Environmental
management

The Alestis Code includes the company's commitment to sustainable business practices that respect the environment, minimize the negative impact of its operations, manage energy and natural resources efficiently, and manage waste in the best way possible.

The organization also maintains an environmental policy, last revised in July 2021, to integrate it with the occupational health and safety policy. In fact, during 2022, the company continued the process of unifying the Environmental Management System and the Occupational Health and Safety Management System to create an integrated system. This management system has been revalidated in all work centers and certified by an independent third party at the Vitoria-Gasteiz site.

In any case, each facility has its own regulation, issued by the competent administration, which defines the environmental controls to be carried out at each site. Specifically, the Integrated Environmental Permit in Vitoria-Gasteiz, the Unified Environmental Permit in Tecnobahía and Seville, and the Environmental Qualification in Puerto Real.

Alestis do Brasil complies with the parameters required by the Conama Resolution, as well as those of the Environmental Company of the State of São Paulo, through the qualification of the facilities and, in turn, the analytical reports applied by NBR 10.004. It is certified by the Ministério do Meio Ambiente, Instituto Brasileiro do Meio Ambiente e dos Recrusos Naturais Renovaváveis; Licença de Operaçao, issued by the Governo do Estado de São Paulo.

The Alestis Code includes the company's commitment to sustainable business practices that respect the environment, minimize the negative impact of its operations, manage energy and natural resources efficiently, and manage waste in the best way possible.

Applying the processes defined in the Environmental Management System, the most representative significant environmental aspects are as follows:

1. In Spain

Non-hazardous waste generation.

1. In Brazil

Atmospheric emission pollution, soil contamination by chemicals and flammable products, water contamination and pest proliferation.

In Spain, we have been working throughout 2022 to improve the separation of non-hazardous waste and to increase the percentage of this waste that is recovered.

Periodic measurements of the various environmental aspects (spills, noise, emissions, etc.) are carried out at each site. However, the company's environmental management goes beyond the legal requirements, as defined in the Environmental Policy.

With regard to the Law on Environmental Responsibility (Law 26/2007 and subsequent regulations), the Vitoria-Gasteiz plant has carried out the corresponding environmental risk analysis in accordance with the internal procedure SA-84.15 for the identification, evaluation and recording of environmental aspects, taking into account the analysis methods included in the UNE150008 standard and the MITECO methodological guides for the evaluation of environmental aspects related to emergency conditions. Using the tool provided by MITECO for the calculation of the Environmental Damage Index (IDM), the reference accidental scenario related to a possible chromium (Cr-VI) spill in a public waterway is determined, whose damage value is 1,375,388.82 €. This means that the activity is exempt from the obligation to provide a financial guarantee, since according to the law itself, for damages whose cost is calculated between 300,000 € and 2,000,000 €, the obligation disappears if an environmental management system is in place.

Nevertheless, Alestis has a civil liability policy for accidental contamination that covers any incident related to environmental variables up to 15 million euros per year.

In addition, Law 7/2022, of April 8, on Waste and Contaminated Soils for a Circular Economy, was enacted in 2022, which requires insurance or an equivalent financial guarantee to cover the liabilities arising from hazardous waste treatment operations and, in all other cases, when required by the regulations governing the management of specific wastes or by the regulations governing management operations. This guarantee must cover, under the conditions and for the amount to be determined by regulation, the compensation due for the death, injury or illness of persons, the compensation due for damage to property and the costs of repairing and restoring the altered environment. This amount shall be determined in accordance with the provisions of environmental liability legislation.

In Spain, we have been working throughout 2022 to improve the separation of non-hazardous waste and to increase the percentage of this waste that is recovered.

Alestis has determined that the activities of its facilities located in Seville, Puerto Real and Vitoria-Gasteiz meet the conditions for obtaining this insurance, and has therefore included them in the policy taken out by Aciturri Aeronáutica, S.L., with effect from January 1, 2023. This policy has a coverage of 1.0 million euros per year, with a deductible of 10,000 euros.

Alestis do Brasil implements a series of measures to reduce its main environmental aspects and risks, the most important of which are the pruning of trees for fire prevention, pest control and the eradication of rats and poisonous animals, as well as the cleaning of water tanks to avoid contamination. The filters in the trimming and painting booths are also changed regularly. There is a spill containment box for chemical and flammable spills. Waste is managed in accordance with current legislation and there is an insurance policy covering the transportation of waste to the final recipient, the waste manager.