RARE METALS SUPPLY CHAINS - CHALLENGES FOR A SUSTAINABLE ENERGY TRANSITION ENGAGEMENT RESULTS

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RARE METALS SUPPLY CHAINS - CHALLENGES FOR A SUSTAINABLE ENERGY TRANSITION ENGAGEMENT RESULTS
Asset Management

RARE
METALS
SUPPLY
CHAINS
CHALLENGES
FOR A SUSTAINABLE
ENERGY TRANSITION

ENGAGEMENT RESULTS
July 2021
Created in 2017, Shareholders for       scribes itself primarily as a “facilita-
    Change is a European network for        tor platform”.
    shareholder engagement, composed        Its 12 members are based in seven
    of institutional investors represent-   different countries:
    ing over €30 billion in assets under    Germany (Bank für Kirche und Caritas
    management.                             eG), Austria (Fair-finance Vorsorgeka-
    Its members are highly involved         sse), Spain (Fundacion Finanzas Eti-
    in shareholder engagement at the        cas), France (Meeschaert AM, Ecofi
    local level, participating jointly in   and Sanso IS), Italy (Etica Sgr and
    general meetings, co-signing let-       Fondazione Finanza Etica), Switzer-
    ters to businesses and meeting with     land (ABS - Alternative Bank Schweiz,
    companies to discuss their respec-      Ethos Foundation and Forma Futura),
    tive commitments. The network de-       UK (Friends Provident Foundation).

2   Rare metals supply chains
RARE METALS SUPPLY CHAINS
  Challenges for a sustainable energy transition
  ENGAGEMENT RESULTS
  July 2021

Introduction                                                                           4

Overview of SfC engagement on rare metals                                              5

• Wind energy                                                                          5
• Automotive manufacturers (Electric Vehicles)                                         6
• Chemical companies                                                                   7

The “Rare metals” engagement with each of the 12 analysed companies                    8

• Wind energy                                                                       8
• Automotive manufacturers                                                         13
• Chemical companies                                                               17

                                                                  Engagement results       3
INTRODUCTION

SfC - Shareholders for Change is a Euro-      The report identified twelve companies       • Audits are very rarely extended be-
pean investor network for shareholder         potentially exposed to risks related to        yond Tier 1 suppliers, which are gen-
engagement, created in December 2017.         the extraction and use of rare metals          erally only brokers of materials ex-
It currently has twelve members from          and rare earths. Five in the wind energy       tracted by other companies;
seven countries and represents a total of     sector: Vestas, Siemens-Gamesa, Or-
over €30bn AUM (www.shareholders              sted, Iberdrola and Nordex; four in the      • Recycling of rare earths and rare met-
forchange.eu).                                automotive sector: PSA, Renault, Daim-         als is at a very early stage and specific
The network’s engagement priorities           ler and BMW; and three in the chemical         recycling targets are generally miss-
are climate related issues, workers and       sector (Johnson Mattey, Umicore and            ing;
human rights and tax transparency.            Solvay).
SfC has completed two engagement                                                           • Details on detected cases of non-com-
projects so far, based on its own research,   Each of these companies was engaged            pliance by suppliers are not disclosed,
focussed on so-called “orphan issues”,        by SfC members between November                while information on corrective meas-
that are still marginal in investor en-       2019 and June 2021, in particular with         ures are limited;
gagement strategies: tax avoidance in         questions on:
the European telecommunication sector                                                      • The sourcing of cobalt, especially
and the ESG risks linked to the extrac-       • the scope of supplier audits’ coverage       from Congo (DRC), remains a source
tion of rare metals.                            (Tier 1, Tier 2, etc.);                      of potential controversies for some of
                                              • procedures in case of non-compli-            the engaged companies.
In May 2019, Meeschaert Asset Man-              ance;
agement, one of SfC’s founding mem-           • the recovery and recycling of materi-      Beginning from September 2021, SfC’s
bers, published the report “Rare metal          als;                                       engagement on rare metals will enter its
supply chains” (https://bit.ly/3klL7sL),      • the sourcing of cobalt.                    “second phase”. While the “first phase”
on behalf of Shareholders for Change,                                                      has been primarily based on “disclo-
evidencing potential social and envi-         The engagement was done in behalf of         sure”, the “second phase” will focus on
ronmental controversies in the supply         the whole SfC network and led by indi-       specific “commitments” by companies.
chains of rare earths (such as Neodymi-       vidual SfC members.                          So far we have just asked companies to
um and Praseodymium) and rare metals          The current engagement report pre-           disclose more information on certain as-
(such as cadmium, cobalt, chromium,           sents the main results of the engage-        pects of their supply chain management
lithium, magnesium, palladium, rhodi-         ment process, that was terminated on         and on recycling. From now on we will
um, etc.)                                     the 30th of June 2021.                       ask them to commit to precise actions or
These are fundamental components of                                                        targets, with the advice of leading inter-
the energy transition to an economy                                                        national experts.
with low greenhouse gas emissions.            I Main results of the engagement             One of them is Julie Klinger, assistant pro-
They are found in wind turbines, electric                                                  fessor at the Department of Geography
car batteries, photovoltaic panels and        The 12 companies were generally cooper-      and Spatial Sciences, University of Dela-
energy-saving light bulbs.                    ative and engaged in a dialogue with SfC,    ware and author of the book “Rare Earth
However, they have at least two main          providing “good” or “very good” answers      Frontiers”. Prof. Klinger, who will accom-
problems: they are extracted and mar-         in more than 80% of cases. Only one com-     pany SfC in the “second phase” of the rare
keted mainly by China, which operates         pany, the automotive group PSA (today        metals engagement project, held a webi-
in a quasi-monopoly situation, or from        Stellantis) did not reply to the network’s   nar on rare metals during the SfC Summer
countries at risk for human rights, such      questions, while the Spanish wind giant      Meeting in June 2021: “Rare earth supply
as the Democratic Republic of Congo           Ibedrola replied in a very generic way.      chains. Persistent myths, policy challenges
(cobalt). And they are exposed to a num-                                                   and possible pathways forward” (link:
ber of risks, both for the environment        The engagement identified some prob-         https://youtu.be/5YmHbwywxSY).
(groundwater pollution, soil erosion,         lems that appears to be structural and
toxic wastewater discharge) and for           common to nearly all companies across
workers (lack of protection).                 the three industries:

