Policies and Corporate Guidelines
Group policies as business activity guidelines
We adopt a Organizational, Management and Control Model based on a set of principles (Code of Ethics, 231 Model, Policies) and management and control tools (risk management, procedures, controls) aimed at overseeing relevant non-financial issues, in line with the applicable fully comply with applicable laws and regulations of the countries in which we operate, as well as with the main international standards and guidelines.
In order to identify, prevent, mitigate and manage actual and potential impacts, as well as address risks and seize opportunities, we have implemented a structured system of ESG policies.
The Board of Directors and the Chief Executive Officer have primary responsibility for implementing and monitoring these policies, ensuring their effectiveness through continuous oversight and integration into strategic decision-making processes. At the operational level, the activities carried out by the Chief Sustainability Officer are also essential; they coordinate ESG strategy and reporting, acting as a pivot among all the company functions involved.
Internal Framework
These policies constitute the reference framework for the Group's sustainability model and represent operational tools for translating the long-term vision into concrete actions. These involve all dimensions of sustainability (environmental, social and governance) and are aligned with the United Nations Sustainable Development Goals (SDGs).
We also promote an inclusive approach, actively involving local communities, the supply chain and all stakeholders through transparent communication tools and integrated reporting processes, as described in detail in the Integrated Annual Report.
Below is a detail of Sesa's ESG Policies and Guidelines, which all Group companies are required to comply with:
DESCRIPTION
OBJECTIVES
DESCRIPTION
Document that defines the ethical principles and rules of conduct that guide all Group companies, promoting integrity, transparency, legality and respect for people. Everyone must operate with honesty and responsibility, protecting the company's reputation and supporting sustainability, diversity and environmental protection.
OBJECTIVES
- Promote integrity and transparency
- Ensure compliance with applicable laws
- Protect people and value diversity
- Prevent illegal or improper conduct
- Ensure environmental and social sustainability
- Protect the Group's reputation and values
CODE OF CONDUCT
DESCRIPTION
Document that defines the principles, values and rules of conduct that guide the Group's behaviour, orienting every activity towards criteria of fairness, integrity, transparency, respect for people, the environment and the law, in order to promote an ethical and responsible corporate culture and protect the Group's reputation and trust.
OBJECTIVES
- Define clear principles of conduct
- Ensure honesty and accountability
- Guide ethical decisions and actions
- Promote transparency in relations
- Prevent improper or illegal conduct
- Consolidate the Group's trust and reputation
DESCRIPTION
Document describing the Group's approach to managing risks and opportunities related to climate change, in line with the recommendations of the Task Force on Climate-related Financial Disclosures (TCFD). It outlines the governance, strategy, risk management processes and key indicators used to monitor climate impacts on the business and long-term performance.
OBJECTIVES
- Improve climate transparency
- Integrate climate risk
- Assess business impacts
- Strengthen climate governance
- Align with TCFD recommendations
- Manage climate risks and opportunities
DESCRIPTION
Document that defines the targets, strategies and concrete actions that the Group intends to implement in the two-year period 2026-2027 to improve its environmental, social and economic performance, promoting sustainability, responsible innovation and the creation of shared value for all stakeholders.
OBJECTIVES
- Define clear sustainability targets
- Promote responsible innovation
- Improve environmental and social impact
- Promote shared value for stakeholders
- Monitor performance and results
- Strengthen ESG reputation and commitment
DESCRIPTION
Document that defines the commitments, principles and targets through which the Group directs its activities towards environmental protection, pollution prevention, compliance with current regulations and continuous improvement of its environmental performance.
OBJECTIVES
- Compliance with environmental regulations
- Pollution prevention
- Efficient use of resources
- Reduction of emissions and waste
- Protection of biodiversity
- Raising awareness among staff and partners
DESCRIPTION
A strategic and value-based document that defines the commitments, principles and actions through which the organisation intends to operate in an ethical, sustainable and responsible manner towards its stakeholders.
OBJECTIVES
- Promote ethics and transparency
- Protect employees and human rights
- Encourage sustainable practices
- Promote inclusion and equal opportunities
- Support local communities
- Strengthen trust and reputation
DESCRIPTION
Document that sets out the commitments, principles and actions through which the Group promotes Gender Equality and Equal Opportunities, ensuring an inclusive, fair and respectful working environment, free from all forms of discrimination, and encouraging the development of skills and professional growth of its resources.
OBJECTIVES
- Promote equal opportunities
- Ensure fair pay
- Foster inclusion and diversity
- Support women's growth and careers
- Prevent discrimination and harassment
- Spread a culture of gender respect
WHISTLEBLOWING POLICY
DESCRIPTION
Document that regulates the procedures for reporting unlawful or irregular conduct, guaranteeing confidentiality, protection of the whistleblower and transparent and correct management of reports, in support of an environment based on integrity and legality.
OBJECTIVES
- Encourage reporting of irregularities
- Guarantee confidentiality of the whistleblower
- Ensure transparent management of reports
- Prevent retaliation or discrimination
- Promote a culture of responsibility
- Strengthen integrity and legality
DESCRIPTION
Document that defines the Group's commitment in preventing the use of minerals from conflict areas, establishing responsible sourcing procedures, supplier traceability and controls along the supply chain, with the aim of promoting legality, transparency and the social and ethical sustainability of the materials used.
OBJECTIVES
- Avoid sourcing from conflict areas
- Ensure supplier traceability
- Promote responsible/sustainable supply chains
- Reduce ethical and social risks
- Compliance with international standards
- Support transparency and accountability
DESCRIPTION
Document that defines the Group's commitment to creating a safe and healthy working environment, promoting risk prevention, protecting workers' health and creating a culture of safety in all Group locations and activities.
OBJECTIVES
- Ensuring occupational safety
- Preventing accidents and injuries
- Promoting employee wellbeing and health
- Implementing effective preventive procedures
- Fostering a culture of safety within the company
- Monitoring results and continuous improvement
SUSTAINABLE PROCUREMENT POLICY
DESCRIPTION
Document that defines the principles and guidelines adopted by the Group to integrate environmental, social and ethical criteria into its procurement processes, promoting responsible and transparent relationships with suppliers and contributing to the creation of sustainable value along the supply chain.
OBJECTIVES
- Integrate ESG criteria into procurement process
- Promote responsible suppliers
- Reduce indirect environmental impacts
- Protect human and labour rights
- Ensure transparency and fairness
- Promote sustainable/resilient supply chains
BIODIVERSITY POLICY
DESCRIPTION
Document that defines the Group's commitment to protecting ecosystems and safeguarding biodiversity by integrating environmental criteria into its business activities and promoting responsible behaviour throughout the value chain, thereby contributing to reducing impacts and creating sustainable value in the long term.
OBJECTIVES
- Protection of natural ecosystems
- Reduction of impacts on biodiversity
- Responsible use of resources
- Integration of biodiversity into processes
- Raising awareness and engagement
- Promotion of sustainable practices
DESCRIPTION
A document that defines the Group's principles and methods of engagement, promoting transparent, ongoing and constructive communication aimed at listening to stakeholders' concerns, strengthening trust and supporting decision-making processes and the creation of sustainable value in the long term.
OBJECTIVES
- Promote transparent and continuous dialogue
- Encourage stakeholders listening
- Strengthen trust and relationships
- Support informed decisions
- Improve the quality of information
- Create shared sustainable value
