Ecobat 2022 Sustainability Report

Powering the Future Sustainably 2 0 2 2 S U S TA I N A B I L I T Y R E P O R T

TA B L E O F C O N T E N T S

Message from the CEO....................................................4 About the Report ..............................................................5 Overview of the Company................................................6 Operations.................................................................................6 Locations....................................................................................7 Services, Products, and Markets .........................................7 Resources..................................................................................7 Logistics.....................................................................................7 Battery........................................................................................7 Solutions.....................................................................................7 Sustainability Management System...............................8 Mission, Vision, and Values....................................................8 Sustainability Approach..........................................................9 Stakeholder Engagement........................................................9 Materiality Assessment............................................................9 Stakeholder Efforts and Communication.......................... 11 Policies and Procedures ..................................................... 11 Standards and Certifications.............................................. 11 SDGs Alignment..................................................................... 12 UNGC Alignment .................................................................. 12 Governance .....................................................................14 Board Structure..................................................................... 14 Risk Committee ..................................................................... 15 Group Enterprise Risk Management Policy..................... 15 Ethics....................................................................................... 15 Information Security.............................................................. 17 Environment.....................................................................19 Energy and Emissions.......................................................... 19 Recycling of Waste and Materials ..................................... 21 Lead Recycling...................................................................... 21 Lithium Recycling.................................................................. 22 Sustainable Procurement ................................................... 22 Social ...............................................................................24 People ..................................................................................... 24 Health and Safety ................................................................. 25 Risk Controls for Blood Lead Levels................................. 26 2023 Blood Lead Level Focus ........................................... 27 Employee Engagement......................................................... 27 Working Conditions............................................................... 27 Diversity and Inclusion......................................................... 28 Training and Career Management...................................... 28 Community ............................................................................. 28 Conclusion.............................................................................. 30 End Notes................................................................................ 31 SASB Correspondence Table............................................. 32 GRI Correspondence Table................................................. 33 ERM CVS Independent Limited Assurance...................... 34

MESSAGE FROM THE CEO

Ecobat’s core business model positions us as a global sustainability leader.

With operations throughout Europe, the United States, and Southern Africa, we lead battery collection, recycling, production and distribution, with expanding operations into lithium battery recycling management. Through our innovative processes, we are also enabling the production of energy storage solutions that is essential in driving a sustainable economy.

Worldwide, lead batteries are the single most recycled consumer product, achieving a 99% recycle rate of components. Lead battery recycling is efficient and demonstrates the power and possibility of a circular economy.

The transportation, medical, telecommunications, and agriculture sectors are just a few examples of industries that currently benefit from lead recycling. It is a critical solution for our growing social needs, supporting the global transition to a low-carbon emission model. In addition, our work enables a reduced carbon footprint in the full life cycle of lead products by decreasing the need for energy-intensive mining extraction.

Ecobat’s strategy includes scaling our lithium-ion battery recycling operations through our facilities in the US and Europe. Our operations remain focused on sustainable processes and practices for the safe, effective handling of heavy metals to protect our workforce and local communities.

In 2022, Ecobat faced many macroeconomic headwinds, globally and industry-wide, which impacted our overall performance. Despite concerns over the European energy crisis, global inflation, increasing lead prices, and ongoing recession fears, Ecobat remained committed to facing these challenges. With our 2022 results, we celebrated record safety performance, record lead production, positioned our lithium business for continued rapid growth, and remained committed to acting as “One Ecobat.”

We are moving forward with the understanding that companies today must provide not only economic value but also environmental and social value. We will continue to make a positive difference for our stakeholders and protect our people and the environment.

Ecobat’s long-term approach includes setting targets and taking actionable steps that address global sustainability challenges. Driven by our vision to be a sustainable supplier of innovation-based solutions that create value for our stakeholders, we consistently reflect on opportunities to improve our strategy and operations through innovation and product development. Simultaneously, we must be responsible stewards of the environment and foster a diverse and inclusive workplace. Please join me in meeting these challenges.

Marcus Randolph Chief Executive Officer

ABOUT THE REPORT

The enclosed information represents Ecobat’s first global Sustainability Report.

All metrics are based on currently available 2021 and 2022 data. Our goal is to set the stage for future reporting. We anticipate that next year’s report will include Key Performance Indicators (KPIs) that have been consolidated and represent fully implemented sustainability topics.

Ecobat is showcasing our efforts to integrate sustainability throughout our company, processes, and the products we produce. Transparency and accountability are crucial building blocks to achieving progress. This report has been prepared in alignment with the Sustainability Accounting Standards Board (SASB) and the Global Reporting Initiative (GRI). Furthermore, Ecobat´s sustainability management and reporting are guided by our commitment to the United Nations’ Global Compact Sustainable Development Goals (SDGs).

We invite stakeholders to learn more about our approach to sustainability by visiting our website at www.ecobat.com. Should you require further information, please contact info@ecobat.com.

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Overview of the Company E C O B AT ’ S C I R C U L A R I T Y M O D E L

E ND USE R R E M OVE S O LD BATTE RY WE COLLECT A ND TRA NS PORT OLD BATTERY

I N STAL L N E W BAT T E RY

WE RECYCLE LEA D, PLASTIC A ND ACID

WE PU RC H ASE AN D D I ST RI B U T E BAT T ER I E S TO EN D U SERS F ROM M AN U FAC T U RE RS WE S MELT A ND REFINE LEA D

WE PAC K AG E AND SHI P LE AD TO BATTE RY M ANUFAC TUR E RS

OPERATIONS

Ecobat is a world leader in the production of lead, lead alloys, and the recycling of lead batteries. Our vast network features 12 smelters across three continents with a 2022 output of over 670,000 tons of lead. Our lead recycling system allows us to recover and repurpose over 99%1 of the metal contained in the battery.

We also offer premium services, such as in-depth consultancy on lead and metallurgy with the help of our industry experts.

In addition, Ecobat actively supports the lead industry with value-added research in significant initiatives to continue driving the sector to a greener, more sustainable future.

With the addition of lithium-focused facilities, we have enhanced this commitment to sustainability by expanding our capabilities to include lithium battery collection, discharge and diagnostics, dismantling, crushing/sorting and recycling management. We take a responsible and technologically advanced approach just as we do with our lead-acid battery recycling facilities.

LOCATIONS

Our operations extend throughout Europe, the United States, and Southern Africa, creating a vast network that powers industries worldwide.

SERVICES, PRODUCTS, AND MARKETS

From the recycling and production of lead used in energy storage solutions to the collection of end-of-life batteries and the distribution of new batteries, Ecobat plays an essential role in the closed-loop supply chain for responsible battery recycling (See Ecobat’s Circularity Model diagram, page 6).

RESOURCES

Ecobat Resources provides an international network of smelters. Alongside our recycling and lead production operations, Ecobat Resources also manages the reclamation of polypropylene used to develop premium polymer solutions. The reclamation of scrap batteries is one of our most important success stories. At Ecobat, we use state-of-the-art technology and a highly trained workforce to ensure the lead-acid batteries we recycle into refined lead do not harm the environment, employees, or the communities in which we work.

According to Battery Council International, 99% of all battery lead is recycled, and a typical new lead-acid battery contains 80% recycled lead and plastic. We are proud to be part of this lifecycle that makes our industry ever more environmentally conscious.

LOGISTICS

Ecobat Logistics offers the collection of end-of-life batteries as part of our commitment to supporting the closed-loop economy through the recycling of energy storage solutions. Our collection services provide a collection truck fleet and 65,000 battery collection

points, offering seamless battery collection and recycling services. In addition to lead batteries, we also manage the collection and handling of other battery chemistries, including lithium-ion.