4   Rare metals supply chains
OVERVIEW OF SFC ENGAGEMENT
     ON RARE METALS

WIND ENERGY

Questions
- Scope of coverage of supplier audits.
- Recovery and recycling of rare metals.
- Supply chain security and sustainability.

 Sector/Companies                Engagement Leader           Quality of answers   Room for improvement
 Vestas                          Etica Sgr                   Good                 Extend audits beyond Tier 1
                                                                                  suppliers

                                                                                  Specific targets on rare metals’
                                                                                  recycling are missing

 Siemens-Gamesa                  Ethos                       Good                 Extend audits beyond Tier 1
                                                                                  suppliers

                                                                                  Specific targets on rare metals’
                                                                                  recycling are missing

 Orsted                          Etica Sgr                   Very good            Extend audits beyond Tier 1
                                                                                  suppliers

                                                                                  Specific targets on rare metals’
                                                                                  recycling are missing

 Iberdrola                       Fundacion Finanzas Eticas   Poor                 No reference to a specific policy
                                                                                  on rare metals

 Nordex                          Alternative Bank Schweiz    Good                 -

                                                                                           Engagement results         5
AUTOMOTIVE MANUFACTURERS (ELECTRIC VEHICLES)

Questions
- Impact of EV development on the supply of rare metals.
- Respect for human and environmental rights in cobalt procurement.
- Sanctions to non-compliant suppliers.
- Traceability in rare metal and battery supply chains.
- Scope of supplier audits coverage.
- Recycling of batteries.

    Sector/Companies             Engagement Leader             Quality of answers   Room for improvement
    PSA                          Meeschaert Asset Management   Very poor            -
                                                               (no reply)

    Renault                      Ecofi                         Good                 More details on environmental
                                                                                    criteria applied to suppliers and
                                                                                    on battery recycling are needed.

                                                                                    Information about the scope
                                                                                    of supply chain monitoring
                                                                                    is missing.

    Daimler                      Ecofi                         Good                 The company has not given
                                                                                    a clear answer on a possible stop
                                                                                    to the import of Congolese cobalt.

                                                                                    Supply chain monitoring should
                                                                                    be extended beyond Tier 1.

    BMW                          Bank für Kirche und Caritas   Good                 Details on detected cases
                                                                                    of non-compliance are not
                                                                                    disclosed yet.

                                                                                    A “Tier-N” monitoring down
                                                                                    to the last level of the supply
                                                                                    chain is still missing.

6    Rare metals supply chains
CHEMICAL COMPANIES

Questions
- Scope of rare metals supplier audits’ coverage. Procedure in case of non-compliance.
- Disclosure of recycling rates per each metal.
- Geographical mapping of rare metals mines.
- Mapping of cobalt supply chain.

 Sector/Companies                Engagement Leader              Quality of answers       Room for improvement
 Johnson Matthey                 Etica Sgr                      Very good                More information on
                                                                                         the procedure for supporting
                                                                                         non-compliant suppliers would be
                                                                                         needed.

 Umicore                         Forma Futura                   Very good                More information on
                                                                                         the procedure for supporting
                                                                                         non-compliant suppliers would be
                                                                                         needed.

                                                                                         Disclosure of recycling rates per
                                                                                         each metal is still missing.

