AMAG Austria Metall

Austria|Metals & Mining|Reporting year:FY2025FY2024|Auditor: EY|View original report →

Sustainability statement, in full

The complete text of AMAG Austria Metall’s FY2025 sustainability statement is held here – 125 pages, captured from the published report. Every disclosure below also links to its own passage.

Value chain diagram – from the 2024 report (click to enlarge)

AMAG value chain showing upstream primary aluminium (Alouette), own operations at Ranshofen rolling mill, and downstream component production (Übersee/Karlsruhe)Source: AMAG Austria Metall 2024 annual report, p.5. View original →

ESRS 2 – General Disclosures

GOV-1The role of the administrative, management and supervisory bodies
Reported

Governance roles

Reference: pages 13-15 (ESRS index cites page 13).

Supervisory Board (page 13). At the AGM of 15 April 2025 the members elected by the AGM fell from ten to nine (eight men, one woman). Four more are appointed by the Works Council, "including, for the first time since 19 November 2025 a woman". The Board met five times and "has solely a supervisory function and no executive responsibility".

Committees (pages 13-14). Audit, Nomination, Strategy, Remuneration, urgent matters and ESG. By resolution of 11 June 2025 "the ESG Committee was dissolved and its previously assigned tasks were transferred to the Audit Committee and the Strategy Committee"; the latter became the Strategy and ESG Committee.

Management Board (page 14). Three members (two men, one woman) as CEO/COO, CFO and CSO; it "defines the long-term direction of AMAG's sustainability strategy" and is responsible for monitoring IROs, implementing programme targets and reporting.

Anchoring (pages 14-15). The Management Systems department, which houses Sustainability, reports directly to the Management Board; a Sustainability Committee of the Board, managing directors and department heads meets once a year to evaluate performance and set targets.

GOV-2Information provided to and sustainability matters addressed by the undertaking's administrative, management and supervisory bodies
Reported

Information provided to the administrative, management and supervisory bodies

Reference: pages 13-14, 23 (ESRS index cites pages 13 and 23).

The Supervisory Board "is informed at Supervisory Board meetings about ongoing sustainability activities in relation to material impacts, risks and opportunities as well as significant regulatory framework conditions and changes" (page 13).

Topics it addressed in 2025 (page 13): decarbonisation (strategy, measures, associated risks and opportunities); climate protection; the sustainable aluminium value chain; green energy supply; new legal framework conditions on energy and emissions; CO2-optimised aluminium; the non-financial statement; and diversity, equal treatment and inclusion.

"In order to ensure objectivity with regard to the assessment of AMAG's sustainability performance, the Supervisory Board commissions an external third party to audit the reporting" (page 13).

The Management Board "is regularly informed about ESG topics by the internal departments and external experts (e.g. via AMAG's Scientific and Technological Advisory Board)" and "In 2025, the Management Board addressed all material impacts, risks and opportunities that form the basis of this non-financial statement" (page 14). Material IROs appear under "Significant impacts, risks & opportunities 2025 (ESRS 2 GOV-2)" on page 23 and are "approved for reporting by a Management Board resolution".

GOV-2(was GOV-3)Integration of sustainability-related performance in incentive schemes
Reported

Sustainability-related performance in incentive schemes

Reference: page 14 (ESRS index cites page 13).

The policy was first adopted in 2020, expanded in 2022 to put sustainability targets in the long-term bonus (LTI), and "revised again in 2025, further strengthening the share price reference in performance-related remuneration".

LTI. The 2025 policy "continues to stipulate that, in addition to the existing criteria for the long-term variable performance bonus (LTI), remuneration is linked to two to four sustainability targets from a predefined list of criteria", granted in annual tranches with a three-year assessment period. "A total of 20% of the LTI is allocated to sustainability targets."

Metrics. "For the LTI tranches 2023 (assessment period: 2023-2025) and 2024 (assessment period: 2024-2026), targets were set for specific CO2 emissions (Scope 1 and 2) and the occupational safety indicator TRIFR (Total Recordable Injury Frequency Rate), each relating to the Ranshofen site."

STI. Sustainability targets "can also be taken into account as an option in the short-term performance bonus (STI) as part of a modifier"; "Different sustainability targets must be selected for the STI and LTI."

Assurance. "The ESG key figures relevant to remuneration for the 2025 financial year are audited by Ernst & Young Wirtschaftsprüfungsgesellschaft m.b.H. with reasonable assurance."

GOV-3(was GOV-4)Statement on due diligence
Reported

Statement on due diligence

Reference: pages 16-17 (ESRS index cites page 13).

AMAG maps its due diligence to six steps and tabulates where each is covered (page 16):

Core elementWhere reported
Due diligence anchoringAll ESG areas; particularly S1 (human rights) and S2
Determination and assessment of impacts and risksMateriality assessment; Stakeholder management
Handling of impacts and risksAll ESG areas (Measures); particularly S1 and S2
Effectiveness monitoringS1 (human rights); S2; all ESG areas
Reporting and communicationAll ESG areas
Enabling exchange and reparationParticularly S1 and S2; G1 (whistleblower system)

The processes "are based on applicable laws, internationally recognised standards and voluntary commitments", supported by certified management systems and "a comprehensive risk management and internal control system".

"The due diligence process focussing on the upstream value chain is anchored in the area of responsible procurement management and is continuously developed and adapted as required, for example due to changes in environmental or human rights conditions in countries or regions."

Effectiveness is "monitored once a year or on a risk basis", and "Based on these reports, the Management Board may specify changes and follow-up measures".

GOV-4(was GOV-5)Risk management and internal controls over sustainability reporting
Reported

Risk management and internal controls over sustainability reporting

Reference: pages 17-18 (ESRS index cites page 13); ICS also page 118.

Risk management is "an integral component for identifying, assessing and controlling all significant strategic, technical and operational risks and opportunities at AMAG" and "is based on the 'Risk Management' standard (ISO 31000) and the COSO ERM Framework" (page 17).

Responsibilities (page 17). The Management Board defines the risk strategy, adopts the programme at least annually, monitors the overall system and "ensures that risk management is integrated into all activities at AMAG". It "regularly informs the Supervisory Board and the Audit Committee about AMAG's risk situation".

Assessment (page 18). Prioritisation uses probability of occurrence and potential EBITDA impact on a five-point scale; "Opportunities are currently assessed qualitatively in risk management." The inventory runs twice a year.

Controls (pages 17, 118). "At the end of the year, the implementation of the measures taken for the individual risks is reviewed. At the beginning of the year, the effectiveness of the risk management system is verified externally." An internal control system safeguards the compliance system.

Data controls (page 12). Energy and environmental data are recorded with system support by Energy and Environmental Management, safety data via occupational safety software and personnel data via the ERP system.

SBM-1Strategy, business model and value chain
Reported

Strategy, business model and value chain

Reference: pages 5-9, 26-29 (ESRS index cites pages 5 and 26).

Business model (page 6). AMAG "produces high-quality semi-finished aluminium products, components, cast and wrought alloys, and primary aluminium" from Ranshofen, Austria, through four divisions: Metal (the 20% Alouette stake, metal flows, aluminium price hedging), Casting (recycled casting alloys), Rolling (sheets, coils, plates, plus AMAG components) and Service. "The raw material base for the two casthouses consists on average of around 75 to 80% recycled aluminium scrap" and "Recycling aluminium requires only around 5% of the energy needed to produce primary aluminium."

Scale (page 7). External revenue EUR 1,478.5 million (2024: EUR 1,448.8 million); shipments 417,600 t (425,000 t); 2,115 employees (2,192).

Value chain (pages 8-9). "For essential raw materials (primary aluminium, rolling ingots, alloy metals and scrap) AMAG has a portfolio of over 250 qualified suppliers", evaluated for ESG risks. "Due to the predominant production of semi-finished aluminium products, AMAG has hardly any direct relationships with end users." Alouette produces over 600,000 t a year on hydroelectric power and holds both ASI standards.

Strategy (page 8). Four values - innovation, sustainability, diversity, humanity - and commitment "to climate protection... and thus to the goal of achieving carbon net zero by 2050".

SBM-2Interests and views of stakeholders
Reported

Interests and views of stakeholders

Reference: pages 19-21 (ESRS index cites page 19).

Stakeholder management rests on mapping, dialogue and exchange, and evaluation of feedback, and "is part of its double materiality analysis". Mapping "involves a comprehensive analysis of AMAG's entire value chain" (page 19).

Three-level model (pages 19-20). Level 1: the Sustainability Department "conducts structured discussions with the relevant departments at fixed intervals" following "a standardised interview guide", with results "forming the basis for the double materiality analysis". Level 2: event-related discussions can be initiated by the sustainability department, other departments "or by stakeholders themselves". Level 3: an online survey lets stakeholders "submit their assessments, suggestions or feedback anonymously".

Views reported for 2025 (page 20). Environment: the circular economy "is regarded as a key factor in environmental responsibility", with focus on climate protection and energy. Social: "working conditions, equal treatment and equal opportunities". Governance: stakeholders "particularly emphasise the relevance of corporate culture, supplier management and the prevention of corruption and bribery".

Feedback reaches the annual sustainability committee with the Management Board, management and department heads. Six stakeholder groups with formats and topics are tabled on page 21.

SBM-3Material impacts, risks and opportunities and their interaction with strategy and business model
Reported

Material impacts, risks and opportunities and their interaction with strategy and business model

Reference: pages 22-24; per-topic IRO tables on pages 37-40 (E1), 55-56 (E2), 62 (E4), 66-67 (E5), 80-82 (S1), 105 (S2), 112-115 (G1). Index cites page 22.

Material topics from the 2025 DMA (page 24). E1 Climate change (adaptation, climate protection, energy), E2 Pollution, E4 Biodiversity and ecosystems, E5 Resource use and circular economy, S1 Own workforce (working conditions; occupational health and safety; diversity and equal opportunities; training and further education; human rights), S2 Workers in the value chain, G1 Business conduct (corporate culture; protection of whistleblowers; corruption and bribery; political commitment; relationships with suppliers).