BATTERY

Ecobat Battery manages the procurement, sale and distribution of energy storage solutions and related accessories and services. We supply batteries for a wide range of uses, including automotive, commercial vehicles, leisure and marine, motorcycle, solar and other renewables and numerous industrial applications. Our comprehensive brand portfolio includes Lucas and Rolls (as sole European license holders), and, Ecobat, Numax, and VMX (as our own brands). We are key distribution partners for Exide, Varta, Trojan, Optima, Sonnenschein, TAB, US Battery, and Pylontech. In addition to this vast range of products, we offer various services to our customers including maintenance contracts, installation, repair and technical support.

As part of the our role in the circular economy, we work in partnership with our Logistics division to ensure efficient collection of products from our customers as they reach end-of life and with the customers of our Resources and Solutions divisions to supply the market with new batteries.

SOLUTIONS

Ecobat Solutions leverages our expansive group network and decades of technical experience to bring robust solutions for lithium-ion battery recycling to the North American and European markets. We conduct technical queries and assist in developing bespoke products based on specific application requirements.

We also drive advancement within our company and industry as part of our commitment to sustainability and environmental stewardship, including offering expertise in transportation, developing technologies and processes for recycling and resource recovery for lithium-ion and other battery chemistries.

In addition, we are the only European provider offering collection, dismantling, diagnostics, and crushing/ sorting capabilities to derive black mass1. We also support research and partner with universities, trade organizations, and government entities to develop safe, more efficient energy storage solutions.

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Sustainability Management System MISSION, VISION, AND VALUES

Every day, billions of people benefit from the technologies that use and rely on lead. It provides efficient energy storage solutions in transportation, medicine, telecom, agriculture, and clean energy.

Lead is a crucial resource that connects us to modern life today and tomorrow.

Our commitment to the well-being of our team members, partners, communities, and the planet guides us in everything we do, and we continually look for new ways to enhance our efforts. Our mission, vision, and values guide our everyday actions to succeed as a sustainability leader.

Our Mission Statement. To lead in the responsible collection, recycling, production, and distribution of resources essential to modern life.

Our Vision. As the market leader, we drive advancement within our industry and work to develop innovative and sustainable products that benefit our stakeholders and meet the ever-growing need for more efficient, reliable energy storage solutions.

Our Values. We clearly communicate our values to all Ecobat team members.

•

WE’RE PROUD: We find a deep sense of pleasure

and satisfaction in the work achievements and qualities we share.

•

WE’RE RIGOROUS: We gather all the facts before

we engage. If you want to get involved with us, we make sure you’ve done your homework.

•

WE’RE CARING: We prioritize the wellbeing of

our people, each other and the planet, and we are intentional about making a positive impact.

•

WE’RE ENGAGED: We are consistent, precise and

purposeful in everything we do.

•

•

S U S TA I N A B I L I T Y A P P R O A C H

During 2022, we worked extensively on realigning our sustainability approach and strategy based on our stakeholder engagement efforts. The Material Topics graphic below outlines our Environmental, Social and Governance (ESG) targets, approaches, and initiatives.

S TA K E H O L D E R E N G A G E M E N T

During 2022, we conducted a comprehensive Environmental, Social, and Governance (ESG) materiality assessment based on extensive research, benchmarking, and engagement with key stakeholder groups. The goal of this analysis was to reveal opportunities for improvement. Using this process, we refined Ecobat’s ESG strategy with stakeholder expectations.

WE’RE OPERATIONALLY EXCELLENT: We embrace principles and tools that produce efficient, superior outcomes.

M AT E R I A L I T Y A S S E S S M E N T

and efficient outcomes because we work together as

We conducted a materiality assessment to identify, refine, and assess potential ESG issues that could affect our business and stakeholders. We undertook the following

a team.

four steps to ensure the validity of our assessment.

WE’RE COLLABORATIVE: We produce effective

M AT E R I A L T O P I C S

M AT E R I A L E S G T O P I C

Energy & Greenhouse Gas Emissions

TA R G E T

• In 2023, establish inventory baseline per GHG Protocol • In 2024, set emissions target

APPROACH

• Detailed dashboards and energy audits support identification of financially favorable energy management opportunities • A baseline GHG inventory established the foundation against which to measure future emissions reductions

I N I T I AT I V E S

• Data improvement • Energy management (energy efficiency and conservation) • Cleaner energy sources

Environmental Protection

• In 2023, further improve data collection to • Standardized monitoring and new technology installations, where monitor lead, cobalt, and nickel releases appropriate, support improvements on to air, soil, and water, globally metals release intensity • In 2024, set a quantitative target

• Data improvement • Release minimization • Release remediation

Waste Management

• In 2023, improve data collection to break out hazardous vs non-hazardous while assessing the potential impact of reduction initiatives • In 2024, set a quantitative reduction target

• Data and market monitoring lay the foundation to take advantage of future waste management opportunities

• Data improvement • Waste diversion • Sustainable waste solutions

Responsible Materials Sourcing

• In 2023, establish a Responsible Materials Sourcing Policy and Questionnaire for Suppliers and Vendors • In 2024, establish compliance targets

• A supply chain sustainability program is established through a new code of conduct, supplier self-assessments, and auditing

• Code of conduct development • Questionnaire distribution • Audit program

• Continue to report on Ecobat's internal HSE metrics of Total Case Incident Rate (TCIR) and blood lead • In 2023, mature high severity program • In 2024, set target • Average Blood Lead < 6 µg/dL by 2025

• Audits & improved training procedures to improve all KPls • Standardized hygiene best practices to improve BLL • Finalized high severity program development and framing • New protocols and upskilling employees to lower TCIR

• Data improvement • Health & safety audit • Training development • Lead exposure reduction • Safety risk reduction

Workforce Health & Safety

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1.

We identified the ESG issues applicable to Ecobat based on current stakeholder engagement, research, and benchmarking (GRI standards, SASB, MSCI materiality maps, and requirements).

2.

We used surveys and interviews with 45 internal and external stakeholders to gather stakeholder feedback and validate their expectations.

3.

We prioritized the list of issues and ranked them to create a preliminary materiality map.

4.

The Materiality Map formed the basis of the Materiality Matrix, allowing us to establish a strategy consistent with supporting results.

Based on the Materiality Matrix, we established five areas of focus.

M AT E R I A L I T Y M AT R I X

1.

Energy and Greenhouse Gas (GHG) Emissions are of increasing importance to customers who set emissions reduction targets. They are businesscritical as the costs of energy are rising and regulations increasingly impact the use of energy.

2. Environmental Protection is an area of focus given the potential environmental impacts and enterprise risks that could results from material exposures to air, water, or soil.

3. Waste Management is a point of differentiation in the marketplace as customers establish targets and data requests, and competitors improve their practices. Additionally, hazardous waste disposal is associated with financial and reputational risks.

4. Responsible Materials Sourcing is required for

sustainable operations. Ecobat recognizes robust measures ensure supply chain accountability provides confidence and assurance to stakeholders and the market.

5. Workforce Health and Safety is a core concern given the nature of work in Ecobat’s facilities. Ecobat must continually track new developments and best practices to ensure adequate safety measures are embedded in the company culture.

S TA K E H O L D E R E F F O R T S A N D C O M M U N I C AT I O N

While conducting the ESG materiality assessment, we identified numerous key stakeholders. Rather than a one-time touchpoint, Ecobat continues to interact with stakeholders on relevant ESG topics. The table below identifies the methods and minimum frequency of stakeholder engagement.