 Solvay                          Meeschaert Asset Management    Good                     More information could be
                                                                                         disclosed about corrective actions
                                                                                         or reasons for low score of rare
                                                                                         earth metals suppliers.

                                                                                         Limited information on recycling
                                                                                         and on geographical mapping
                                                                                         of rare metals mines.

                                                                                                  Engagement results          7
THE “RARE METALS” ENGAGEMENT
      WITH EACH OF THE 12 ANALYSED COMPANIES

I Wind Energy                               • Engaged companies:                       half of offshore wind turbines are us-
                                                                                       ing direct-drive technology, which em-
                                            Vestas, Siemens-Gamesa, Orsted, Iber-
                                                                                       ploys rare-earth elements like neo-
                                            drola, Nordex.
                                                                                       dymium and dysprosium. Therefore,
                                                                                       actors in the wind turbine value chain
                                            • Economic context
                                                                                       have a responsibility to conduct rea-
                                            The European Union wants 32% of its        sonable checks on their suppliers to
                                            energy mix to come from renewable          identify, prevent and reduce any nega-
                                            energy by 2030 (compared with 22.7%        tive impacts. This responsibility is all
                                            today). Depending on the scenario, re-     the greater because there are only a
                                            newable energy and hydropower are          small number of companies in the
                                            expected to account for 65% to 81% of      market, which therefore have a strong
                                            Europe’s energy mix by 2040, includ-       potential to influence over the entire
                                            ing 30% to 35% wind power. Since 2020,     supply chain.

1. VESTAS WIND SYSTEMS A/S

• Location: Aarhus, Denmark                 - Optimisation of recovery and recy-       magnets, and also in the magnets used
                                              cling rates.                             in the towers make a negligible contri-
• Revenue 2020: €14.82bn                    - Supply chain security and sustainabil-   bution to total resource depletion, con-
                                              ity in risk mapping.                     tributing below 0.1% of total life cycle
• Employees: 29,230                         - EROEI (energy returned on energy         impacts.
                                              invested rate) of the company’s tur-     The field of recycling composites is not
• Onshore/offshore positioning:               bines.                                   mature and is an emerging area regard-
Mainly onshore. Offshore development                                                   ing recycling technology available and
via “MHI Vestas Offshore Wind” (100%        • How the company answered                 technology readiness levels.
owned since October 2020).                  The quality of the company’s answers
                                                                                       Vestas is involved in the Wind Europe
                                            was good.
• Level of exposure to rare metals:                                                    Dismantling Task Force – to develop in-
                                                                                       dustry guidelines for end-of-life.
Neodymium and dysprosium used in            Monthly performance dialogue meet-
                                                                                       Targets to limit product waste by 7% to-
the towers of all models of wind turbines   ings with suppliers.
                                                                                       wards 2020 compared to baseline from
and in the permanent magnet genera-         Detailed monitoring in global procure-
                                                                                       2017. No specific target on rare metals.
tors of older models.                       ment on approximately 160 suppliers
                                            with scorecard monitoring.
                                                                                       • What can be improved?
• Engagement leader: Etica Sgr              Proactive Risk Management is an inte-
                                            gral part of Global procurement.           It is not clear whether Tier 2, 3, etc. sup-
• Engagement period:                        Compared to older permanent-magnet         pliers are covered or not.
                                            generators, the new EnVentus generator     The names of suppliers are not dis-
November/December 2019
                                            uses less light rare-earth material per    closed.
                                            MW and has eliminated use of heavy         Specific targets on rare metals’ recy-
• Questions/areas of engagement:
                                            rare earth materials altogether.           cling are missing.
- Consideration of higher tier suppliers,   The contribution of rare earth ele-
  further upstream in the supply chain.     ments used in the turbine generator

8   Rare metals supply chains
2. SIEMENS GAMESA RENEWABLE ENERGY SA (SGRE)

• Location: Zamudio, Spain                   the company’s CSR plan?                     In the company’s sustainability report
                                           - How many suppliers are monitored?           (January 2021), SGRE mentions rare
• Revenue 2020: €9.91bn                    - Optimisation of recovery and recy-          earths for the first time as “high risk
                                             cling rates.                                from a sustainability point of view”.
• Employees: 25,950                        - Target rates for recovery and recycling.    The company formally commits to re-
                                           - Supply chain security and sustainabil-      duce or eliminate the use of heavy rare
• Onshore/offshore positioning:              ity in risk mapping.                        earths such as dysprosium and terbium.
Onshore and Offshore.
                                           • How the company answered                    • What can be improved?
• Level of exposure to rare metals:        The quality of the company’s answers          The names of suppliers are not disclosed.
Neodymium used in NdFeB magnets.           was good.                                     The company should conduct unan-
                                                                                         nounced audits.
• Engagement leader: Ethos Foundation      The company explained that its five sup-      ‘Tier 2’ suppliers should be covered too.
                                           pliers of rare metals have signed a code of   The company needs more specific tar-
• Engagement period:                       conduct and a set of environmental re-        gets on rare metals’ recycling.
                                           quirements. However, monitoring stops
May 2020/March 2021
                                           at the first level of the supply chain, the
                                           so-called ‘Tier 1’: the company’s direct
• Questions/areas of engagement:
                                           suppliers, that are only intermediaries.
- How are rare metals taken into account   SGRE commits to extending the re-
  in the “Responsible Supply Chain” of     quirements to ‘Tier 2’.