Thresholds (page 23). "Those impacts and risks that are rated with a probability of occurrence or severity of 4 or above are material (light blue area) or prioritised (dark blue area) for AMAG... The EBITDA impact ranges from a low materiality threshold of EUR 250,000 (up to EUR 3 million in the low range) to a very high financial impact of over EUR 150 million."

Changes versus 2024 (page 23). "Compared to 2024, most of the impacts, risks and opportunities remain the same." E5 gained a positive impact on reduced primary raw material use and a potential risk on industrial water extraction consensus; G1 gained regional social engagement, cyber security and a certifications opportunity.

IRO-1Description of the processes to identify and assess material impacts, risks and opportunities
Reported

Processes to identify and assess material impacts, risks and opportunities

Reference: pages 22-23 (index cites page 22); topic-level IRO-1 on pages 44-45 (E1), 57 (E2), 64 (E4), 68 (E5).

The DMA "was carried out for the first time for the 2024 reporting year in accordance with the European Sustainability Reporting Standards (ESRS) and updated in 2025", in four steps.

1. Corporate context. NaDiVeG, ESRS, the EU Taxonomy Regulation, OECD Guidelines, UN Global Compact and SDGs and the German LkSG are used, with ASI sector standards and the EcoVadis, CDP, VÖNIX and Sustainalytics ratings, producing a longlist.

2. Identification. "New topics are identified by means of a top-down process"; existing material topics are re-evaluated for topicality and relevance.

3. Assessment. Severity covers extent, scope and remediability on a five-point scale ("1 = low extent/low scope/very easy to remedy; 5 = very high extent/large scope/very limited remediability"). Notably: "In the case of possible negative impacts on the environment (in the form of incidents) and human rights, the severity of the impact takes precedence over its probability of occurrence." Risks and opportunities are assessed on "probability of occurrence and potential impact on EBITDA and the company's reputation".

4. Reporting (page 23). Material topics with targets and measures go to the Management Board and are "approved for reporting by a Management Board resolution".

IRO-2Disclosure requirements in ESRS covered by the undertaking's sustainability statement
Reported

Disclosure requirements covered by the sustainability statement

Reference: page 25; the ESRS index on pages 279-282 and the ESRS 2 Appendix B table on pages 283-287.

AMAG prints a full ESRS content index, headed "AMAG Austria Metall AG has reported in accordance with the European Sustainability Reporting Standards (ESRS) for the period from 1 January 2025 to 31 December 2025" (page 279). Each disclosure requirement carries either a page number or the words "not material", plus the NaDiVeG issues covered.

Marked "not material" (pages 279-282): E2-5; E3-1 to E3-5; E4-1, E4-4, E4-5, E4-6; S3-1 to S3-5; S4-1 to S4-5; and G1-6.

Reasons (page 25). Four topics or sub-topics were excluded at the corporate-context stage "as these do not apply to AMAG": E2 microplastics and substances of (very) high concern; E3; S3; S4. Two fell below the threshold at assessment: E3, where "no significant impacts, risks or opportunities were identified within the meaning of E3", water being reported under E5; and S3, where "None of these groups have been identified within the immediate areas of influence of the AMAG sites."

Note for readers: in the English edition the index page references for the E1, E2 and E4 chapters run one to two pages behind the printed pages where those disclosures appear.

E1 – Climate Change

E1-1Transition plan for climate change mitigation
Reported

Transition plan for climate change mitigation

Reference: pages 41-43 (ESRS index cites page 40).

Approval. "The decarbonisation strategy was approved and signed by the Management Board"; "The roadmap was presented to and approved by the Supervisory Board's Strategy- and ESG Committee." The Management Board implements the Scope 1, 2 and 3 targets.

Levers (page 42). Recycling expertise; "More energy-efficient new systems, process optimisation and reduction of heating energy requirements"; and "Substitution" of fossil fuels.

Investment (page 41). "The investments and financial resources for implementing the Decarbonisation Roadmap currently range between EUR 200 million and EUR 400 million, excluding possible subsidies." Specific amounts are withheld for competitive reasons.

Locked-in emissions (page 42). "The cumulative greenhouse gas emissions of the production plants at the Ranshofen site, taking into account the current Decarbonisation Roadmap, amount to around 600,000 t CO2eq from 2025 to 2030 and around 1,500,000 t CO2eq from 2024 to 2050."

2025 progress (pages 42-43). "The electrification of the first units at the Ranshofen site has been completed... The decarbonisation measures already implemented will save around 1,800 tonnes of CO2 (reference year 2022)." Two Green Frontrunner R&D projects (DeCAST, DekaWW) were completed.

E1-2(was covered under ESRS 2 IRO-1)Identification of climate-related risks and scenario analysis
Reported

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 and the E1 climate IRO tables, where this content is disclosed in the FY2025 report (pages 18, 37-40, 44-45). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Classification (pages 18, 37-40). "Climate-related risks are divided into transitory and physical risks, the latter in turn into acute and chronic risks" (page 18). The E1 IRO tables label each row "physical" or "transitory".

Methodology (pages 44-45). "The physical risks for the Ranshofen site were determined based on the robust climate and vulnerability assessment carried out as part of the 'EU Taxonomy Study'", drawing on the ÖKS15 Austrian climate scenarios and GeoSphere Austria data.

Scenario (pages 44-45). Climate data was "summarised with the key statements of the federal state-specific worst-case future scenario for Upper Austria (key statements according to RCP8.5 - climate scenario with high emissions)". The time horizon is "10 years in accordance with the EU Taxonomy Regulation" (page 43).

Transition basis (page 45). "The materiality assessment was based on the premise of compliance with the 1.5 °C target of the Paris Climate Agreement." "No business activities were identified that are not compatible with a climate-neutral economy."

Gap. No 1.5°C-aligned transition scenario is named, and no temperature projection per scenario is stated.

E1-3(was covered under ESRS 2 SBM-3)Resilience in relation to climate change
Reported

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 and the "Resilience analysis" subsection, where this content is disclosed in the FY2025 report (pages 17, 43-44). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Basis (page 17). "The resilience of the strategy is ensured by risk management. Risks and opportunities are identified and quantitatively assessed as part of the risk inventory, which takes place twice a year."

Scope (page 43). The assessment "includes operations at the production sites as well as the hedging of input materials and impacts on the downstream value chain", drawing on the "Study on EU Taxonomy" prepared for the DNSH assessment.

Results (pages 43-44). "AMAG's business model, with its strategic focus on innovation and sustainability and its emphasis on risk management, has a robust foundation and strong resilience. This includes AMAG's assets, products and access to finance." Physical risks "such as extreme weather events were systematically identified".

Capacity to adjust (page 43). "Risk reduction and decarbonisation are defined as an investment category in the 'AMAG Investment Guidelines'."

Uncertainty (pages 8, 41). "Regulatory uncertainties are placing a noticeable strain on the entire aluminium industry", and the EUR 200-400 million investment figures hold only if "the general conditions assumed in the investment planning remain unchanged".

E1-4(was E1-2)Policies related to climate change mitigation and adaptation
Reported

Policies related to climate change mitigation and adaptation

Reference: pages 45-46 (ESRS index cites page 44).

"The reduction of air emissions, the commitment to decarbonisation, the increase in energy and resource efficiency... are set out in the corporate policy, which is substantiated by the environmental guidelines" (page 45).

Management systems (page 45). "The ISO 50001 and ISO 14001 certifications at the Ranshofen site are a key pillar in reducing the impacts and risks associated with climate protection." Responsibility sits with the Management Systems department.

Renewable electricity (page 46). "AMAG favours the use of renewable electricity without a nuclear component at all production sites."

Named instruments. The energy and environmental programme (page 45); the net energy footprint, "the central document of energy management and has been updated annually since 1957", in which Scope 1 emissions are calculated; an Energy Officer at Ranshofen; the EU ETS for AMAG casting and AMAG rolling, where "The annual emissions reports are verified by third parties"; and procurement rules routing projects into "risk reduction" or "decarbonisation" categories (page 46).

Adaptation (page 46). Around 45,000 m² of infiltration systems "have been installed to absorb large amounts of precipitation in a controlled manner and prevent flooding" (page 46).

E1-5(was E1-3)Actions and resources in relation to climate change policies
Reported

Actions and resources in relation to climate change policies

Reference: page 47 (ESRS index cites page 45); resources also page 41.

"The decarbonisation roadmap, first drawn up in 2021, will be updated regularly. The update will take into account changing technical and legal requirements as well as a current assessment of the total investment required."

Mitigation actions (page 47).

  • Energy efficiency. The homogenisation recipe project achieved "savings of 71,600 kWh (based on 2024)", with results "implemented in the production process from 2025 onwards".
  • Photovoltaics. "In 2024, the plant was doubled to around 123,000 m². This measure will increase annual energy production from 7.3 GWh to 13.3 GWh."
  • PPAs. "In addition to the existing AMAG green electricity contract, the purchase of electricity from renewable sources was secured by concluding PPA contracts for the purchase of energy from an Austrian hydropower plant and for the purchase of electricity from wind power plants in Lower Austria." Adaptation actions (page 47). "In 2025, a new infiltration basin with a surface area of approx. 1,400 m² was constructed in the foundry area"; "further infiltration areas totalling 270 m² were created and the former building yard covering an area of 1,700 m² was dismantled and unsealed." A blackout-focused crisis exercise was held in 2025. Action-level CapEx is not given; the aggregate Roadmap figure is EUR 200-400 million (page 41).
E1-6(was E1-4)Targets related to climate change mitigation and adaptation
Reported

Targets related to climate change mitigation and adaptation

Reference: page 48 (ESRS index cites page 46); programme overview page 26.