S TA K E H O L D E R E N G A G E M E N T

Stakeholder

Method of engagement

Frequency of engagement

Management/Internal leadership

Monitoring of targets and progress; budgeting

Quarterly or monthly depending on topic

Executive Committee

Presentation on targets and progress; oversight

Bi-annual

Board

Presentation on targets and progress; oversight

Annual

Investors

Individual meetings on targets and progress

Annual

Customers

Responses to data requests; two-way discussions on ESG best practices

As needed data sharing; annual discussions

Trade associations

Participation in requests for comment on new program development; two-way discussions on ESG best practices

Ad hoc program development; annual discussions

Local communities

Public meetings, facility tours, etc.

At least one touchpoint annually, additional as needed

All

Published sustainability report

Annual

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POLICIES AND PROCEDURES

Policies and procedures are essential for consistent application of sustainability principles. Below is an illustrative list of controls Ecobat has enacted to address ESG concerns.

Environment

Social

Governance

Compliance

• Health, Safety, Environmental & Sustainability (HSE&S) Policy • Incident Data Management & Investigation Program • Sustainable Procurement Policy • Supplier Code of Conduct

• Global Code of Conduct • Working Conditions Policy • Pension and PostRetirement Benefits Policy • Leave Policy (USA Only) • Anti-Bribery and Corruption Guide for Third-Parties • Parental Leave – Minimum global standards • New Employee Referral Program • US Employee Handbook

• Avoidable Loss Reporting • Travel and Expense Policy • Cost Accounting • Trade and Other Payables • Cost of Sales • Lease Accounting • Bank Accounts • Foreign Currency • Intergroup Sales & Transfers • Intercompany Loans • Inventory • Property, Plant, & Equipment • Revenue Recognition • Derivatives Use & Hedging • Financial Reporting • Income Tax Filing • Indirect Tax Filing • Intercompany Transfer Pricing

• • • • • •

S TA N D A R D S A N D C E R T I F I C AT I O N S

Ecobat is committed to the highest international standards and holds almost 60 International Standards Organization (ISO) certifications, including ISO 9001 (Quality), ISO 14001 (Environmental Management) and ISO 45001 (Occupational Health and Safety), ISO 50001 (Energy Management) and ISO 17025 (Testing and Calibration Management). We leverage these certifications to help us set even higher targets for improvement.

The United Nations Global Compact1 (UNGC) and the Sustainable Development Goals2 (SDGs) form the basis of our sustainability efforts and help us

• • • • •

Global Code of Conduct Delegation of Authority Matrix Ethics & Confidential Helpline Guidelines Whistleblowing procedure Anti-Bribery and Corruption Procedures & Guidance Antitrust & Competition Compliance Procedures and Guidance Ecobat Conflict Minerals Policy Statement Ecobat Modern Slavery & Human Rights Statement Prohibited Parties Compliance Guidelines Group Enterprise Risk Management Policy Dawn Raid Procedures

Marketing: • Brand Standards • Communication Toolkit IT: • Change Management Policy • Acceptable Usage and Mobile Device Management Policy • IT Governance Policy • Cybersecurity Policy • Data Privacy Policy • IT Business Continuity & Incident Response Policy

strategically address pressing global challenges. Our strategy embraces the 10 UNGC Principles as well as 9 SDGs. The SDGs allow us to frame our business within a wider perspective that takes into account social and environmental impacts, also embracing their interconnected and mutually dependent nature.

We have aligned our management system and sustainability efforts to adhere to internationally recognized sustainability best practices such as the Global Reporting Initiative3 and SASB4 Standards.

Moreover, we consistently work towards contributing to the SDGs in all our operations and strive to embody the UNGC 10 principles.

E C O B AT ’ S P R O G R A M A L I G N S W I T H :

U N I T E D N AT I O N S S U S TA I N A B L E D E V E L O P M E N T G O A L S

SEE WITHIN OUR REPORT THE SECTIONS: PEOPLE, ENVIRONMENT & ETHICS

#3 Good Health and Well-Being, #4 Quality Education #5 Gender Equality #8 Decent Work and Economic Growth #9 Industry, Innovation and Infrastructure #10 Reduced Inequalities #11 Sustainable Cities & Communities #12 Responsible Consumption and Production

Our commitment to the well-being of our team members, partners, communities, and the planet guides us in everything we do, and we continually look for new ways to enhance our efforts by embracing quality education, gender equality, decent working conditions and good health and wellbeing.

We are proud to say that we supply key resources necessary to our global energy supply, and that we help develop and produce the next generations of low-emission technologies. Managing the production and recycling of lead responsibly is essential to making this possible. At Ecobat, our operations are centered around sustainable processes and practices for the safe, effective handling of lead. Recycling and resource recovery comprise more than 80% of our business.

Our closed-loop recycling approach helps us maintain the supply of lead while reducing the overall environmental footprint of lead. At the same time, we’ve invested millions to help preserve the environment by reducing and eliminating emissions from our operations.

#13 Climate Action

U N I T E D N AT I O N S G L O B A L C O M P A C T

Principle 1

We support and respect the protection of internationally proclaimed human rights and legislation as shown within our management system.

Principle 2

We make sure that we are not complicit in human rights abuses by applying our policies and procedures.

Principle 3

We uphold the freedom of association and the effective recognition of the right to collective bargaining.

Principle 4

We are committed to the elimination of all forms of forced and compulsory labor and apply legislation where we operate.

Principle 5

We are committed to the effective abolition of child labor; and

Principle 6

the elimination of discrimination in respect of employment and occupation.

Principle 7

We support a precautionary approach to environmental challenges.

Principle 8

We undertake initiatives to promote greater environmental responsibility; and

Principle 9

encourage the development and diffusion of environmentally friendly technologies.

Principle 10

We work against corruption in all its forms, including extortion and bribery.

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Governance Ecobat’s governance framework ensures efficient and effective use of resources and aligns closely with stakeholder interests. The framework requires custodial accountability and balances our economic and social goals. We believe our governance enhances the stability and equity of our communities.

BOARD STRUCTURE

Ecobat, LLC is a limited liability company whose corporate governance is subject to the requirements, rights, and obligations set out in its formation document, including its governing LLC agreement.

Ecobat's Board is comprised of 12 individuals appointed by unitholders. Board members have varied and expansive depth of experience in financial sectors, with members adding expertise in global industries, manufacturing, and service.

The Board charter spells out the responsibilities of the Board and delegates authority to the Chief Executive Officer. The charter also provides the Board the authority to add management positions to further reinforce its commitment to good governance. This includes positions such as Legal and Health, Safety and Environment (HSE).

The Board retains decision making capacity and authority for the annual budget and has oversight for significant or exceptional decisions. The Board has four committees to provide structured oversight and governance, including the Audit Committee, Capital Expenditures Committee, and Health, Safety, Environmental and Sustainability Committee and the Governance and Compensation Committee.

Each committee has its own charter and these are the Controlling documents. To ensure the Board alignment with management, there are eight board meetings a year and additional meetings, as required.

RISK COMMITTEE

The Ecobat Enterprise Risk Committee (ERC), comprised of Ecobat’s Executive Committee and the Director of Audit and Risk Services (ARS), is a management-level risk committee accountable for enabling leadership to understand, evaluate, and mitigate the risk that may negatively impact enterprise value and prevent the achievement of Company goals and objectives.

The annual Enterprise Risk Assessment (ERA) evaluates Ecobat’s broader portfolio of operational, commercial, strategic, financial, technological, legal/ regulatory, and human capital risks and creates a priority list of the most critical enterprise-level risks. The ARS team further formulates their annual audit project plan based on the outputs of the ERA, to reduce risks to an acceptable level. In addition, the ERC meets quarterly to review risk owners’ response plans to Ecobat’s top risks, and discuss any emerging enterprise risks, shifts in risk priorities, and high-priority audit recommendations.

GROUP ENTERPRISE RISK MANAGEMENT POLICY

Ecobat monitors business ethics through the Annual Enterprise Risk Assessment, quarterly enterprise risk committee meetings comprised of the Executive Team, internal reporting through the SpeakUp hotline, and internal avoidable loss reporting.