                                                                                                           Engagement results    9
3. ORSTED A/S

 • Location: Fredericia, Denmark             - Supply chain security and sustainabil-     However, this is relevant and needed
                                               ity in risk mapping.                       only in few occasions.
 • Revenue 2020: €6.84bn                     - Is the Company planning to develop a       In January 2020 Orsted started the de-
                                               product life cycle assessment meth-        velopment of a “Metals and Minerals
 • Employees: 6,310                            od?                                        Programme” to address and minimize
                                                                                          the social and environmental risks re-
 • Onshore/offshore positioning:             • How the company answered                   lated to the extraction of key metals (in-
 Onshore and Offshore.                                                                    cluding rare earth metals). The Pro-
                                             The quality of the company’s answers
                                                                                          gramme is initially focused on the
                                             was very good.
 • Level of exposure to rare metals:                                                      offshore portfolio but will be extended
                                                                                          to all business areas, including energy
 Mainly exposed to the use of neodymi-       Risk screenings to identify suppliers for
                                                                                          storage.
 um through its turbine suppliers, in-       further engagement based on spend,
                                                                                          Orsted is working with key supplier to (i)
 cluding Siemens Gamesa.                     country, and category risks. On-site vis-
                                                                                          map the use of these metals, (i) identify
                                             its to assess adherence with the compa-
                                                                                          the current social and environmental
 • Engagement leader: Etica Sgr              ny’s Code.
                                                                                          risks and (iii) developing ways to miti-
                                             Improvements plans and dialogue with
                                                                                          gate the risks. This last step also includes
 • Engagement period:                        suppliers.
                                                                                          identifying opportunities to recycling or
                                             Only less than 0.2% of suppliers are
 June 2020/December 2020                                                                  substituting these metals and the poten-
                                             based in high risk countries.
                                                                                          tial risks associated with that.
                                             In 2019 the company identified some
 • Questions/areas of engagement:
                                             risks in the supply chain, mainly related
                                                                                          • What can be improved?
 - Scope of coverage of suppliers’ audits.   to poor working conditions. All issues
 - Monitoring of risks linked to the use     have been addressed satisfactorily by        Specific targets on rare metals’ recy-
   of rare metals.                           the suppliers.                               cling are missing.
 - Is impact management applied to           Initial focus on Tier 1 suppliers. Screen-   The monitoring of the supply chain is
   storage battery production?               ing also on selected Tier 2 suppliers.       still largely limited to Tier 1 suppliers.

10   Rare metals supply chains
4. IBERDROLA SA

• Location: Bilbao, Spain                 • Engagement period:                        areas for improvement and proposes a
                                                                                      customised action plan.
                                          January-February 2021
• Revenue 2020: €33.81bn                                                              Suppliers that do not manage to adapt to
                                                                                      ESG requirements within a reasonable pe-
• Employees: 38,300                       • Questions/areas of engagement:
                                                                                      riod of time are excluded from future ten-
                                          - Monitoring of risks associated to rare    ders.
• Onshore/offshore positioning:             metals.                                   With regard to wind blades, between 2014
Mainly onshore. Offshore wind farm pro-   - Recycling of rare metals components.      and 2016, Iberdrola developed the Life
jects are under development.              - How broad is the coverage of supplier     BRIO project, which demonstrated the fea-
                                            audits and the scoring system?            sibility of a route for the reuse of wind blade
• Level of exposure to rare metals:                                                   materials. The fibrillar material obtained
                                          • How the company answered                  from the mechanical recycling of wind
Exposure to technologies that use neo-                                                blades can be used, among other things, as
dymium and dysprosium, through fu-        The quality of the company’s answers
                                                                                      a reinforcement fibre in precast concrete.
ture offshore projects, supplied mainly   was poor.
by Vestas and Siemens Gamesa.                                                         • What can be improved?
                                          Iberdrola is committed to ensuring that
• Engagement leader:                      70% of its main partner companies (those    No reference to a specific policy on rare
                                          with a turnover with the company of more    metals was made in the answers.
Fundacion Finanzas Eticas                 than €1m) comply with environmental,        It is not clear whether Tier 2, 3, etc. sup-
                                          social and governance objectives by 2022.   pliers are covered or not.
• Co-lead:
                                          The company provides suppliers that         No reference to any specific targets for
Friends Provident Foundation              obtain a low score with support to detect   the recycling of rare metals.