TargetHorizon202520242030 target
Scope 1+2 specific CO2, Ranshofen20300.162 t CO2e/t0.1630.163
Scope 1+2 absolute CO2, Ranshofen203090,500 t CO2e92,200110,000
Scope 3 specific CO2, primary aluminium upstream chain20307.4 t CO2e/t7.56.1
Renewable electricity, all sitesongoing100%100%100%

The headline target is a "Reduction of CO2 emissions by 30% (specific) or 20% (absolute) by 2030 (base year 2017) with the target of CO2-neutral production (net-zero) by 2050 for the Ranshofen site", plus a 20% cut in specific upstream primary-aluminium CO2 by 2030 against 2018-2020.

"The greenhouse gas reduction targets are gross targets. CO2 credits in the form of certificates are not part of the AMAG strategy."

Change in 2025. "The specific reduction target for 2030 was adjusted to take into account compliance with legal requirements and in line with the 1.5 °C target of the Paris Agreement."

Boundary. Scope 1 and 2 targets cover Ranshofen, "> 99% of total Scope 1 emissions". The Scope 3 target covers "around 30%" of total Scope 3.

Caveat. The base year is given as 2017 in the table but the narrative says "The base year for the reduction targets is set at 2018". No third-party target validation is reported.

E1-7(was E1-5)Energy consumption and mix
Reported

Energy consumption and mix

Reference: pages 49-51 (ESRS index cites page 47).

Energy consumption and mix, MWh (page 50):

Item20252024
Total energy consumption661,300677,300
Coal and coal products00
Crude oil and petroleum products9,80010,700
Natural gas420,100429,800
Other fossil (propane gas)80120
Total fossil430,000 (65%)440,600 (65%)
Nuclear0 (0%)0 (0%)
Purchased renewable electricity217,700229,700
Self-generated non-fuel renewable13,6007,000
Total renewable231,300 (35%)236,700 (35%)

Ranshofen accounts for 653,500 MWh (2024: 668,600) and AMAG components for 7,800 MWh (8,700), where the renewable share is 90% (86%).

Intensity (page 51). Total energy intensity 0.45 kWh/TEUR of turnover (2024: 0.47), because "AMAG's turnover is predominantly generated from activities related to climate-intensive sectors (NACE code 24.42)". Specific consumption at Ranshofen was 1,168 MWh/t on 559,000 t of production (2024: 1,180 MWh/t on 567,000 t), an entity-specific metric.

Method (page 49). Quantities are "calculated from the actual fuel quantities measured, multiplied by the respective conversion factors", using national inventory calorific values. "Energy in the form of renewable fuels (wood chips, biodiesel), cooling or steam energy is not purchased" and "AMAG does not purchase electricity from nuclear sources".

E1-8(was E1-6)Gross Scopes 1, 2, 3 and Total GHG emissions
Reported

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 51-54 (ESRS index cites page 50).

GHG emissions, t CO2e (page 53):

Item20252024
Scope 1 gross90,80092,500
Scope 2 location-based28,60040,400
Scope 2 market-based00
Scope 3 raw materials (in 3.1)939,9001,017,800
Other Scope 31,147,5001,109,100
Total Scope 32,087,4002,127,000
Total (Scope 2 market-based)2,178,2002,219,500
GHG intensity (market-based)0.00147 t CO2e/EUR0.00153

Scope 3 by category, t CO2 (page 54): 1 purchased goods 951,600 (2024: 1,029,200); 3 fuel/energy-related 20,900; 4 upstream transport 10,100; 5 waste 9,000; 9 downstream transport 19,200; 10 processing of sold products 516,800 (456,600); 11 use of sold products 38,600; 12 end-of-life 29,400; 15 investments 490,600 (505,600).

Method (pages 44, 51). "Due to the procurement of electricity from hydroelectric power and other renewable sources, no Scope 2 emissions according to the market-based method have been caused at the production sites since the 2018 reporting year for Ranshofen and from the 2022 reporting year for Karlsruhe and Übersee.""

Primary data (page 52). 50% for raw materials (2024: 42%), 46% of total emissions. 93% of Scope 1 sits within the EU ETS. A 2024 Scope 3 raw-material figure was restated from 964,400 to 972,600 t CO2e (page 12).

E1-9(was E1-7)GHG removals and GHG mitigation projects financed through carbon credits
Reported

GHG removals and GHG mitigation projects financed through carbon credits

Reference: page 54 (ESRS index cites page 53).

AMAG reports a nil return on both limbs.

Removals. "AMAG is not currently pursuing any projects for the extraction and storage of CO2 equivalents at the site or in the upstream or downstream supply chain" (page 54).

Carbon credits. "The purchase of CO2 credits in the form of certificates with the aim of CO2 reduction is not part of AMAG's business strategy, which focuses on technical solutions for CO2 reduction and substitution" (page 54).

This is consistent with the target disclosure - "The greenhouse gas reduction targets are gross targets. CO2 credits in the form of certificates are not part of the AMAG strategy and are not applied when meeting the targets" (page 48) - and with the Scope 1 method note that "AMAG rolling and casting plants are subject to European emissions trading (EU ETS), CO2 credits are not applied at AMAG" (page 51).

Readers are referred onward to the Climate Protection Transition Plan section (pages 41-43) for the technical abatement route AMAG relies on instead, which rests on recycling expertise, energy efficiency and fossil fuel substitution.

E1-10(was E1-8)Internal carbon pricing
Reported

Internal carbon pricing

Reference: page 54 (ESRS index cites page 53).

AMAG discloses that it operates no internal carbon pricing scheme, and explains why.

"Internal carbon pricing is fundamentally important for companies in order to incorporate climate-related risks into their strategy and promote investments in lower-emission technologies. AMAG is aware of its responsibility in the area of climate protection and is already pursuing a clear climate strategy with the implementation of the net zero target by 2050. The Decarbonisation Roadmap for the Ranshofen site takes into account technical feasibility, investment costs, changes in operating costs and, for example, plant depreciation and CO2 certificate costs. This means that even without internal CO2 pricing as an aid, the reduction path is clearly tracked and additional CO2 pricing as a tax instrument is not required" (page 54).

Exposure to an external carbon price is disclosed instead. AMAG casting GmbH and AMAG rolling GmbH are subject to the EU ETS, covering 93% of Scope 1 emissions (2024: 94%) (pages 46, 52), and from 2026 "CBAM will be expanded to include actual pricing. Companies in the EU will be charged additional taxes ('CO2 certificates') for purchasing imported aluminium, based on the CO2 price of the EU Emissions Trading System" (page 46). "Increased expenses from the procurement process for CO2 certificates and from CBAM" is carried as a material transition risk (page 39).

E1-11(was E1-9)Anticipated financial effects from material physical and transition risks and potential climate-related opportunities
Reported

Anticipated financial effects from material physical and transition risks and potential climate-related opportunities

Reference: page 54 (ESRS index cites page 53).

"In relation to the risks, there were no unexpected financial impacts in the 2025 reporting year. Potential financial impacts that may occur if risks materialise without preventive or mitigating measures (inherent risks) are recorded in risk management... and are currently classified as between low and severe (EUR 3 million to EUR 150 million)" (page 54).

That band sits inside the DMA's EBITDA scale, which runs "from a low materiality threshold of EUR 250,000 (up to EUR 3 million in the low range) to a very high financial impact of over EUR 150 million" (page 23).

Opportunities are not quantified. "Climate-related opportunities arise from AMAG's good market positioning as a company with a focus on recycling... Opportunities are not reported monetarily in AMAG's risk management" (page 54), consistent with "Opportunities are currently assessed qualitatively in risk management" (page 18).

What is not given. No monetary amount or share of assets at material physical risk by acute and chronic hazard, no share of net revenue from products incompatible with a climate-neutral economy, and no location disaggregation. The link between climate assumptions and the financial statements is cross-referred to the risk and opportunity report (page 45).

E2 – Pollution

E2-1Policies related to pollution
Reported

Policies related to pollution

Reference: pages 57-58 (ESRS index cites page 56).

"The reduction or avoidance of environmental impacts is defined as a central objective in the corporate policy, which is concretised in the environmental guidelines. The ISO 14001 and ISO 50001 certifications of the environmental and energy management system at the Ranshofen site are key pillars of the company's commitment to environmental protection. The ASI Performance Standard also defines principles and criteria for sustainability aspects in the area of the environment for the aluminium value chain" (page 57).

Chemicals legislation (page 57). "Compliance with legal requirements under chemicals legislation is integrated into the processes of operational environmental protection and occupational safety", covering REACH registration of metals in products, review of auxiliary and operating materials, "updates to the candidate list, Annex XIV and Annex XVII of the REACH Regulation and the passing on of information in the supply chain".

Responsibilities (page 58). Environmental officers at each site; an energy and environmental planning team of the Management Board, managing directors, environmental officer and plant managers meeting annually; an environmental management team, "the central committee of the environmental and energy management system at the Ranshofen site", meeting quarterly with minutes to the Management Board; and appointed REACH officers.

E2-2Actions and resources related to pollution
Reported

Actions and resources related to pollution

Reference: pages 58-60 (ESRS index cites page 57).

"The energy and environmental program summarises targets and measures for the avoidance and reduction of air emissions, effluents and waste as well as the reduction of energy and resource consumption" (page 58).

Landfills and contaminated sites (pages 58-59). "In 2024, two contaminated sites were identified in and around the Ranshofen site. The remediation project was launched in 2024 and a specialist company was commissioned to develop possible safety and remediation options, which will subsequently be agreed with the authorities."

Best available technology (page 59). The updated approval notices "ensure that AMAG Ranshofen fulfils the technical assessment criterion of the emission limits of the Delegated Regulation (EU) 2021/2139 on environmental objective 5". Air emissions are also cut "through the gradual substitution of fossil fuels at the plants as part of the implementation of the Decarbonisation Roadmap".