ETHICS

Sustainability requires commitment to a higher standard. Ecobat enhanced business ethics in the following ways in 2022: Three Navex platforms for global Ecobat employees to work more efficiently while highlighting ethics and compliance standards.

•

EthicsPoint - Launched in May 2022, EthicsPoint is an internal hotline for employees to alert management of alleged incidents concerning unethical or otherwise illegal activity.

•

PolicyTech – Launched in October 2022, this tool provides centralized, easy access for all employees to access global company policies and procedures.

•

Engage – Phased launch beginning in July 2022, this compliance training platform provides all employees with vital competition and antitrust training.

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An internal Data Privacy Committee, which oversees the importance and application of data privacy cross-company in compliance with the General Data Protection Regulation (GDPR).

Delegation of Authority (DOA) Matrix used companywide to communicate the clearly defined functional and financial responsibilities of Ecobat team members.

The Matrix specifies upper limits on approval authority, describes the required action of each team member to organize the business, streamlines the decision-making process, and elaborates upon Ecobat’s corporate matrix structure.

Global Dawn Raid app supported by White and Case across all Ecobat locations and functions.

•

Dawn Raid is an engine for Ecobat employees to use in the event a dawn raid occurs on an Ecobat entity. This application will alert select individuals within Ecobat’s upper management with guidance on how to protect employees and the business with onsite and virtual legal support.

Additional business ethics accomplishments in 2022 include: •

Investigations handbook and manual development.

•

Global investigations training (live day-long training).

•

Self-service, on-demand reporting to HR and Audit.

•

Global SpeakUp line for employees to report business ethics concerns via web, email, telephone, or text, and anonymously correspond with investigators.

•

Rolled out global c-suite level Delegation of Authority matrix.

•

The Whistleblowing Procedure, using the SpeakUp hotline, includes the following procedures:

BUSINESS ETHICS REPORTING METRICS

LMS: Anti-Trust and Competition Law Training

• • •

USA – 610 or 63% UK – 364 or 80% Global Battery Division (France, Netherlands, Spain, UK) – 232 or 68%

Online training on market dominance

Eversheds Sutherland – Global Battery Division

Number of confirmed corruption incidents

0

Percentage of all operational sites for which an internal audit/risk assessment concerning business ethics issues has been conducted

100%

Percentage of all operational sites with certified anti-corruption management system

0

Cases of child labor, forced labor and human trafficking

0

Number of discrimination incidents

0

Number of harassment incidents

0

SpeakUp line activations/ report conducted

78 calls received in 2022, 76 investigations completed to date

Employees may submit an allegation of an unethical or illegal nature through the SpeakUp hotline. Once a claim is received, Compliance is alerted and reviews the case within 24 hours of receipt. The claimant is then notified that their claim is being processed.

After the case has been reviewed, if Compliance deems an investigation to be necessary, an internal or external third-party investigator will be assigned.

Internal investigators are given two weeks to complete an investigation. A report detailing the investigation will be uploaded to the SpeakUp hotline where the synopsis of the case will be recorded, and the case marked as closed. If an external investigator is selected, the due date of the investigation will coincide with the availability of the third-party investigator.

However, as the internal investigator, a full report will be uploaded once the investigation is complete, and the case marked as closed.

Ecobat’s Business Ethics reporting metrics are shown to the left.

Ecobat is committed to high ethical standards and a code of conduct that guide the management of our business. We believe that our organizational philosophy and values drive our business objectives, performance, and culture.

We employ a range of policies and protocols to bolster our ethical framework, including key areas such as: •

Confidentiality

•

Whistleblowing

•

Anti-money Laundering

•

Inducement & Gifts

•

Anti-corruption (Foreign Corrupt Practices Act)

•

Compliance with Laws

•

Fair Operating Practices

Ecobat strictly adheres to all laws and regulations, acting in a fair manner with all business partners and stakeholders. Our people practice accountability, are fair in all dealings, and treat all individuals with respect - reinforced by Ecobat’s policies and guidelines for: •

Political & charitable contributions

•

Promoting social responsibility in the supply chain

•

Respect for property rights

•

Fair competition

Ecobat did not experience any confirmed incidents of corruption in 2021 as defined by GRI Standards Disclosure 205-31or 206-12; meaning no reports of: •

Employee dismissal

• Terminated contracts with business partners •

New public legal cases

•

Legal actions for anti-competitive, antitrust or a monopoly

I N F O R M AT I O N S E C U R I T Y

Ecobat is committed to upholding the privacy of employee, client, and customer data through: An Information Security Policy in place to effectively communicate to stakeholders how their data is processed and stored.

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Controls that include a Data Privacy Committee; engaging a third party as the single, global data privacy officer (DPO).

Security reviews on new vendors, including contractual clauses encompassing data privacy elements.

A whistle-blower procedure in place to allow employees to report any information security concerns.

Additional precautionary password protection steps to protect data privacy, including multi-factor authentication.

Employee education through Fair Business Practices Awareness Training about the risks related to data breaches and the importance of preventing information security breaches.

Security software that included: •

Deploying real-time monitoring of all Ecobat networks.

•

Deploying Managed Security Services Provider and primary cyber security platform.

•

Performed email phishing testing and awareness training for employees.

Annual case monitoring of data breach incidents with a KPI dashboard.

Ecobat monitors critical KPIs through dashboards that display specific cybersecurity effectiveness and awareness. These measures assist Ecobat team members in immediately addressing outstanding issues that impact information security operations.

Ecobat Information Security program aligns with: National Institute of Standards and Technology (NIST)

Cybersecurity Framework ID.AM-6, ID.GV-2, DE.DP-2, SP 800-37 3.3, SP 800-53 AT-3.2, CA-3.4, PS-3.16

Control Objectives for Information and Related Technologies (COBIT)

APO01.02, APO01.11, APO07.03, APO07.05, APO13.01, APO13.02, DSS04.05

General Data Protection Regulation (GDPR)

Article 32

Health Insurance Portability and Accountability Act of 1996 (HIPPA)

164.308(a)(1)(ii)(B), 164.312(a)(2)(iv)

International Organization for Standardization (ISO)

27001 7.3, A.7.2, A.8.1.3, A.8.2

Payment Card Industry Data Security Standard (PCI DSS)

12.3.5

Environment Environmental stewardship is the core of Ecobat’s business, and we use best practices and leading standards to protect the environment. We believe that improved operational efficiency and resource management can sustain significant economic growth, while reducing our impact on the environment.

The more lead we recover through recycling, the less we need to extract through mining. This approach allows for greater preservation of natural resources.

We work continually to reduce our footprint by improving our operational efficiency, including minimizing air emissions from our operations, lowering energy consumption and carbon dioxide generation, lowering water consumption in our operations, and reducing waste generation from our processes. To support our environmental management practices, all of our facilities are certified under ISO 14001 and several are certified for energy management under ISO 50001.

ENERGY AND EMISSIONS

Because of our internal standards, industry regulations, and legal requirements for lead manufacturing, lead battery production is reported to have the lowest environmental footprint and lowest production energy and carbon emissions of all widely-used battery technology manufacturing. The use of recovered lead to produce new batteries is less energy intensive than using primary lead, conserving resources needed to support a growing demand for advanced lead battery technology.

Ecobat has voluntarily invested more than $100 million in emission control and sustainability efforts, including the wet electrostatic precipitator (WESP) which has additional efficiency after upstream controls.

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We understand that transparency in our performance and results is paramount. Ecobat engaged third party assurance provider, ERM Certification and Verification Services, Inc. (ERM CVS) to assure its global Scope 1 Direct GHG Emissions and Scope 2 Indirect GHG Emissions results presented below. See the Independent Assurance Statement (pages 34-35) for full details of the assurance scope, assurance standards used, work undertaken and conclusions to assure our Scope 1 and 2 reporting.

