Aurubis AG

Association work and political lobbying **GRI 2-28, 415-1** The appropriate and transparent representation of Aurubis' interests with respect to political and social institutions is an important part of responsible corporate governance. We consider ourselves a reliable, factual, transparent discussion partner for governments, political parties, elected representatives, and non-governmental organizations. Corporate External Affairs serves as the central interface for political and regulatory issues in the Aurubis Group. This division coordinates political measures at the corporate level and represents the company to policymakers. The head of Corporate External Affairs reports directly to the CEO. Experts in our specialized divisions and production sites support the work in subject-specific areas. Aurubis' political lobbying is based on the Corporate External Affairs Policy, which defines the responsibilities, duties, and processes in this area. This corporate policy is supplemented by the Corporate Policy on the Management of Associations. In addition to independent lobbying, Aurubis is an active member of national and international economic, industry, and specialist associations. Our goal is to constructively and critically oversee political initiatives together with the other association members and to actively represent our positions in a back-and-forth dialogue with stakeholders from the worlds of business, science, and civil society. As members of business association committees, we also participate in political discussions on the further development of tax laws _Taxes, page 32. We take part in trade associations with_ the aim of ensuring the fair, transparent and administratively simple further development of tax law. Our employees in the Group representative offices in Brussels (Belgium) and Berlin (Germany) serve as contacts for members of the European Commission, the European Parliament, the German Bundestag, the German federal ministries, and German federal state representations. Moreover, Aurubis maintains a continuous dialogue with local officeholders and interest groups in the areas around our sites. We feel it is crucial to convey the political conditions Aurubis needs to grow sustainably and responsibly. All our political communication is transparent and open. One result of our transparent approach to political lobbying is our contributions to public consultations, which are accessible on the European Commission's website. Furthermore, our positions on individual topics are outlined in the factsheets available at _[www.aurubis.com/en/ and in the position papers](https://www.aurubis.com/en/)_ of associations, which are available online. Aurubis is included in the European Union's Transparency Register, which publishes expenditures for lobbying at the European level. Since the passing of the German Lobby Register Act, which we advocated for together with the German Chemical Industry Association (VCI), Aurubis has also been listed on the German Transparency Register at the German Bundestag _[www.lobbyregister.bundestag.de. It lists](http://www.lobbyregister.bundestag.de)_ the amounts reported by Aurubis: € 960,001 to € 970,000 for the representation of interests in Germany and € 500,000 to € 599,999 for the representation of interests in Europe. Aurubis does not donate to any political parties or candidates.

### Social matters

##### Governance and ethics — Work in associations and political lobbying

We view the appropriate and transparent representation of Aurubis' interests with respect to political and social institutions as an important part of responsible corporate governance. We consider ourselves a reliable, factual, transparent discussion partner for governments, political parties, elected representatives, and non-governmental organizations.

Corporate External Affairs, part of the Corporate Sustainability and External Affairs division, serves as the central interface for political and regulatory issues in the Aurubis Group. The department head reports directly to the Executive Board chairman. Corporate External Affairs coordinates political measures at a corporate level and represents the company to policymakers. Experts in our specialized divisions and production sites support the work in subject-specific areas, for example in preparing public opinions, briefings, commentary on position papers, and political meetings. Furthermore, Corporate External Affairs informs other departments about political developments.

Aurubis' political lobbying is based on the Corporate External Affairs Policy, which defines the responsibilities, duties and processes. The corporate policy is supplemented by the Corporate Policy on Management of Associations.

In addition to independent lobbying, Aurubis is an active member of national and international economic, industry and specialist associations. Our goal is to constructively and critically oversee political initiatives together with the other association members and to actively represent our positions in a back-and-forth dialogue with stakeholders from the worlds of business, science and civil society.

Our employees in the Group representative offices in Brussels (Belgium) and Berlin (Germany) serve as contacts for members of the European Commission, the European Parliament, the German Bundestag, the German federal ministries, German federal state representations, and German federal state parliaments and ministries. Moreover, Aurubis maintains a continuous dialogue with local officeholders and interest groups in the areas around our sites via association committees, in public discussion rounds, and in personal conversations, for example. We feel it is crucial to convey the political conditions Aurubis needs to work sustainably and responsibly. All our political communication is transparent and open.