Supplier action (page 59). "All approved primary aluminium and rolling slab manufacturers of AMAG have also signed the ESG requirements for AMAG suppliers or are certified according to the ASI Performance Standard." New in 2025: copper was added to the Extended Minerals Reporting Template and AMAG "expanded the existing assessment for scrap and alloy metal suppliers for copper to include a supplier survey".

E2-3Targets related to pollution
Reported

Targets related to pollution

Reference: page 60 (ESRS index cites page 59); programme overview page 26.

TargetHorizon202520242026 target
No environmental incidentsannually ongoing200
No violations related to environmental pollutionannually ongoing000

The incident target is marked delayed; the violations target achieved.

2025 outcome (page 60). "In the reporting year 2025, there were no violations in connection with environmental pollution. There were two incidents that were classified as environmental incidents due to their direct impact on the environment (discharge into the receiving watercourse of a flowing watercourse)... One incident occurred during cleaning work. Crystalline citric acid residues were cleaned from a basin using service water and then mistakenly discharged into the rainwater sewer. The second incident was caused by a defective pipe/pump, which resulted in a leak of lye that subsequently entered a rainwater drain." "Technical and organisational remedial measures were taken for both incidents."

Supporting metric (page 60, outside the ESRS requirements). "At the Ranshofen site, 97% (2024: 98%) of employees complete training on correct behaviour in the event of environmental incidents via the ALEX training platform. Of this target group, 99% (2024: 85%) had completed the training by 31 December 2025."

E2-4Pollution of air, water and soil
Reported

Pollution of air, water and soil

Reference: page 61 (ESRS index cites page 60).

Air emissions, Ranshofen (page 61):

PollutantUnit20252024
Total nitrogen oxides at the siteNOx in t106.7118.4
Of which AMAG casting GmbHNOx in t95.2106.3
Specific NOxNOx in kg/t0.1910.209
Total carbon monoxideCO in t155.5186.9
Specific COCO in kg/t0.2780.330
Total dustDust in t2.02.5
Specific dustDust in kg/t0.00360.0044

All three pollutants fell year on year in absolute and specific terms.

Source (page 61). "The production of secondary aluminium via recycling generates process- and raw material-related air pollutant emissions such as carbon monoxide (CO), nitrogen oxides (NOx) and dust at the Ranshofen site. AMAG components at the Übersee and Karlsruhe sites does not make a significant contribution."

E-PRTR (page 61). Optimised process management and energetic use of organics in the smelting furnace "has led to an increase in nitrogen oxides in AMAG casting since 2021 and thus to a reporting obligation in accordance with the European Pollutant Release and Transfer Register (E-PRTR)... These values correspond to both the approved emission limits and the state of the art."

No emissions to water or soil are quantified in tonnes.

E2-5Substances of concern and substances of very high concern
Not Material
E2-6Anticipated financial effects from pollution-related impacts, risks and opportunities
Reported

Anticipated financial effects from pollution-related impacts, risks and opportunities

Reference: pages 57 and 60 (ESRS index cites pages 56 and 59).

"There were no unexpected financial effects in relation to the risks in the 2025 reporting year. Potential financial effects that may occur if risks materialise without preventive or mitigating measures (inherent state of risks) are recorded in risk management... and are currently classified as significant (EUR 10 to 50 million)" (page 57).

That is a narrower band than the equivalent E1-9 and E5-6 disclosures, which both use EUR 3 million to EUR 150 million (pages 54, 78), and it sits within the DMA's EBITDA scale (page 23).

The underlying risks (page 56). Four potential short-term risks: "Environmental damage, reputational damage and fines for non-compliance with limit values or environmental incidents"; the same for "discharging contaminated effluent into the public sewer system or the River Inn"; "Environmental damage, reputational damage, disposal costs and potential remediation costs in the event of soil contamination at the Ranshofen site"; and "Landfills - non-compliance with official requirements; emission of pollutants and damage to the landfill site".

Actual 2025 expenditure (page 60). "No separate operating and investment expenses were incurred as a result of environmental incidents and accidents. The funds required to implement the measures were financed from ongoing operations."

E4 – Biodiversity and Ecosystems

E4-1Transition plan on biodiversity and ecosystems
Not Material
E4-2Policies related to biodiversity and ecosystems
Reported

Policies related to biodiversity and ecosystems

Reference: pages 63-64 (ESRS index cites page 63).

"AMAG is dedicated to biodiversity, an important criterion of the ecological dimension of business, both for the site and along the supply chain" (page 63). Since 2018 Ranshofen has been certified to the ASI Performance Standard, whose eleven aspects include "biodiversity and ecosystem services".

Two policy levers (page 64).

  • Recycling. "Recycling and closing material cycles conserve primary raw materials, reducing pressure on natural ecosystems and counteracting biodiversity loss."
  • Supply chain. "The ESG requirements for AMAG suppliers explicitly call for the protection of existing ecosystems and the promotion of appropriate measures with regard to animal welfare, biodiversity and soil quality, as well as the prevention of harmful interventions both by the business activities of direct suppliers and by their suppliers."

Responsible procurement management (page 64). "The general purchasing process is regulated in the purchasing guidelines and in internal procedural instructions and aims to minimise purchasing-specific risks - e.g. significant dependencies - and to ensure responsible procurement management, including with regard to biodiversity."

Site anchoring (page 65). "Aspects such as minimising the impact on biodiversity and the sustainable promotion of biodiversity at the Ranshofen site are anchored in the environmental guidelines."

E4-3Actions and resources related to biodiversity and ecosystems
Reported

Actions and resources related to biodiversity and ecosystems

Reference: pages 64-65 (ESRS index cites page 63, as "Actions and resources related to biodiversity and ecosystems change").

Supply chain actions (page 64). "To ensure a sustainable supply chain and to avoid or minimise negative impacts on biodiversity and the ecosystem, key suppliers (including scrap metal, primary metal, rolled slabs, alloy metal and energy suppliers and service providers) are assessed." "By processing ASI-certified material, it is possible to label AMAG products as ASI-certified."

Site actions, disclosed outside the ESRS requirements (page 65). "AMAG has owned the forest area around the plant site in Ranshofen for more than 80 years", designated "as a welfare forest" under the forest development plan. A six-indicator ecological management concept covers deadwood, old wood islands, forest structure ("well-structured, uneven-aged, stable and climate-fit mixed forest stands"), forest edges, biotopes, and "Promotion of rare or endangered animal and plant species: introduction of rare tree species and creation of flower meadows on the company premises".

"BEE COLONIES: Ten bee colonies were established in the immediate vicinity of the Ranshofen factory site", managed with the Upper Austria-Salzburg Beekeeping Group.

E4-4Targets related to biodiversity and ecosystems
Not Material
E4-5Impact metrics related to biodiversity and ecosystems change
Not Material
E4-6Anticipated financial effects from biodiversity and ecosystem-related impacts, risks and opportunities
Not Material

E5 – Resource Use and Circular Economy

E5-1Policies related to resource use and circular economy
Reported

Policies related to resource use and circular economy

Reference: pages 68-70 (ESRS index cites page 67).

"Increasing resource and energy efficiency along the value chain is part of the corporate policy", and "The recycling strategy is an integral part of AMAG's business strategy" (page 68).

Recycling principle (page 68). "AMAG works according to the 'alloy-to-alloy' recycling principle. This means that - as far as possible - the recycled material should have the same or a very similar composition to the original material so that it can be used for its original purpose." At Ranshofen "75 to 80% scrap (including closed-loop scrap) is used on average across all products".

Named instruments (pages 68-69). The Recycling Center Ranshofen, "equipped with state-of-the-art technologies for metal assessment, separation and sorting", where "All incoming scrap deliveries at the Ranshofen site undergo a radioactivity test" and LIBS and XRT sensor sorting separates mixed scrap; purchasing guidelines, under which "Preference is generally given to suppliers whose management systems are certified in accordance with ISO 9001/14001/45001"; ASI membership with three procedural instructions and internal audits; and regional procurement, favouring local Innviertel suppliers.

Waste hierarchy (page 70). "The following approach applies at all locations: prevention BEFORE recycling BEFORE disposal. AMAG thus pursues the Zero Waste to Landfill goal."

E5-2Actions and resources related to resource use and circular economy
Reported

Actions and resources related to resource use and circular economy

Reference: pages 70-71 (ESRS index cites page 69).

Sourcing (pages 70-71). "AMAG Ranshofen purchases ASI-capable material, i.e. primary aluminium or rolling slabs, and ASI-capable scrap from its upstream suppliers. ASI-eligible scrap includes so-called 'post-consumer' scrap... (e.g. used rims, aluminium scrap from end-of-life vehicles, used aluminium packaging) and aluminium dross."

Closed loop (page 71). "In order to expand resource-conserving closed-loop relationships, talks are held on an ongoing basis and contracts are concluded with customers." "The production sites of AMAG components make a key contribution to closing the AMAG cycle by separating their machining residues, such as chips, by type."

Research projects (page 71). SMA²RT - "the energy consumption of smelting furnaces was reduced through the efficient use of scrap based on exhaust gas values". SCRAP - characterisation of scrap with organic adhesions, with the sampling furnace commissioned and connected. ART - "to introduce new material flows for recycling in order to expand the raw material base".

Product footprint (page 71). "Emissions from primary aluminium with the AMAG AL4® ever certificate are a maximum of 4 tonnes of CO2 per tonne of aluminium", versus a 14.4 t global average, "a saving in greenhouse gas emissions of more than 70 per cent", ISO 14067 verified by LRQA.

E5-3Targets related to resource use and circular economy
Reported

Targets related to resource use and circular economy

Reference: pages 72-73 (ESRS index cites page 72); programme overview page 27.