                                                                                                           Engagement results       11
5. NORDEX SE

 • Location: Hamburg, Germany              • Engagement period:                          box and a double-fed asynchronous gen-
                                                                                         erator. This type of generator does not
                                           June 2020
 • Revenue 2020: €4.94bn                                                                 contain any rare earth magnets.
                                                                                         The Nordex Group is and remains a
 • Employees: 8,390                        • Questions/areas of engagement:
                                                                                         pure onshore manufacturer (and won’t
                                           - Plans to develop offshore technologies.     thus make us of rare earth metals in the
 • Onshore/offshore positioning:           - Monitoring of lithium supply risks for      future either).
 Onshore only.                               lithium-ion storage batteries.              Nordex technology is not based on any
                                           - Scope of supplier audits coverage.          kind of lithium-ion batteries. The elec-
 • Level of exposure to rare metals:                                                     trical pitch technology is equipped with
                                           • How the company answered                    lead batteries.
 The company is developing its own                                                       The audit coverage is focussing on di-
 asynchronous turbine technology that      The quality of the company’s answers
                                                                                         rect suppliers and in some individual
 does not involve the use of permanent     was good.
                                                                                         cases on sub-suppliers. The individual
 magnets. The development of an off-                                                     cases depend on the outsourced pro-
 shore strategy could potentially expose   The use of rare earth materials in Nor-
                                                                                         cess/component at the sub-supplier.
 it to the use of rare metals.             dex wind turbines is very limited.
                                           Very few rare earth materials are used in
                                                                                         • What can be improved?
 • Engagement leader:                      motors, batteries and electronic compo-
                                           nents in the auxiliary power supply sys-      Considering the very low exposure to
 ABS - Alternative Bank Schweiz            tem of the wind turbine.                      rare metals, this question does not apply
                                           The drive train concept consists of a gear-   to Nordex.

12   Rare metals supply chains
I Automotive manufacturers                  • Engaged companies:                         batteries of an electric car, per Mega-
                                                                                         watt (MW) of installed capacity.
                                            PSA, Renault, Daimler, BMW.
                                                                                         Until now, the rare earths market has
                                                                                         been led by the wind power sector. How-
                                            • Economic context
                                                                                         ever, it has to be considered that, in the
                                            The electrification of road transport is a   coming years, the number of wind tur-
                                            key step in limiting global warming and      bines will not increase at the same rate
                                            improving air quality. In its “2°C scenar-   as that of electric cars, the market for
                                            io”, the International Energy Agency pre-    which is starting now, while the wind en-
                                            dicts a very strong growth in road trans-    ergy market is already consolidated.
                                            port electrification by 2060; for example,   Therefore, in order to understand the
                                            the number of light electric vehicles is     rare earth market in the future, we need
                                            expected to reach 1.25 billion worldwide.    to focus on the evolution of the electric
                                            Wind turbines use quantities of neo-         car market.
                                            dymium and praseodymium that are 40          Electric cars also use rare metals for their
                                            times higher than those needed for the       batteries, such as cobalt and lithium.

6. GROUPE PSA (PEUGEOT SA)

• Location: Paris, France                   tery. PSA’s electric best seller in 2020     - Battery technologies envisaged, as-
                                            was Peugeot 208 EV with 31,550 units.          sociated rare metals.
• Revenue 2020: €74.7bn
                                            • Engagement leader:                         • How the company answered
• Employees: 209,000
                                            Meeschaert Asset Management                  The company never answered to Mee-
In January 2021 the group merged with                                                    schaert’s questions.
FCA to create Stellantis.                   • Engagement period: 2020
                                                                                         • What can be improved?
• Exposure to rare metals:                  • Questions/areas of engagement:
                                                                                         Not applicable.
Hybrid or electric version of all new car   - Impact of EV development on the
models from 2019. By 2021: launch of 8        supply of rare metals.
plug-in hybrid models and 7 EVs (elec-      - Traceability in rare metal and battery
tric vehicles). 50 kWh lithium-ion bat-       supply chains.

