Embracing the concept of sustainability for a business first of all means showing responsibility.

For our owners, we have a responsibility to deliver value. For our employees, we aim to offer reliable employment, fair working conditions, and a safe work environment. For our customers, we are responsible for the quality of our products and services – classically, this is meeting the customers’ specifications related to alloy type, quantity, time of delivery etc. Beyond that we recognize our responsibility to prevent wasting natural resources and energy as well as to carefully manage our emissions and releases into the environment. These are mere starting points for a long journey. But we see our entire industry transform from cost-orientation to sustainability-orientation - a transformation which is demanded from both society and customers. At REAL ALLOY, our mission is to capture the inherent economic value of recycled Aluminium by offering environmentally responsible processing solutions.

We understand today’s imperative for sustainable resources and are proud to supply our customers with high-quality recycled Aluminium and Magnesium. In comparison to primary Aluminium the production of our alloys requires much less energy and results in far lower CO2 emissions. This process-based advantage is complemented by continual improvement of our operations, efficient and intelligent sourcing, development alongside the entire recycling value chain, and the employment of digital solutions. This all will help us to futher reduce our ecological footprint and to successfully work towards sustainability.

Russell Barr
EXECUTIVE VICE PRESIDENT
AND MANAGING DIRECTOR EUROPE

REAL ALLOY is the European and global market leader in third-party Aluminium recycling and specification alloy production. We convert Aluminium scrap and by-products into reusable Aluminium metal for a growing number of applications across various industries.

Our customers can choose from an extensive range of cast and wrought alloys made from Aluminium scrap and metal, delivered to their door in the form of molten metal, Recycled Secondary Ingots (RSI), small ingots, or cones. Additionally, we also produce various magnesium alloys based on Magnesium scrap and metal, delivered as solid ingot form. With six facilities in three countries in Europe, REAL ALLOY is ideally positioned to respond to the needs of an increasingly recycling-conscious world.

Advanced technologies enable us to process a large variety of scrap types and skimmings. Therefore, our products are widely based on low CO2 footprints. This report summarises the efforts towards sustainability at REAL ALLOY with our German sites Grevenbroich, Deizisau, and Töging, our Norwegian sites Eidsvåg and Raudsand, and our site in Swansea, UK.

REAL ALLOY's employees are spread across six production sites in Europe, yet they are all united by the REAL ALLOY mission. We share a passion for excellence and are committed to integrity and accountability. At each site, our teams foster an environment of trust and empowerment, where good ideas are encouraged and setbacks are viewed as learning opportunities. Always tuned in to the bigger picture, we are motivated by a strong sense of responsibility towards our colleagues, customers, suppliers, other business partners, and our communities.

Our values define what we stand for. In addition, our policies provide a framework and directions and set clear expectations on an ethical and responsible approach to business not only for all our managers and employees, but also for our suppliers. They describe how our business partners and all our stakeholders may expect us to operate. Among these REAL ALLOY policies are:

Respect for Human Rights, including Women's Rights, and Labour Rights are foundations of our corporate culture. We have a clear commitment to legal compliance and strictly oppose any form of discrimination and harassment, child labour or forced labour or any other un-ethical behaviour. By joining the Aluminium Stewardship Initiative in November 2019 we have made a clear commitment towards sustainability:

To this end we have also strengthened our organization by allocating additional resources to both sustainability and health & safety.

With Aluminium recycling at the core of our business, Aluminium stewardship is an inherent part of our corporate “fabric”. Thus, becoming a member of ASI seems a natural step for us to make. We are looking forward to becoming a part of the ASI community and to benefit from as much as contribute to the sharing and learning offered by their members.

Russell Barr
EXECUTIVE VICE PRESIDENT AND
MANAGING DIRECTOR EUROPE

We seek to outperform our competition fairly and honestly. We seek competitive advantages through superior performance and our processes, never through unethical or illegal business practices.

