Ecobat 2023 Sustainability Report

Recharging Resources Responsibly 2 0 2 3 S U S TA I N A B I L I T Y R E P O R T

Introduction

Strategy

Governance

People & Community

Environment

Performance Metrics

Table of Contents 3

10

INTRODUCTION

17

GOVERNANCE

ENVIRONMENT

3

CEO’s Letter

18 Governance

35 Environment

4

Ecobat’s International Sustainability Goals

18 Board Structure

36 Energy & Greenhouse Gas Emissions

5

About This Report

19 Risk Committee

36 Air Pollution Prevention Measures

6

World Challenges and Market Trends

19 Group Enterprise Risk Management Policy

37 Hazardous Materials

6

Future Demand for Lead Batteries

20 Ethics

37 Water Management

7

Ecobat Circularity

21 Third-Party Compliance and Code of Conduct

38 Waste Management

8

Company Overview: Locations and Services Per Country

22 Information Security

8

Local Presence, International Impact

9

A Look Forward: 2024 and Beyond

S T R AT E G Y

11 Strategy 11 Mission, Vision, and Values 11 Our Mission 11 Our Vision 12 Our Values 13 Stakeholder Engagement & Materiality 14 Stakeholder Efforts and Communication 15 EcoVadis 16 The United Nations Global Compact (UNGC) and the Sustainable Development Goals (SDGs)

22 Information Security Controls

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39

PERFORMANCE METRICS

44

ANNEX

23 Information Security Alignment

24

PEOPLE & COMMUNITY

45 Report Alignment with GRI

25 Our People

46 Report Alignment with SASB

26 Employee-Focused HR Initiatives

47 Report Alignment with UNGC SDGS

27 Health and Safety

48 ERM-CVS Third Party Assurance Statement

28 Controlling Occupational Exposure Risks

51 General Disclaimer

29 Working Conditions 30 Diversity, Equity & Inclusion 31 Social Dialogue 31 Career Management & Training 32 Child Labor, Forced Labor, and Human Trafficking Measures 32 Responsible Material Sourcing 33 Community

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Annex

Introduction

Strategy

Governance

People & Community

Environment

Performance Metrics

Annex

CEO’s Letter At Ecobat, we provide an essential service and value proposition to the world. We incorporate a business model that focuses on recycling in a circular environment. We strive to deliver products in a timely fashion that are designed for longevity and extended product use with exceptional quality and service.

Executing our circular sustainability strategy is essential to our company, partners, and customers. By recharging resources responsibly, our business model aims to ensure that our customers receive high-quality, recycled products that support their economic, sustainability, and customer goals.

In 2023, we continued to rebound from macroeconomic headwinds of energy, inflation, and workforce pressures through focused enterprise risk management. We achieved an all-time lead production record internally. Restarted Italian operations focusing on a profitable business model and successfully divested Stolberg and South African operations to strengthen core business offerings and activities.

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2023 S U STA I N A B I LI T Y R E P OR T

Ecobat’s focus on health extends from our fiscal responsibility to our dedication to our employees’ health, safety, and well-being. In 2023, we outperformed our 12-month rolling average blood lead improvement goals of 10% for the organization. Additionally, we recorded a 10% year-over-year improvement in employee engagement scores through the National Business Research Institute for our organization.

Since formalizing our sustainability programs in 2022, we have established goals that align with international standards and deployed business practices that support our commitment to striving towards exceptional lead, polypropylene, and lithium-ion battery transportation, collection, recycling, and distribution services. Our efforts were internationally recognized with the EcoVadis Gold Sustainability rating award, placing Ecobat in the top 5% of all participating companies.

We are proud of our story. We are proud to support a low-carbon future. We are proud of our continued effort to sustainability. No other material has a more efficient and prolific recycling story than lead. It is the premier standard of recycling demonstrated by our ability to take a waste product, recycle 99% of its components, and place these valuable commodities back into the supply chain for use.

We look for Ecobat to maintain our focus on providing a superior product and look to continue our successes throughout 2024 and beyond.

Tom Slabe Chief Executive Officer

Introduction

Strategy

People & Community

Governance

Ecobat’s International Sustainability Goals We hold ourselves accountable by measuring our efforts against these international standards, methodologies, and principles:

Sustainability Accounting Standards Board (SASB) and Global Reporting Initiative (GRI) Standards We’ve looked to integrate these sustainability frameworks in our business processes since 2022.

EcoVadis Gold Medal Sustainability Rating EcoVadis is an international organization that assesses environment, labor and human rights, ethics, and sustainable procurement performance. Ecobat earned this award in 2023, placing us in the top 5% of all organizations assessed

by EcoVadis.

Our commitment to respect human and labor rights, safeguard the environment, and work against corruption in all its forms aligns with our product sourcing and production values and goals. Our approach to sustainability extends to our supply chain partners and customers, and it supports UNGC principles. We use an established assessment and review process to ensure our partner organizations align with Ecobat’s Code of Conduct expectations.

Metrics measure the success of our execution.

Starting in 2022 and continuing in 2023, we developed our materiality tracking and reporting systems, supported by streamlined KPI tracking. With established processes and baseline data now in place, we have more confidence in the accuracy and scope of our data. And because we recognize the importance of shareholder confidence,

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United Nations Global Compact (UNGC) Participant

International Sustainability Standards Board

We’ve focused on embedding the Ten Principles of the UNGC into Ecobat strategies since 2023.

For the 2024 reporting year, we plan to increase transparency to our stakeholders through ISSB sustainability framework consistency.

we conduct third party limited assurance of key reporting metrics, such as our annual global greenhouse gas emissions (GHG) footprint. Metrics transparency reflects our commitment to embedding safe, responsible resource recycling procedures. This is fundamental to our story.

As sustainability practices develop worldwide, legislative and regulatory requirements evolve to keep pace.

While we continue to concentrate on providing quality products to our customers, we are also actively engaged with trade organizations, symposiums, and peer organizations to stay up to date on any regulatory impact on our organization and our sustainability goals.

Environment

Performance Metrics

Annex

Introduction

About This Report The enclosed information sets forth Ecobat’s global Sustainability Report. Transparency and accountability are crucial building blocks to achieving progress. Here, we showcase our efforts towards integrating sustainability throughout our company, processes, and products.

All metrics represent 2022 and 2023 data and results.

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. For more information, please contact info@ecobat.com.

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Strategy

Governance

People & Community

Environment

Performance Metrics

Annex

Introduction

Strategy

Governance

People & Community

Environment

Performance Metrics

Annex

Business World Challenges and Market Trends

Future Demand for Lead Batteries

Advantages of Lead Batteries for Industrial Sectors

Electric and Combustion Energy Vehicles

Ecobat’s Competitive Advantage

Lead is the primary focus of our business. We recognize that this 99% recyclable resource is an essential component of today’s commercial and consumer goods. We believe that a circular business model is the optimal way to bring this commodity to market.

We believe that lead continues to be a solution for today and tomorrow. As the global need for energy accelerates, a diverse array of battery solutions must coexist. With electric vehicle (EV) adoption on the rise, we anticipate that the transition of the overall fleet to advanced battery chemistries will gradually progress. Despite the growth of lithium batteries, we expect that lead will continue to play a vital role in EV manufacturing and operation, powering electrical systems such as lights, windows, navigation, air conditioning, and airbag systems into the future. We estimate that by 2040, approximately 42% of the United States and European vehicles will continue to rely on leadacid batteries in internal combustion engine applications.

By leveraging our decades of lead-acid battery recycling expertise, Ecobat has expanded our offerings to recycle advanced battery chemistry waste, such as lithium-ion batteries. We recognize the pivotal role that advanced battery chemistries will play and look to meet the rising global marketplace demand for recycling services.

Transportation, healthcare, telecommunications, agriculture, and consumer goods industries use lead as a primary energy source and product component.

Lead has distinct advantages over other natural resources, including:

1

2

3

B O R N R E C YC L A B L E

Lead is inherently recyclable - up to 99% and maintains undegraded performance post-recycling due to its long-lasting chemical properties.

SAFE AND COST EFFECTIVE

Lead offers a safe, cost-effective storage solution for industry and consumer goods.

S TA B I L I T Y

Lead’s stable battery chemistry adds value to products it is used in.

Lead plays a critical role as both a primary energy source and a fundamental component in equipment and tools, driving essential sectors globally.

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Alternative Energy Resources Require Lead Batteries Lead batteries will likely also be required for alternative energy sources, including solar panels and wind turbines, as our society works to reduce its reliance on fossil fuels. However, solar and wind resources will still require batteries for a continuous 24-hour energy supply. With their stability, cost efficiency, and reliability, lead-acid batteries may prove ideal for expanding applications like energy storage.

Increased Global Regulations Governments, including the European Union, are actively working to fortify circularity and sustainability regulations for batteries and waste Regulation (EU) 2023/1542 of the European Parliament and of the Council of 12 July 2023, with initiatives like the European Union Batteries Regulation. We believe that lead-acid battery recycling continues to be the model for circularity and efficiency for other products to emulate.

We also offer a key solution for vehicle original equipment manufacturers (OEMs) responsible for achieving EU Endof-Life Vehicles Directive recycled plastic requirements, Directive 2000/53/EC of the European Parliament and of the Council of 18 September 2000. We provide a second life for all battery components, including polypropylene.

Offering recycled polypropylene is another way we plan to meet the needs of society and our customers.

We believe that our commitment to a circular business model, responsible collection and recycling, and safe business practices make us a global leader in sustainable lead production today and in the future.

Introduction

Strategy

Governance

People & Community

Performance Metrics

Environment

Annex

Ecobat Circularity The United Nations projects the world’s population will increase by nearly 2 billion people in the next 30 years, from the current 8 billion to 9.7 billion in 2050.

We anticipate that with the growth, the demand for raw materials rises significantly. However, the supply of strategic and critical raw materials is limited. We believe that finite supplies of materials call for a departure from the traditional, take-make-consume-throw-away linear economic model.

Our goal is to demonstrate a different model of production and consumption, powered by the circularity model.

We aim to extend the lifecycle of our products through our closed-loop recycling approach. We take end-of-life products and provide a second life, keeping their material circulating within the economy. This approach reduces waste and greenhouse gas emissions and creates further value, as the products can be used repeatedly. With a 99% recyclability rate, lead is the prime example of the success of circularity.