                                                                                                            Engagement results      13
7. RENAULT SA

 • Location: Boulogne-Billancourt, France     • How the company answered                    tions would be very precise. However,
                                                                                            Renault has not provided details of the
                                              The quality of the company’s answers
 • Revenue 2020: €43.47bn                                                                   criteria used nor of water consumption
                                              was good.
                                                                                            and wastewater production.
 • Employees: 170,160                                                                       Renault did not provide sufficient infor-
                                              In 2019, approximately 20 audits were
                                                                                            mation on battery recycling.
 • Exposure to rare metals:                   carried out on cobalt suppliers. Renault
                                                                                            The company is a member of the Re-
                                              did not find any significant case of
 Nearly 118,900 EVs sold in 2020 (6.7% of                                                   sponsible Cobalt Initiative.
                                              non-compliances. Currently the audits
 sales). 25% of market share in Europe.       are not very effective because the com-
 Renault’s Zoe was the best-selling elec-                                                   • What can be improved?
                                              pany is obliged to announce the audits
 tric car in Europe in 2020 (99,610 units).   to the suppliers some days in advance.        Details on the environmental criteria
                                              The company plans to make agreements          applied to suppliers and on battery recy-
 • Engagement leader: Ecofi                   with some competitors to perform joint        cling are missing.
                                              audits. In addition, the cobalt supply        No information about water consump-
 • Engagement period: 2020                    chain is particularly complicated to be       tion and wastewater production in co-
                                              monitored because it is often composed        balt mining activities.
 • Questions/areas of engagement:             of small suppliers that close down,           No information about the scope of sup-
 - Respect for human and environmen-          change frequently and therefore strug-        ply chain monitoring.
   tal rights in cobalt procurement.          gle to meet the set of criteria required by
 - Research and development of less co-       a group like Renault.
   balt-dependent solutions.                  The internal environmental policy is
 - Recycling of batteries.                    also imposed on suppliers. The ques-

14   Rare metals supply chains
8. DAIMLER AG

• Location: Stuttgart, Germany             - Sanctions to non-compliant suppliers.        define measures for addressing 100% of
                                           - Monitoring of supply-chain risks for         raw materials linked to high risk of hu-
• Revenue 2020: €158.10bn                    rare metals.                                 man rights violations by 2028.
                                           - Dialogue with critical stakeholders.         Daimler prefers to dialogue with the
• Employees: 288,060                                                                      suppliers and to train them, instead to
                                           • How the company answered                     put in place commercial sanctions.
• Exposure to rare metals:                                                                Daimler’s suppliers are more than
                                           The quality of the company’s answers
Mercedes-Benz Cars sold more than                                                         15.000. In 2019 Daimler audited more
                                           was good.
160,000 plug-in hybrids and all-electric                                                  than 1,100 suppliers, but not just on hu-
vehicles (xEVs) in 2020. xEV share of                                                     man rights.
                                           According to its policy (“Daimler Supplier
Mercedes-Benz Cars increased to 7.4% in                                                   The dialogue with critical stakeholders
                                           Sustainability Standards”), in the con-
2020 (from 2% in 2019). 2025 outlook:                                                     is generally good.
                                           tracts that Daimler signs with its direct
15% to 25% of turnover generated by                                                       The company is a member of several in-
                                           suppliers (Tier 1), the company asks to
sales of all-electric models.                                                             itiatives in the industry: Responsible
                                           control sub-suppliers (Tier 2, etc.), but at
                                                                                          Cobalt Initiative, EconSense, Responsi-
                                           the moment it doesn’t go further than that.
• Engagement leader: Ecofi                                                                ble Steel, VDA, Aluminium Stewardship
                                           The company explained to have charged
                                                                                          Initiative.
• Co-lead:                                 an external firm, in 2019, with a three-
                                           year audit of its cobalt supply chains for
Bank für Kirche und Caritas, Fondazione                                                   • What can be improved?
                                           the battery cell suppliers of Mercedes-
Finanza Etica.                             Benz AG. The program covers both               On some issues, such as a possible stop
                                           downstream (from battery manufactur-           to the import of Congolese cobalt, asso-
• Engagement period: 2020                  ers to refineries) and upstream suppli-        ciated to a high risk of human rights
                                           ers (from mines to refineries).                abuses, the company has not given a
• Questions/areas of engagement:           Moreover, Daimler has committed to             clear answer.
- Auditing of cobalt supply chain be-      evaluate 70% of suppliers of all high-risk     Supply chain monitoring should be ex-
  yond Tier-1.                             raw materials by 2025, while it aims to        tended beyond Tier 1.

                                                                                                            Engagement results    15
9. BAYERISCHE MOTOREN WERKE AG (BMW)