It is our strong commitment to comply with all applicable international, national and local laws and regulations, contractual agreements and internationally recognized standards. Our practices conform to generally accepted industry standards. We obtain, maintain and keep up-to-date all applicable permits, certificates, licences and registrations.
REAL ALLOY expects its employees, contractors, and business partners to refrain from unethical or illegal business practices such as offering or giving to any person bribes, preferential benefits and kickbacks, or soliciting or accepting from any person bribes, preferential benefits and kickbacks. The laws to adhere to include the U.S. Foreign Corrupt Practices Act (“FCPA”) and the UK Bribery Act 2010, which apply everywhere REAL ALLOY does business globally, as well as all applicable anti-corruption laws in each country of business activities.
Anti-corruption laws as well as the REAL ALLOY Code of Conduct prohibit offering or giving anything of value, directly or indirectly, to any government official to influence decisions or the performance of official functions in order to obtain or retain business or secure an improper advantage. These laws as well as our Code of Conduct also prohibit making improper payments to persons who are not government officials, known as “commercial bribery”. Also offering – even if the offer is not accepted –, soliciting or accepting bribes is prohibited. We demand this compliance also from our business partners, as REAL ALLOY may be held liable for their actions.
In our Code of Conduct, we detail out how we expect our employees to act responsibly and in compliance with legal and ethical expectations and company requirements. REAL ALLOY’s Code of Conduct references Human Rights, including Women’s Rights, and Labour Rights. We are committed to provide a work environment that is free of unlawful discrimination and harassment. REAL ALLOY expects all employees to treat one another with respect, dignity, and professionalism.
The company will not tolerate discrimination or harassment of any form directed toward employees, applicants, contractors, customers, vendors or others on the basis of an individuals race, color, religion, sex, age, national origin, disability or any other characteristic protected under applicable law. REAL ALLOY’s policy addresses not only the core ISO topics – quality, health & safety, environment, and energy – but also engagement with stakeholders and resource efficiency.
Management board (from left to right)
Ralf Köring,
Russell Barr,
Uwe Wülbers,
Christoph Will,
Dr. Claudia Schiffer.
REAL ALLOY is committed to sound environmental management and practices. Our personnel must comply with environmental requirements applicable to our operations and obtain environmental permits when required. Any waste materials created from our operations must be disposed of following all applicable EU, national and state requirements. Any employee who becomes aware of a spill, release or other environmental event that might have a negative impact on employees, the community or the environment is required to promptly notify the necessary functions.

All employees are invited and expected to actively contribute to an environmentally compliant and safe workplace by following health & safety rules and practices and reporting accidents, injuries and unsafe equipment, practices or conditions. This requires them to understand the hazards and risks and to know about safe work practices. It also includes, if necessary, the authority to stop or refuse unsafe work.

REAL ALLOY’s Code of Conduct references Human Rights, including Women’s Rights, and Labour Rights. We are committed to provide a work environment that is free of unlawful discrimination and harassment. REAL ALLOY expects all employees to treat one another with respect, dignity and professionalism. The company will not tolerate discrimination or harassment of any form directed toward employees, applicants, contractors, customers, vendors or others on the basis of an individual’s race, color, religion, gender, age, national origin, disability or any other characteristic protected under applicable law.

REAL ALLOY wants it clearly understood that all its directors, officers, employees and agents are expected to adhere to the company’s Code of Conduct. Those who violate the standards of the code are subject to disciplinary action, up to and including termination of employment.
REAL ALLOY’s management board under the leadership of the Executive Vice President and Managing Director Europe sets the targets for the organization, including financial and operational performance, quality, health & safety, environment, energy, and general sustainability. An integrated management system based on ISO 14001 (environment), ISO 45001 (health & safety), ISO 50001 (energy), and ISO 9001 / IATF 16949 (quality) supports our continuous improvement efforts on any business aspect. It also facilitates compliance with legal requirements and other commitments and generates relevant information for regular performance review by the management team. While compliance is a minimum, it is still important that REAL ALLOY received no material fine in 2020 for non-compliance with applicable law.
Excelling in our business and equally recognizing our multiple responsibilities and commitments towards our various stakeholders can only be achieved by deploying structured, proven, and well monitored management approaches and systems. To this end, REAL ALLOY Europe has implemented an integrated management system, RAI. This system provides the backbone and infrastructure to define, communicate, implement and monitor our policies, process descriptions, standards, work instructions, etc. It also allows us to maintain and uphold our management system certifications that we have achieved for most of our sites on quality management (ISO 9001 and/or IATF 16949), health & safety management (ISO 45001 or OHRIS), environmental management (ISO 14001), and energy management (ISO 50001). By joining ASI, the scope of this management system has been extended to cover sustainability matters in general, for example sustainable supply chain management.

We continually look to improve the way we work, and our employees are always committed to delivering the right result. Sharing best practices among teams and different sites around our organization, performing structured process analyses, and applying Six Sigma tools helps REAL ALLOY capture and inspire creativity and innovation.

By complying with the various management system standards, we have decided not only to comply with all corresponding legal obligations, but also to improve our operational performance and efficiency continuously and systematically. These certifications are therefore one more important step on our way to sustainable business practices. The introduction of ISO-based certified management systems in our two Norwegian plants is already included in the strategic planning for the further development of our system, just like including more sites into the ASI certification after now starting with Deizisau.

The effectiveness and appropriateness of the management system is reviewed and monitored through structured and regular meetings involving all levels of the company. Regular business and operations reviews, dedicated HSEQ and project management reviews are complemented by regular team, functional, and cross functional meetings. These follow standardised reporting formats and are, where necessary, amended by ad hoc reports and information to senior management and all responsible managers of operational and functional units.

For REAL ALLOY, embracing the concept of sustainability for a business means showing responsibility. For our customers, we are responsible for the quality of our products and services. This includes maintaining a sustainable supply chain through supporting sustainable environmental, social and governance practices throughout our supply chain related activities.