As a foundational component of the European Green Deal focusing on sustainable growth, the EU adopted the Circular Economy Action Plan (CEAP). The CEAP establishes measures to achieve a climate-neutral, sustainable, toxic-free and fully circular economy by 2050. To achieve 2050 targets, the EU will introduce tighter recycling and binding targets for material use and consumption by 2030, European Commission, Directorate-General for Communication, Circular economy action plan - For a cleaner and more competitive Europe, Publications Office of the European Union, 2020.

We believe Ecobat is uniquely positioned to advance these emerging legislative initiatives, which will only grow in importance with global raw material and resource pressures. Recycling and resource recovery comprise more than 80% of our business. We believe we will supply vital resources necessary in the global energy supply as the next generations of low-emission technologies develop and mature.

Ecobat’s Circularity Model is shown to the right.

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almost

1 .1 M T E ND US E R R E M OVE S O L D BAT T E RY

of scrap in 2023

W E CO LLEC T A N D T RA N S P O RT O LD BAT T ERI ES

INSTA L L NE W BAT T E RY

over

3M

W E RECYC LE LEA D, P LAST I C A N D AC I D

batteries sold in 2023 WE PURCHAS E A ND DIST R IBUT E BAT T E R IE S TO E ND US E RS F RO M M A NUFACT URE RS

600KT of lead

W E S M ELT A N D REF I N E LEA D

WE PACK AGE A ND S HIP L E A D TO BAT T E RY M A NUFACT UR E RS

565KT sales in 2023

53KT of plastics

1 1 S M E LT E R S 6 COUNTRIES

Introduction

Strategy

Governance

People & Community

Environment

Performance Metrics

Annex

Company Overview: Locations and Services Per Country Local Presence, International Impact With over 90 years of experience, Ecobat’s extensive history in the lead-acid battery recycling market provides a tremendous marketplace advantage. Decades of technical acumen, practical experience and operational excellence drive our focus on sustainable processes and practices for safe, effective lead handling. Our operations’ scope and breadth allow us to capitalize on transferable advantages, including vast logistical knowledge, strategic geographic positioning, and industry contacts. We believe that managing the responsible production and recycling of lead gives us a distinct competitive advantage.

We aim to provide customers with global, best-in-class recycling, logistics, and distribution services. We recognize the importance of meeting our customers’ needs in the low-carbon transition. That’s why we extended our capabilities to include lithium-ion battery recycling. Moving forward, we strive to provide the same best-in-class services for advanced battery chemistries, complementing our core business expertise in lead and lead-acid battery recycling.

Ecobat Resources Ecobat Resources is one of the leaders in the responsible recycling and production of resources essential to modern life. Backed by an international network of smelters, we are the world’s largest producer of lead and lead alloys used in energy storage solutions and a range of other industrial and commercial applications.

Alongside our lead production and recycling operations, Ecobat Resources also manages the reclamation of polypropylene used in the development of premium polymer solutions and other commodities.

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Headquarters Ecobat Resources Ecobat Logistics Ecobat Battery Ecobat Solutions

Ecobat Logistics Ecobat Logistics manages the collection of end-of-life batteries as part of our commitment to supporting the closed-loop management and recycling of energy storage solutions. We provide collection services for the markets we operate in through our 11 smelting facilities, a collection truck fleet, and 65,000 battery collection points, aiming to offer a seamless service for battery collection and recycling in Europe. Our Logistics locations geographically complement our European Resources and Solutions operations. In addition to lead batteries, we also manage the collection and handling of other battery chemistries, including, but not limited to, lithium batteries.

Ecobat Battery Ecobat Battery manages the procurement and sale of energy storage solutions. We supply batteries for a wide range of uses, including automotive, commercial vehicle, marine and leisure, motorcycle, and industrial applications. We are the sole European license holder and distributor of Lucas and Rolls batteries and a key distributor for Exide, Varta, US Battery, Trojan, Optima,

Sonnenschein, Tab and more. In addition to our vast portfolio of products, we offer various services to our industrial customers, including battery maintenance contracts, installation, and repair.

Ecobat Solutions Ecobat Solutions leverages our extensive technical experience and international team to bring innovative products and solutions to market in the advanced battery chemistry space. We also work to drive innovation within our company and industry as part of our commitment to sustainability and environmental stewardship, in the development of technologies and processes for recycling and resource recovery for lithium-ion and other battery chemistries. We have capabilities for collection, dismantling, diagnostics, and crushing/sorting to derive black mass for advanced battery chemistries. We also support research and partner with universities, trade organizations, and government entities to develop safe, more efficient energy storage solutions.

Introduction

A Look Forward: 2024 and Beyond As the world continues to evolve in the transition to a lowcarbon future, Ecobat remains steadfast in progressing our program and operational practices with sustainability in mind. Material changes to the business, marketplace, and regulation will drive our strategy and response.

We believe that our model, which aims to provide safe, environmentally responsible product recycling helps drive the future of the low-carbon transition. We’re proud of the essential role we have the potential to play in the circular economy not only today but also in the future of recharging resources responsibly.

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Strategy

Governance

People & Community

Environment

Performance Metrics

Annex

Introduction

Strategy

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Strategy

Governance

People & Community

Environment

Performance Metrics

Annex

Strategy

Introduction

Governance

People & Community

Environment

Performance Metrics

Annex

Strategy Mission, Vision, and Values Every day, it is estimated that billions of people benefit from the technologies that use and rely on lead. It provides efficient energy storage solutions in transportation, medicine, telecommunications, 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 our practices, and we continually look for new ways to enhance our efforts.

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

Our Vision

Ecobat’s Relevant Documents Supporting This Section: • • • • •

•

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

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•

• • •

Ecobat Modern Slavery & Human Rights Statement Prohibited Parties Compliance Guidelines Group Enterprise Risk Management Policy

As a market leader, we drive advancement within our industry and work to develop innovative and sustainable products that help our customers succeed, protect our environment and improve our communities while meeting the ever-growing need for more efficient, reliable energy storage solutions.

Introduction

Strategy

Governance

People & Community

Environment

Performance Metrics

Our Values

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We’re Proud

We’re Engaged

We find a deep sense of pleasure and satisfaction in the work achievements and qualities we share.

We aim to be consistent, precise, and purposeful in the way we conduct our business.

We’re Rigorous

We’re Operationally Excellent

We gather and review the facts before we engage. If you want to get involved with us, we will make sure you’ve done your homework.

We look to embrace principles and tools that produce efficient outcomes.

We’re Caring

We’re Collaborative

We aim to prioritize the wellbeing of our people, each other, and the planet, and we seek to be intentional about making a positive impact.

We believe we produce effective and efficient outcomes because we work together as a team.

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Annex

Strategy

Introduction

People & Community

Governance

Stakeholder Engagement and Materiality Materiality Matrix data comes from surveys and interviews with 45 internal and external stakeholders, gathering feedback and expectations. Next, we prioritize and rank the list of issues, visually representing them in the Materiality Matrix shown below. The data in the matrix represents annual data for 2023 used to support and validate progress against identified issues.

In 2022, we refined Ecobat’s Environmental, Social, and Governance (ESG) strategy based on a comprehensive materiality assessment that included extensive research, benchmarking, and key stakeholder engagement. We plan to continue to conduct materiality assessments every three years, using a Materiality Matrix to visually highlight key focus areas.

Environmental High Materiality High

Significance to Stakeholders

EP

WHS

EGE RMS

T DEI

WM

PEM ERM

LCE

WS HR

WRR

TPO

Biodiversity & Habitat Protection

WM

Waste Management

PEM

Product End-of-Life Management

EGE

Energy & Greenhouse Gas Emissions

EP

Environmental Protection

WS

Water Stewardship

Social

EAC AT

BHP

WHS

Workforce Health & Safety

HR

Human Rights

DEI

Diversity, Equity, and Inclusion

LCE

Local Community Engagement

RMS

Responsible Materials Sourcing

WRR

Workforce Recruitment & Retention

Governance BHP

Low

High Business Impact

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T

Transparency

EAC

Ethics & Anti-Corruption

AT

Anti-Trust

ERM

Enterprise Risk Management

TPO

Trade & Political Organizations

Environment

Performance Metrics

Annex

Introduction

Strategy

Governance

People & Community

2 0 2 3 S U S TA I N A B I L I T Y S T R AT E G Y S TAT U S

Material Topic

Energy & Greenhouse Gas Emissions

Environmental Protection

Waste Management

Responsible Materials Sourcing

Workforce Health & Safety

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2022 Sustainability Report Published Targets

2023 Published Targets Status Report

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

• Scope 1 & 2 Inventory data available for years 2021, 2022, and 2023.

• After establishing GHG emissions data years 2021, 2022, and 2023, Ecobat is on track to set an emissions target in 2024.

• I n 2023, further improve data collection to monitor lead, cobalt, and nickel releases to air, soil, and water, globally • I n 2024, set a quantitative target

• Ecobat has aligned data collection procedures globally to allow for consistency in methodology and comparisons of information. Internally, 2023 data collected in alignment with procedures has been reviewed to validate process.

Quantitative target will be set in 2024.

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

• Ecobat has aligned data collection procedures globally associated with hazardous and non-hazardous waste generation. Internally, 2023 data collected in alignment with procedures has been reviewed to validate this process.

Quantitative target will be set in 2024.

• I n 2023, establish a Responsible Materials Sourcing Policy and Questionnaire for Suppliers and Vendors • I n 2024, establish compliance targets •C ontinue to report on Ecobat’s internal HSE metrics of Total Case Incident Rate (TCIR) and blood lead • I n 2023, mature high severity program • I n 2024, set target for Solutions •A verage Blood Lead < 6 μg/dL by 2025

2023 S U STA I N A B I LI T Y R E P OR T

• Ecobat has established a Responsible Materials Sourcing Policy and has implemented the associated questionnaire for Supplier and Vendors and is on track to establish compliance targets in 2024.

• We continue to report Ecobat's internal HSE metrics of Total Case Incident Rate (TCIR) and blood lead.

• Established continuity of terminology in Risk Matrix methodology for severity categories. Updated Incident Investigation Program to align reporting and investigations requirements for 2024.

• We continue to improve our biological testing regime for Solutions occupational exposure in 2023 and 2024 in process.

• Average 12-month rolling average of 6.72 μg/dl for its leadexposed populations in 2023.

Environment

Performance Metrics

Annex

Stakeholder Efforts and Communication Engaging with key stakeholders helps Ecobat stay abreast of emerging issues and areas for improvement.

We typically follow a routine cadence, shown below, to interact with internal and external parties to ensure Ecobat addresses their material ESG concerns. The table below outlines the frequency and focal points of our ESG engagement.

