Environmental stewardship policy

Introduction 

1.1 Objective 

At Umicore, we recognize the urgent need to transition toward a more sustainable future. Our business model is dedicated to delivering sustainable products and services, and to developing safe, sustainable, and innovative solutions that enhance the quality of life for people and the planet. This Environmental Stewardship Policy outlines how we manage material environmental impacts, risks, and opportunities across our operations and value chain¹. The policy establishes a framework that ensures responsible environmental stewardship and continuous improvement, with a strong focus on mitigating negative impacts and prioritizing sustainable practices.

1.2 Scope 

This policy applies to the Umicore Group’s global consolidated activities. 

1.3 Regulations

Umicore is committed to ensuring compliance with applicable environmental laws, regulations, and permits related to our operations as well as compliance with internal Umicore standards. We understand that safeguarding the environment is a shared responsibility and actively collaborate with experts, local communities, and stakeholders. 

General Principles

This policy is driven by a risk-based approach that focuses on managing the most material environmental impacts, risks, and opportunities for our operations. It offers guidance on areas that are significant to our business and to our stakeholders. By prioritizing material issues while capturing emerging concerns, we aim to mitigate negative environmental impacts, enhance resilience, and contribute to long-term sustainable development.

2.1 Climate Action

Umicore plays a key role in the transition to a low-carbon future. Our materials address the global need for clean air and clean mobility while supporting climate change mitigation and adaptation. We are reducing greenhouse gas emissions and improving energy efficiency across our operations. Our climate transition plan aligns with science-based targets and the Paris Agreement, ensuring that we mitigate climate-related risks and contribute to global decarbonization efforts. Our focus is on energy consumption, transitioning to renewable energy, and engaging with our supply chain to minimize the carbon footprint of our activities and products.

2.2 Pollution prevention and control

We prioritize the prevention of pollution through emissions to air, water, and soil within our direct operations. Controls, advanced abatement technologies, and continuous process improvements are implemented to reduce harmful emissions and meet both internal and external environmental standards, as well as local legal requirements.

2.3 Water Stewardship

We manage water resources responsibly, recognizing their critical role in both our operations and the health of ecosystems. Our approach focuses on prioritizing actions in water-stressed areas, reducing water consumption, improving wastewater treatments, adapting processes to enhance water efficiency, and addressing impacts on freshwater and marine water quality.

2.4 Circular economy and resource efficiency

Our commitment to a circular economy is most visible in how we have positioned our recycling activities as one of our core businesses and in the closed loop we can offer our customers. Resource efficiency is central to how we operate. We design our processes and products for quality, efficiency, longevity and recycling. We ensure that waste is minimized and that resources can be continuously reintegrated into the production cycle. We maximize the use of secondary and recycled materials and reduce primary resource use whenever feasible as a key piece of our business model.

Managing Impacts

Our approach is built on a robust, multi-level enterprise risk management (ERM) framework that includes a Business Risk Assessment (BRA), which is carried out across the Group, and the impact, risk and opportunity-based double materiality assessment required under the Corporate Sustainability Reporting Directive (CSRD). 

• Each site conducts and documents environmental risk assessments, identifying and managing specific risks and impacts relevant to their operations. This process includes developing localized mitigation strategies, action plans, and monitoring progress. 
• Each Business Unit screens business partners in their value chain. This screening process evaluates whether current or prospective partners, contractors, or other third parties meet the required standards for ESG practices, and other identified risks. It identifies, prevents, and mitigates material environmental, social, financial, legal, and reputational risks, ensuring alignment with our Umicore's risk-based due diligence standards. 

We integrate climate-related and environmental risks into our broader ERM process. Our assessment includes both physical risks (e.g., extreme weather events, water scarcity) and transition risks (e.g., regulatory changes, market shifts). We use a scenario-based approach to assess the short-, medium-, and long-term impacts.

Implementation 

Our Environmental Management System (EMS) is implemented across all sites to drive continuous improvement in environmental performance. Efficient management of environmental services is critical to safeguarding human health, the environment, and the communities in which we operate. We prioritize safety and maintain a robust emergency response program to ensure rapid action in the event of environmental incidents.

4.1 Climate change

For Scope 1 and 2 emissions the action plan follows a three-tiered approach:

1. Avoiding emissions wherever possible,
2. Replacing high-carbon energy sources with renewable and zero-carbon alternatives, and
3. Capturing residual emissions through innovative technologies.

Efficiency is a key operational component of avoiding emissions. Each site is expected to:

• Identify and implement energy-efficiency and/or carbon reduction projects that deliver value, reducing both energy use and emissions.
• Evaluate capital investments for their impact on our decarbonization roadmap. We prioritize low- and zero-carbon, energy-efficient options wherever feasible. This evaluation is supported by a diversified shadow carbon pricing model, which reflects the potential financial impacts of carbon-related costs to inform investment decisions.