TargetHorizon202520242026 target
Recyclability and circularity of products at 100%ongoing100%100%100%
Scrap utilisation rate 75-80% of total foundry inputongoing77.6%76.0%75-80%
ASI-certified scrap share above 35%ongoing46%43%35%
100% recyclable packaging procuredongoing100%100%100%
Primary aluminium and rolled ingots from certified sustainable sources, >90% of volume2025>99%new>90%
Production-specific waste volume <16 kg/t, Ranshofen202516.8 kg/t18.5 kg/t<16 kg/t
Specific service water withdrawal limited to 6 m³/t, Ranshofen20254.8 m³/t5.1 m³/t6 m³/t

The waste target is the one marked delayed; the rest are marked achieved.

Rationale (page 73). "AMAG products can be directly recycled without any further pre-treatment steps." On waste: "The reduction target for waste volume in 2025 was not fully achieved, but the development shows a noticeable improvement compared to previous years and an overall positive trend."

Status (page 73). The targets "contribute to the operational implementation of AMAG's business strategy... and are voluntary". "In 2025, the first projects for sustainable and resource-efficient procurement and use of packaging materials were launched."

E5-4Resource inflows
Reported

Resource inflows

Reference: pages 73-74 (ESRS index cites page 73).

External procurement of raw materials, tonnes (page 74): external aluminium scrap 135,700 (2024: 130,700); primary aluminium 78,300 (81,600); rolling slab 51,300 (51,500); alloy metals 8,500 (8,500); semi-finished aluminium products 1,050 (3,590); titanium semi-finished products 40 (140); semi-finished steel products 10 (520); iron 2 (3). Total 274,900 t (2024: 276,600 t).

Packaging, tonnes (page 74): plastic 38 (40); wood 186 (172); paper 8 (7); packaging for components 33 (33). Total 269 t (256 t). "The proportion of organic materials in packaging is 72% (2024: 67%)."

Secondary content (page 74). "In the 2025 financial year, the scrap input (purchased external scrap and recycled scrap from our own production) amounted to around 296,700 tonnes (2024: 294,700 tonnes). This corresponds to an average scrap utilisation rate of 77.6% (2024: 76.0%) across all products."

Water (page 74). Specific industrial water withdrawal at Ranshofen 4.8 m³/t (2024: 5.1). Drinking water extraction 106,000 m³ (157,000 m³); industrial water production 3,056,000 m³ (3,263,000 m³), of which 2,708,000 m³ attributable to AMAG.

Suppliers (page 73). "The number of aluminium scrap suppliers is 167 (2024: 159). 16 main suppliers (2024: 16) cover 50% of the total scrap requirement."

E5-5Resource outflows
Reported

Resource outflows

Reference: pages 75-78 (ESRS index cites page 75).

Recyclability of products (page 75). "AMAG semi-finished aluminium products, cast alloys and components can be 100% recycled and are manufactured according to the basic principle of closed-loop orientation. Customers' production scrap, for example, can be recycled in a closed-loop approach. The technically recyclable proportion of AMAG products, including packaging, is 100%."

Durability and design (pages 68, 71). "In theory, aluminium is 100% recyclable without any loss of quality, which extends the useful life of the material." AMAG works to the "alloy-to-alloy" principle, and "In cooperation with customers, AMAG focuses on recycling-compatible alloys as well as taking back and recycling aluminium production waste in a closed loop."

Data collection (page 75). "At the AMAG Ranshofen site, centralised waste logistics and the digital recording of waste by type, quantity, origin and whereabouts is performed by AMAG service and the operating companies." "Since the 2024 financial year, AMAG no longer has any radioactive sources."

Reporting-date caveat (page 75). "The production-specific waste indicators excluding salt slag correspond to the status on the reporting date. The final metrics will be reported to the authority by the waste management team in good time and published with the 2026 Annual Report."

E5-6Anticipated financial effects from resource use and circular economy-related impacts, risks and opportunities
Reported

Anticipated financial effects from resource use and circular economy-related impacts, risks and opportunities

Reference: pages 68 and 78 (ESRS index cites pages 67 and 78).

"In relation to the risks, there were no unexpected financial impacts in the 2025 reporting year. Potential financial impacts that may occur if risks materialise without preventive or mitigating measures (inherent risks) are recorded in risk management... and are currently classified as low to existential threat (EUR 3 million to EUR 150 million)" (page 78).

Underlying risks (page 67). Eight potential risks: increased competition in the scrap market; lack of supply of raw materials, consumables and supplies; supplier default (counterparty risk, including "labour and production bans, IT cyber attack on suppliers, restrictions due to pandemic, non-compliance with ESG requirements"); raw material shortages and conflicts along the supply chain; "Insufficient scrap availability due to export of aluminium scrap and end-of-life vehicles"; "Possible changes to the water usage consensus"; failure of wastewater disposal at Ranshofen; and fines or remediation penalties "due to incorrect disposal".

Risk posture (page 68). "As a recycling company, AMAG does not face any increased risk in a business-as-usual scenario due to its business activities and procurement management."

No monetary amount of assets at risk, revenue-at-risk figure or quantified circular-economy CapEx is disclosed.

E5-5(was E5-5-Waste)Waste
Reported

Waste

Reference: pages 75-78; tables on pages 76-77.

Total waste, tonnes (page 76):

ItemTotal 2025Total 2024Ranshofen 2025Components 2025
Hazardous waste46,89045,51046,650240
Non-hazardous waste4,3704,7104,020340
Total51,25050,22050,680580
Non-recycled waste7,360 (14%)8,040 (16%)7,190 (14%)170 (29%)
Waste for recycling44,650 (87%)43,190 (86%)44,080580
Waste for disposal6,600 (13%)7,040 (14%)6,600<1
Specific waste volume (excl. salt slag)--16.8 kg/t-

Salt slag (page 75). "At 41,300 tonnes (2024: 39,000 tonnes), salt slag is AMAG's largest waste fraction and can be 100% recycled... The salt and aluminium recovered in this process can be returned to the recycling process... The recycled oxide residue is used, for example, in the cement industry."

Treatment (page 77). Of waste for recycling: preparation for reuse 130 t (2024: 140), recycling 43,890 (42,190), other recovery 760 (1,000). Of waste for disposal: incineration 0, landfill 12 (16), other disposal 6,450 (6,880), almost all hazardous.

Training (page 78, outside the ESRS requirements). 97% of Ranshofen employees are in the waste management training group and "100% had completed the training by 31 December 2025 (2024: 98%)".

S1 – Own Workforce

S1-1Policies related to own workforce
Reported

Policies related to own workforce

Reference: pages 85-86, 91, 95, 98, 101-103 (the ESRS index cites pages 85, 91, 95, 98 and 101 - one anchor per S1 sub-area).

Codes (page 86). "The AMAG Code of Conduct and the AMAG Code of Human Rights are also among the central principles of action... adopted by a resolution of the Management Board." The Code of Human Rights covers "the prohibition of child labour and any other form of forced or compulsory labour (modern slavery), protection against discrimination and a commitment to diversity and equal opportunities". Four key implementation documents are named on pages 101-102: Human Rights Code, Code of Conduct, Guideline on respectful behaviour and Data Protection Directive. A separate Modern Slavery Statement is published (page 102).

Occupational health and safety (page 91). "The processes and standards in the area of occupational safety are based on the requirements of the international occupational health and safety management standard ISO 45001, which are integrated into the existing management system and documented in a corresponding guideline. All employees (including temporary workers) are covered by this." Four pillars: workplace evaluation; incident/safety audit database; legal compliance; machine safety. Governance runs through the SILAS committee, "the highest supervisory body for occupational safety and health management", chaired by the Management Board, and the ASA occupational safety committee.

S1-2Processes for engaging with own workforce and workers' representatives about impacts
Reported

Processes for engaging with own workforce and workers' representatives about impacts

Reference: page 84 (ESRS index cites page 84).

Channels (page 84):

  • Works Council - "Employees are involved in identifying and understanding significant impacts, risks and opportunities through the Works Council and other points of contact, such as the Youth Council and the Women's Representative. The Works Council is the most important employee representative body within AMAG and ensures that the interests of employees are taken into account in relevant corporate policy decisions."
  • MAZEG - "There is also an annual employee target-setting and development dialogue (MAZEG), in which employees' perceptions, concerns and development potential are recorded." Participation exceeded 99% in 2025 (page 100).
  • AMAG Connect app - "Employees are regularly informed via the internal AMAG Connect app, where they can share feedback, suggestions and opinions."
  • AMAG Compliance Line - usable by employees and external stakeholders, "also anonymously", to report violations or suspected cases "or to contact a person of trust regarding personal concerns".
  • Public stakeholder survey on the AMAG website, accessible all year round.
  • Continuous improvement process (CIP) - "all employees can contribute specific expertise and practical experience and ideas... and help to recognise the relevance of certain topics and address them".
S1-2(was S1-3)Processes to remediate negative impacts and channels for own workforce to raise concerns
Reported

Processes to remediate negative impacts and channels for own workforce to raise concerns

Reference: pages 91-92, 95, 103 (ESRS index cites pages 91, 92 and 103); whistleblower system detail pages 118-119.

The AMAG Compliance Line (pages 118-119). Reports can be made online at https://hint.amag-al4u.com, by email to ethics@amag.at or by telephone. "Whistleblowers do not suffer any disadvantages as a result of reporting concerns or misconduct, and their identity is treated with absolute confidentiality." The internal Whistleblower System Guideline, owned by the Legal department, defines responsibilities and procedures for handling reports; where a report concerns a person in the internal reporting office, "the person concerned is excluded from processing the report". The system meets the Austrian Whistleblower Protection Act (HSchG) and EU Directive (EU) 2019/1937. "The effectiveness of the complaints procedure is reviewed once a year or on an ad hoc basis. In addition, the Management Board is informed at least once a year about the statistics of the reports received and any measures taken."

Remediation (pages 95, 103). "All reported suspicions or incidents are dealt with by the HR department and suitable remedial measures are taken in consultation with those affected to prevent, contain or end stressful situations" (page 95). "The HR department will take appropriate remedial action, agreed exclusively in consultation with the persons concerned" (page 103).