 • Location: Munich, Germany                  • Questions/areas of engagement:              supply chain, it works closely together
                                                                                            with its direct suppliers. BMW requires
                                              - What sustainability requirements do
 • Revenue 2020: €102.52bn                                                                  the supplier to implement immediate cor-
                                                BMW’s supplier location audits in-
                                                                                            rective action to stop the violation. Addi-
 • Employees: 126,020                           clude?
                                                                                            tionally, the company applies a “multi-step
                                              - There were 193 cases of non-compli-
                                                                                            escalation process” which can ultimately
 • Exposure to rare metals:                     ance in 2018. Do any of these cases
                                                                                            lead to the exclusion of the supplier.
                                                include rare metals suppliers?
 During the twelve months of 2020, BMW                                                      None of the 193 cases of non-compli-
                                              - Is there a specific audit policy on rare
 Group delivered a total of 192,646 plug-                                                   ance reported for 2018 included rare
                                                metals?
 in cars (EVs and hybrid; up 31.8% year-                                                    metals suppliers, since the company
                                              - Sourcing of cobalt from Congo (RDC).
 over-year), which accounts for 8.3% of the                                                 doesn’t source these materials directly.
                                              - Scope of supplier audits coverage.
 total volume of 2.32 million.                                                              For the same reason, a specific audit pol-
 In Europe, where most of the plug-ins                                                      icy on rare metals is not in place.
                                              • How the company answered
 were sold (over 135,000), the plug-in                                                      Supplies from Congo DRC have ceased
                                              The quality of the company’s answers          due to the high ESG risks. Preference is
 share is at 15%. 2025 outlook: 15% to 25%
                                              was good.                                     now given to Australia and Morocco,
 of turnover generated by electric vehi-
 cles, thanks to the launch of 25 electric                                                  which are considered less risky.
                                              BMW specified that it uses (and moni-         Despite this, the company continues to
 models.                                      tors) only “indirect” suppliers of rare       be involved in the “Cobalt for Develop-
                                              metals (Tier 1, i.e. brokers). For the time   ment” project in Congo.
 • Engagement leader:
                                              being, it does not monitor who actually
 Bank für Kirche und Caritas                  extracts the materials (Tier 2, 3, etc.).
                                                                                            • What can be improved?
                                              However, the company’s “Tier 1” suppliers
 • Co-lead: Ecofi                             have to implement processes to forward        Details on detected cases of non-com-
                                              sustainability requirements to their own      pliance are not disclosed yet.
 • Engagement period: 2020                    supply chain. In case BMW becomes             A “Tier-N” monitoring down to the last
                                              aware of any violations in its whole tier-N   level of the supply chain is still missing.

16   Rare metals supply chains
I Chemical companies                       • Engaged companies:                           Cathodes, for example, are vital compo-
                                                                                          nents of electric vehicle batteries and cat-
                                           Johnson Matthey, Umicore, Solvay.
                                                                                          alytic converters, which reduce the pollu-
                                                                                          tion caused directly by vehicles with
                                           • Economic context
                                                                                          combustion engines. Thanks to their in-
                                           Chemical manufacturers play a key              novation capacity and their position in the
                                           role in the energy transition of other         supply chain, chemical manufacturers are
                                           sectors. Chemicals are used to make            able to improve technologies to shift to-
                                           components that promote energy effi-           ward recycling and substitution materials.
                                           ciency and low-carbon energy develop-          The sector’s supply chain comprises
                                           ment.                                          mines, smelters and metal refineries.

10. JOHNSON MATTHEY PLC

• Location: London, United Kingdom         • How the company answered                     from secondary sources (i.e. recycled) is a
                                                                                          very important source of input. During
• Revenue 2020: €18.35bn                   The quality of the company’s answers
                                                                                          2019/20 the company implemented a re-
                                           was very good.
                                                                                          sponsible platinum and palladium guid-
• Employees: 13,560                                                                       ance for all material handled through its
                                           The company does evaluate suppliers
                                                                                          UK and US refineries, which includes us-
• Exposure to rare metals:                 further upstream in the supply chain.
                                                                                          ing third party experts to implement a
                                           For example, with battery material prod-
The company manufactures catalysts                                                        value chain due diligence program on
                                           ucts, Johnson Matthey (JM) is commit-
and cathodes (LFP/eLNO) for the auto-                                                     the sources of all input feeds to refineries.
                                           ted to using only raw materials that have
motive sector and recycles metals. 1.5%                                                   JM engages its suppliers through its
                                           been ethically sourced and ensure it
of turnover from EVs’ supply chain.                                                       “Supplier Code of Conduct” to ensure re-
                                           knows the provenance of the critical met-
                                                                                          sponsible behaviours. JM may conduct
                                           als back to mine: cobalt, lithium and nick-
• Engagement leader: Etica Sgr                                                            periodic assessments, surveys or audits
                                           el. The company has partnered with an
                                                                                          of the supplier’s systems, products and
                                           independent audit company who special-
• Engagement period: 2020                                                                 processes to ensure that they meet re-
                                           ises in working in the cobalt supply chain.
                                                                                          quirements. The supplier may also be
                                           In early 2020 the company joined the Glob-
• Questions/areas of engagement:                                                          asked, on occasion, to participate in JM
                                           al Battery Alliance and agreed to ten guid-
                                                                                          training on ethics and sustainability.
- Are higher tier suppliers, further up-   ing principles for a creation of sustainable
  stream in the supply chain, consid-      battery value chains globally by 2030.
                                                                                          • What can be improved?
  ered in the company’s monitoring?        For operations using pgms (platinum
- Is there a procedure for supporting      group metals), Johnson Matthey uses            More information on the procedure for
  suppliers that do not comply with the    metal from its own refineries, other in-       supporting non-compliant suppliers
  company’s Code?                          dustrial suppliers and the market. Metal       would be needed.

