Heidelberg Materials

Sustainability strategy and accountability
HeidelbergCement discloses its process for identifying and prioritising its most relevant sustainability impacts as well as the outcome of this process, in relation to its sustainability strategy. The company reports consistently against all its set targets.

Water
HeidelbergCement has a commitment to respect the right to water. The company requires access to water and sanitation, including refraining from negatively affecting access to safe water, to be included in contractual arrangements with its business relationships.

Solid and air pollution
HeidelbergCement has reported that by 2030, it will reduce cement production-related SOx and NOx emissions by 40% and dust by 80% compared with 2008.The company reports regularly against these targets.

Invasive species
HeidelbergCement identifies the activities that could lead to the introduction of invasive species in its own operations.

Indigenous Peoples’ and land rights
HeidelbergCement is committed to respecting Indigenous Peoples’ rights.

Sustainability strategy and accountability
The company does not disclose group-wide targets on key sustainability topics for the most material parts of its value chain. The company reports that two thirds of the overall target achievement for the annual bonus is measured by company targets (Group share of profit and CO2 component) and one third by individual targets. However, no evidence as to what counts as ESG targets could be found. The company does not disclose whether its highest governance body has expertise regarding nature-related topics.

Stakeholder engagement
The company does not sufficiently disclose the issues raised through stakeholder engagement. The company does not disclose its process for engaging with stakeholder groups beyond its materiality assessment.

Lobbying
The company discloses a limited list of trade associations of which it is a member. It should however provide a more comprehensive list. The company discloses a framework for assessing alignment of its trade associations with nature-positive policies. It should however disclose a clearer and more detailed framework. While the company reports some misalignments between the lobbying activities of its trade associations and nature-positive policies, it only applies the framework on a limited selection of 13 key associations.

Impact and dependencies assessment
The company has reported they regularly use the Integrated Biodiversity Assessment Tool (IBAT) to assess the potential implications of new regulatory developments. However, the usage of this tool is focused on assessing potential implications of new regulatory developments and not for assessing its impacts on nature, including biodiversity, within its own operations. Further, no evidence that they disclose the results after using the IBAT could be found in the public domain. The company does not disclose any assessment of its impacts on nature, including biodiversity, in its supply chain. The company does not disclose any assessment of its dependencies on nature within its own operations. The company does not disclose any assessment of dependencies on nature of its upstream business relationships.

Key areas and species
The company has reported that they do not disclose details of all their extraction sites that are in or adjacent to areas important to biodiversity due to the large number of extraction sites involved. The company does not disclose the locations of its suppliers that are in or adjacent to areas important for biodiversity. The company does not disclose species populations existing in or adjacent to its own locations. The company does not disclose species populations existing in or adjacent to the locations of its suppliers. The company does not disclose the status according to national and international conservation lists of species identified in its own locations.

Ecosystem conversion and restoration
The company does not disclose a commitment to ensure zero conversion. The company does not disclose activities to achieve conversion-free supply chains. The company does not disclose time-bound targets to achieve conversion-free supply chains. The company does not disclose a commitment to minimise ecosystem conversion. The company does not disclose activities to minimise ecosystem conversion. The company does not disclose a commitment to restore ecosystems. The company has reported that they do not report the details of each protected or restored habitat, as this is not possible given the large number.

Resource exploitation and circularity
The company has reported that they do not report on the weight or volume of the materials used. They further report that this information is relevant to competition and subject to confidentiality.  The company does not report quantitatively on its group-wide circularity performance. The company does not disclose activities to improve soil health or agrobiodiversity in its production or sourcing practices. The company does not disclose a target to improve soil health in its production or sourcing practices.

Water
The company has reported an increase in water withdrawal (million m3) from its cement operations from 60. 2 in 2020 to 60.3 in 2021. While the company has reported some targets to reduce water consumption, it does not report baseline year for any of these targets. The company reports how much water is withdrawn for its own operations in water-stressed areas. The company does not engage with suppliers to reduce water withdrawal. The company does not provide adequate qualitative evidence of reducing water quality pressures. The company does not disclose its processes for managing and monitoring discharge water quality. The company does not regularly report on water pollution. The company does not disclose targets to reduce water pollution. The company does not disclose its processes for implementing preventive and corrective action plans for identified specific risks to the right to water and sanitation in its own operations.