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

Biannual

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; bi-annual discussions

Local Communities

Public meetings, facility tours, etc.

At least one touchpoint annually, additional as needed

All

Published sustainability report

Annual

Introduction

Strategy

Governance

People & Community

Environment

Performance Metrics

Annex

EcoVadis With over 125,000+ companies rated across 160 countries, EcoVadis is a globally recognized platform that provides reliable industry sustainability ratings. EcoVadis supplies benchmarks for ethical and environmental standards across many industries in four key categories: environmental impact, labor and human rights standards, ethics, and procurement practices.

Earning an EcoVadis medal or badge acknowledges achievement relative to other assessed companies across the EcoVadis database. To be eligible for a medal, a company must achieve a minimum score of 30 in each of the four themes: environment, ethics, labor and human rights, and sustainable procurement.

In 2023, Ecobat received the Gold Badge from EcoVadis, earning a minimum performance score of 70 across all categories and ranking in the 95th percentile across all firms EcoVadis evaluated. This achievement recognizes our successful efforts in the areas of environment, ethics, labor and human rights, and sustainable procurement.

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F R A M E W O R K S , 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 striving to achieve the highest international standards and holds almost 60 International Standards Organization (ISO) certifications, including ISO 9001 (Quality), ISO 14001 (Environmental Management), ISO 45001 (Occupational Health and Safety), ISO 50001 (Energy Management) and ISO 17025 (Testing and Calibration Management). We leverage these certifications to help advance performance through continuous improvement.

Introduction

The United Nations Global Compact (UNGC) and the Sustainable Development Goals (SDGs) The UNGC and SDGs form the basis of our sustainability framework and help us 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 into a broader perspective that considers social and environmental impacts, 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 Initiative and SASB Standards.

We also consistently work towards contributing to the SDGs in our business operations and strive to embody the UNGC 10 principles.

Strategy

Governance

People & Community

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Performance Metrics

Annex

O U R S U S TA I N A B I L I T Y A I M S

In developing our people and planet aims, we used the UN sustainable development goals to inform our thinking. Although our business activity touches the majority of the SDGs, we are focusing our efforts on those that align with our aims in order to sustainable development and for people over the next decade.

We strive to: Enhance wellbeing Enhance the health and wellbeing of our employees, contractors and local communities.

Greater equity Support greater diversity, equity and inclusion for our workforce and customers.

Transparency leader Be recognized as an industry leader for the transparency of our reporting.

Enable clean energy Provide an essential material to aid in the low-carbon transition through battery applications.

Sustainable purchasing Develop a more sustainable supply chain.

Promote circularity Unlock enterprise of value through circularity.

Just transition Support a just energy transition that advances human rights, environmental stewardship, and education.

Incentivizing employees Incentivize our global workforce to deliver on our aims and mobilize them to become advocates for circularity.

Advocating Aligning associations More actively advocate for Set new expectations for policies that support circularity, our relationships with trade including material recycling rates. associations around the globe.

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Environment

Introduction

Governance

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Strategy

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People & Community

Environment

Performance Metrics

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Introduction

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Annex

Governance Ecobat’s governance framework aims to ensure 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 documents, including its governing LLC agreement. Ecobat’s Board is comprised of 12 individuals appointed by unitholders.

Board members have a varied and expansive depth of experience in financial sectors, with members adding expertise in global industries, manufacturing, and service.

Ecobat’s Relevant Documents Supporting This Section: • • • • • • • • • • • • • • •

Avoidable Loss Reporting Travel and Expense Policy Delegation of Authority 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

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• • • • • • • • • • •

Financial Reporting Income Tax Filing Indirect Tax Filing Intercompany Transfer Pricing 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 Health, Safety, Environmental & Sustainability Policy

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

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

Each committee has its own charter, and these are the governance documents. The Board charter requires four board meetings per year at minimum and additional meetings as required to ensure Board alignment with management.

Introduction

Strategy

Governance

People & Community

Environment

Performance Metrics

Annex

Risk Committee

Group Enterprise Risk Management Policy

The Ecobat Enterprise Risk Committee (ERC), comprised of Ecobat’s Executive Leadership team 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.

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

The annual Enterprise Risk Assessment (ERA) evaluates Ecobat’s broader portfolio of operational, commercial, strategic, financial, technological, legal/ regulatory, and human capital risks. It creates a priority list of the most critical enterprise-level risks. The ARS team further formulates the 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.

GOVERNANCE

2022

2023

% of the total workforce across all locations who received training (e.g. e- learning) on business ethics issues

%

70%

100%

% of all operational sites for which an internal audit & control concerning business ethics issues has been conducted

%

100%

100%

% of all operational sites for which a risk assessment concerning business ethics issues has been conducted

%

100%

100%

# confirmed incidents of corruption and actions taken

#

0

0

Total number and nature of confirmed incidents of corruption*

#

0

0

Total number of confirmed incidents in which employees were dismissed or disciplined for corruption*

#

0

0

Total number of confirmed incidents when contracts with business partners were terminated or not renewed due to violations related to corruption*

#

0

0

Public legal cases regarding corruption brought against the organization or its employees during the reporting period and the outcomes of such cases

#

0

0

Legal actions for anti-competitive behavior, antitrust, monopoly practices

#

0

0

Number of legal actions pending or completed during the reporting period regarding anti-competitive behavior and violations of anti-trust and monopoly legislation in which the organization has been identified as a participant

#

0

1

% of all operational sites with an information security management certification (ISO 27001)

%

0

0

# of SpeakUp hotline reports

#

78

29

* Corruption is defined as making a payment, offer or promise (or the authorization of a payment, offer or promise) of anything of value directly or indirectly to a foreign public official for the purpose of obtaining or retaining business for reporting purposes.

19

2023 S U STA I N A B I LI T Y R E P OR T

Introduction

Strategy

Governance

People & Community

Environment

Performance Metrics

Annex

Ethics 2023 Accomplishments Building on the successes in 2022, Ecobat continued our focused efforts to enhance business ethics in 2023. We:

1

We enhanced global ethics and compliance tool platforms launched in 2022. We strengthened on-demand reporting to Human Resources and Audit with self-service options for employees, promoting engagement, accountability, and access.

•

EthicsPoint - EthicsPoint is an internal hotline for all global employees to report alleged incidents of unethical or otherwise illegal activity. It has continued to evolve and grow in our culture. The SpeakUp hotline allows employees to report business ethics concerns via web, email or telephone and anonymously correspond with investigators. To ensure consistency in the investigation process, the SpeakUp hotline has a Whistleblowing Procedure. This was developed alongside an investigation handbook, tool manual development, and global investigations training.

•

PolicyTech - This is a centralized hub where all employees can access global company policies and procedures.

Engage - This compliance training platform provides all employees with vital competition and antitrust training.

2023 S U STA I N A B I LI T Y R E P OR T

S T R E N G T H E N E D D ATA P R I VA C Y EFFORTS

We created an internal Data Privacy Committee to ensure data privacy is a business priority.

The committee oversees the application of data privacy cross-company in compliance with applicable laws.

I M P L E M E N T E D T O O L P L AT F O R M S

•

20

2

3

E X PA N D E D D E L E G AT I O N O F A U T H O R I T Y ( D O A ) M AT R I X

We are guided by fiduciary responsibility.

The DOA Matrix directs Ecobat’s monetary approval authorities and guides various areas of responsibility for each function. The process starts with our Executive team and extends to the various functions in the submatrices. The Matrix is used company-wide to communicate the clearly defined functional and financial responsibilities of our 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.

4

DEVELOPED A COMPLIANCE CHAMPIONS PROGRAM

We brought together members from across functions and countries to ensure diverse viewpoints to collaboratively champion compliance throughout our business.

5

INCREASED OUR GLOBAL COMPLIANCE PROGRAM T R A N S PA R E N C Y

We established a global training calendar for employees via The Terminal, our Intranet site.

Managing Directors are provided with a quarterly reporting tool for team training visibility. A biannual compliance newsletter was created to communicate compliance trends that could affect employees. We also published and shared an enterprise-wide compliance program for all employees through the Terminal.

Introduction

Third-Party Compliance and Code of Conduct Ecobat’s supplier and customer partnerships are critical to our success. Relationships with organizations who do not share Ecobat’s values and have known ethics violations and governance concerns pose risks to our business. So, in 2023, we invested in a platform that looks to provide end-to-end visibility of the supply chain. From a risk mitigation control perspective, this onboarding and sanctions monitoring tool aims to ensure our partnerships align with our organizational values.

During the new onboarding process, each third party must be reviewed prior to conducting business with Ecobat. We share our Third-Party Supplier Code of Conduct requirements and suppliers are required to note acknowledgment.

We use this supply chain platform to: •

Assess all suppliers, customers, and employees through a standardized watchlist

•

Send external questionnaires for additional clarification

•

Demonstrate a level of due diligence for the company

•

Evaluate affiliated persons

•

Evaluate parent or subsidiary companies

•

Indicate past standard sanctions applied to the specific entry

•

Conduct a questionnaire on Health, Safety, and Environmental program

•

Analyze Environmental, Social and Governance Program

•

Communicate and confirm conformance to Code of Conduct expectations

21

2023 S U STA I N A B I LI T Y R E P OR T

Strategy

Governance

People & Community

Environment

Performance Metrics

Annex

Introduction

Strategy

Governance

People & Community

Environment

Performance Metrics

Annex

Information Security Ecobat recognizes that digitization and sustainability are intrinsically linked, and that successfully managing its impacts requires credible and secure data measurements and inputs. Therefore, Ecobat has developed a digital strategy that is pivotal to attaining its sustainability goals.

One area of Ecobat’s digital strategy that presents an opportunity for sustainability is Artificial Intelligence (AI).

AI provides a measure by which Ecobat can leverage state-of-the-art technology to achieve its environmental and social goals. Ecobat actively invests in AI across a number of initiatives to ingest data, train models, analyze forecasts, and ultimately predict, respond, and mitigate future trends across its operations. Some examples of how Ecobat aims to use AI for sustainability are: •

AI-powered energy management systems that aim to optimize energy consumption and reduce greenhouse gas emissions.

•

AI-enabled predictive maintenance that reduce downtime, improves efficiency, and should extend the lifespan of equipment.

•

AI-facilitated health and safety monitoring that is designed to detect hazards, alerts workers, and prevent accidents and injuries.

