of Sustainability, Environment, Health, and Safety is responsible for the overall sustainability strategy for the organization and reports results to the Management Board on a regular basis.

AMG conducts materiality assessments to advance its sustainability program by identifying environmental, social, governance, and product-related impacts, risks, and opportunities that are most critical to AMG’s business and stakeholders. The results of these materiality assessments informed the content of this report, including specific topics and metrics to track and disclose. ESG Materiality assessments by nature are not static and related disclosures may change over time. AMG’s list of material issues was developed primarily through two exercises: desktop research including peer benchmarking and stakeholder interviews.

• Desktop Research: A third-party consulting partner reviewed publicly available information, such as relevant Global Reporting Initiative and Sustainability Accounting Standards Board standards and conducted benchmarking of several peer companies using publicly available sustainability reports and websites. This information was used to develop a list of relevant sustainability topics to guide stakeholder interviews.
• Stakeholder Interviews: The third-party consulting partner also interviewed AMG executives, including AMG’s Chief Executive Officer, Chief Operations Officer, Chief Financial Officer, Vice President of Corporate Development, Vice President of Investor Relations, and Vice President of Sustainability, Environment, Health, and Safety. Insights were gathered on sustainability impacts, risks, and opportunities across AMG’s value chain. These internal stakeholders vetted the list of sustainability topics developed from the desktop research for relevance and significance given their understanding of corporate risk formed through the ongoing company-wide risk assessment process. Additionally, information gathered through routine engagements and dialogue with customers, investors, regulatory agencies, and community groups was considered and informed their feedback on material sustainable topics. The list of sustainability topics was narrowed down to a priority list of material sustainability topics for AMG.

In 2021, AMG reviewed the Materiality Assessment taking into consideration stakeholder engagements and determined that previously identified material topics for AMG were still applicable and no additions were required.

Material topics were considered across AMG’s supply and value chain:

AMG’s Supply and Value Chain

Throughout this report, we report on the ESG topics that have been identified as most significant in accordance with GRI methodology, detailing our management approach and key metrics for measuring performance across such topics.

The priority list of material sustainability topics for AMG are provided in the table below:

Extractive Industries Transparency Initiative

AMG continues its support of the Extractive Industries Transparency Initiative (EITI), a global initiative to improve governance in resource-rich countries through the verification and full publication of Company payments and government revenues from oil, gas, and mining. EITI works to build multi-stakeholder partnerships in developing countries to increase the accountability of governments. Over 30 countries have now committed to the EITI principles and criteria. As of today, AMG has two extractive operations in EITI-implementing countries: Germany and Mozambique.

United Nations Global Compact

AMG is an active participant in the United Nations Global Compact. The Global Compact is a strategic policy initiative for businesses that, like AMG, are dedicated to aligning their operations and strategies with 10 universally accepted principles in the areas of human rights, labor, the environment, and anti-corruption. Since 2009, the AMG Management Board has expressed its commitment to the Global Compact and its intent to support the 10 principles. AMG reaffirms its support and submits its Communication on Progress annually.

CHURCH OF ENGLAND INVESTOR MINING AND TAILINGS SAFETY INITIATIVE

AMG participates with the Church of England Investor Mining and Tailings Safety Initiative to provide disclosures regarding the management of tailings storage facilities.  Information regarding AMG Mining disclosures can be found at the Church of England Global Tailings Portal.

AMG is currently in the process of completing a gap analysis of our current mining and tailings management system to the Global Industry Standard on Tailings Management, August 2020 (GISTM). Although we are confident that our current management system addresses the applicable requirements of the GISTM, AMG is committed to the closure of any identified gaps, if identified, which directly affect the safe design, construction, operation, and closure of AMG tailings facilities.

Memberships

AMG is a participating member of the International Antimony Association, International Lithium Association, and Vanitec, with employees serving on the governance body for each organization. The International Antimony Association or i2a is the Brussels-based organization representing the producers, importers and users of multiple Antimony substances. i2a’s aim is the sustainable and responsible production, use and recycling of Antimony. ILiA is the global trade association for the lithium industry and represents the entire lithium value chain. The Association was established in 2021 as an international not-for-profit industry association run by and for its members. ILiA, supports the lithium industry’s efforts to supply high quality lithium sustainably and responsibly, and proactively promote a better understanding of ILiA members’ ESG credentials. Vanitec brings together representatives of companies and organizations involved in the mining, processing, manufacture, research and safe use of vanadium and vanadium-containing products.