                                                                                                              Engagement results      17
11. UMICORE SA

 • Location: Bruxelles, Belgium                - Geographical mapping of rare metals       consisting of more than 20 different cri-
                                                 mines.                                    teria.
 • Revenue 2020: €20.71bn                      - Mapping of cobalt supply chain.           Mitigating actions are systematically
                                                                                           reported to the management, corre-
 • Employees: 13,320                           • How the company answered                  sponding to the respective strategic ob-
                                                                                           jectives and identified risks. However,
 • Exposure to rare metals:                    The quality of the company’s answers
                                                                                           these specific risks and mitigation ac-
                                               was very good.
 The company manufactures NMC cath-                                                        tions are not public as they constitute an
 odes and catalysts for the automotive                                                     essential part of the supply strategy of
                                               Umicore has a specific policy regarding
 sector; it recycles materials. 36% of turn-                                               the company’s business units.
                                               responsible global supply chain of min-
 over generated by EVs’ supply chain.                                                      The company tracks the origin of all of
                                               erals from conflict-affected and high-
                                                                                           its cobalt raw materials to the level of
                                               risk areas.
 • Engagement leader:                                                                      the mine through mass balance and a
                                               In the area of cobalt sourcing, Umicore
                                                                                           chain of custody documentation.
 Forma Futura                                  has implemented a “Sustainable Pro-
                                                                                           Umicore certifyies to customers that its
                                               curement Framework for Cobalt”.
                                                                                           products do not contain any artisanally
 • Co-lead:                                    Specific recycling rate per metal are not
                                                                                           mined cobalt units and are free of any
                                               disclosed. However, the company does
 Etica Sgr                                                                                 child labour.
                                               indicate the origins of its raw materials
                                               input. In 2018 it disclosed that 42% of
 • Engagement period: 2020                                                                 • What can be improved?
                                               its input came from primary sources
                                               and 58% from secondary (i.e. recycled)      More information on the procedure for
 • Questions/areas of engagement:              material sources, including end of life     supporting non-compliant suppliers
 - Rare metals supplier audits’ coverage.      products.                                   would be needed.
   Procedure in case of non-compliance.        With respect to critical raw materials,     Disclosure of recycling rates per each
 - Disclosure of recycling rates per each      every business unit has its dedicated ap-   metal is still missing.
   metal.                                      proach which is based on a risk matrix

18   Rare metals supply chains
12. SOLVAY SA

• Location: Bruxelles, Belgium              • Questions/areas of engagement:              suppliers, 70% have 3rd party assess-
                                                                                          ment completed to date.
                                            -   Supply chain alert mechanism.
• Revenue 2020: €9.63bn                                                                   The company specified that only one
                                            -   Scope of suppliers’ audits.
                                                                                          out of its six rare earth suppliers
• Employees: 23,000                         -   Recycling measures in place.
                                                                                          achieved an audit score above 45 (the
                                            -   Geographical mapping of rare metals
                                                                                          minimum threshold). Corrective actions
• Exposure to rare metals:                      mines.
                                                                                          would be in place for the five, low per-
Produces fluorine and rare earth formu-     • How the company answered                    forming suppliers. On top, a quality au-
lations for automotive applications. Bat-                                                 dit was performed in 2020 for all rare
tery component sales account for 0.5%       The quality of the company’s answers          earth suppliers.
of turnover but are growing strongly.       was good.                                     At present, the company recycles and
                                                                                          valorises Neodymium and Praseodymi-
                                            Solvay operates three sites that process      um tailings from past activities in France.
• Engagement leader:
                                            rare earths: France, Japan and China. It
Meeschaert Asset Management                 has multi-year contracts, including ca-       • What can be improved?
                                            pacity reservation, for all main raw ma-
• Co-lead:                                  terials. Its main sources (for rare earths)   More information could be disclosed
                                            are China and Australia but it has iden-      about corrective actions or reasons for
Fondazione Finanza Etica
                                            tified viable alternatives outside China      low score of rare earth metals suppliers.
                                            that can be 2nd or 3rd sources of supply.     Limited information on recycling and
• Engagement period:
                                            All critical suppliers are under contract     on geographical mapping of rare metals
2020-2021 (letter and escalation to AGM)    and audited regularly. Of its 450 core        mines.

                                                                                                             Engagement results     19
Published in July 2021 by SfC - Shareholders for Change
www.shareholdersforchange.eu
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