Another aspect of Ecobat’s digital strategy that supports its sustainability goals is the transformational implementation of S4 HANA Cloud ERP across its operations. This strategic initiative gives Ecobat more visibility into its supply chain and recurring operating costs, making it easier through analytics to identify opportunities for improvement. Ecobat’s single, global cloud-based ERP (SAP) enables it to combine, connect, and link financial and non-financial metric views into one holistic reporting. A single source of truth for data contributes to giving Ecobat clear visibility for performance management and internal and external disclosure requirements. Some benefits of Ecobat’s cloud ERP for sustainability are:

22

2023 S U STA I N A B I LI T Y R E P OR T

•

Cloud ERP reduces the need for physical infrastructure, hardware, and maintenance, which lowers Ecobat’s environmental footprint and operational costs.

Controls include: •

Data Privacy Committee

•

Engaging a third party as the single, global data privacy officer (DPO)

•

Cloud ERP enables real-time data collection, integration, and analysis, which should improve Ecobat’s decision-making and transparency.

•

Security reviews on new vendors

•

•

Cloud ERP facilitates the tracking and reporting of Ecobat’s sustainability performance, which helps Ecobat communicate its progress and achievements to its stakeholders.

Contractual clauses encompassing data privacy elements

•

Whistleblower 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

Cloud ERP supports the alignment of Ecobat’s sustainability goals with its business strategy, which aims to ensure Ecobat’s long-term viability and competitiveness. Ecobat’s digital strategy is a key enabler for its sustainability goals, as it provides the tools and capabilities to measure, manage, and improve its environmental and social impacts. By investing in AI and cloud ERP, Ecobat demonstrates its leadership and innovation in the battery recycling and metal production industry, and its commitment to creating a circular economy for battery materials. Ecobat’s digital strategy aims to promote sustainability by improving waste reduction emissions source tracking and reporting, and transparency.

Information Security Controls We recognize that digital transformations present security and privacy concerns. We are committed to upholding the privacy of employee, client, and customer data through an Information Security Policy, put in place to effectively communicate to stakeholders how their data is processed and stored.

Security control monitoring and testing includes: •

Deploying real-time monitoring of Ecobat networks

•

Deploying a Managed Security Services Provider and primary cyber security platform

•

Performing email phishing testing and awareness training for employees

In addition, we monitor critical KPIs through dashboards that display specific cybersecurity effectiveness and awareness. These measures help our team members quickly address outstanding issues that impact information security operations and business continuity concerns.

Introduction

Governance

Strategy

People & Community

Performance Metrics

Environment

Annex

Information Security Alignment Ecobat Information Security program aligns with:

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

U P D AT E : C Y B E R S E C U R I T Y P R O G R A M S C O R E B O A R D Q1 - Q4 2023 (As of January 18, 2023)

APO01.02, APO01.11, APO07.03, APO07.05, APO10.01, APO13.02, DSS04.05

Article 32

NIST Cyber Security Framework

BitSight Security Rating Score

Microsoft 365 Cloud Compliance

91%

95%

94%

GOAL

GOAL

GOAL

100% alignment with 108 Subcategories

760 as recommended by BitSight as a top industry target

80% as recommended by Microsoft Cloud compliance

Current: 98 of 108

Current: 720

Current: 75%

Security Patching Cadence Effectiveness

Security Awareness Training Effectiveness

Incident Detection & Response Effectiveness

100%

90%

100%

GOAL

GOAL

Organizational Risk Score of 80

Zero (0) Confirmed Security Incidents

Current 72 of 80

Current: 0 of 5

GOAL

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

Zero (0) Open Critical & High Severity Vulnerabilities exposed to the internet Current: 0 of 32

Keys to Continued Resilience - Global Policy, Infrastructure, Oversight, Education

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

23

2023 S U STA I N A B I LI T Y R E P OR T

12.3.5

CIO Perspective

2024 Plan

•

Completed 3rd Party Penetration Test

1.

•

Completed BYOD (Bring Your Own Device) in U.S.

Integrate Ecobat Battery (Emrol acquisition) networks into Corporate Footprint

2.

Simulated Phishing

3.

Password Phrases

Introduction

People & Community

24

2023 S U STA I N A B I LI T Y R E P OR T

Strategy

Governance

People & Community

Environment

Performance Metrics

Annex

Introduction

Strategy

Governance

People & Community

Environment

Performance Metrics

Annex

Our People Ecobat depends on our talented, diverse workforce to succeed in a competitive market. To ensure we attract the right talent, we rely on recruiters, recruitment tools, and search engines that promote our employment opportunities. We also remain focused on a diverse pipeline of applicants. Additionally, our employment practices and training programs support work and social protections, helping to improve our employees’ experiences at their jobs and in their personal lives.

Our commitment to our values drives us to ensure our employees receive fair pay and treatment for their contributions to our global success.

In 2023, Ecobat was awarded the National Business Research Institute (NBRI) Circle of Excellence Award for the significant improvements made over our 2022 Employee Engagement Survey results. This prestigious award demonstrates our dedication to the highest levels of employee experience.

Ecobat’s Relevant Documents Supporting This Section: • • •

•

Global Code of Conduct Working Conditions Policy Pension and Post-Retirement Benefits Policy Leave Policy (USA Only) Anti-Bribery and Corruption Guide for Third-Parties Parental Leave - Minimum Global Standards New Employee Referral Program

25

2023 S U STA I N A B I LI T Y R E P OR T

• • •

• •

• • • • •

US Employee Handbook Marketing: Brand Standards Communication Toolkit Ethics & Confidential Helpline Guidelines Ecobat Conflict Minerals Policy Statement Ecobat Modern Slavery & Human Rights Statement Prohibited Parties Compliance Guidelines Sustainable Procurement Policy

Ecobat Resources UK achieved the prestigious Investors in People Gold status, a testament to our commitment to employee development and organizational excellence. Notably, the Investors in People program recognizes only one award higher than Gold: Platinum.

Ecobat’s UK operations emphasize the significance of investing in the success of all employees, recognizing it as the cornerstone of organizational success. As a program, it provides a comprehensive framework for organizations to evaluate and enhance their people management practices. A three-year accreditation cycle lets us strategize and implement initiatives aimed at continuous improvement and addressing identified opportunities for growth.

Introduction

Employee-Focused HR Initiatives In 2023, we focused on enhancing employee experience, development and enrichment in the following ways: •

Introduction and implementation of Ecobat company values

•

Successful union contract negotiations in California, United States operations

•

Conducted Employee Engagement focus groups across North American plants and Battery Division to drive action and engagement

•

Developed a job mapping and alignment tool to drive salary standardization and align employment terms across the organization

•

Execution of Accelerate My Potential Leadership (AMP) course with approximately 180 participants with a survey rating of 4.7 out of 5.0 across the program

•

Developed and piloted the Emerging Supervisor Program for 2023 engagement

•

Implementation of the Ecobat 360 Coaching Program

•

Deployed the TalentGuard program for enterprise performance management and individual development planning

•

Created a Refinery Training Program for competency assurance

•

Deployed LMS365, a tool to manage training curriculum and tracking to streamline and integrate training platforms and offerings

•

Conducted the first Functional/Talent Assessment Reviews

•

Supported the Leading the Charge initiative with quarterly development webinars and led the 2023 Women’s Virtual Conference

•

Updated the Retirement Plan Committee charters for 401(k) and pension plan for improved governance and to ensure compliance

•

Launched financial planning and well-being workshop and seminar series

26

2023 S U STA I N A B I LI T Y R E P OR T

Strategy

Governance

People & Community

Environment

Performance Metrics

Annex

Introduction

Strategy

Governance

People & Community

Environment

Performance Metrics

Annex

Health and Safety The health and safety of our workforce is integral in achieving our mission “To lead in the responsible collection, recycling, production, and distribution of resources essential to modern life.” We recognize that we can’t meet the needs of our customers and partners without a safe and healthy workforce. The success and sustainability of our organization depends on it. With that in mind, Ecobat has the following Health and Safety program and process controls:

•

Annual PPE risk assessment review and signoff by managers and employees

•

Annual hazardous assessment program review and signoff by employees

Health and Safety Emergency Action Plan

•

Training

•

•

Proper tool selection and equipment design

•

Job rotation where required

Emergency Response, Crisis Communication, and Business Continuity have been identified in our Enterprise Risk Management (ERM) corporate focus areas. We also implement an internal auditing schedule for emergency action plan reviews.

•

Stop Work Authority Program

•

Annual LOTO procedure reviews

Repetitive Strain Injury Prevention

Equipment Safety Inspections or Audits •

Written, site-specific Emergency Action Plans are in place and reviewed annually. We typically hold annual drills to test these procedures.

Pre-use, weekly, monthly, quarterly and annual equipment safety inspection

•

Weekly, monthly, and quarterly inspections of emergency response and other safety equipment

Actions to Control Hazardous Substance Exposure

•

•

•

Third-party audits annually

Employee Complaint Procedure for Reporting Occupational Incidents, Risks and Concerns

•

Administrative Controls, Safety Data Sheets, Hazard Communication Program

•

SpeakUp hotline and Safety Committees

•

Near Miss reporting, tracking and corrective actions

Personal Protective Equipment appropriate for job task, including a written compliance plan

•

Job Risk Assessment

•

Behavioral Based Safety (BBS) Observations

•

TRACE and “Stop and Think” program

27

2023 S U STA I N A B I LI T Y R E P OR T

Health and Safety Training for Subcontractors Working On Premises •

Documented Hearing Conservation Program for all employees

•

Annual employee audiogram

•

Annual review of our ‘Noise Reduction Efforts’ (part of Engineering and Administrative Controls)

Health and Safety Risk Training For All Employees •

Annual employee and refresher safety training

•

Daily Crew Briefs

Actions to Address Stress and Promote Psychological Well-Being

The health and safety of our employees is a measure of our success. We aim to use our established programs and controls to continuously evaluate and improve the health and safety of our workforce.

Training, Standard Work Instructions, internal and third-party audits, emergency response drills, and air quality monitoring

Non-Routine JRA’s

•

Ecobat Employee Assistance Program (EAP) counseling and services

•

•

Noise Exposure Prevention

•

Monthly supervisors’ safety reports and inspections

Routine Job Risk Assessment (JRA’s)

Chemical Hazard Assessment Reviews

Critical Control Behavior Safety Observations by Supervisors/Managers and HSE

•

•

•

Ecobat provides resources and training

Engineering controls include ventilation, compatible material design, tank spill control, and similar procedures

Employee Health and Safety Risk Assessment

Management of Change Review Process

•

•

•

•

Contractor Visitor Safety Program

Respiratory Protection Program •

Training

•

Behavior-based observations

H E A LT H & S A F E T Y K P I

2022

2023

% of all operational sites for which an employee health & safety risk assessment has been conducted.