We are proud to be a member of a forward-thinking industry, committed to reducing the negative impacts of climate change. United States Environmental Protection Agency National Emissions Inventory (NEI) data reported that secondary smelters like Ecobat only comprised 0.44% of US lead emissions. In addition, the EU Commission in the Battery Directive evaluation report cited that use of recycled materials reduces the ecological points of the lead-acid battery up to 49%, a positive direction we are proud to support. We remain committed to achieving

G H G E M I S S I O N S T O TA L S B Y S O U R C E C AT E G O R Y 2 E C O B AT G H G I N V E N T O R Y 2 0 2 1

Scope

Location-Based Total by Scope (MT CO2e)

Market-Based Total by Scope (MT CO2e)

Source Category

Location-Based Total

by Category (MT CO2e)

Market-Based Total

by Category (MT CO2e)

Stationary Combustion Mobile Combustion Fugitives Process Emissions

254,581 9,677 705 131,658

254,581 9,677 705 131,658

Scope 1 Direct Emissions^

396,621

396,621

Scope 2 Indirect Emissions from Purchased Energy

70,416^

83,902

Purchased Electricity Purchased Energy

64,079 6,337

77,566 6,337

Total

467,037

480,523

Total

467,037

480,523

^ This metric was assured by ERM CVS in 2023. Reference Independent Limited Assurance Statement to Ecobat, LLC for details.

G H G E M I S S I O N S T O TA L S B Y E N T I T Y 3 E C O B AT G H G I N V E N T O R Y 2 0 2 1

Entity

Stationary Combustion: (MT CO2e)

Mobile Combustion (MT CO2e)

Fugitive Emissions and Refrigerants (MT CO2e)

Battery Logistics Resources Solutions Corporate Misc. Mobile

160 no data 254,637 5 12 --

-2,668 7,009 ----

35 289 265 23 6 88

--131,658 ----

256 287 68,875 708 58 --

355 469 81,963 824 58 --

451 3,243 462,443 736 75 88

550 3,426 475,532 852 75 88

Total

254,813

9,677

705

131,658

70,184

83,670

467,037

480,523

Process Emissions (MT CO2e)

Purchased Energy Location-Based (MT CO2e)

Purchased Energy Market-Based (MT CO2e)

Location-Based Total (MT CO2e)

Market-Based Total (MT CO2e)

our sustainability goals by cooperating with our industry partners and consumers who act today to preserve tomorrow. We manage our processes responsibly and continually improve and reduce our environmental footprint.

The table to the left summarizes GHG analysis results used to determine GHG Emissions.

R E C Y C L I N G O F W A S T E A N D M AT E R I A L S

Lead recycling Lead recycling is a critical way to help meet the growing demand for energy availability worldwide, allowing us to deliver essential resources and, at the same time, leave a smaller footprint. Lead batteries provide nearly 70% of all rechargeable battery energy storage capacity worldwide, and 99% of the materials lead batteries are made with can be recycled or reused. So it is no surprise that lead batteries are the most recycled consumer product on earth.

Ecobat’s closed-loop recycling system means we manage the recycling process from start to finish, from collection through recycling and production of metal alloys, including recycled plastics and materials from sulfur, and finally through distribution and servicing of new batteries. We accomplish this using our extensive global network of collection, recycling, and distribution facilities. This approach allows us to maximize the recyclability of and return from recycled batteries, increasing value to our customers and enabling greater sustainability.

The process begins with collecting batteries for recycling and delivering them to our facilities. The core material from these batteries is then recovered and refined to manufacture the highest quality lead and lead alloys, over 80% of which is returned to battery manufacturing. Keeping batteries within our network minimizes the logistical requirements of transporting batteries and reduces our environmental impact.

Alongside our recycling and lead production operations, Ecobat also manages the reclamation of polypropylene used to develop premium polymer solutions. We have been developing PP-recyclate for over a decade as a high-quality alternative to industrial polymers.

Finally, our comprehensive production process and network also allows us to offer many supplementary products and derivatives, including precious metals. Ecobat’s production of precious metals, including silver, gold, copper, platinum, tin, and bismuth, is an integral part of our drive to derive everything from our raw material sources and provide maximum value to our customers.

In 2022, we fully recycled 70 million vehicle batteries.

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Through our active involvement in the International Lead Association (ILA), we work to eliminate unregulated recycling practices and to educate low- and middleincome countries to improve standards and protect communities where these irresponsible recycling practices occur.

Equally important, as we reduce our footprint as a company, we reduce the footprint of millions of endusers. We are excited to fill that space in the lifecycle and enable our industry to positively impact society.

Lithium recycling Ecobat Solutions opened its first EV Diagnosis and Disassembly center in Darlaston, UK, in January 2021. Designed as the blueprint for developing Ecobat Solutions sites around Europe and the US, this facility has processed over 3,000 EV batteries. This business model is based on service and sustainability, partnering with major OEMs and Tier 1 suppliers to offer a flexible, integrated package of services designed to maximize the potential of lithium-ion and other advanced batteries.

At Ecobat Solutions in Darlaston, UK, this power is captured and directly routed to EV charging bays to benefit visitors and staff.

Ecobat captures resources which have already been mined, refined, and manufactured via collections and reuse in second-life applications or by recapturing the base materials for the creation of new batteries. In 2022, Ecobat Solutions offered pan-European collection, including critical batteries, and recycled in both the UK and Germany.

Process upgrades will take place at

Electric Vehicle (EV) charging facility at Ecobat’s Darlaston site powered by energy recovered from discharged batteries prior to recycling.

both facilities in 2023 to increase the volume of batteries recycled and the recovery of metals recycled. In addition, construction of the first North American facility began in 2022. Ecobat Solutions plans to continue to add logistics collections, consolidation storage locations and recycling facilities across Europe and North America over the coming years, to grow with the increasing need demand for end-oflife battery and factory scrap recycling.

Ecobat Solutions prides itself on operating safe and environmentally responsible facilities, leveraging our experience in metals recycling that offers value-added, smart engineering options for battery packs, ancillary elements, modules, and cells, potentially extending each component’s material life and saving the resource cost of manufacturing more elements from scratch.

Our employees utilize best-in-class personal protective equipment and participate in regular monitoring programs to prevent exposure to harmful metals. Our engineers can find and fix faults within production-ready units so that they may be returned to manufacturing and perform remedial servicing on battery management systems or battery cooling systems.

S U S TA I N A B L E P R O C U R E M E N T

Ecobat recognizes its ethical responsibility to assess its supply chain from a risk-based due diligence perspective, evaluate the wide range of suppliers that supply goods for sale, provide services, and support our operations. Our product supply chain is complex, with multiple levels between Ecobat and the source of raw materials entering the manufacturing process. This complexity means we must be increasingly diligent and constantly evolve our procurement policies.

Our commitment to sustainable procurement requires Ecobat to address the specific roles and responsibilities of our vendors, contractors, and business partners to ensure ethical behavior within our supply chain relationships. All parties remain accountable for their actions and must adhere to all applicable laws and standards. These responsibilities include respecting human rights, not participating in modern slavery practices, offering safe working conditions, and respecting employees’ health, safety, and welfare.

Respect for the environment is also paramount as we monitor the use of conflict minerals and adherence to applicable environmental safety laws.