Based on our ability to influence business partners and suppliers we support and encourage efforts towards a more sustainable supply chain of our goods and services by
  • identifying the key suppliers of the goods and services;
  • assessing the environmental, social and governance risks associated with our key suppliers;
  • using the outcomes of the risk assessment to inform the selection of our suppliers and attempt to influence positive and sustainable changes in our supply chain.
REAL ALLOY’s Supplier Sustainability Guideline was developed according to industry guidelines, in particular those provided by European Aluminium (EA) and the Aluminium Stewardship Initiative (ASI). The guideline follows a risk-based approach which uses independent human rights and environmental performance indices to help identify suppliers with potential sustainability risk. The assessment covers the following principles:
  • Suppliers are expected to comply with all locally applicable laws and regulations.
  • Respect for Human and Labour Rights is essential to REAL ALLOY. Our suppliers are expected to respect these values, including
    • Non-discrimination;
    • Prevention of forced labour, child labour and human trafficking;
    • Compliance with legal requirements on working hours, wages and benefits;
    • Respecting the rights of freedom of association and collective bargaining.
  • Suppliers shall offer a safe and healthy work environment that complies with applicable laws and regulation and takes into account recognized standards in their respective industry.
  • Suppliers are expected to avoid pollution, to reduce emissions, including greenhouse gas emissions, and other releases to the environment, and to enhance resource and energy efficiency with all reasonable effort. They should carefully manage the use of hazardous chemicals and comply with all applicable requirements like CLP regulations, REACh, RoHS, etc.
  • Suppliers are encouraged to implement appropriate management systems, for example based on ISO 14001 (environment), ISO 50001 (energy), ISO 45001 (occupational health & safety).
  • Within their scope of activities, suppliers are expected to take adequate preventive measures to protect privacy of personal data of employees, customers, and other business partners.
It is essential for REAL ALLOY to evaluate all possibly relevant aspects when planning a new project or modifying existing facilities, such as environmental, social and cultural aspects, including gender analysis. Therefore, those have been integrated in our project management process.
All sites have plans in place based on their local legal requirements which define their responses to emergency situations, including those which could cause harm to humans or the environment. These plans are aligned with the local external emergency forces, such as fire brigades.

For the Grevenbroich, Töging, and Eidsvåg sites, which fall under the (lower tier) requirements of the Seveso Directive, corresponding information is offered via our website.

REAL ALLOY’s corporate culture embodies the principles of transparency and respect for others. Our ability to operate efficiently and sustainably in the European market requires consistent and professional communication. We adhere, therefore, to the principles of transparency, honesty and accountability when interacting with our stakeholders.

This 2020 Sustainability Report marks a new level of transparency as REAL ALLOY refers to the reporting structure and comprehensiveness as formulated by the Aluminium Stewardship Initiative. Those guide us in our ambition to demonstrate responsibility and provide transparency about our performance.

REAL ALLOY is committed to building a culture of trust where stakeholders are comfortable to ask questions, raise concerns, and report suspected violations. Internally, concerns and complaints should be raised with the employee’s supervisor. However, if an individual feels uncomfortable with that, the issue can be addressed to HR, Legal or to the external compliance hotline.

Via this hotline, hosted by external ethics and compliance experts, employees can anonymously raise their concern – either per web or per tollfree phone call in their language (English, German, Norwegian). Grievance or complaint mechanisms are important to understand the impact of REAL ALLOY’s operations in its surrounding communities. Grievances may be of any kind, including social and environmental issues.
The company strives for easy addressability – to solve issues before they become bigger problems. Meetings with local stakeholders, such as neighbours, local politicians, citizen associations, and the media, should safeguard a continuous exchange of information in both directions. Additionally, REAL ALLOY opened a Social Media channel to offer a further platform for communication.

Each entry from the community is forwarded to the appropriate internal function and reviewed, if necessary, with additional expertise from other functions. The complainant receives an immediate confirmation of receipt and a timely response on the matter raised.

Special information for the local communities, which are required by national law (§ 8a Störfall-Verordnung in Germany, § 12 Storulykkeforskriften in Norway) are published on the corporate website.

Aluminium and Magnesium are light materials, which demonstrate a high degree of strength. They are corrosion-resistant, excellent conductors of heat, and can be easily molded and processed. These qualities make Aluminium and Magnesium suitable for intelligent product solutions and commercial applications.

In the mobility sectors especially, they allow for light weight solutions, thus saving emissions and energy in the use of vehicles, trains, aircraft etc. Moreover, these metals’ unique properties are unaffected by the recycling process, so these precious resources can be reused countless times with no loss of quality.

Best of all: The recycling process for these metals is hugely more energy and CO2 efficient than their primary production: Recycling Aluminium requires only about 5 percent of the energy needed for primary Aluminium production. This makes recycling of these metals a must-do in terms of sustainability!