100%

100%

Lost time injury

46 LT, 39 Days away

44 LT, 42 Days away

Lost time severity

1.9 (LTIR)

1.8 (LTIR)

Average 12-month Blood Lead level

6.72 μg/dl

Introduction

Strategy

People & Community

Governance

Performance Metrics

Environment

Annex

Controlling Occupational Exposure Risks Our success also depends on protecting our workforce from the impact of lead exposure. Ecobat is proud of our industry-leading blood lead level (BLL) performance, which we achieve through effective engineering controls, personal hygiene protocols, and personal protective protocols. These measures are critical to the safety of our employees and our ongoing success.

We developed a Global Blood Lead Standard to set standards and ensure a consistent approach across all our operations. Our program addressed blood lead sampling requirements, sampling populations, minimum Blood Lead Reduction program elements, and mentorship expectations.

In 2023, we implemented consistent practices to ensure that employee BLL stay within acceptable ranges, including: •

Mandatory training and mentoring programs to educate and monitor employees’ actions, ensure compliance with best practices, and answer questions.

•

Bi-weekly, monthly, and quarterly employee-driven BLL improvement teams ensure improvement of existing protocols.

•

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

•

Mandatory monthly testing for new employees to monitor transitioning into a work environment exposed to lead.

COMMITTEE AND TRAINING KPIS

2023

Percentage of the total workforce across all locations represented in formal joint management-worker health & safety committees

75%

Average hours of HSE-related training provided per month

16,071

28

2023 S U STA I N A B I LI T Y R E P OR T

BLL performance is shared across all levels of the organization, including the Board of Directors, to ensure appropriate risk management.

Our commitment to protecting employees requires us to stay up to date on new and changing Occupational Exposure Limits (OEL) regulatory requirements. Globally, Ecobat Resources achieved a 12-month rolling average of 6.72 μg/dl for its lead-exposed populations. This metric represents our best performance to date as an organization. We continue to look for opportunities to advance the protection of our exposed populations and protect the health and safety of our workforce.

T O TA L C A S E I N C I D E N T R AT E ( T C I R ) * 20

4.00 3.00

2.56

15

2.00

2.01

10

1.00

1.93

5 0

0.00

7

5

5

5

8

5

6

4

4

6

4

2

Jan 23

Feb 23

Mar 23

Apr 23

May 23

Jun 23

Jul 23

Aug 23

Sep 23

Oct 23

Nov 23

Dec 23

Total Incidents

2023 Year-End Goal

TCIR 3m

TCIR 12m

BLOOD LEAD LEVEL (BLL) PERFORMANCE* 7.60 7.40 7.20 7.00 6.80 6.60 6.40 6.20 6.00

7.07

7.09

7.09

7.08

7.05

7.01

6.96

6.92

6.88

6.84

6.80

6.72

7.15

7.03

6.73

6.57

6.56

6.56

6.50

6.70

6.69

6.88

6.83

6.49

Jan 23

Feb 23

Mar 23

Apr 23

May 23

Jun 23

Jul 23

Aug 23

Sep 23

Oct 23

Nov 23

Dec 23

Weighted Average µg/dl

Weighted Average µg/dl - 12m

* Group Results exclude Stolberg and South Africa divestitures and Italian shutdown.

2023 Year-End Goal (6.77 µg/dl)

Introduction

Strategy

People & Community

Governance

Environment

Performance Metrics

Annex

Working Conditions Ecobat offers a comprehensive portfolio of programs intended to create a good working environment for our employees. They include: Employee Benefit Programs U.S. employees who work either full or part time and work more than 30 hours per week are eligible for Ecobat’s comprehensive benefit programs under a costsharing program. Benefits include: •

Medical and prescription drug plans

•

Health Savings Account (HSA)

•

Flexible Spending Account (FSA)

•

Tele-health

•

Dental and vision coverage

•

Basic and voluntary AD&D

•

Short and long-term disability programs

•

Supplemental benefit programs

•

Parental leave

•

401(k) retirement savings accounts, including company-matching funds

•

Employee Assistance Program (EAP)

•

Identity theft protection

•

Financial wellness program

•

Consumer insurance programs via Gallagher Marketplace

Family-Friendly Programs Starting in 2023, U.S. non-union employees were given enhanced vacation and maternity leave, and we introduced paternity leave. Programs were democratized for salaried positions.

Additionally, family protection programs were offered at no cost to employees. Programs included home and renters insurance and extended vehicle warranties.

29

2023 S U STA I N A B I LI T Y R E P OR T

WORKING CONDITIONS KPIS (U.S. Employees)

2022

2023

Total employees (as of 12.31.2023)

#

1,129

1,125

Total Male Employees

#

1,022

1,024

Total Female Employees

#

107

101

Office-Based

#

361

383

Due to General Data Protection Regulations (GDPR) privacy and security regulations, EU based results related to these sections are not disclosed.

Pay Grade Framework Guide In March 2023, we implemented a Pay Grade Framework to define pay levels for employees. Through the Pay Grade Framework’s leveling criteria, jobs were assigned to grade levels within broad work categories (e.g., Executive Management, Middle Management, Professional & Sales, and Business and Technical Support). Each grade level was aligned to a pay range. The guide is also to establish benchmarking across similar positions at companies we compete with to attract talent.

We ensured transparent communication by sharing a guide with employees detailing the new program and how they would be impacted, including contact information for the Compensation Team if they had any questions.

Work Leave & Holiday Policies Ecobat grants family and medical leave in accordance with the requirements of applicable federal and state law in effect at the time the leave is granted. Employees will be eligible for the most generous benefits available under applicable law.

We believe in every employee’s right to paid time off away from work, individual and family-related illness and other types of leave. Eligible U.S. non-union employees have access to vacation, sick leave, and paid parental leave (including primary and secondary caregiver leave where appropriate).

Compensation Policies Ecobat has specific policies that describe employee union / non-union and exempt / non-exempt employment status. Policies for each Ecobat location outline specific guidelines for pay periods, regular and shift premium pay, holiday and vacation pay, overtime pay, personal days pay, jury duty pay, as well as pay policies for bereavement, safety related, Leadman, stipend, and mentors.

If there are discrepancies between our policies and/or documents and applicable law, the law applies.

Employee Engagement Surveys Every fall, we conduct the annual employee engagement survey to encourage employees to provide anonymous feedback about their experience at Ecobat. Additionally, exiting employees are invited to share employment feedback during their exit interview with an onsite local HR representative.

Introduction

Strategy

Governance

People & Community

Diversity, Equity & Inclusion Ecobat is continuously focused on building a more diverse, equitable, and inclusive environment for our employees. Here, we’ve outlined our efforts to ensure we create a space where all employees feel supported.

Preventing Discrimination and Workplace Harassment Our SpeakUp hotline allows employees to anonymously report workplace concerns, including allegations of discrimination and workplace harassment. Additionally, all employees are required to participate in Code of Conduct training, which outlines our anti-harassment and anti-discrimination workplace environment.

Initiatives and Advancements Ecobat’s women’s initiative, Leading the Charge, launched in 2022. It was created to build awareness and development opportunities for women. DEI indicators on the annual engagement survey are one of the top three rated areas across the organization.

DIVERSITY & INCLUSION KPIS

Wage Benchmarking We adopted fair wage practices by appropriately and effectively benchmarking pay scales from industry-leading compensation survey organizations.

DEI Awareness Training Managers and supervisors are required to complete mandatory e-learning for DEI via the PowerUp tool.

Discrimination and/or Harassment Remediation Employees who believe they have been victims of discrimination or harassment can report substantiated concerns via the SpeakUp hotline, either by phone or email. HR has processes in place to begin investigating the claim and address any substantiated concerns of discrimination or harassment.

2022

2023

currently not tracked

currently not tracked

Percentage of women in top executive positions

25%

20%

Female in board of Directors

0

0

Percentage of women in managerial positions

25%

13%

Total people from minority group

771

724

Total people from minority groups in executive positions

0

4

# Discrimination Incidents

0

0

Percentage of disabled workers out of total workforce

30

2023 S U STA I N A B I LI T Y R E P OR T

Environment

Performance Metrics

Annex

Introduction

Strategy

Governance

People & Community

Performance Metrics

Environment

Social Dialogue

Career Management & Training

Ecobat has appropriate agreements in place in the U.S. and European locations to ensure a positive social dialogue.

We strive to ensure our employees are positioned well for future career opportunities while being properly trained for their current position. Our efforts include:

Collective Agreements Ecobat has labor union contracts in the U.S. (California, New York, Indiana) and European Work Councils contracts (Austria, France, Germany, Italy, United Kingdom).

Agreements cover various time periods and employee groups as appropriate.

Employee Representatives All locations have employee representatives. In the U.S., they are called Union Stewards, and they have special rights and protections. In Europe, Ecobat employees sit on the Works Councils and have special rights and privileges.

The number of Union Stewards and Works Councils members varies by the facility’s location and size.

SOCIAL DIALOGUE KPIS

2022

% of the total workforce across all locations who are covered by formal collective agreements concerning working conditions

%

Minimum number of weeks notice typically provided to employees and their representatives prior to the implementation of significant operational changes that could substantially affect them

#

For organizations with collective bargaining agreements, report whether the notice period and provisions for consultation and negotiation are specified in collective agreements % of the total workforce across all locations who are covered by formallyelected employee representatives 31

2023 S U STA I N A B I LI T Y R E P OR T

%

64%

4 weeks

2023

64%

4 weeks

Yes

Yes

64%

64%

Annex

•

Promoting career mobility. This includes identifying high potential talent and necessary skill development, along with socializing succession planning with leadership.

•

Transparent recruitment process. Ecobat aims to provide all local recruiters with tools and resources (i.e. LinkedIn, Career Site, Indeed) to consistently attract talent.

•

Individual performance assessments. Performance check-ins are a progressive, dynamic way to provide employees with performance feedback and help them progress toward goals.

•

•

Individual career plans and development.

Ecobat’s Talent Management HR function allows employees to create and discuss comprehensive career plan development.

Skills development training. Ecobat’s Emerging Supervisor (ESP) and Accelerating My Potential (AMP) Programs provide new and current leaders with comprehensive management and leadership development. Additionally, we adopted a training methodology for frontline roles (Tell, Show, Do, Review) with the launch of the Refinery Training Program.