Ecobat also balances due diligence with economics. We strive to ensure indirect procurement drives cost savings while maintaining operational stability across a dynamic economic landscape. We have developed a strategic partnership with our energy brokers to explore the benefits of renewables to include solar, battery storage, demand response, and peak shaving. All of which will allow Ecobat to reduce it carbon footprint as we continue to strive for excellence in sustainability. That is why our sustainable procurement mission addresses the following: •

Reducing operational expenses across all categories

•

Providing plan operational stability

•

Maintaining an excellent reputation for delivery

•

Lowering working capital

The practical application of this vision requires us to establish a straightforward mission-driven approach, guided by seven pillars of success which serve to: Drive competition. We evaluate multiple vendors for our procurement needs to drive down costs.

Build resiliency. We ensure our procurement programs can support ongoing operations.

Champion commonality. We promote shared assets across the organization.

Establish robust metrics. We produce metrics that evaluate program effectiveness.

Work cross-functionally. We engage partners across business lines for diverse viewpoints that serve organizational goals.

Take risks. We take calculated risks in our supply chain where appropriate.

Secure opportunity. We identify vendors and products to support ongoing operations.

Ecobat evaluates supplier risks through a third-party monitoring software.

For certain third parties, mandatory contractual provisions are enacted.

Our vision, mission, and commitment to ethical practices are at the heart of our sustainable procurement efforts. As our operations expand to offering additional products and broadening our global footprint, we will evolve our procurement practices to ensure safe, ethical, and responsible practices.

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Social Our business success is directly tied to the progress, health, and prosperity of the people we work with and the communities where we operate.

PEOPLE

Ecobat is dedicated to hiring, engaging, and retaining a talented and diverse workforce. We use a variety of recruitment tools, recruiters, and search engines to encourage equal employment opportunities that create a diverse workforce.

Ecobat’s employment practices and targeted employee training promotes strong work and social protections while upholding our goal to eliminate workforce discrimination. Ecobat reinforces a healthy workplace environment that centers on our values. Ecobat focuses on efforts to improve the lives and jobs of our valued employees. We are continually making improvements to ensure fair treatment and pay for our associates worldwide.

In 2022, our projects focused on global alignment and standardization initiatives within HR. In 2023, we anticipate full integration and deployment of the programs globally. 2022 global accomplishments include: The initiation of ADP global implementation will be completed in 2023 and will align all HRIS and payroll operations under a single platform.

The development and launch of a global grade and salary structure project to provide tools to enable managers to make smart pay decisions and better manage pay for their non-union staff.

Payment of bonuses and short-term incentives to better align pay outcomes to company and individual performance through standard financial and safety measures.

The initiation and implementation of the Accelerating My Potential (AMP) management and leadership development across the US. This program is also scheduled for launch in Europe and the UK in 2023.

Distribution of our global Employee Engagement Survey, the first engagement survey to be benchmarked against 15 other organizations that share our NAICS code and participate in similar industries and businesses.

Implementation and global launch of SpeakUp, an employee reporting tool that allows employees to report concerns regarding safety, bullying, discrimination, and unethical behavior.

Implementation and global launch of Leading the Charge Women’s Initiative to engage individuals and empower teams to collaborate and enhance Ecobat culture.

Distribution of financial relief to European employees for unexpected high inflation rates.

Employee Engagement Our 2022 Employee Engagement Survey was performed for all global employees with a response rate of 44%. The overall score of 56% was higher than the industry average of 50%.

Survey results prompted action plans to promote: 1) Clear communication of vision and values; 2) Management accountability for employee engagement and communication; and 3) Two-way communication through employee forums, meetings, and suggestion boxes.

H E A LT H A N D S A F E T Y

Ecobat considers our employees’ health and safety as the foundation of our business operations. Therefore, safeguarding our staff is a paramount in every decision made. We have established our Occupational Health and Safety framework in accordance with ISO 45001.

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Ecobat’s safety management system focuses on:

Risk Controls for Blood Lead Levels

•

Hazard Identification, Risk Assessments and Operational Controls

•

Legal and Other Requirements

•

Competency, Training and Awareness of Staff

•

Established Emergency Preparedness and Response

•

Incident Investigation, Corrective Actions, Preventive Action

•

Performance Measurements, Monitoring, Assessments and Communication

Given the nature of our work, protecting our workforce from the recognized health impacts of lead exposure is core to what we do. We focus on effective engineering, administrative and personal protective measures to manage our performance. Ecobat has developed a Global Blood Lead Standard to ensure consistency in approach and expectations for all divisions with respect to Blood Lead Sampling requirements, sampling populations, minimum Blood Lead Reduction program elements, and mentorship expectations. Ecobat has established practices to ensure that employee Blood Lead Levels (BLL) stay within acceptable ranges.

Several improvements to the safety program were initiated in 2022 that provided significant benefit and transparency to the global operations. In 2022, a global behavior-based safety (BBS) program was developed that focused on critical operations that have the potential to result in loss of life or limb. The BBS program allowed observers to validate at-risk and compliant behaviors in an effort to understand trends in procedure non-compliance and improve overall behavior and performance. Additionally, a global hazard identification, near-miss, and incident management system was initiated. This system allowed for further transparency of global incidents across the business and provided a greater opportunity to see business trends and lessons learned. These program enhancements resulted in the best 12-month rolling Total Reportable Incident Rate

These practices include: •

Mandatory training and mentoring programs are in place to educate and monitor employees actions to ensure compliance with best practices and answer any related questions.

•

Monthly and quarterly employee-driven BLL improvement teams ensure continuous improvement of existing protocols.

•

Quarterly testing of blood levels provided for exposed employees. If levels exceed established thresholds, additional testing is required and the employee may be reassigned to work in a nonexposure area.

(TCIR) of the organization’s recent history.

2 0 2 2 T O TA L C A S E I N C I D E N T R AT E ( T C I R ) R E S U LT S

3-MONTH VS 12-MONTH ROLLING TCIR

3-Month TCIR

12-Month TCIR

Annual Target

2.80

2.30

1.80

1.30

.80 JAN 22

FEB 22

MAR 22

APR 22

M AY 2 2

JUN 22

JUL 22

AUG 22

SEP 22

OCT 22

NOV 22

DEC 22

•

Mandatory monthly testing for new employees to help monitor transitioning into a work environment where they are exposed to identified constituents.

•

BLL trends are communicated at all levels of the organization including the Board of Directors, to ensure appropriate risk management.

European legislation sets Occupational Exposure Limits (OEL) for lead in the blood of employees in at 70 µg lead per dL blood (µg/dL), whereas United States and California medical removal limit for lead is established at 60 µg/dL. Globally, Ecobat Resources achieved a 12-month rolling average of 7.37 μg/dl in 2022. We look for continuous opportunities to advance the protection of our exposed populations.

WORKING CONDITIONS

Ecobat is committed to ethical employment and working condition practices.

Ecobat treats every employee with respect and dignity and does not tolerate discrimination or harassment of any kind. Employment-related decisions are based on relevant factors such as qualifications, skills, performance, and relevant experience.

We strongly believe that management in the following five areas are key to controlling, monitoring, and improving our social performance:

Employment is freely chosen

Freedom of association and the right to collective bargaining are respected

Working conditions are safe and hygienic

Child labor will not be used

Working hours will not be excessive

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DIVERSITY AND INCLUSION

During 2022, Ecobat reported data on our US employee population, serving as baseline to expand upon in future years. As we continue to centralize our core business functions and associated systems, our reported employee population data, especially from our European locations, will further reflect the breadth and depth of diversity within our global organization. Key results from our 2022 US employee population include: •

Approximately 9% of the US workforce is female.

•

We have 38 women in leadership positions in the U.S.

•

Underrepresented groups make up 62% of our U.S. workforce.

Ecobat is committed to creating a diverse and inclusive culture for its workforce and future reporting will appropriately reflect the demographics of our entire employee population.