ESG Rating Agencies

AMG is actively engaged with ESG Rating Agencies which through publicly available sustainability information and direct engagement, provide AMG with scores based upon its environmental, social, and governance performance. AMG is committed to improving its scoring with these rating agencies through policy improvement, increased engagement, and identification of risks, opportunities, and mitigation within AMG. The rating agencies AMG is fully engaged with are ISS Corporate Solutions, Inc., Sustainalytics, Carbon Disclosure Project (CDP), and EcoVadis.

The EU Taxonomy Regulation requires companies, such as AMG, to report on the share of the Revenue, Capital Expenditure and Operational Expenditure that are aligned with environmental objectives laid out in the Taxonomy directive.
We apply the following regulations and definitions internally relating to the Taxonomy:

• Taxonomy Regulation – Regulation (EU) 2020/852 of the European Parliament and of the Council of June 18, 2020 on the establishment of a framework to facilitate sustainable investment and amending Regulation (EU) 2019/2088.
• Climate Delegated Act – Commission Delegated Regulation (EU) 2021/2139 of June 4, 2021 supplementing Regulation (EU) 2020/852 of the European Parliament and of the Council by establishing the technical screening criteria for determining the conditions under which an economic activity qualifies as contributing substantially to climate change mitigation or climate change adaptation and for determining whether that economic activity causes no significant harm to any of the other environmental objectives.
• Taxonomy-Eligible – Economic activities that can make a substantial contribution to one or more environmental objectives under the Taxonomy Regulation, and consequently have received technical screening criteria.
• Taxonomy Non-Eligible – means any economic activity that is not described in the delegated acts supplementing the Taxonomy Regulation.
• Taxonomy-Aligned – An economic activity is environmentally sustainable and aligned where that activity:
  • Makes a substantial contribution to one or more environmental objectives.
  • Does not significantly harm any of the environmental objectives.
  • Is carried out in compliance with the minimum social safeguards, and
  • Complies with the established technical screening criteria.
• Transitional activities – These are activities for which there are no technologically and economically feasible low-carbon alternatives, but that support the transition to a climate-neutral economy in a manner that is consistent with a pathway to limit the temperature increase to 1.5 degrees Celsius above pre-industrial levels, for example by phasing out greenhouse gas emissions.
• Enabling Activities – These are activities that enable other activities to make a substantial contribution to one or more of the environmental objectives, and where that activity:
  • Does not lead to lock-in assets that undermine long-term environmental goals considering the economic lifetime of those assets; and
  • Has a substantial positive environmental impact based on lifecycle considerations.

For 2021 the reporting requirements are limited to eligibility. Activities identified as eligible during this reporting period does not necessarily mean that these activities will be disclosed as Taxonomy-Aligned in subsequent reports. Future reports will include KPIs on Taxonomy-Alignment when the full Taxonomy Regulation is promulgated.

The regulation is complex and still under development. As an example, on February 2, 2022, the European Commission approved, in principle, the Complementary Climate Delegated Act to include specific nuclear and gas energy activities in the list of economic activities covered by the Taxonomy. AMG will assess the impact of these and other changes as they are presented. This disclosure was prepared based on our current interpretation of the Taxonomy Regulation, Climate Delegation Act, and the available data.

Taxonomy Approach

The Taxonomy Regulation requires the adoption of a “bottom-up” approach. The approach AMG has taken follows 5 steps:

1. Identified AMG’s economic activities over financial year 2021.
2. Performed an assessment of economic activities to determine if they could be linked to the activities as published in the EU Taxonomy Climate Delegated Act and be identified as Taxonomy-Eligible economic activities.
3. Technically screened each economic activity to determine if the activity substantially contributes to climate change mitigation and/or adaption.
4. Further screened economic activities that are determined to substantially contribute to climate change mitigation and/or adaption, to confirm they do no significant harm to any of the other environmental objectives; and
5. Confirmed that the economic activity complies with minimum social safeguards.

Core business activities and external turnover

Our assessment of Taxonomy-Eligible activities is focused on economic activities defined as the offering of goods or services in a market, thus (potentially) generating revenues (at the present time or in the future). AMG is a producer of highly engineered specialty metals and mineral products and provide related vacuum furnace systems and services to the transportation, infrastructure, energy, and specialty metals and chemicals end markets. In this context, we assess our business by our contribution to provide climate neutral, low carbon, and other low carbon technologies. Therefore, the eligible activities (described below) represent our core business activities which we evaluate against the Taxonomy Regulation.

Taxonomy-Eligible economic activities:

We have examined the relevant Taxonomy-Eligible economic activities based on our activities and assigned them to the following economic activities in accordance with Annex I and II of the Climate Delegated Act. The table below indicates for which environmental objective the activities qualify as eligible:

It was determined that all of our activities should be allocated to climate change mitigation as the contribution to climate change adaptation and the Taxonomy does not allow double counting.