REAL ALLOY’s recycling of Aluminium and Magnesium into new input materials for industrial production is an important contribution towards a circular economy. It helps preserve natural resources and minerals as well as energy while maintaining highest quality of the recycled products.

REAL ALLOY has the knowledge, experience, and technical equipment to recycle a large variety of different raw materials, whether generated from production processes, or available as post-consumer scrap. These include, for example, turnings, cuttings, foils, shredded scrap, incinerator scrap, skimmings, and drosses. They can be converted into different shapes and quality grades to meet the needs of customers in a broad variety of industry segments.
We deliver these highly versatile metals in a variety of different alloys in molten and solid ingot forms. Molten Aluminium is delivered directly to the customer in specially designed crucibles. This reduces metal losses due to oxidation and helps our customers save significant amounts of energy that they would otherwise require to melt solid input material. Just-in-time molten metal delivery also reduces production complexity at our customers and helps them improve their process efficiency.

Solid Aluminium or Magnesium is produced according to customer demands in line with quality and chemical specifications and also presenting low CO2 footprints.

REAL ALLOY is member of various trade associations within the Aluminium and Magnesium industry, both at European and at national level. This includes memberships with European Aluminium (EA), Bureau of International Recycling (BIR), Gesamtverband der Aluminiumindustrie (GDA), Wirtschaftsvereinigung Metalle (WVM) and Aluminium Federation (ALFED). Members of the management and corporate experts participate in committees and task forces, engage in relevant discussions and contribute to sharing and learning efforts. We report data and information to these associations to support industry wide efforts towards improved transparency and sustainability. In 2019 we joined the Aluminium Stewardship Initiative (ASI) – an important step for REAL ALLOY in developing a consistent and coherent corporate sustainability strategy.
Recycling of Aluminium and Magnesium existed long before circular economy became a major trend. Used Aluminium and Magnesium parts, alloys and scrap are not only too valuable to dispose of, they are also great for reprocessing and remodelling. Recycling Aluminium and Magnesium is much more efficient than producing it from raw materials.

Remelting consumes only about 5 percent of the energy needed for primary production. In addition, both materials lose none of their properties through recycling. This has two advantages; the metal retains its value and can be reprocessed as often as is desired. Recycled alloys are therefore the logical choice for environmentally conscious customers who want greater efficiency in their metal supply. With decades of experience, state-of-the-art technologies, and the constant development of new and environmentally friendly processes, REAL ALLOY can provide the best possible Aluminium and Magnesium recycling solutions, while consuming as little energy and as few additives as possible.
The low-energy footprint, in comparison with primary metals, has also reduced the carbon footprint of our metal. Recycled Aluminium and Magnesium are therefore ideal for all customers aiming to reduce the carbon and climate impact in their supply chain. The light weight of these two metals bring about more of these advantages in the use phase of related products in most sectors. As a member or European Aluminium (EA), REAL ALLOY actively participated and contributed to EA ́s work around a Life Cycle Assessment (LCA) for Aluminium.
A growing number of customers across all industry segments are demanding metal based on low CO2 footprints. Together with customers, REAL ALLOY is not only exploring suitability and availability of possible raw materials, but also discusses specification of products, their applications and opportunities for reducing energy and carbon intensity.
Reclaiming Aluminium and Magnesium scrap from the various production wastes and post-consumer wastes and returning it as a resource into the value chain is the essence of Aluminium and Magnesium recycling and the core of REAL ALLOY’s business model. It is the most resource and energy efficient key for the supply of metal with low CO2 footprint.

For Aluminium, typical end-of-life (EOL) scrap types are used beverage cans (UBC), window profiles, incinerator scrap or market scrap. REAL ALLOY offers long-standing experience, the required know-how and state-of-the-art technology for sourcing and processing these scrap types. We are familiar with the main challenges around processing such scrap, for example due to contaminations with other materials or varying alloy compositions in scraps from different uses. Our sampling and testing routines are designed to control the remelting process and the product quality levels closely.

As an international recycler of Aluminium and Magnesium scrap and skimmings, our business model revolves around resource efficiency, environmental protection, and energy management. The focus of our operations is reclaiming valuable metal from waste and returning it back into the cycle of valuable products.

Careful scrap management and separation, sophisticated blending calculation, advanced production technology, and strict process and quality control make sure that we achieve maximum recoveries of high-quality recycled light metal alloys with the least possible demand for energy and other resources.

The environmental impact of our business activities is regularly and comprehensively monitored and documented. Waste reduction, the prevention of emissions to air and water, and decreasing the noise and odor emissions are given high priority. Nevertheless, substantial positive environmental impact results from the resource and energy savings through the recycling of more than 330,000 tonnes of valuable Aluminium and Magnesium from a large variety of production and post-consumer scrap in the reporting period 2020.