S1-3(was S1-4)Taking action on material impacts on own workforce
Reported

Taking action on material impacts on own workforce

Reference: pages 85, 87, 91-93, 96, 99, 103 (ESRS index cites pages 85, 87, 91, 92, 96, 99 and 103).

Occupational health and safety (pages 92-93). The 2025 occupational safety programme rests on four pillars, with workshops "under the motto 'We look out for each other'". Named measures include "the implementation of a dashboard that evaluates and displays the latest safety figures on a daily basis, and a safety concept for the implementation of hydrogen-powered melting and chamber furnaces"; the weekly "Safety Quarter Hour"; and the STOP principle, under which "new protective equipment was specified and a new concept for emergency showers was developed and implemented". Health promotion in 2025 included a "health week", free counselling with the occupational and health psychologist, and retention of the workplace health promotion seal of approval, "valid until 2026".

Diversity and equal opportunities (page 96). "Implementation of a guideline on respectful behaviour to prevent stressful incidents (discrimination, harassment, bullying, violence)" and "Stakeholder dialogue with the AMAG women's representatives". "TRAINING ON RESPECTFUL BEHAVIOR: ... since 2025, ALEX training on respectful behavior has been provided to all employees." 2025 measures to promote women include Girls' Day with the Braunau Training Centre, the Female Mentoring Programme, and a START scholarship.

S1-4(was S1-5)Targets related to own workforce
Reported

Targets related to own workforce

Reference: pages 88, 93, 96, 99, 104 (ESRS index cites those same pages); programme overview pages 28.

TargetHorizon202520242026/medium term
Fluctuation rate below 8%2025 and ongoing6.2%6.0%<8%
TRIFR accident rate to ≤1.0 under the "zero accidents" strategy2025 and ongoing1.41.9≤1.0
Female apprentice rate to 25%202723%22%25%
Women in senior management relative to the average overall proportion of women202712%11%16%
All employees trained on respectful behaviour and prevention of discriminatory acts2025 and ongoing90%new for 2025100%
Average of 2 days training and development per employee202525h27h-
MAZEG completion rate above 90%new>99%96%>90%
Compliance with basic human rights principles and no human rights violations (in particular discrimination, data protection violations)2025 and ongoing01 (data protection violation)0

The TRIFR target and the respectful-behaviour training target are marked on course; the female apprentice and women-in-management targets are marked delayed in the E-section programme table; the fluctuation, MAZEG, training-hours and human-rights targets are marked achieved (pages 28, 88, 93, 96, 99, 104).

S1-5(was S1-6)Characteristics of the undertaking's employees
Reported

Characteristics of the undertaking's employees

Reference: pages 88-89 (ESRS index cites pages 88 and 89).

Headcount at the key date (page 88):

CategoryAMAG total 2025AMAG total 2024Ranshofen 2025AMAG components 2025
Male employees1,7711,8421,552219
Female employees34435031430
Total employees2,1152,1921,866249
Permanent - total2,0902,1731,853237
Fixed-term - total25191312

Full-time, part-time and other (page 89): full-time 1,930 (2024: 2,014), of which male 1,708 and female 222; part-time 185 (178), of which male 63 and female 122; "Employees without guaranteed working hours" 1 (5) - "those with contract for services".

Turnover and tenure (page 89): resignations 172 (2024: 183), of which male 150 and female 22; entries 83 (2024: 203), of which male 65 and female 18; average length of service 12.1 years (2024: 11.4), 12.5 years at Ranshofen and 9.5 years at AMAG components. The fluctuation rate was 6.2% (2024: 6.0%) (page 88).

Gender recording method (page 84). "The gender of employees is recorded based on the information provided in official documents. The ERP system can be used to assign the categories 'female', 'male', 'diverse', 'inter', 'open' and 'not specified'. As no (temporary) employees provided any information other than 'female' or 'male' about gender, the other categories are not shown in the tables."

S1-6(was S1-7)Characteristics of non-employee workers
Reported

Characteristics of non-employee workers

Reference: page 89 (ESRS index cites page 89, under the heading "Characteristics of non-employee workers in the undertaking's own workforce").

Temporary (agency) workers at the key date (page 89):

CategoryAMAG total 2025AMAG total 2024Ranshofen 2025AMAG components 2025
Male62824
Female0100
Total62924

"Temporary employees are external workers employed by the company who are provided by transferor companies. AMAG has no employment contracts with self-employed persons" (page 89).

Contractual arrangement (page 84). "SCOPE OF WORKING CONDITIONS: The rights and obligations regarding working conditions, diversity and equal opportunities as well as human rights apply to the entire workforce, including all temporary workers. These are mainly deployed in production. The framework conditions for the provision of labour are regulated in the transfer agreement between AMAG and the transferor company. The temporary workers have an employment relationship with the transferor. However, supervision and management are the responsibility of the hiring company."

External contractors at Ranshofen are treated separately and receive training "on topics such as hazards, safety rules and human rights", with an ID card issued only after training (page 109).

S1-7(was S1-8)Collective bargaining coverage and social dialogue
Reported

Collective bargaining coverage and social dialogue

Reference: page 90 (ESRS index cites page 90).

Coverage (page 90):

MetricAMAG total 2025AMAG total 2024Ranshofen 2025AMAG components 2025
Employees covered by collective labour agreements88%88%99%0%
Employees represented by a works council93%93%100%39%

"The proportion of employees covered by collective bargaining agreements in Ranshofen is 99% (2024: 99%) - this does not include the respective Managing Directors and the Management Board, with whom individual contracts have been concluded. No collective labour agreements apply to employees at the AMAG components sites; remuneration is based on the standard industry pay in the federal states of Bavaria and Baden-Württemberg. In total, 88% (2024: 88%) of AMAG employees are covered by a collective labour agreement" (page 90).

"The employees in Ranshofen and Karlsruhe are represented in their interests by a works council, which corresponds to 93% (2024: 93%) of the AMAG workforce. There is no agreement on representation by a European Works Council" (page 90).

Social dialogue policy (page 87). "AMAG Austria Metall AG recognises the right of all employees to form employee representative bodies and to conduct collective bargaining... Employees are neither favoured nor disadvantaged on the basis of their membership or non-membership of a trade union."

S1-8(was S1-9)Diversity metrics
Reported

Diversity metrics

Reference: page 97 (ESRS index cites pages 96, 97 and 99).

Diversity indicators (page 97):

MetricAMAG total 2025AMAG total 2024Ranshofen 2025AMAG components 2025
Women in management positions12%11%10%22%
Female apprentices23%22%26%0%
Proportion of women, total16%16%17%12%
Industrial workers, total1,2111,3401,083128
Of which women4052400
Salaried employees, total816852707109
Of which women28429825430

Age distribution (page 97). Average age 40.0 years (2024: 39.4); under 30 years 19.4% (2024: 21.4%); between 30 and 50 years 59.9% (58.3%); over 50 years 20.8% (20.3%). At Ranshofen the average age is 39.6 and at AMAG components 43.3, where 32.9% of employees are over 50.

Nationality (pages 96-97). "In total, the AMAG workforce is made up of 41 nationalities (2024: 41). 64% come from Austria (2024: 63%), 27% from Germany (2024: 28%) and around 9% from other countries (2024: 9%)." "Around 74% of senior managers (i.e. people in the 1st management level below the Management Board) come from Austria (2024: 69%)." "AMAG employs people from 41 nations and thus promotes a cultural diversity that brings different perspectives, ways of thinking and problem-solving approaches to the company."

"The relatively low overall proportion of women in the company is due to its industrial structure" (page 97).

S1-9(was S1-10)Adequate wages
Reported

Adequate wages

Reference: page 86 (ESRS index cites page 86).

"AMAG guarantees fair pay that is at least equal to the statutory minimum wage applicable at the place of employment and constitutes adequate remuneration that ensures a decent standard of living, based on the principle of equal pay for work of equal value, regardless of gender" (page 86).

Reference values used (page 86).

  • Ranshofen, Austria: "The minimum wage defined in the collective agreement (01 November 2024 until 01 November 2025: EUR 2,518.43) serves as a reference value for appropriate remuneration of employees at the Ranshofen site." The source is footnoted as the framework collective agreement and salary scale for the non-ferrous metal industry association, "as of 4 December 2025".
  • AMAG components, Germany: "For employees at the AMAG components sites in Germany, the general statutory minimum wage applies as a reference value. The wage and salary agreements for AMAG components employees are based on the pay customary in the industry in Bavaria and Baden-Württemberg and comply with all requirements under German and EU law." The source is footnoted to the Institute of Economic and Social Sciences (2025), "Minimum wages in Germany at a glance", as of 4 December 2025.

AMAG states the position as a blanket guarantee rather than giving the percentage of employees paid below an applicable adequate-wage benchmark by country; on its own account no employees fall below it.

S1-10(was S1-11)Social protection
Reported

Social protection

Reference: page 86 (ESRS index cites page 86).

"All AMAG employees are covered by the state against loss of earnings (due to illness, unemployment, accidents at work, disability, parental leave and retirement) or by additional company pension programmes (health and retirement benefits). The pension scheme can be utilised from the age of 20 and the 3rd year of service" (page 86).

Supporting provisions.

  • Retention incentives include flexible working hours, established teleworking arrangements and "Additional benefits such as a company pension plan are also provided" (page 86).
  • Employees also hold an equity interest: "AMAG's employees participate in the company via the AMAG Arbeitnehmer Privatstiftung (AMAG Employees' Private Foundation). The private foundation holds 11.5% of the company's shares and enables employees to participate directly in AMAG's success" (page 87).
  • Family-related leave entitlements are set out under S1-15: "In accordance with the applicable collective agreements, all employees are entitled to leave for family reasons, such as care leave, special care periods or maternity or paternity leave" (page 87).
  • For employees unable to continue in their original role, AMAG "offers social workplaces within the company that enable employees to remain in the company in another suitable area of work", and partial reintegration at 50 to 75% of previous working hours after long sick leave (page 93).
S1-11(was S1-12)Persons with disabilities
Reported

Persons with disabilities

Reference: page 97 (ESRS index cites page 97).