For Scope 3 emissions—those generated across our value chain, including from suppliers, transport, and disposal of our products—we are addressing the largest contributor to our footprint, raw materials, by:

1. Engaging suppliers to reduce the carbon intensity of raw materials, through data transparency, and through responsible and strategic sourcing,
2. Promoting circularity by closing material loops and increasing the volume of recycled content in our input.

Addressing the raw material impact also leads to reducing the overall carbon footprint of the product delivered to the customer. We are expanding the use of life cycle assessments (LCA) to measure the improvement of lower footprint raw materials and identify further ways to reduce emissions associated with the entire product lifecycle.

In addition, as part of our Sustainable Logistics Roadmap to reduce emissions from transporting raw materials, products, and waste, we are improving data quality and reporting of transport-related emissions, aligning our practices with globally recognized methodologies, exploring low-carbon transport options, and seeking strategic partnerships and innovative solutions. 

We also foster minimizing transport-related emissions from employee mobility. We promote the use of low-carbon travel alternatives for commuting and business travel, and continuously encourage our employees to adopt sustainable transportation options.

4.2 Emissions to air, water and soil

Umicore sites have made significant progress in reducing emissions, even as production volumes have grown. We remain focused on further mitigating the potential impacts of our emissions by continuously refining our processes and implementing advanced abatement technologies. Guided by internal standards, e.g., Ambient Air Quality Program, our approach emphasizes prevention, monitoring, and continuous improvement in emissions management to minimize environmental impact.

4.3 Water and marine resources

We manage water resources with a focus on reducing consumption in water-stressed areas and maintaining the quality of freshwater or marine environments where we have direct influence. Each site’s water-related measures are tailored to local operational context and environmental conditions, ensuring local regulatory compliance and minimizing our overall environmental impact.

4.4 Resource use and transition to circular economy

We recover precious and non-ferrous metals from industrial waste, end-of-life products, and scrap materials through high-efficiency processes that minimize waste generation. Our recycling activities reduce reliance on primary materials, address resource scarcity, and foster innovation in sustainable materials management. Our secondary materials are sourced and treated responsibly, ensuring sustainable practices throughout the recycling chain. We collaborate with customers to design products with lower lifecycle emissions, particularly through enhanced recyclability, whenever possible.

While we strive to maximize the use of secondary-sourced materials and reuse any waste from our processes, we recognize that processing some primary-sourced materials remains necessary. To mitigate this, we prioritize responsible sourcing across our supply chain, guided by our dedicated sourcing frameworks.

As a recycler of highly complex waste streams, the nature and quantities of our waste—whether hazardous or non-hazardous—are directly linked to the diversity and composition of input materials we process. This complexity highlights the challenge of implementing waste reduction strategies and the consequent focus on ensuring the best environmental outcomes instead.

4.5 Other impacts on the environment

Other environmental impacts may be identified during risk assessments or through engagement with local stakeholders. As part of prioritizing responsible land use, sites are expected to identify and address local environmental characteristics and integrate necessary mitigation and/or remediation actions into their operations, where applicable. At Group level, we have applied the LEAP (Locate, Evaluate, Assess, Prepare) approach to map potential interactions with protected ecosystems. This approach supports preparation for regulatory evolutions on environmental topics, e.g., biodiversity.

Monitoring and Reporting

Each site tracks, monitors, and reports environmental data into the EMS, and ensures that data is regularly evaluated against both internal targets and external regulatory requirements. The centralization of data ensures consistent reporting and supports decision-making and compliance with regulatory requirements. The Group reports environmental performance within the sustainability statements of the annual consolidated report. A recognized third-party auditor provides limited assurance on CSRD compliance of reported environmental data. 

Governance 

We emphasize collective responsibility, with every employee contributing to environmental awareness and continuous improvement. Group EHS and ESG collaborate with site managers and local EHS managers to ensure implementation of this policy and environmental performance programs. Business Units are responsible for ensuring their environmental performance is aligned with Group sustainability objectives. The SVP EHS oversees compliance, risk mitigation, and data reporting across the Group. The EVP ESG leads ESG strategy, performance, and compliance within the Executive Leadership Team, while the Supervisory Board’s Sustainability Committee ensures the necessary policies and processes are in place and monitors performance. Umicore’s Executive Remuneration Policy includes environmental performance targets to drive accountability.

Annex: Environmental stewardship performance objectives

In line with then European Corporate Sustainability Reporting Directive (CSRD) requirements, Umicore reports on its environmental performance, targets, and progress in its annual sustainability disclosures. The most up-to-date information, including long-term ambitions and detailed performance data, can be found in our Annual Report and/or in the sustainability area of the Umicore website.

This annex outlines the current set of environmental objectives under Umicore’s Environmental Stewardship Policy. These objectives reflect our near-term priorities and are subject to periodic review based on regulatory developments, business priorities, and advancements in environmental best practices.

This policy was approved by the EVP ESG and EHS. Group ESG is responsible for reviewing the policy no later than December 2025. The last update was recorded on September 24, 2024. 

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^{1 We incorporate the risk-based approach in our Global Sustainable Sourcing Policy and Product Stewardship Policy, to manage environmental risks and opportunities across our supply chain and product lifecycle.}