Compared to the average carbon footprint of primary Aluminium used in Europe (8.6 kg CO2/kg Al according to European Aluminium, Environmental Profile Report 2018), the amount of Aluminium recycled by REAL ALLOY in 2020 saved more than 2,690,000 tonnes of CO2 emissions.

Additional energy savings result from the shipment of liquid Aluminium: With every kilogramm of liquid Aluminium delivered, the customer saves approximately 0.3 kWh of energy that would otherwise have to be spent on heating up and melting down the Aluminium.
In 2020, more than 160,000 tonnes of Aluminium were delivered in liquid form. This saved more than 48,000 MWh of energy at our customers.

Taking into account that modern melting furnaces have an efficiency of about 60 percent, the savings from liquid instead of solid metal delivery increases to over 80,000 MWh or almost 18,700 tonnes of CO2.

But the supply of liquid metal also promotes resource and energy efficiency in another important aspect: When solid metal is melted down, about 1 percent of the metal used is usually lost through re-oxidation to Aluminium oxide. So, our supply of liquid metal also saves the material, the energy, and the CO2 emissions which would have been consumed or generated when replacing this lost 1 percent by primary metal production. In 2020, approximately 1,600 tonnes of metal were thus obtained through our liquid deliveries. In the EU, the production of 1 tonne of primary metal requires about 18.7 MWh of energy corresponding to about 6.7 tons of CO2 emissions. For our 1,600 tonnes, this corresponds to almost 30,000 MWh of energy and more than 10,000 tons of CO2 emissions saved in 2020.
One of the major global challenges is related to climate change. This is directly linked to the CO2 emissions from REAL ALLOY’s operations and the Carbon footprint of our products. The general public, policy makers and increasingly also our customers are requesting not only transparency but also actions to reduce CO2 emissions. Policy sets very ambitious targets, which businesses need to pick up and translate into action.

For us at REAL ALLOY, CO2 emissions are dominated by the emissions resulting from the natural gas we use in our furnaces, heating stations, etc. This again represents the overwhelming part of our energy cost. In addition, we – either directly or indirectly – pay a price for all our CO2 emissions, for example through the cost associated with the EU Emissions Trading System (ETS). Reducing our specific CO2 emissions is equivalent to reducing the energy consumption which again is an important driver for the financial success of our company.

Compared against our emission levels in 2010, our emission levels in 2019 were approximately 12 percent lower. We certainly need to continue our efforts to further improve. In November 2020, we therefore decided to set ourselves a mid-term target:
Until 2025, REAL ALLOY will improve the energy efficiency and reduce the CO2 intensity of its operations by 20 percent, compared against a 2010 baseline.
For the years 2020 to 2025, this requires us to achieve a further improvement of our energy efficiency by 8 percent.

We expect that – among other projects to be started in year 2021 – new crucible heating stations in Grevenbroich and Töging will help us make the next steps towards improved energy and carbon efficiency.

In addition, we assess all options for improving the efficiency of our consumption of all relevant energies, i.e. electric power, natural gas, and transportation fuels. This includes all natural gas powered furnace and burner operations, electrical drives (especially bag house fans or compressors), combined heat and power generation (CHP) and the use of industrial waste heat, optimized transportation routing of vehicles, both onsite and offsite, or optimized just-in-time and just-in-sequence material flows. Where possible, switching to green electricity and biogas will also be considered.

Our greenhouse gas emissions are given as CO2 emissions, covering scope 1 (direct emissions from the use of fossil fuels in own installations and equipment) and scope 2 (emissions from externally sourced electricity), as defined in the Greenhouse Gas Protocol.

Scope 1 covers emissions from the use of natural gas (and Propane in Norway) as well as from Diesel consumption by our forklifts, wheel loaders, and internal mobile equipment. Scope 2 covers purchased electricity, but without taking account of the fact that we have purchased green power certificates for the electricity consumption of our Deizisau and Töging sites. The data are based on information from REAL ALLOY’s accounting systems. In addition, the data from the German sites are reviewed and checked via our ISO 50001 energy management audits and also externally validated in the course of the reporting into the EU Emissions Trading System (ETS). The emission factors are also taken from the ETS.