•

Resource planning. Leadership must approve all additions to headcount, frequently requiring resource planning to ensure functions are not over-sourced.

SOCIAL DIALOGUE KPIS

2022

2023

% of the total workforce across all locations who received regular performance and career development reviews

%

100%

100%

% of the total workforce across all locations who received career- or skills-related training

%

100%

100%

Average hours of HSE-related training provided per month

#

16,701

26,452

% of the total workforce across all locations who received training on preventing discrimination and human rights violations

%

100%

100%

Hours of non HSE-specific training (Cybersecurity, professional development, diversity and compliance)*

#

4

7,817

*Investments in a learning management system provided better visibility and reporting on completed training for the organization in 2023.

Introduction

Strategy

Child Labor, Forced Labor, and Human Trafficking Measures

Governance

People & Community

•

Remediation procedure in place for identified victims

Ecobat has a robust screening tool to promote sustainable procurement. Responsible Materiality sourcing involves integrating social, ethical and environmental performance factors into the process of selecting suppliers. From a Risk Mitigation control perspective, we use a supply chain monitoring tool to promote responsible material sourcing for our operations. During the new onboarding process, the aim is for all third party partners providing materials and services be reviewed before they can do business with us. Suppliers are required to acknowledge Ecobat’s Third-Party Supplier Code of Conduct, provide annual attestations, and are subject to regular monitoring and periodic auditing based on their risk profile. We address responsible material sourcing in the following ways:

•

Stakeholders consultation

•

Supplier CSR Code of Conduct

•

Monitoring of internal controls to ensure no child labor

•

Supplier assessment on environmental and social practices

•

Impact assessment

•

Integration of social and environmental clauses within contracts

•

Worker voice surveys or other supplier monitoring practices

Grievance Mechanism on Child Labor, Forced Labor and Human Trafficking Employees can air grievances and concerns via the anonymous SpeakUp hotline. This mechanism provides action to protect young workers. HR representatives work directly with employees to listen and act on any concerns.

The SpeakUp investigatory process addresses the following areas:

Awareness Training Training is provided to identified populations of corporate, office, management, and supervisory roles to identify human trafficking and modern slavery concerns.

Age Verification of Candidates While job candidates do not have to provide proof of age, all employees must provide ID documents and proof of residency, which includes their birth date, to prove they can work legally in each country.

% of all operational sites that have been subject to human rights reviews or human rights impact assessments*

2022

%

100%

RESPONSIBLE SOURCING KPIS

100%

2023

%

100%

100%

% of suppliers in line with our Code of Conduct & Supplier Code of Conduct*

%

100%

100%

% of suppliers with recognized high-quality products/services

%

not currently tracked

not currently tracked

% of suppliers with an environmentally efficient policy and plan

%

100%

100%

% locally based

%

not currently tracked

not currently tracked

% of suppliers in compliance to Health and Safety measures

%

100%

100%

% of suppliers which present high level of reliability

%

not currently tracked

not currently tracked

*In alignment with staged entity integration.

2023 S U STA I N A B I LI T Y R E P OR T

2022

% of all suppliers which has gone through a CSR assessment/audit

2023

* Identified populations providing operational site oversight; including, corporate, office, management, and supervisory roles.

32

Annex

Responsible Material Sourcing

We take seriously our commitment to ensuring that our operations and our business partners refrain from using child labor, forced labor, or human trafficking. We’ve put the following policies in place to support our efforts:

HUMAN RIGHTS KPIS

Performance Metrics

Environment

Introduction

Strategy

Governance

People & Community

Community While Ecobat operates globally, we also act locally by building relationships and investing in our communities.

We focus on employee engagement, job creation, economic growth, and outreach to ensure we positively impact the communities we operate in.

Our external stakeholder engagement principles guide our interactions with local communities. We commit to using Community Relations resources to monitor and respond to stakeholder requests to ensure we capture valuable feedback. In addition, we have facility-specific, region-specific, and scope-specific engagement strategies based on the five qualitative pillars of stakeholder analysis:

1

S TA K E H O L D E R A G E N C Y

2

SYSTEM ROLES

3

POWER AND INFLUENCE

4

ALIGNMENT TO THE PROBLEM

5

T R A N S F O R M AT I O N A L P O T E N T I A L

This approach keeps Ecobat accountable to our external stakeholders and communities.

33

2023 S U STA I N A B I LI T Y R E P OR T

Positive community relationships are a result of our actions, including our charitable contributions. Locally, we contribute to Boys and Girls Clubs, sports, academics, Science, Technology, Engineering, Arts, and Mathematics (STEAM) sponsorships, community health fairs, blood drives, toy and food drives, and other local events. Our community involvement, with help from the employees who participate in them, ensures that these organizations have a positive local impact.

Finally, we recognize that our operations affect our communities. It’s essential to remain committed to our sustainability principles with this in mind. We actively evaluate, measure, and manage our community impact to ensure the safety of the people and environment.

We strive to prioritize our ongoing efforts to ensure the health and safety of the environment and our neighbors, in addition to providing charitable contributions. We aim to engage with our local communities in these areas: •

Safety procedure engagement

•

Community health initiatives

•

Educational programs about Ecobat’s role in the industry

•

Neighborhood improvement projects, including partnering with local organizations

Environment

Performance Metrics

Annex

Introduction

Environment

34

2023 S U STA I N A B I LI T Y R E P OR T

Strategy

Governance

People & Community

Environment

Performance Metrics

Annex

Introduction

Strategy

Governance

People & Community

Environment

Performance Metrics

Annex

Environment Environmental stewardship aligns with our core value of prioritizing the well-being of our people and planet.

To stay true to our values, we use best practices and internationally recognized industry standards to protect the environment, improve our operational efficiency and resource management to sustain economic growth, and reduce negative environmental impact. We continue to work towards preserving our natural resources through recycling, not mining, with the goal of capturing 99% of the inherent properties of lead-acid batteries through our operations.

We set our standards appropriately high, focusing on increasing our energy efficiency, in turn reducing air emissions, energy consumption and carbon dioxide generation, lowering water consumption, and reducing waste generation per ton produced. Eighty four percent (84%) of our facilities are certified under ISO 14001.

Thirty five percent (35%) are certified for energy management under ISO 50001. Aspiring for operational efficiency, employing best practices, and monitoring our progress make up the foundation of our environmental stewardship.

RISK ASSESSMENT & TRAINING

Ecobat’s Relevant Documents Supporting This Section: •

• • •

Health, Safety, Environmental & Sustainability Policy Incident Data Management & Investigation Program Sustainable Procurement Policy Supplier Third-Party Code of Conduct Emergency Response & Crisis Communication

35

2023 S U STA I N A B I LI T Y R E P OR T

•

2023

% of the total workforce across all locations who received training on environmental issues

%

90%

% of all operational sites for which an environmental internal audit & control has been conducted

%

91%

% of all operational sites for which an environmental risk assessment has been conducted

%

92%

Introduction

Strategy

Governance

People & Community

Environment

Performance Metrics

Annex

Energy & Greenhouse Gas Emissions

Air Pollution Prevention Measures

We strive to diligently manage our energy consumption and greenhouse gas emissions in the following ways:

We look to mitigate air and noise pollution through strategic measures and proactive initiatives to safeguard public health. This includes:

•

Improvement of energy efficiency through technology or equipment upgrades

•

Work processes and technology implemented to mitigate emissions of VOC, SO2, NOx or heavy metals

•

Use of waste heat recovery system or combined heat and power units

•

Work processes and technology implemented to mitigate emissions of dust and particular matter

•

Actions to prevent emission of atmospheric pollutants and other environmental nuisances (noise, odor, vibration, road, light)

•

Work processes implemented to mitigate odor

•

Work processes implemented to mitigate noise

•

Periodical analysis on the volumes of major air pollutants or ambient air quality monitoring

•

Purchase or generation of renewable energy

•

Training of employees on energy conservation/climate

•

Fuel switch to achieve higher energy efficiency and lower carbon emission intensity

•

Energy or carbon audit

•

Managing the lifecycle of our GHG performance, includes understanding our Scope 3 emissions. In 2024, we look to validate our Scope 3 methodology approach for future reporting.

^ This metric was assured by ERM CVS in 2024. Reference Independent Limited Assurance Statement to Ecobat, LLC for details. * South Africa, Stolberg, and Peru entities not including in reporting.

Stolberg asset divestiture in 2022 with South Africa asset divestiture finalized in 2023. ** Updates in methodology have improved accuracy and is reflected to align figures for consistency across reporting years. *** Total Energy Consumption figures have been updated from 2021 reporting and now include all stationary combustion, mobile combustion, and purchased energy.

Spotlight: Indianapolis Energy Assessment Decreasing energy consumption supports the environment and the communities where we operate, contributing to Ecobat’s operational efficiency. Our Indianapolis, Indiana, facility set out to reduce energy consumption, leveraging engineering consulting expertise to review primary sources of electrical demand within the plant. By analyzing use cases and power bills and modeling energy savings scenarios, the plant discovered they could modify their equipment start-up procedures and install variable speed drives. The Indianapolis plant now expects to reduce its energy consumption between 5-7% by modifying procedures and equipment.

36

2023 S U STA I N A B I LI T Y R E P OR T

E N E RGY & G H G E M I S S I O N S 2 0 2 1 -2 0 23 *

2021

2022

2023

6.19

5.94

5.38

Total Energy Consumption (kWh)

1,277,467,555**

1,281,723,759

1,210,953,475

Energy Consumption - Purchased Electricity (kwh)

241,945,100***

232,533,405

216,743,387

Scope 1 Direct Emissions (MT CO2e)

396,621

402,114^

371,273^

Scope 2 Indirect Emissions (MT CO2e) [Location-based]

70,416

68,411^

63,106^

Scope 2 Indirect Emissions (MT CO2e) [Market-based]

83,902

79,267^

73,782^

Total

467,037

470,525

434,379

Energy efficiency (GJ / MT of output)

Introduction

Strategy

Governance

People & Community

Hazardous Materials

Water Management

We remain committed to protecting our employees and the environment from the impact of hazardous materials.