"AMAG records the employment rate of people with disabilities in accordance with the Disability Employment Act (BeinstG). As of 31 December 2025, AMAG employed 2% of disabled people with disabilities (2024: 2%)" (page 97).

The figure is reported on a group basis and is stated as subject to legal reporting requirements rather than voluntary estimation, with the Austrian Disability Employment Act named as the recording basis. No breakdown by gender is given.

Workplace accommodation (page 96). "Employees with a physical disability are supported at AMAG through a targeted workplace evaluation. This evaluation includes analysing the workplace and working environment to ensure that they meet the individual needs of the person concerned. Ergonomic adjustments are made and technical aids such as height-adjustable desks are used. The aim is to identify and remove potential barriers in order to maximise employees' ability to work and their comfort. A regular review ensures that the workplace is designed in the best possible way, even as needs change."

AMAG does not report the figure separately for its Austrian and German sites, nor state whether legal restrictions on collecting such data apply in either jurisdiction.

S1-12(was S1-13)Training and skills development metrics
Reported

Training and skills development metrics

Reference: page 100 (ESRS index cites page 100).

Training hours (page 100):

MetricAMAG total 2025AMAG total 2024Ranshofen 2025AMAG components 2025
Hours per employee25272620
Hours per man26272623
Hours per woman2426263
Hours per industrial worker6858
Hours per salaried employee814118
Hours per apprentice434398460271
Total hours53,52658,60048,4515,075

Performance and development reviews (page 100):

MetricAMAG total 2025AMAG total 2024
MAZEG target group as share of all AMAG employees91%90%
Of the target group, finalised>99%96%
Finalised (count)1,9371,915
Of which men85%86%
Of which women15%14%

"The target group for the 'employee target-setting and development dialogue' (MAZEG) comprises 91% of AMAG employees. Excluded from this are apprentices, employees with reasons for absence (e.g. military/civilian service, maternity leave, parental leave) and employees who have been with the company for less than six months. Employee participation in the MAZEG was > 99% in the 2025 reporting year, including AMAG components" (page 100).

S1-13(was S1-14)Health and safety metrics
Reported

Health and safety metrics

Reference: pages 93-94 (ESRS index cites pages 93 and 94).

ESRS S1-14 metrics (page 94):

MetricAMAG total 2025AMAG total 2024Ranshofen 2025AMAG components 2025
Accidents at work (count)2333185
Of which employees2332185
Of which temporary employees0100
Days lost to work-related injuries/illnesses1,1931,2031,004189
Fatalities from work-related injuries/illnesses0000
Work-related illnesses0000
Employees covered by the OHS management system100%100%100%0%
Covered by ISO 4500188%88%100%0%

Injury rates (page 94). TRIFR per 1,000,000 hours: 6.8 total (2024: 9.3), 6.1 at Ranshofen, 11.7 at AMAG components. TRIFR per 200,000 hours, the company's own basis: 1.4 total (2024: 1.9).

Definition (page 93). "Accidents (per capita) with lost time injury (LTI) plus incidents requiring medical treatment... are measured in relation to the total number of productive hours, multiplied by 200,000 hours. Commuting accidents and accidents involving employees of external companies at the site are not included in the statistics."

Illness recording (page 94). Cases "include cases that were reported to the company, including by doctors or health authorities", plus cases identified in 2025 among former employees. "There were no such cases of work-related illnesses in 2025."

S1-14(was S1-15)Work-life balance metrics
Reported

Work-life balance metrics

Reference: page 90 (ESRS index cites page 90, under the heading "Work-life balance").

Leave of absence for family reasons (page 90):

MetricAMAG total 2025AMAG total 2024Ranshofen 2025AMAG components 2025
Employees entitled to take family-related leave100%100%100%100%
Employees that took family-related leave - total27%28%30%3%
Of those, men83%82%83%57%
Of those, women17%18%17%43%

"The following reasons were taken into account in the statistics: Nursing leave, special care leave, hospice/nursing leave, death, wedding, maternity leave, parental leave, paternity leave, birth, paternity month and parental leave days" (page 90).

Entitlement basis (page 87). "In accordance with the applicable collective agreements, all employees are entitled to leave for family reasons, such as care leave, special care periods or maternity or paternity leave."

"Compatibility of professional and private life" is a named sub-element of the material working-conditions sub-topic (page 80), and "Work-life balance" appears in the outside-in working-conditions list (page 82). Part-time employees numbered 185 in 2025, of whom 122 were women (page 89).

The metric reports the share of employees who took family-related leave rather than disaggregating take-up for each individual leave type, and the 100% entitlement figure covers both Austria and Germany.

S1-15(was S1-16)Compensation metrics (pay gap and total compensation)
Reported

Compensation metrics (pay gap and total compensation)

Reference: page 97 (ESRS index cites page 97).

Gender pay gap (page 97). "Gender-specific salary differences (gender pay gap): In 2025, the average basic salary for women was 98% (2024: 99%) of that for men. The calculation takes into account all employees including apprentices, blue-collar and white-collar workers, managers and the Management Board. The data is based on the local payroll systems of the Ranshofen site (Austria) and the Karlsruhe and Übersee am Chiemsee sites (Germany) and is calculated on the basis of the average basic salary (gross hourly earnings) of employees."

Expressed as a gap rather than a ratio, this is a 2% gap in 2025 (2024: 1%), on gross hourly basic earnings.

Total compensation ratio (page 97). "This key figure represents the ratio of the highest-paid individual to the median total annual compensation. The median is calculated based on all employees, excluding marginal employees, persons with interruptions in employment... and employees who joined or left the company during the year... The factor in 2025 was 19.8 (2024: 23.1)."

S1-16(was S1-17)Incidents, complaints and severe human rights impacts
Reported

Incidents, complaints and severe human rights impacts

Reference: page 104 (ESRS index cites page 104).

Metrics (page 104):

MetricAMAG total 2025AMAG total 2024Ranshofen 2025
Cases of discrimination, including harassment101
Complaints of discrimination, including harassment000
Significant fines, sanctions and compensation payments for discrimination and harassmentEUR 0EUR 0EUR 0
Serious incidents relating to human rights in the workforce (child labour, forced labour, forms of modern slavery)000
Significant fines, sanctions and compensation payments for other serious human rights violations in the workforceEUR 0EUR 0EUR 0

Narrative outcome (page 104). "In the 2025 reporting period, there were two relevant reports in the area of data protection and one regarding discrimination/harassment (for the latter, see the following table of key figures). After reviewing the reports, the responsible departments found no violations. Furthermore, AMAG is not aware of any incidents relevant to human rights."

Comparison with 2024. The human rights target table shows 2024 performance as "1 (Data protection violation)" against a target of zero, with the 2025 result zero and the target marked achieved (pages 28, 104). The programme footnote for 2024 reads "Compliance breach against data protection: Incident has been rectified and measures taken" (page 28).

S2 – Workers in the Value Chain

S2-1Policies related to value chain workers
Reported

Policies related to value chain workers

Reference: page 107 (ESRS index cites page 107); human rights framework pages 101-102.

Due diligence anchoring (page 107). "In addition to the laws and standards set out in S1, the company takes into account the requirements of the German Supply Chain Due Diligence Act in its supply chain management." The six-step human rights due diligence process described in S1 "are applied to both the production sites and the supply chain".

Key documents (page 107). The ESG requirements for suppliers, a supplier code covering business management, human rights, occupational safety and environmental protection, integrated into the General Terms and Conditions of Purchase; and:

  • "Responsible procurement management" procedural instruction. "A systematic approach is pursued along the supply chain in order to avoid or remedy human rights violations and negative impacts on the environment as far as possible." Purchasing departments check all major new and existing suppliers (scrap, primary metals, rolling slabs, alloy metals, dross, alumina and energy) "for compliance with human rights on a risk-based basis", across four areas: the ESG requirements, the material origin risk, certifications, and key issues including origin of goods and ESG reporting. "Depending on the level of risk identified, the respective supplier must be reassessed every one to three years."
S2-2Processes for engaging with value chain workers about impacts
Reported

Processes for engaging with value chain workers about impacts

Reference: page 107 (ESRS index cites page 107).

"In order to be able to recognise and take into account the interests and needs of the workforce along the value chain, an exchange takes place at various levels" (page 107). Four named routes:

  • Direct communication with suppliers. "AMAG maintains ongoing communication with suppliers. The aim is to identify potential challenges at an early stage and develop solutions together."
  • Audits and on-site visits. "The company regularly carries out audits and visits to its suppliers, gaining an insight on site."
  • Reporting channels. "With the Compliance Line, which is publicly accessible via the company website, AMAG provides a reporting and complaints mechanism for all stakeholders. Any grievances in the supply chain can be reported here."
  • Exchange with organisations and associations, through which "AMAG gains additional insight into potentially relevant issues (including working conditions for employees) in the supply chain".

Preventive stance where direct insight is limited (page 108). "As the supply chain in aluminium production is geographically widely ramified and raw materials are sometimes extracted in critical areas or countries and the handling is not directly within the company's sphere of influence, AMAG pursues a preventive approach here and defines a potential risk for all central human rights in the supply chain."

S2-2(was S2-3)Processes to remediate negative impacts and channels for value chain workers to raise concerns
Reported

Processes to remediate negative impacts and channels for value chain workers to raise concerns

Reference: pages 109-110 (ESRS index cites page 109).

"ENABLING EXCHANGE AND REDRESS (ESRS S2-3): The possibility of reporting concerns to AMAG via the Compliance Line is also described in the ESG requirements and thus actively communicated to suppliers. In addition, the Compliance Line and other AMAG contacts are accessible to all stakeholders via the website" (page 109).

Remediation route (page 109). "If negative impacts on labour in the supply chain are reported to the company, the legal department examines the situation and involves relevant specialist departments in order to take appropriate remedial measures within their sphere of influence."