Emissions to air from REAL ALLOY’s operations mainly are
  • Dust from handling dusty input and output materials and from our melting processes;
  • Nitrous oxides (NOx) from the natural gas based combustion processes;
  • Hydrogen chloride (HCl) and Hydrogen fluoride (HF), from the flux (Chloride and Fluoride salts) in our furnaces and also from organic contaminants in some scraps;
  • Chlorine (Cl2), used to refine our metal according to customer specifications;
  • Traces of Dioxins and Furanes (PCDD/PCDF) from the thermal treatment of scrap which is contaminated with organics.
Our water consumption is characterized by the use of water for sanitary purposes. Only small quantities of water are used for cooling purposes at our Töging and Deizisau site. Only in Raudsand, REAL ALLOY uses large quantities of water from a surface water reservoir as fresh water for our salt slag recycling process.
Besides emissions to air, REAL ALLOY’s operations may cause noise emissions as well as odour emissions, especially in plants handling and generating salt slag.
In 2020, we did not experience any significant spills of oil, Diesel, or other water endangering liquids to sewage systems or water bodies. Minor spills were detected quickly and contained via immediate action.
The vast majority of REAL ALLOY’s input material is waste:
  • Production scrap – like drosses, skimmings, turnings, foil and sheet scrap, casting scraps, etc.;
  • Post-consumer scrap – like used beverage cans (UBC), scrap from construction applications, incinerator scrap (the Aluminium fraction collected from waste incinerator ashes), etc.
In 2020, we treated a total of approximately 430,000 tons of waste and recovered more than 330,000 tons of recycled Aluminium and Magnesium.
Roughly 90 percent of the waste generated in REAL ALLOY’s own operations consist of salt slag from our rotary furnaces, in 2020 a total of approximately 150,000 tons. The slag consists of salt (a mixture of NaCl and KCl), Aluminium oxide and small amounts of other metal oxides and metal compounds. All our salt slag is being recycled.

The next important waste type is filter dust, generated in our filter systems designed to reduce the emissions from our processes to legally permissible levels according to our permits. Again, the majority of this filter dust is being recycled.
All our drosses are recycled internally, either at the site where they are generated or at another European REAL ALLOY site.
All REAL ALLOY sites in Europe, except the Deizisau plant, have a long-standing industrial history and are located in areas which have been used for industrial purposes for many decades, in Grevenbroich and Töging even for more than a century. Their operating permits are based on European and local laws and regulations. This legal framework again was designed and issued taking account of all possible environmental impacts, including the impact on biodiversity from emissions to air, water and waste.
For the Deizisau plant, a full environmental impact assessment was done as part of the permitting procedure and no concern related to biodiversity was raised. For our Raudsand plant with its direct discharge of waste water to the adjacent fjord, regular studies on the condition of flora and fauna in the water body have been performed, showing that relevant condition indicators remained constant or have improved over recent years.

None of our operations involve new land use. With most of our scraps sourced from local or regional sources also the introduction or spreading of alien species represent a negligible risk. Overall, our impact on biodiversity is defined and minimized by our operation within the given permits and regulatory framework.

Our Deizisau plant is the first to be certfied against the ASI Performance Standard. The plant was built as a greenfield plant in 2004 in a designated industrial area. It is designed to deliver molten recycled Aluminium directly to the cast houses of our customers. By delivering molten metal we help our customers save substantial amounts of energy and also CO2 emissions, since they do not have to re-melt solid metal themselves.

The plant is currently operating five melting/casting furnaces. The metal input consists of clean or only lightly contaminated scrap. The emissions from the furnaces are captured and treated in a modern filter system compliant with the most recent EU-based environmental requirements.

The main waste fraction, dross from the salt free melting process, is recycled in one of the other European REAL ALLOY plants. Only approximately 3 percent of the plant's waste was not recycled in 2020, most of this being filter dust from the filter system.

Apart from metal scrap and energy (natural gas, electricity, and Diesel fuel), the plant also uses adsorbent in its filter system to increase scrubbing efficiency for inorganic and organic pollutants.

In addition, Nitrogen gas and Chlorine are used to refine the molten metal according to our customers' specifications.

The plant receives water from the municipality and the main use is for sanitary purposes. In addition, water is needed to compensate for the evaporation losses and very small water discharge from the closed cooling systems of the plant. Cooling water and sanitary water are discharged to the municipal sewer system. Surface and stormwater are discharged directly to the adjacent river Neckar.

REAL ALLOY's employees are spread across six production sites in Europe, yet they are all united by the REAL ALLOY mission. We share a passion for excellence and are committed to integrity and accountability. At each site, our teams foster an environment of trust and empowerment, where good ideas are encouraged and setbacks are viewed as learning opportunities. Always tuned in to the bigger picture, we are motivated by a strong sense of responsibility towards our colleagues and our communities.

Our values define what we stand for. In addition, our policies provide a framework and directions and set clear expectations on an ethical and responsible approach to business not only for all our managers and employees, but also for our suppliers. They describe how our business partners and all our stakeholders may expect us to operate. Among these REAL ALLOY policies are



Respect for Human Rights, including Women’s Rights (according to UN CEDAW), and Labour Rights are foundations of our corporate culture. We have a clear commitment to legal compliance and strictly oppose any form of discrimination and harassment, child labour or forced labour or any other unethical behaviour.