Steps we take to work toward reducing this impact include:

We strive to conserve and protect our water resources using these protocols: •

Technologies to recycle or reuse water

•

Wastewater quality assessment

•

Water accounting or audit

•

Specialized treatment and safe disposal of hazardous substances

•

Training employees to safely handle and manage hazardous substances

•

Adoption of a cooling system with reduced or recycled water consumption

•

Prescribed actions for labeling, storing, handling and transporting hazardous substances

•

Control of wastewater generated in finishing operations such as quenching or demurring

•

Process optimizations that reduce material consumption

•

Use of recovered input materials

•

Environmental emergency measures in place

Spotlight: Managing Hazardous Materials Through Lithium Recycling Although lead remains integral to our future, we have the opportunity to use our vast recycling expertise and deep experience handling lead batteries to provide solutions for emerging advanced battery chemistry recycling.

Our operational expertise is a key differentiator. Capabilities include sorting, shredding, and separating battery materials to produce black mass. Our lithium recycling footprint includes: Hettstedt, Germany, Casa Grande, AZ, United States, and a third in Darlaston, United Kingdom with commissioning in 2024.

We’re confident of our expansion into the lithium battery recycling market and of our ability to leverage our proven expertise in this marketplace in the management of hazardous materials.

37

2023 S U STA I N A B I LI T Y R E P OR T

Environment

Performance Metrics

Annex

WAT E R K P I S

Water consumption

2023

m3

11,402,173

Introduction

Strategy

Governance

People & Community

Environment

Performance Metrics

Annex

Waste Management We have procedures in place to reduce and limit where possible the waste we produce, including: •

Internally sorting and disposing of waste according to waste streams

•

Training to raise employee awareness of waste reduction and sorting

•

Reducing internal waste through material reuse, recovery or repurposing

•

Mapping of waste streams

Spotlight: Waste Management Increases Production Bazoches-les-Gallerandes, France Plant Ecobat’s Bazoches-les-Gallerandes, France plant recently achieved remarkable improvements by focusing on removing the waste, gypsum, from their smelter feed. Gypsum is a byproduct of electrolyte neutralization with lime, but by isolating the gypsum from the lead paste, the plant can increase the capacity of the smelters by 5%. This results in an additional 3,000 tons of lead production and an approximate 25% reduction in energy consumption and CO2 hazardous materials at this site.

38

2023 S U STA I N A B I LI T Y R E P OR T

WA S T E K P I S

2023

Waste Generated

tons

418,950

Hazardous Waste

tons

320,225

Non-Hazardous waste

tons

103,856

Total waste recovered (recycled-reused)

tons

318,113

Introduction

Performance Metrics

39

2023 S U STA I N A B I LI T Y R E P OR T

Strategy

Governance

People & Community

Environment

Performance Metrics

Annex

Introduction

Strategy

Governance

People & Community

Environment

Performance Metrics

Annex

We continue to review the following KPIs with the aim of tracking performance year-on-year. For some of the following metrics, we are in the process of establishing targets which the business should strive to meet. Such targets are subject to change, and no assurance can be given that such targets will be met.

Governance GOVERNANCE

2022

2023

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

2023

% of the total workforce across all locations who received training (e.g. e-learning) on business ethics issues

%

70%

100%

NIST Cyber Security Framework

%

91%

% of all operational sites for which an internal audit & control concerning business ethics issues has been conducted

%

100%

100%

BitSight Security Rating Score

%

95%

% of all operational sites for which a risk assessment concerning business ethics issues has been conducted

%

100%

100%

Microsoft365 Cloud Compliance

%

94%

# confirmed incidents of corruption and actions taken

#

0

0

Security Patching Cadence Effectiveness

%

100%

Total number and nature of confirmed incidents of corruption

#

0

0

Security Awareness Training Effectiveness

%

90%

Total number of confirmed incidents in which employees were dismissed or disciplined for corruption

#

0

0

Incident Detection & Response Effectiveness

%

100%

Total number of confirmed incidents when contracts with business partners were terminated or not renewed due to violations related to corruption

#

0

0

Public legal cases regarding corruption brought against the organization or its employees during the reporting period and the outcomes of such cases

#

0

0

Legal actions for anti-competitive behavior, antitrust, monopoly practices

#

0

0

Number of legal actions pending or completed during the reporting period regarding anti-competitive behavior and violations of anti-trust and monopoly legislation in which the organization has been identified as a participant

#

0

1

% of all operational sites with an information security management certification (ISO 27001)

%

0

0

# of SpeakUp hotline reports

#

78

29

40

2023 S U STA I N A B I LI T Y R E P OR T

Introduction

Strategy

Governance

People & Community

Environment

Performance Metrics

Annex

Health & Safety H E A LT H & S A F E T Y K P I

2022

2023

% of all operational sites for which an employee health & safety risk assessment has been conducted.

100%

100%

Lost time injury

46 LT, 39 Days away

44 LT, 42 Days away

Lost time severity

1.9 (LTIR)

1.8 (LTIR)

Average 12-month Blood Lead level

41

2023 S U STA I N A B I LI T Y R E P OR T

6.72 μg/dl

COMMITTEE AND TRAINING KPIS

2023

Percentage of the total workforce across all locations represented in formal joint management-worker health & safety committees

75%

Average hours of HSE-related training provided per month

16,071

Introduction

Strategy

Governance

People & Community

Environment

Performance Metrics

Annex

People & Community DIVERSITY & INCLUSION KPIS

2022

2023

SOCIAL DIALOGUE KPIS

currently not tracked

currently not tracked

Percentage of women in top executive positions

25%

20%

% of the total workforce across all locations who are covered by formal collective agreements concerning working conditions

Female in board of Directors

0

0

Percentage of women in managerial positions

25%

13%

Minimum number of weeks notice typically provided to employees and their representatives prior to the implementation of significant operational changes that could substantially affect them

Total people from minority group

771

724

Total people from minority groups in executive positions

0

4

For organizations with collective bargaining agreements, report whether the notice period and provisions for consultation and negotiation are specified in collective agreements

# Discrimination Incidents

0

0

% of the total workforce across all locations who are covered by formally- elected employee representatives

2022

2023

HUMAN RIGHTS KPIS

100%

100%

Percentage of disabled workers out of total workforce

SOCIAL DIALOGUE KPIS

% of the total workforce across all locations who received regular performance and career development reviews

%

% of the total workforce across all locations who received career- or skills-related training

%

100%

100%

Average hours of HSE-related training provided per month

#

16,701

26,452

% of the total workforce across all locations who received training on preventing discrimination and human rights violations

%

Hours of non HSE-specific training (Cybersecurity, professional development, diversity and compliance)*

#

100%

4

100%

7,817

* Investments in a learning management system provided better visibility and reporting on completed training for the organization in 2023.

42

2023 S U STA I N A B I LI T Y R E P OR T

% of all operational sites that have been subject to human rights reviews or human rights impact assessments*

2022

2023

%

64%

64%

#

4 weeks

4 weeks

Yes

Yes

64%

64%

2022

2023

100%

100%

%

%

*Identified populations providing operational site oversight; including, corporate, office, management, and supervisory roles.

RESPONSIBLE SOURCING KPIS

2022

2023

% of all suppliers which has gone through a CSR assessment/audit

%

100%

100%

% of suppliers in line with our Code of Conduct & Supplier Code of Conduct

%

100%

100%

% of suppliers with recognized High-quality products/services

%

not currently tracked

not currently tracked

% of suppliers with an Environmentally efficient policy and plan

%

100%

100%

% Locally based

%

not currently tracked

not currently tracked

% of suppliers in Compliance with Health and Safety measures

%

100%

100%

% of suppliers which present high level of Reliability

%

not currently tracked

not currently tracked

Introduction

Strategy

Governance

People & Community

Environment

Performance Metrics

Annex

Environment E N E RGY & G H G E M I S S I O N S 2 0 2 1 -2 0 23

2021

2022

2023

Energy efficiency (GJ / MT of output)

6.19

5.94

5.38

Total Energy Consumption (kWh)

1,277,467,555*

1,281,723,759

1,210,953,475

Energy Consumption - Purchased Electricity (kwh)

241,945,100**

232,533,405

216,743,387

RISK ASSESSMENT & TRAINING

Scope 1 Direct Emissions (MT CO2e)

396,621

402,114^

371,273^

% of the total workforce across all locations who received training on environmental issues

%

90%

Scope 2 Indirect Emissions (MT CO2e) [Location-based]

70,416

68,411^

63,106^

% of all operational sites for which an environmental internal audit & control has been conducted

%

91%

Scope 2 Indirect Emissions (MT CO2e) [Market-based]

83,902

79,267^

73,782^

% of all operational sites for which an environmental risk assessment has been conducted

%

92%

Total

467,037

470,525

434,379

WAS T E K P I S

2023

Waste Generated

tons

418,950

Hazardous Waste

tons

320,225

Non-Hazardous waste

tons

103,856

Total waste recovered (recycled-reused)

tons

318,113

43

2023 S U STA I N A B I LI T Y R E P OR T

WAT E R K P I S

Water consumption

2023

m3

11,402,173

2023

Introduction

Annex

44

2023 S U STA I N A B I LI T Y R E P OR T

Strategy

Governance

People & Community

Environment

Performance Metrics

Annex

Introduction

Strategy

People & Community

Governance

G R I S TA N D A R D S 2 0 2 1

Environment

Performance Metrics

Annex

G R I S TA N D A R D S 2 0 2 1

102-1

Name of the organization

1

305-4

GHG emissions intensity

14

102-2

About the company

8

103-1

Explanation of the material topic and its boundary

13-14

102-3

Location of headquarters

8

103-2

The management approach and its components

13-23

102-4

Location of operations

8

103-3

Evaluation of the management approach

13-23

102-5

Ownership and legal form

8-18

403-1

Occupational health and safety management system

26-29

102-6

Markets served

8

403-2

Hazard identification, risk assessment and incident investigation

27

102-7

Scale of the organization

8

403-3

Occupation health services

28-29

102-8

Information on employees and other workers

21, 25-32

403-5

Worker training on occupational health and safety

27-28, 31

102-9

Supply chain

21, 32

403-9

Work-related injuries

27-28

102-10

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

3

103-1

Explanation of the material topic and its boundary

13-14

103-2

The management approach and its components

11-16

102-11

Precautionary principle or approach

11-14

103-3

Evaluation of the management approach

11-16

102-12

External initiatives

14, 33

404-1

Average hours of training per year per employee

23-24, 31

102-13

Membership of associations

4, 15-16

103-1

Explanation of the material topic and its boundary

13-14

102-15

Description of key impacts, risks, and opportunities

6-22

103-2

The management approach and its components

13-23

102-16

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

11-21

103-3

Evaluation of the management approach

13-23

102-17

Mechanisms for advice and concerns about ethics

20-21

205-1

Operations assessed for risks related to corruption

18-21

102-18

Governance structure

18-19

205-3

Confirmed incidents of corruption and actions taken

18-21

102-26

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

18

103-1

Explanation of the material topic and its boundary

13-14

102-30

Effectiveness of risk management processes

19

103-2

The management approach and its components

13-23

102-31

Review of economic, environmental, and social topics

all

103-3

Evaluation of the management approach

13-23

102-40

List of stakeholder groups

14, 33

416-2

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

27-30

102-42

Identifying and selecting stakeholder

13-14, 33

403-5

Worker training on occupational health and safety

26-30

102-43

Approach to stakeholder engagement

13-14, 33

403-6

Promotion of worker health

26-29

102-44

Key topics and concerns raised

13

102-53

Contact point for questions regarding the report

5

403-7

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

27-31

103-1

Explanation of the material topic and its boundary

13-14

403-8

Workers covered by an occupational health and safety management system

27-31

103-2

The management approach and its components

11-16

403-9

Work-related injuries

27-28

103-3

Evaluation of the management approach

11-16

403-10

Work-related ill health

27-28

302-1

Energy consumption within the organization

36

404-2

Programs for upgrading employee skills and transition assistance programs

25-26, 31

302-3

Energy intensity

36

305-1

Direct (Scope 1) GHG emissions

36

404-3

Percentage of employees receiving regular performance and career development reviews