Our KPIs and Accounting Policies

The key performance indicators (“KPIs”) include the turnover KPI, the Capex KPI and the Opex KPI. For the reporting period 2021, the KPIs must be disclosed in relation to our Taxonomy-eligible and Taxonomy-non-eligible economic activities (Art. 10 (2) of the Art. 8 Delegated Act).
The specification of the KPIs is determined in accordance with Annex I of the Art. 8 Delegated Act. We determine the Taxonomy-eligible KPIs in accordance with the legal requirements and describe our accounting policy in this regard as follows:

Turnover KPI

The proportion of Taxonomy-eligible economic activities in our total turnover has been calculated as the part of net turnover derived from products and services associated with Taxonomy-eligible economic activities (numerator) divided by the net turnover (denominator), in each case for the financial year from 1.1.2021 to 31.12.2021.

The denominator of the turnover KPI is based on our consolidated net turnover in accordance with IAS 1.82(a). For further details on our accounting policies, refer to note 3(c) and note 5 within the notes to the consolidated financial statements contained in the 2021 Annual Report.

The numerator of the turnover KPI is defined as the net turnover derived from the following products and services associated with Taxonomy-eligible economic activities:

Activity 3.4. Manufacture of batteries – generates net turnover from the sale of Graphite, Lithium and Silicon materials for electric vehicle batteries.

Activity 3.5. Manufacture of energy efficiency equipment for buildings – generates net turnover from the sale of Graphite for Gray Insulation and coating products for Low-E Glass for buildings. AMG’s high-purity natural graphite is primarily used in the infrastructure industry as thermal insulation for the building materials. AMG also produces a variety of low-E coating materials used in the windows manufacturing industry. Low-E coatings in insulated glass units (IGUs) are key to lowering energy expenditures in the built environment, achieved by reducing heating (passive low-E glasses) or cooling (solar control low-E glasses) requirements.

Activity 3.9. Manufacture of iron and steel generates net turnover from the sale of ferrovanadium, ferroniobium, and nickel niobium alloys. AMG Vanadium produces a low-aluminum ferrovanadium known as FEROVAN®. This engineered product is used in a broad range of applications such as structural steel, high strength low alloy (HSLA) steel, flat rolled products, reinforcing bar, line pipe, and rail steel. FEROVAN® offers advantages to steelmakers over other vanadium alloys including a low melting point, low aluminum content, low carbon content, maximum recoveries in less time, improved cast product quality, application versatility and custom packaging. When added to carbon steel, ferrovanadium creates a high performance HSLA steel with extremely high tensile strength.

AMG Vanadium’s ferronickel-molybdenum alloy co-product called FeNiMoly® is produced from the continuous production of ferrovanadium and provides a cost savings to customers through its replacement of primary nickel products, ferromolybdenum and molybdenum oxide, and scrap. FeNiMoly® is available in ingots which are used to produce stainless steel, special bar quality steel, and low alloy steels such as 4300 and 8600.

CapEx KPI

Our CapEx KPI represents the proportion of a non-financial undertaking’s capital expenditure that is either already associated with environmentally sustainable economic activities or is part of a credible plan to extend such activities or for activities which are not yet taxonomy-aligned. During 2021, AMG had three major projects to extend or create environmentally sustainable economic activities. These activities included the construction of our spent catalyst recycling project in Zanesville, Ohio, development of our first module of the battery-grade lithium hydroxide upgrader, and development of our lithium vanadium battery (“LIVA”) for industrial power management applications. CapEx for each project was considered 100% eligible.

Our consolidated amount for 2021 is shown in the table below. The consolidated CapEx amount includes assets pertaining to lease arrangements accounted for under IFRS 16 and capitalized borrowing costs.

OpEx KPI

Our OpEx KPI represents the proportion of operating expenditure associated with environmentally sustainable economic activities or the above-mentioned CapEx plan. The operating expenditure covers essentially non-capitalized costs relating to the maintenance and servicing of company assets (plant, equipment) that are necessary to ensure the continued and effective use of such assets associated with taxonomy-alignment.

Our Activities:

The following provides AMG’s disclosure on the proportion of Taxonomy-eligible and non-eligible KPI’s for Revenue, Capital Expenditure (CAPEX) and Operational Expenditure (OPEX).

Art. 8 (2) Taxonomy Regulation in conjunction with Art. 10 (2) of the Art. 8 Delegated Act

Table 1 – Proportion of Taxonomy-Eligible and Taxonomy-Non-Eligible economic activities in total Revenue, CapEx, and OpEx

General Disclosures

Specific Disclosures