All our plants are located in the EU, Great Britain and Norway. All these countries maintain highest Human Rights standards in their legal frameworks and are signatories to the relevant Human Rights related declarations of the United Nations. Society and the general public also show strong engagement in all human rights related matters and questions. Within that framework and based on our own Code of Conduct, compliance with Human Rights is a must-have for our organization.
We conducted a structured Human Rights compliance self-assessment, using the “HRCA Quick Check” published by the Danish Institute for Human Rights. We have no indication of material or even systematic non-compliances with our Code of Conduct and Human Rights in general.
All our processes and management decisions take environmental requirements and standards into consideration, as well as stakeholder concerns and the demands of the market. REAL ALLOY pursues an open information policy and works closely with the relevant government agencies and associations. We are similarly committed to maintaining a dialogue with the public, our suppliers, customers, and other contractual partners. In new projects as well as in ongoing operations, we continuously assess our impact on the surrounding communities. We do so to offer transparency and insights into the activities of our various sites and related environmental considerations. This transparency is a prerequisite for sustaining an asset of immense value for REAL ALLOY: the support and trust of the communities we operate and live in.
Grievance or complaint mechanisms are important to even better understand the impact of REAL ALLOY’s operations in its surrounding communities. Grievances may be of any kind, including social and environmental issues. We strive for easy addressability – to solve issues before they become bigger problems. Annual meetings with local stakeholders, such as neighbours, local politicians, citizen associations, and the media, should safeguard a continuous exchange of information in both directions. Additionally, REAL ALLOY started a Facebook site to open another channel for communication.

Each entry from the community is handled jointly by Communications, with additional expertise from special branches. The complainant receives an immediate confirmation of receipt and notice of a timely solution.

Special information for the local communities, which are required by national law (§ 8a Störfall-Verordnung in Germany, § 12 Storulykkeforskriften in Norway) are published on the corporate website.
Our more than 580 employees in Europe are key to our success. They come from approximately 15 different countries and thus bring diversity to our business. They are – on behalf of REAL ALLOY – those who deliver responsibility and sustainability to our stakeholders.
We understand that their knowledge and capabilities are a prerequisite for being successful, both for them as individuals as well as for REAL ALLOY as a company. Training and qualification are therefore integral parts of our daily business. Health and safety, environmental protection, responsible use of energy and resources are regular training topics just like good operating practices for all our production equipment. This is part of our efforts to provide a good and safe working environment. It also supports our attractiveness as an employer and helps attract and retain talented people in a highly competitive labour market.
We are committed to respecting and fostering human rights. We also expect our business partners, and particular our suppliers, to fully observe Human Rights. We continually review our processes and activities with respect to Human Rights.
We fill our job vacancies exclusively according to ability, potential, and performance. We do not tolerate discriminatory behavior either when we hire new employees or in our daily interaction with each other. We aim to develop the full potential of our employees, regardless of external circumstances. To do so, we want to identify and remove barriers in our thinking and in our processes. We are convinced that a diversified workforce and an open and appreciative company culture are important success factors in a globalized world.
...genders:
Our goal is to continually increase the share of female representation at all levels of the organization. We support the career development of women at all levels. In 2020 the proportion of women in management team was 20 percent.

...cultures:
Cultural diversity is a part of everyday working life at Real Alloy. Awareness of different value systems and their influence on our daily behavior helps to meet the challenges of mixed teams.

...generations:
We encourage learning across all generations. We promote knowledge transfer and a change of perspective between experienced and less experienced employees. The aging population in industrialized countries is a challenge for the companies. Regular demographic analysis helps us to understand the challenges we may be facing in the future and plan early enough the activities to prevent any workforce shortage.
We are committed to communicating openly with our employees and their representatives and pursuing a constructive dialog. Our goal is to inform them early on about important issues and to involve them in the process. As a result, we are in a position to successfully face challenges and changes in society, the economy and politics in order to remain competitive and sustainable in the future. We involve employee representatives in many decision-making processes beyond those for which worker participation is a statutory requirement.
Preserving jobs and dealing responsibly with necessary structural changes are important to us. In order to secure the company’s competitiveness, we continually adapt our structure to market conditions. If jobs are affected by this, we enter into a solution- oriented dialog with the employee representatives before actions are taken. In doing so, we follow all applicable codetermination legislation and apply the required procedures for each action. We aim to reach agreements with socially compatible arrangements for the particular employees. To date, we have been able to manage the necessary restructuring measures while reconciling interests. The actions involved range from early retirement through to support with professional reskilling and refocus.
Appreciation of our employees is an important element of our company culture and enables us to ensure our long-term and sustainable business success. For this reason, it is important to recognize our people’s performance through appropriate remuneration in line with the market. The compensation systems for our non-managerial employees are based on local requirements and existing collective agreements. Wages are regulated through the collective bargaining agreement of the sector, and those are the rules clearly implemented.
Management positions’ groupings are externally assessed every two years and benchmarked against comparable competitors. Here, we use short- term variable remuneration components to reward individual contributions to the company’s success. The Management Incentive Program (MIP) paid out annually takes into account both our medium-term financial targets and each person’s individual performance. There is no systematic difference between the compensation received by male and female employees.
There is a freely elected workers council in place in each European REAL ALLOY site and Collective Bargaining Agreements are implemented. Our policies and procedures clearly state the recognition of the principle of freedom of association and the right to join employee organizations.
There is no employment of workers under the age of 18 years. Child labour is prohibited in Europe. The hiring of minors (under 18 years) is not allowed in any position. In line with the conventions of the International Labor Organization (ILO), REAL ALLOY only offers fixed-term internships, education programs and seasonal employment to young people when this does not impair their safety, health and compulsory school attendance in any way and compliance with the requirements in precisely monitored.
REAL ALLOY neither engage nor support the use of forced labour. We do not engage in or support human trafficking either directly or through any employment or recruitment agencies. Practices such as withholding personal property, passports, wages, training certificates, work permits or any other document for inappropriate reason are not acceptable. We do not tolerate slavery and forced or compulsory labor and human trafficking in our supply chain.