26, 31

305-2

Energy indirect (Scope 2) GHG emissions

36

406-1

Incidents of discrimination and corrective actions taken

30

305-3

Other indirect (Scope 3) GHG emissions

14

45

2023 S U STA I N A B I LI T Y R E P OR T

Introduction

Strategy

Governance

People & Community

Environment

Performance Metrics

Annex

S A S B R E N E W A B L E R E S O U R C E S & A LT E R N AT I V E E N E R G Y S E C T O R F U E L C E L L S & I N D U S T R I A L B AT T E R I E S S U S TA I N A B I L I T Y A C C O U N T I N G S TA N D A R D

46

RR-FC-130a.1

(1) Total Energy Consumed, (2) Percentage grid electricity, (3) P ercentage renewable

35

RR-FC-320a.1

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

27

RR-FC-320a.2

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

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

36-37

RR-FC-440a.1

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

36-37

2023 S U STA I N A B I LI T Y R E P OR T

26-27

Introduction

Strategy

Governance

People & Community

Environment

Performance Metrics

Annex

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: Governance, People & Community, and Environment #3 G ood Health and Well-Being #4 Q uality Education #5 G ender Equality

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

#8 D ecent Work and Economic Growth #9 I ndustry, Innovation and Infrastructure #10 Reduced Inequalities

#11 Sustainable Cities & Communities

#12 Responsible Consumption and Production

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 generation 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 in accordance with industry standards. 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.

#13 Climate Action U N I T E D N AT I O N S G L O B A L C O M PA 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.

47

2023 S U STA I N A B I LI T Y R E P OR T

Introduction

Strategy

Governance

People & Community

Environment

Performance Metrics

Annex

Independent Limited Assurance Report to Ecobat Resources ERM Certification & Verification Services Incorporated (“ERM CVS”) was engaged by Ecobat, LLC (“Ecobat”) to provide limited assurance in relation to the selected information set out below and presented in Ecobat 2023 Sustainability Report (the “Report”).

Engagement summary Whether the 2022 and 2023 selected KPIs are fairly presented in the Report, in all material respects, in accordance with the reporting criteria.

Scope of our assurance engagement

GHG Emissions: 

Total Scope 1 GHG emissions [metric tonnes CO2e]



Total Scope 2 GHG emissions (location-based) [metric tonnes CO2e]



Total Scope 2 GHG emissions (market-based) [metric tonnes 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

1st January 2022 to 31st December 2022 1st January 2023 to 31st December 2023

Reporting criteria

 

Assurance standard and level of assurance

48

Ecobat’s reporting criteria as explained in footnotes in the Report WMSCD/WRI GHG Protocol (2004, as updated January 2015) as relevant for the Scope 1 and 2

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 Assurance 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.

2023 S U STA I N A B I LI T Y R E P OR T

Introduction

Respective responsibilities

Strategy

Governance

People & Community

Environment

Performance Metrics

Annex

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 a conclusion to Ecobat on the agreed scope based on our engagement terms with Ecobat, the assurance activities performed and exercising our professional judgement.

Our conclusion Based on our activities, as described below, nothing has come to our attention to indicate that the 2022 and 2023 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 Report a multi-disciplinary team of sustainability and assurance specialists performed a range of procedures that included, but was not restricted to, the following: 

Evaluating the appropriateness of the reporting criteria for the selected disclosures

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

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Reviewing of a sample of qualitative and quantitative evidence supporting the reported information at a corporate level;

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Performing an analytical review of the year-end data submitted by all locations included in the consolidated 2022 and 2023 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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Conducting one in-person and one virtual site visit to the Ecobat facilities in Middletown, New York, USA and Arnoldstein, Austria to review source data for 2022 and local reporting systems and controls;

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Conducting two desk-based reviews for the Ecobat facilities in Middletown, New York and Arnoldstein, Austria to review source data for 2023 and local reporting systems and controls ,

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Evaluating the 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).

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Strategy

Governance

People & Community

Environment

Performance Metrics

Annex

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 the IESBA Code relating to assurance engagements.

ERM CVS 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.

Heather I. Moore Partner, Corporate Assurance Manhattan, New York June, 7 2024 On behalf of: ERM Certification & Verification Services Incorporated www.ermcvs.com | post@ermcvs.com

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Introduction

Strategy

Governance

People & Community

Environment

Performance Metrics

Annex

General Disclaimer References to environmental, social and governance (ESG) matters, including with respect to sustainability, refer to the current initiatives and commitments of Ecobat.

Discussion of such factors have been included for purposes of illustrating that Ecobat also expects to take into account certain ESG factors when making business decisions. While Ecobat expects that in many cases the ESG strategy may align with the business and financial objectives of the company, Ecobat generally does not intend for ESG considerations to be determinative when making business decisions. There can be no guarantee that we will be able to successfully consider ESG factors while achieving our business strategy. The information provided herein is intended solely to provide an indication of the ESG or impact-related initiatives and standards that Ecobat strives to apply when seeking to evaluate and/ or improve the characteristics of its business as part of a larger goal of maximizing financial objectives (howsoever they may be measured). There are also significant differences in interpretation of what positive ESG outcomes mean by region, industry and topic, as well as the interpretation of their scope, severity, remediability and materiality. Interpretations and decisions made by Ecobat are expected to differ from others’ views and could evolve over time. ESG practices are evolving rapidly and market pressures, including the potential adverse reactions by investors and other participants to the application of ESG factors to investment processes, could result in tensions, conflicts of interest or other potential issues as companies navigate how to balance competing interests with respect to ESG considerations. There is also a growing regulatory interest across jurisdictions in improving transparency regarding the definition, measurement, management and disclosure of ESG factors. The ESG practices maintained by Ecobat could become subject to additional regulation in the future, and we cannot guarantee that our current approaches will meet future regulatory requirements or predict the manner in which any such future requirements (including any enforcement with respect thereto) could affect our business, including with respect to future administrative burdens and costs.

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It should not be assumed that any ESG or impactrelated initiatives, standards or metrics are applicable to us. Methodologies for measuring ESG metrics may also differ across industries and asset classes. While we seek to integrate certain ESG factors into our business and operational processes in accordance with our ESG strategy and subject to our fiduciary duty and any applicable legal, regulatory or contractual requirements, there is no guarantee that our ESG strategy will be successful or that it will create a positive ESG impact. ESG risk factors are only some of the many considerations that we take into account when making business decisions, and other considerations can be expected in certain circumstances to outweigh those considerations. In addition, applying ESG factors to business decisions is qualitative and subjective by nature, and there is no guarantee that the criteria utilized by Ecobat, or any judgment exercised by Ecobat, will reflect the beliefs or values of any particular person or industry participant. In connection with such determination, we may rely to a large extent on the due diligence, reporting and other materials provided by consultants, accounting firms and other third parties. There can be no assurance that Ecobat or these third parties will accurately evaluate the potential or actual ESG or impact-related outcomes of business decisions. Further, a focus on one or more ESG outcomes may come at the expense of others.

Ecobat is permitted to determine in its discretion that it is not feasible or practical to implement or complete certain of its ESG initiatives, policies, and procedures based on cost, timing, or other considerations. Statements about ESG or impact-related initiatives or practices related to Ecobat’s business do not apply in every instance and depend on factors including, but not limited to, the relevance or implementation status of an ESG or impact-related initiative to or within its business; and other factors as determined by management teams, subsidiaries, and/or businesses on a case-by-case basis.

Certain information contained herein relating to any ESG, impact, or other similar industry frameworks is subject

to change, and no assurance can be given that Ecobat will remain a supporter, or member of such initiatives or other similar industry frameworks. Similarly, information contained herein relating to any goals, targets, intentions, or expectations and related timelines, is subject to Ecobat’s fiduciary duty and subject to change, and no assurance can be given that such goals targets, intentions, or expectations will be met. Descriptions of any ESG or impact-related achievements or improved practices or outcomes are not necessarily intended to indicate that Ecobat has substantially contributed to such achievements, practices, or outcomes.

There is no guarantee that any ESG measures, targets, programs, commitments, incentives, initiatives, or benefits will be implemented or applicable to the investments managed by Ecobat and any implementation of such ESG or impact-related measures, targets, programs, commitments, incentives, initiatives, or benefits may be overridden or ignored at the sole discretion of Ecobat at any time.

In addition, anti-ESG concerns have been raised across the U.S., with several states and Congress having proposed or enacted “anti-ESG” policies, legislation or initiatives or issued related legal opinions. Additionally, companies have been subject to recent scrutiny related to ESG-focused industry working groups, initiatives, and associations, including organizations advancing action to address climate change or climate-related risk. Such anti-ESG policies, legislation, initiatives and scrutiny could expose Ecobat to the risk of litigation, antitrust investigations or challenges and enforcement by state or federal authorities, result in injunctions, penalties and reputational harm and require certain investors to divest or discourage certain investors from investing in Ecobat.

Ecobat could become subject to additional regulation, regulatory scrutiny, penalties and enforcement in the future, and Ecobat cannot guarantee that its current approach or its investments will meet future regulatory requirements, reporting frameworks or best practices, increasing the risk of related enforcement.

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