Channel details (pages 118-119). Reports can be submitted at https://hint.amag-al4u.com, by email to ethics@amag.at or by telephone. The system "is available to employees and business partners as well as the public", and "Whistleblowers do not suffer any disadvantages as a result of reporting concerns or misconduct". "The effectiveness of the complaints procedure is reviewed once a year or on an ad hoc basis" (page 119).

Outcome in 2025 (page 110). "In 2025, AMAG was not aware of any violations of human rights in the supply chain." AMAG does not report whether value chain workers are aware of, or trust, the Compliance Line.

S2-3(was S2-4)Taking action on material impacts on value chain workers
Reported

Taking action on material impacts on value chain workers

Reference: page 109 (ESRS index cites page 109); risk handling also page 109.

Actions taken in 2025 (page 109):

  • "Ongoing preparations and reviews of internal procedures with regard to the EU Corporate Sustainability Due Diligence Directive (CSDDD)"
  • "Regular evaluation of procurement management and revision of key documents and procedural instructions (e.g. Code of Conduct, Human Rights Code, ESG requirements for suppliers)"
  • "Regular implementation of supplier audits"
  • "Participation in webinars and online programmes on supply chain topics"

Where a dependency is admitted (page 109). "Alloy metals, including manganese, magnesium, and silicon, which are necessary for the production of semi-finished aluminum products, must be sourced from regions with potentially elevated (e.g., China) or high risk due to global raw material availability and AMAG's volume requirements. Since certain alloy metals are only available in very small quantities outside these regions, the company is currently unable to source these raw materials from other sources. The share of quantities delivered from countries or regions with potentially increased or high risk amounts to less than 2% of the total delivery volume of raw materials in 2025."

Resources (page 109). "The implementation of the measures did not require any separate financial expenditure in 2025."

S2-4(was S2-5)Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities
Reported

Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

Reference: page 110 (ESRS index cites page 110); programme overview page 29.

TargetHorizon202520242026/medium term
Compliance with basic human rights principles in the supply chain and no violations2025 and ongoing000

The target is marked achieved: "In 2025, AMAG was not aware of any violations of human rights in the supply chain" (page 110).

What the target commits suppliers to (page 110, footnote 13). "AMAG expects all business partners to actively support the company in fulfilling this responsibility by communicating AMAG's ESG requirements (Revision 01, March 2023) or at least equivalent requirements to their employees... and ensure compliance with ESG requirements along their supply chain to the extent possible."

Supporting outcome metrics (page 125). "A total of 292 key suppliers in the upstream chain (alloy metals, scrap, primary aluminium and rolling slabs) have been identified as part of responsible procurement management. In 2025, no materials were sourced from high-risk suppliers. Over 95% of the total procurement volume (2024: > 95%) came from low-risk suppliers."

G1 – Business Conduct

G1-1Business conduct policies and corporate culture
Reported

Business conduct policies and corporate culture

Reference: pages 116-119, 126 (ESRS index cites pages 116, 117, 118 and 126).

Corporate culture (page 116). "Acting with integrity towards all stakeholders... and fair competition are of the utmost importance to the company... Undue influence by employees, suppliers and customers, for example in the form of corruption, bribery or unfair competition, is contrary to this conviction and will not be tolerated."

Compliance system (page 118). "The primary aim of the compliance system is to prevent violations." Cornerstones: systematic risk analysis; a compliance programme; a compliance organisation defining monitoring responsibilities; "training & communication for dialogue with risk owners"; the AMAG Compliance Line; and monitoring "to adapt, control and review the adequacy and efficiency of the compliance system". "Relevant compliance issues are regularly reported to the Management Board by the Compliance Committee. The latter in turn informs the Supervisory Board."

Compliance training (page 126):

TrainingAddressees as share of employees 2025Completed in period 2025Addressees 2024Completed 2024
Corruption prevention15%99%13%95%
Issuer compliance11%98%9%43%
Data protection97%79%71%78%
Code of Conduct100%96%100%90%
Human rights4%98%5%97%
G1-2Management of relationships with suppliers
Reported

Management of relationships with suppliers

Reference: page 122 (ESRS index cites page 122); supplier assessment mechanics page 107; results page 125.

"AMAG defines acting as responsibly as possible in procurement as an essential component of sustainable corporate management... Ecological and social aspects are considered in purchasing decisions, as are price, quality, reliability and flexibility. A binding purchasing guideline for auxiliary and operating materials, capital goods, services and energy defines the central purchasing principles and procedures" (page 122).

ESG conditionality (page 122). "AMAG attaches great importance to suppliers and their subcontractors adhering to the same high ESG standards as AMAG. In addition to fair, transparent business conduct (including anti-corruption) and the promotion of human, labour and social rights, the ESG requirements also include environmental protection and the promotion of ecological diversity... If a supplier is not prepared to support and pass on these ESG standards, AMAG may terminate the business relationship in extreme cases. If the ESG standards are not confirmed from the outset and no equivalent own documents are submitted, no contract is concluded with the supplier."

"The AMAG components sites are independently responsible for procurement management and conduct regular supplier audits" (page 122).

G1-2(was G1-3)Prevention and detection of corruption and bribery
Reported

Prevention and detection of corruption and bribery

Reference: pages 119, 126 (ESRS index cites pages 119 and 126).

"CORRUPTION PREVENTION (ESRS G1-3): In addition to the Code of Conduct, the guideline on the prevention of corruption sets out detailed definitions, behaviours and reporting obligations that are intended to guide and support AMAG employees in acting in a morally and legally correct manner. The aim and purpose of this guideline is to prevent damage arising from the inappropriate granting or acceptance of any benefits. The policy defines clear conditions and limits for gifts and invitations. The policy is available to all employees via the internal platform ALEX" (page 119).

Target group and training (page 119). "A defined group of addressees, which includes the Management Board, the management of all AMAG companies and, in other relevant areas, the management level and, in some cases, all employees in a department, undergo corruption prevention training in addition to annual confirmation of the policy."

Training metrics (page 126). Corruption prevention training addressees were 15% of AMAG employees in 2025 (2024: 13%), of whom 99% completed the training (2024: 95%). Corruption prevention is also "enshrined in the Code of Conduct and receive[s] correspondingly broad training (100% of employees)"; Code of Conduct training reached 96% completion in 2025 (2024: 90%).

G1-3(part of MDR-T/GDR-T disclosures)Targets related to business conduct
Reported

Targets related to business conduct

Back-filled from the business conduct chapter, where targets are addressed as part of the MDR-T/GDR-T disclosures rather than as a numbered disclosure requirement. G1-3 became a standalone DR only in the 2025/2026 ESRS; under the 2023 ESRS that AMAG applied, G1-3 was "Prevention and detection of corruption and bribery".

AMAG does set measurable business conduct targets, reported under "TARGETS AND PERFORMANCE (ESRS G1-4, G1-5)" on page 124 and in the programme on page 29.

TargetHorizon202520242026/medium term
Continuous further development of the compliance system, taking into account current legal developments and regulatory requirements2025 and ongoing"See strategies, concepts and measures"--
No compliance violations2025 and ongoing010

Both are marked achieved (pages 29, 124). Effectiveness is also tracked through compliance training completion: corruption prevention 99%, issuer compliance 98%, data protection 79%, Code of Conduct 96%, human rights 98% (page 126).

Scope of the zero-violation target (page 124). "AMAG's definition of compliance violations covers the following areas: Corruption and bribery (including undue influence on stakeholders, financial contributions or contributions in kind to political institutions); Antitrust and monopoly law; Issuer compliance; Tariff and foreign trade law; Human rights; Data protection."

G1-4Incidents of corruption or bribery
Reported

Incidents of corruption or bribery

Reference: page 124 (ESRS index cites page 124, under the heading "Confirmed incidents of corruption and bribery").

AMAG reports a nil return. Against its target of "No compliance violations", performance for 2025 is recorded as 0 (2024: 1), and the target is marked achieved (page 124).

"In the 2025 reporting period, there were two relevant reports in data protection and one regarding discrimination/harassment... After reviewing the reports, the responsible departments found no violations. Likewise, there were no violations or proceedings in the other compliance areas defined above" (page 124). Those areas expressly include "Corruption and bribery (including undue influence on stakeholders, financial contributions or contributions in kind to political institutions)", antitrust law, issuer compliance and foreign trade law. So for 2025 there were no confirmed incidents, convictions, fines or proceedings.

Political contributions (page 120). "Neither payments nor benefits in kind to political institutions are tolerated - such conduct is considered a violation of AMAG's compliance principles... Accordingly, no financial contributions or benefits in kind were made for the purpose of political influence in 2025."

G1-5Political influence and lobbying activities
Reported

Political influence and lobbying activities

Reference: pages 117, 120-121, 124 (ESRS index cites pages 117, 120 and 124).

"PARTICIPATION IN POLITICAL DISCOURSE & MEMBERSHIP IN ASSOCIATIONS (ESRS G1-5): AMAG Austria Metall AG actively participates in political discourse to incorporate the perspective of companies in decision-making processes in an appropriate and transparent manner at all times" (page 120).

Main topics (page 120). "AMAG's activities and positions generally focus on issues related to energy, climate and the environment, research and development, recycling and the circular economy."

Transparency register (page 120). "AMAG service GmbH has been listed in the EU Transparency Register since 2025 under registration number 269478898921-08."

Financial contributions (page 120). "In dealings with authorities, companies, public officials and politicians, any kind of undue influence (benefits, leverage) is strictly prohibited. Neither payments nor benefits in kind to political institutions are tolerated... Accordingly, no financial contributions or benefits in kind were made for the purpose of political influence in 2025."

Revolving door datapoint (page 120). "None of the Supervisory Board members, Management Board members or members of the management who assumed one of these positions in the 2025 reporting year held a comparable position in the public sector in the previous two years."

G1-6Payment practices
Not Material