At REAL ALLOY, we want all our employees, guests, visitors, and subcontractors to be safe! That is why every REAL ALLOY facility has a comprehensive health & safety program designed to prevent injuries and work-related illnesses. Many of our sites in Europe are certified according to recognised health & safety management standards, such as ISO 45001 or BS OHSAS 18001.

REAL ALLOY deploys a set of standards and elements that establish clear expectations for health & safety processes and activities and support a continuous improvement approach through various monitoring and accountability systems. Beyond compliance with the relevant legal provisions and operational requirements, REAL ALLOY’s management and employees place the utmost importance on the protection of health and safety.
We incorporate occupational health and safety considerations into all our operational activities and decisions. “Zero injuries” is our ultimate goal and the driver of our ongoing efforts to improve our health & safety performance, which have so far resulted in injury rates that are low compared to our industry’s average. Beyond the immediate concerns regarding safety in the workplace, we also offer programs for preventative health care and protection, partly in collaboration with external partners like the German “Berufsgenossenschaft”.

The events are divided into clusters. Each event is followed by an assessment and an analysis. Identifiable trends are evaluated separately. Notable events are shared with other plants using the Safety Incident Alert and measures are taken to prevent recurrence.
By complying with the various management system standards (table page 8), we have decided not only to comply with all corresponding legal obligations, but also to improve our operational performance and efficiency continuously and systematically. These certifications are therefore one more important step on our way to sustainable business practices.

Even the plants that are not yet certified work in accordance with the individual standards. The aim is to harmonise processes across plants, with project teams working on the specific topics in accordance with the action plans.

Various campaigns were carried out in 2020. The two most prominent topics were “Avoiding Near Misses” with the introduction of a “Safety Card” and the focus on employee involvement as well as “Man Machine Interface” with the assessment of driving and walking routes to identify specific risk areas and optimise them accordingly, whereby the harmonisation of the selected equipment across the plants was also carried out.
Health & safety meetings are held regularly – from the Management Board to the shop floor. The aim is to make sure health & safety related information is exchanged between all relevant parties working at our sites. Every employee is required to attend some form of safety meetings and to actively engage in and contribute to improving health & safety at the workplace. Standardised reporting on health & safety matters, incidents and activities supports transparency within the teams and supports learning and sharing of best practices between sites and also via associations.
The events are divided into clusters. Each event is followed by an assessment and an analysis. Identifiable trends are evaluated separately. Notable events are shared with other plants using the Safety Incident Alert and measures are taken to prevent recurrence.

This report is an update and advancement to our first sustainability brochure published in 2018. It is our first sustainability report by the means of the Aluminium Stewardship Initiative (ASI). We became a so-called production & transformation member of the initiative in November 2019 and now aim for a first certification at our German site Deizisau. The report uses the ASI Performance Standard with its three overall chapters Governance, Environment, and Social as a reference point and covers REAL ALLOY’s operations in Europe with our German sites Grevenbroich, Deizisau, and Töging, our Norwegian sites Eidsvåg and Raudsand, and our site in Swansea, UK. Our European headquarter is also located in Grevenbroich. Data provided in this report are for the calendar year 2020, unless stated otherwise.

In most cases, this report is a reference measurement for further development and improvements which we will assess with further reports in the following years. Deizisau, as our first site to be ASI-certified, is covered in special comprehensiveness. Besides any efforts that might already have improved REAL ALLOY’s environmental performance, the year 2020 is naturally overshadowed by effects due to the COVID-19 pandemic. A decrease in demand and resulting decreases in energy consumption, emissions, and utilization is mainly caused by the temporary slow-down of the entire industry. REAL ALLOY as a global company is headquartered in Beachwood, Ohio. In this report, the appellation “REAL ALLOY” only refers to the REAL ALLOY Europe business unit, as defined above, unless stated otherwise.