TRAINING AND CAREER MANAGEMENT

Enhancing worker skills and expertise is critical for Ecobat’s growth. Below are 2022 results and overview of 2023 improvement efforts.

IT SaaS training portal 2022 results include: 1,543 users accessed 42,885 videos.

•

Popular items were (Excel, Concur, Windows 11)

•

Popular user journeys (OneDrive, Time saving tips for Outlook, Teams)

•

Popular skill paths (Teams, Ecobat Security, tips / tricks for Outlook)

•

15,923 assigned courses completed

An annual performance review program is in place for all employees and a more dynamic performance feedback and engagement program is expected in 2023.

Total hours of training tracking through number of hours per year and/or per employee for all training programs in the company.

A Learning Management System in 2023 for improved reporting of training metrics.

A leadership development program, AMP, in the US with 85 leaders receiving 2,380 hours of training.

Global implementation of AMP is planned for 2023.

COMMUNITY

Ecobat strives to create a positive impact in our communities. We actively advance these communities through employee engagement, job creation, economic growth, and community outreach. The success of the local communities where we live and operate is integral to our success. Therefore, we work to enhance the relationships and investment in these communities.

However, we also realize that we are not only stewards of our environment but must be mindful of our role as a global citizen. Ecobat believes it is critical to support others in need, especially when their existence depends upon the contributions of others. During 2022, we contributed $100,000 to Ukrainian humanitarian relief organizations to assist this part of the world that requires financial assistance to survive extraordinary circumstances.

On a local level, Ecobat’s investments in the communities in which we operate include Boys and Girls Club partnerships, sports, academic, and STEAM sponsorships, community health fairs, blood drives, toy and food drives, and similar initiatives. Our participation builds relationships and ensures these organizations continue to thrive and serve their members.

Communities are significant stakeholders in our sustainability efforts. Ecobat respects the locations and constituents where we operate, recognizing that our operations have a far-reaching impact. That is why we take an active role in evaluating, measuring, and managing our activities so that we continue to safeguard the people and environments in which we operate.

Because of our valued stakeholder relationships, Ecobat has committed Community Relations resources to monitor and respond to stakeholder requests, ensuring that our actions stay aligned with Ecobat’s external stakeholder engagement principles.

We have developed facility-specific, region-specific, and scope-specific external stakeholder engagement strategies based on the five qualitative pillars of stakeholder analysis, which include 1) stakeholder agency, 2) system roles, 3) power and influence, 4) alignment to the problem, and 5) transformational potential. This method allows us to track our efforts to ensure Ecobat remains accountable to our valued community and external stakeholder relationships.

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CONCLUSION

Our global operations reflect our dedication to being a sustainability leader and progressing the circular economy to support the low-carbon transition. This report demonstrates our sustainability commitment, validates our success, and paves the way for future insights.

Innovative solutions are critical for our business as they are to the future of our environment. Ecobat believes we will see enhanced innovation in our industry sector as we position ourselves at the forefront of this evolving space.

However, while we remain dedicated to moving the industry forward, we must also balance our responsibilities to the environment, our stakeholders, and our people.

As our sustainability program matures, our reporting, including the metrics related to material topics, will be more robust, detailed, and informative. Our leadership commitment includes increasing our reporting transparency using meaningful targets and metrics that reflect our operational and environmental success.

We look forward to the coming year, communicating our successes, and powering the future sustainably.

END NOTES Page 6 1

SmithBucklin Statistics Group. 2019. National Recycling Rate Study. BCI_482347-20_2019-Study.pdf (batterycouncil.org).

Page 7 Black Mass is an intermediate waste stream within the full battery recycling value chain, containing valuable metals such as lithium, cobalt and nickel.

1

Page 12 1

The UN Global Compact, The Ten Principles. The Ten Principles | UN Global Compact

The United Nations Department of Economic and Social Affairs, Sustainable Development, The 17 Goals.

THE 17 GOALS | Sustainable Development (un.org) 2

3

The Global Reporting Initiative, The GRI Standards. GRI - Standards (globalreporting.org).

4

Sustainability Accounting Standards Board, Standards Overview. Standards Overview - SASB.

Page 20 US EPA. 2021. “2017 National Emissions Inventory (NEI) Data (Updated January 19, 2021).” Accessed on August 15, 2022 at https://www.epa.gov/air-emissions-inventories/2017-national-emissions-inventory-nei-data.

1

2

Disclosures: • Ecobat uses the operational control boundary as defined by the GHG Protocol.

• Southern Africa and Stolberg facilities are excluded from the GHG assessment as the facilities were projected to be divested at the end of 2022 and divestments are removed retroactively in accordance with the GHG Protocol.

• Activity data is mapped to emission factors from credible sources including the European Commission, Green-e, UK DEFRA, US DOT, US EPA, and WRI. • Historic data, including that presented here, will be restated if needed in future years if/where significant changes are made due to data improvements. For GHG metrics, significant is defined as 5% of the total inventory.

• The market-based method reflects the emissions from the electricity that a company is purchasing, which may be different from the electricity that is generated locally (location-based).

• For US facilities without consumption data but with square footage data, natural gas usage is estimated using average consumption per square foot (3 owned and 2 leased facilities). For European facilities without consumption data and US facilities without usage or square footage data available, no estimates are included (14 owned facilities and 12 leased facilities).

• Within mobile combustion, 2022 data is used as a proxy to estimate 2021 consumption for US vehicles because 2021 data was not available.

• Within process emissions, it is assumed that all carbon atoms turn to CO2 in a 1:1 conversion.

• Purchased electricity includes estimations for office sites using factors for average consumption per square foot.

3

Disclosures: • Stationary Combustion includes both scope 1 combustion and purchased natural gas for heating in leased spaces, which is part of scope 2 emissions.

• Mobile Combustion includes both on and off-road sources. Mobile sources are not always affiliated with a specific entity, so emissions are presented in a separate ‘Misc. Mobile’ line.

• Purchased Energy includes both purchased electricity and purchased steam.

• Fuel type and energy usage data were not available for some facilities, noted as “No Data”. Where an emission source was not applicable, cells are labeled with “—“. Where an emission source recorded zero usage, cells are labeled “0”.

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F R A M E W O R K C O R R E S P O N D E N C E TA B L E S

SASB RE N E WA B L E R ES OU RC ES & A LT E RN AT I VE E N E RGY SECTO R FU E L CE L L S & I N DU ST RI A L BATTER IES S U STA INA B IL I T Y ACCO U N T I N G STA N DA RD

AC C O U N T I N G M E T R I C

RR-FC-130a.1

(1) (2) (3)

Total Energy Consumed, Percentage grid electricity, Percentage renewable

20-21

RR-FC-320a.1

(1)

Total recordable incident rate (TRIR) and (2) fatality rate

25-26

RR-FC-320a.2

Description of efforts to assess, monitor, and reduce exposure of workforce to human health hazards

25-27

RR-FC-410a.1

Average storage capacity of batteries, by product application and technology type

Contact info@ecobat.com

RR-FC-410a.3

Average battery efficiency as coulombic efficiency, by product application and technology type

Contact info@ecobat.com

RR-FC-410a.5

Average operating lifetime of batteries, by product application and technology type

Contact info@ecobat.com

RR-FC-410b.1

Percentage of products sold that are recyclable or reusable

Contact info@ecobat.com

RR-FC-410b.2

Weight of end-of-life material recovered, percentage recycled

Contact info@ecobat.com

RR-FC-410b.3

Description of approach to manage use, reclamation, and disposal of hazardous materials

21-22

RR-FC-440a.1

Description of the management of risks associated with the use of critical materials