In the year under review, Corporate External Affairs coordinated with the departments on the aim of working towards a political framework that would ensure Aurubis' secure energy supply at internationally competitive prices. Together with associations such as the Association of German Industries (BDI), the German Chemical Industry Association (VCI), and the Federation of German Waste, Water, and Raw Materials Management Industry (BDE), we are working with other forward-looking companies on developing constructive contributions to the discussion and practical recommendations for action for an ambitious and sustainable energy and climate policy.

Our contributions to public consultations, which are accessible on the European Commission's website, are one result of our transparent approach to political lobbying commission.europa.eu/about/service-standards-and
[principles/transparency/consultations_de.](https://commission.europa.eu/about/service-standards-and-principles/transparency/consultations_de)

Aurubis is included in the European Union's Transparency Register [transparency-register.europa.eu, which](https://transparency-register.europa.eu/index_en)
publishes expenditures for lobbying at the European level. In Germany too, Aurubis is included in the
national lobbying transparency register www.lobbyregister.bundestag.de. It lists the amounts reported by
Aurubis: In fiscal year 2022/23 Aurubis spent €960,001 to €970,000 (2021/22: €960,001 to 970,000) on the
representation of interests in Germany and €500,000 to 599,999 (2021/22: €500,000 to 599,999) on the
representation of interests in Europe.[13] Aurubis does not donate to any political parties or candidates.

Furthermore, the CEO and CFO take part in the weekly Group Financial Meeting (GFM), which also includes managers from the Finance and Energy & Climate Affairs Group functions. One purpose of the GFM is to monitor the development of price and cost drivers as well as the resulting risks and opportunities, among them climate-related risk factors. Where necessary, positions are hedged accordingly on the basis of this analysis. [...] In addition, together with the responsible departments, the Aurubis Group Sustainability division supports and manages relevant projects and activities, along with their development, with extensive sustainability KPIs, including climate-related KPIs, and reports directly to the CEO. The objective is to proactively address challenges and introduce the appropriate countermeasures early on. [...] Group Sustainability is responsible for managing the Group-wide decarbonization strategy and coordinates the development and implementation of the Aurubis sites' corresponding decarbonization road maps, which are regularly presented in the Strategy Committee (StratCo). Group Sustainability includes Corporate Energy & Climate Affairs in the process with a view to identifying and controlling the impacts on Group-wide CO2 management in good time. [...] Aurubis' Supervisory Board handles climate-relevant topics and decisions in two main areas: the approval of key investment decisions that involve climate-related aspects, and consulting on the company strategy, which includes climate-relevant issues and projects. The Supervisory Board's Audit Committee is involved in monitoring the accounting processes, sustainability and risk management. In its quarterly meeting, it follows a consistent agenda that covers sustainability and risk management, and therefore climate-related risks. The Executive Board approves the investment budget as part of the medium-term planning, as well as individual projects related to the climate, before they are passed on to the Supervisory Board for additional approval.

Moreover, the Aurubis Group Sustainability & External Affairs division works with the responsible department, offering support and managing relevant projects and activities, along with their development, with extensive sustainability KPIs, including climate KPIs. Aurubis Group Sustainability & External Affairs reports directly to the CEO. This allows us to proactively address challenges and introduce appropriate countermeasures at an early stage. [...] As part of Corporate Sustainability & External Affairs, Group Decarbonization is responsible for managing the Group-wide decarbonization strategy and targets and coordinates the advancement and realization of the Aurubis sites' individual decarbonization roadmaps, which are regularly discussed as part of the Strategy Committee (StratCo) and in the quarterly site reviews (QSRs). Group Decarbonization includes Corporate Energy & Climate Affairs in the process with a view to identifying and controlling the impacts on Groupwide CO2 management in good time. [...] The Aurubis Supervisory Board handles climate-relevant topics and decisions in two main areas: The approval of key investment decisions that involve climate aspects, and consulting on the company strategy, which includes climate-relevant issues and projects. The Audit Committee of the Supervisory Board is involved in monitoring the accounting processes, sustainability and risk management. At quarterly meetings, it follows a consistent agenda that covers sustainability (including the status of the decarbonization roadmap) and risk management, and therefore climate risks. The Executive Board approves the investment budget as part of the medium-term planning, as well as individual projects related to the climate, before they are passed on to the Supervisory Board for additional approval.

Does your organization have a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement?[…]Yes