Solid and air pollution
The company only reports the hazardous waste it has produced in 2021. Therefore, it cannot be determined whether they reduced the production of hazardous waste.  No evidence that the company reduces plastic use and waste in its own operations was found. The company does not report on the amount of plastic waste generated and proportions directed from or to disposal. The company reports regularly on air quality parameters of emissions of harmful air pollutants.

GHG emissions
The company has reported an increase in its scope 1 and 2 emissions from 2020 to 2021. The company has a time-bound target to reduce its scope 1 and 2 emissions. The company does not report progress against its scope 1 and 2 emissions target. No evidence that the company’s scope 1 and 2 emissions target is aligned with a 1.5-degree trajectory was found. The company is reducing its scope 3 emissions. The company does not disclose a time-bound target to reduce its scope 3 emissions.  The company does not report progress against its scope 3 emissions target. No evidence that the company’s scope 3 emissions target is aligned with a 1.5-degree trajectory was found.

Invasive species
No evidence was found that the company identifies the activities that could lead to the introduction of invasive species in its value chain.

Safe, clean, healthy and sustainable environment
The company does not disclose a commitment to respecting local communities’ right to a safe, clean, healthy and sustainable environment. No evidence that the company tracks its actual or potential negative impacts on the health of local communities was found. The company is not committed to zero tolerance for acts of violence, threats, intimidation or judicial harassment committed against land and environmental rights defenders.

Indigenous Peoples’ and land rights
The company does not disclose its processes for identifying and recognising the rights of Indigenous Peoples when activities in its own operations may impact their rights, nor does it describe how it obtains Indigenous Peoples’ free, prior and informed consent. The company does not disclose a commitment to respect ownership and use of land and natural resources and related legitimate tenure rights, as set out in the relevant part(s) of the VGGTs or the IFC Performance Standards. The company in its Supplier Code of Conduct states that “The supplier shall respect any applicable local, national and international land, water and resource rights. Unlawful forced evictions are not permitted.” However, this is not sufficient to translate into evidence that the company requires its business relationships to have a process to identify legitimate tenure rights holders.

The company describes the process for identifying its human rights risks and impacts in specific locations or activities covering its own operations. The company describes the process for identifying human rights risks and impacts in its business relationships.  The company states that it carries out risk assessments on the topic of human rights in its country organizations, however, it does not describe its process for assessing its human rights risks and discloses what it considers to be its salient human rights issues. This description includes how relevant factors are taken into account, such as geographical, economic, social, and other factors. The company states that it takes mitigation measures that may include guidelines, training, process controls, etc, however, there is no evidence the company discloses what it considers to be its salient human rights risks. Therefore, it has an opportunity to disclose what it considers to be its salient human rights risks and thereafter describe the global system in place to act on, prevent or mitigate its salient human rights issues.  No evidence that the company provides an example of the conclusions reached and actions taken or to be taken on at least one of its salient human rights issues as a result of assessment processes was found.  While the company discloses the categories of stakeholders it engages with generally on sustainability issues, it is not clear if these stakeholders are those whose human rights have been or may be affected by its activities. No evidence that the company provides examples of its engagement with stakeholders whose human rights have been or may be affected by its activities was found.

The company has a publicly available policy statement which shows it is committed to respecting the health and safety of workers. The company has a publicly available policy statement which shows it expects its suppliers to commit to respecting the health and safety of their workers. No evidence that the company discloses a time-bound target for paying all workers a living wage or that it has achieved paying all workers a living wage was found. No evidence that the company describes how it determines a living wage for the regions where it operates was found. The company discloses that its compensation and benefits shall comply with fundamental principles relating to minimum wages. However, it does not disclose if the minimum wage is enough to maintain a decent standard of living for employees of its business relationships and their family. Also, it does not disclose how it works to support the payment of a living wage through its business relationships. No evidence that the company discloses the proportion of its total direct operations workforce covered by collective bargaining agreements was found. While the company states that its suppliers shall respect employees’ right to freedom of association and the right to collective bargaining, it has an opportunity to describe how it works to support the practices of its suppliers in relation to those.

The company discloses a global tax strategy. The company takes steps to identify and address bribery and corruption.  The company requires its suppliers to comply with its supplier’s code of conduct, any violation of which will result in the termination of contracts; however, it does not specifically require its suppliers to prohibit corruption and bribery. No evidence that the company has a publicly available policy statement or policy setting out its lobbying and political engagement approach was found. No evidence that the company has a publicly available policy statement that specifies that it does not make political contributions was found.