15, 22-23

GR I STA N DA RDS 20 21 102-1

Name of the organization

1

102-2

About the company

6-7

102-3

Location of headquarters

7

102-4

Location of operations

6-7, 30

102-5

Ownership and legal form

6-7, 15

102-6

Markets served

6-7

102-7

Scale of the organization

6-7

102-8

Information on employees and other workers

24-28

102-9

Supply chain

22-23

102-10

Significant changes to the organization size, structure, ownership, or supply chain

4

102-11

Precautionary Principle or approach

8-13

102-12

External initiatives

12-13

102-13

Membership of associations

12-13

102-15

Description of key impacts, risks, and opportunities

8-18

102-16

A description of the organization’s values, principles, standards, and norms of behavior

8-18

102-17

Mechanisms for advice and concerns about ethics

8-17

102-18

Governance structure

14-15

102-26

Role of highest governance body in setting purpose, values and strategy

14-15

102-30

Effectiveness of risk management processes

14-15

102-31

Review of economic, environmental, and social topics

all

102-40

List of stakeholder groups

9-11

102-42

Identifying and selecting stakeholder

9-11

102-43

Approach to stakeholder engagement

9-11

102-44

Key topics and concerns raised

9

102-53

Contact point for questions regarding the report

5

103-1

Explanation of the material topic and its boundary

9

103-2

The management approach and its components

8-15

103-3

Evaluation of the management approach

8-15

302-1

Energy consumption within the organization

20

302-3

Energy intensity

20

305-1

Direct (Scope 1) GHG emissions

20

305-2

Energy indirect (Scope 2) GHG emissions

20

305-3

Other indirect (Scope 3) GHG emissions

20

305-4

GHG emissions intensity

20

103-1

Explanation of the material topic and its boundary

9

103-2

The management approach and its components

8-15

103-3

Evaluation of the management approach

8-13

403-1

Occupational health and safety management system

25-28

403-2

Hazard identification, risk assessment and incident investigation

25-28

403-3

Occupational health services

25-26

403-5

Worker training on occupational health and safety

25-27

403-9

Work-related injuries

25-26

103-1

Explanation of the material topic and its boundary

9

103-2

The management approach and its components

8-15

103-3

Evaluation of the management approach

8-15

404-1

Average hours of training per year per employee

25-28

103-1

Explanation of the material topic and its boundary

9

103-2

The management approach and its components

8-13

103-3

Evaluation of the management approach

8-13

205-1

Operations assessed for risks related to corruption

15-17

205-3

Confirmed incidents of corruption and actions taken

15-17

103-1

Explanation of the material topic and its boundary

9

103-2

The management approach and its components

8-15

103-3

Evaluation of the management approach

8-15

416-2

Incidents of non-compliance concerning the health and safety impacts of products and services

24-28

403-5

Worker training on occupational health and safety

24-28

403-6

Promotion of worker health

24-28

403-7

Prevention and mitigation of occupational health and safety impacts directly linked by business relationships

24-28

403-8

Workers covered by an occupational health and safety management system

24-28

403-9

Work-related injuries

25-27

403-10

Work-related ill health

25-27

404-2

Programs for upgrading employee skills and transition assistance programs

24, 28

404-3

Percentage of employees receiving regular performance and career development reviews

24, 28

406-1

Incidents of discrimination and corrective actions taken

16

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Independent Limited Assurance Statement to Ecobat, LLC ERM Certification & Verification Services Incorporated (“ERM CVS”) was engaged by Ecobat, LLC (“Ecobat”) to provide limited assurance in relation to the selected 2021 disclosures set out below and presented in the Ecobat 2022 Sustainability Report (the “Report”).

Engagement summary Whether the 2021 data for the following selected disclosures, as indicated in Table 1 on page 21 are fairly presented in the Report, in all material respects, in accordance with the reporting criteria.

Disclosure Scope 1 Direct Emissions Scope 2 Indirect Emissions from Purchased Energy (location-based)

Scope of our assurance engagement

Unit MT CO2e MT CO2e

Our assurance engagement does not extend to information in respect of earlier periods or to any other information included in the Report.

Reporting period

Reporting criteria

Assurance standard and level of assurance

Respective responsibilities

1 January 2021 - 31 December 2021 • •

WBCSD/WRI GHG Protocol (2004, as updated January 2015) for the Scope 1 and 2 GHG emissions.

Ecobat’s Basis of Reporting

We performed a limited assurance engagement, in accordance with the International Standard on Assurance Engagements ISAE 3000 (Revised) ‘Assurance Engagements other than Audits or Reviews of Historical Financial Information’ issued by the International Auditing and Standards Board.

The procedures performed in a limited assurance engagement vary in nature and timing from and are less in extent than for a reasonable assurance engagement and consequently, the level of assurance obtained in a limited assurance engagement is substantially lower than the assurance that would have been obtained had a reasonable assurance engagement been performed.

Ecobat is responsible for preparing the Report and for the collection and presentation of the information within it, and for the designing, implementing, and maintaining of internal controls relevant to the preparation and presentation of the Report.

ERM CVS’ responsibility is to provide conclusions to Ecobat on the agreed scope based on our engagement terms with Ecobat, the assurance activities performed and exercising our professional judgement. We accept no responsibility, and deny any liability, to any party other than Ecobat for the conclusions we have reached.

Our conclusion Based on our activities, as described below, nothing has come to our attention to indicate that the 2021 data and information for the disclosures listed under ‘Scope’ above are not fairly presented in the Report, in all material respects, in accordance with the reporting criteria.

Our assurance activities Considering the level of assurance and our assessment of the risk of material misstatement of the Selected Information, a multi-disciplinary team of sustainability and assurance specialists performed a range of procedures that included, but was not restricted to, the following: •

Assessing the appropriateness of the reporting criteria for the selected disclosures.

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Interviews with management representatives responsible for managing the selected disclosures.

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Interviews with relevant staff to understand and evaluate the relevant management systems and processes (including internal review and control processes) used for collecting and reporting the selected disclosures.

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A review at corporate level of a sample of qualitative and quantitative evidence supporting the reported information.

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An analytical review of the year-end data submitted by all locations included in the consolidated 2021 group data for the selected disclosures which included testing the completeness and mathematical accuracy of conversions and calculations, and consolidation in line with the stated reporting boundary.

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One in-person and one virtual site visit to Ecobat facilities in Indianapolis, Indiana, USA, and Welwyn Garden City, United Kingdom to review source data and local reporting systems and controls.

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Confirming conversion and emission factors and assumptions used.

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Reviewing the presentation of information relevant to the scope of our work in the Report to ensure consistency with our findings.

The limitations of our engagement The reliability of the assured information is subject to inherent uncertainties, given the available methods for determining, calculating, or estimating the underlying information. It is important to understand our assurance conclusions in this context.

Our independence, integrity, and quality control ERM CVS is an independent certification and verification body accredited by UKAS to ISO 17021:2015.

Accordingly, we maintain a comprehensive system of quality control, including documented policies and procedures regarding compliance with ethical requirements, professional standards, and applicable legal and regulatory requirements. Our quality management system is at least as demanding as the relevant sections of ISQM-1 and ISQM-2 (2022).

ERM CVS applies a Code of Conduct and related policies to ensure that its employees maintain integrity, objectivity, professional competence, and high ethical standards in their work. Our processes are designed and implemented to ensure that the work we undertake is objective, impartial and free from bias and conflict of interest. Our certified management system covers independence and ethical requirements that are at least as demanding as the relevant sections of Parts A & B of the IESBA Code relating to assurance engagements.

The team that has undertaken this assurance engagement has extensive experience in conducting assurance on environmental, social, ethical and health and safety information, systems and processes, and provides no consultancy related services to Ecobat in any respect.

Beth Wyke Head of Corporate Assurance Services Malvern, PA May 1, 2023 ERM Certification & Verification Services Incorporated www.ermcvs.com | post@ermcvs.com

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