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Cembre Environmental & Social Information 2021

Mar 30, 2021

4425_sr_2021-03-30_06980e2c-39d6-4c10-81af-91e0e42e9398.pdf

Environmental & Social Information

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SUSTAINABILITY REPORT 2020

NON-FINANCIAL STATEMENT 2020 IN ACCORDANCE WITH ITALIAN LEGISLATIVE DECREE 254/2016

S CEMBRE

Contents

LETTER TO STAKEHOLDERS
THE CORPORATE IDENTITY AND GROUP PROFILE 5
MAIN TYPES OF RISK 14
MATERIALITY ANALYSIS AND STAKEHOLDER ENGAGEMENT 17
MANAGEMENT OF ENVIRONMENTAL MATTERS 22
Risks and opportunities 22
The policies applied by the CEMBRE Group 23
Non-financial performance 25
MANAGEMENT OF SOCIAL AND STAFF-RELATED MATTERS 32
Risks and opportunities 32
The policies applied by the CEMBRE Group 33
Product labelling 43
HEALTH AND SAFETY MANAGEMENT 44
Risks and opportunities 44
The policies applied by the CEMBRE Group 45
Non-financial performance 46
MANAGEMENT OF THE FIGHT AGAINST CORRUPTION 40
Risks and opportunities 49
The policies applied by the CEMBRE Group 49
Non-financial performance 51
SUPPLY CHAIN MANAGEMENT 52
Risks and opportunities 52
The policies applied by the CEMBRE Group 52
Non-financial performance 54
MANAGEMENT OF LEGAL AND FISCAL MATTERS 55
Risks and opportunities 55
The policies applied by the CEMBRE Group 55
Non-financial performance 56
METHODOLOGICAL NOTE 57

Letter to Stakeholders

Dear Stakeholders,

As Chairman and CEO of Cembre Spa, I am pleased to present to you our 2020 Consolidated Non-Financial Declaration, a document through which the Company reports on its commitment to social responsibility and sustainability.

Since its inception, Cembre has operated with passion and determination according to deeply-rooted values and principles while respecting the environment and people.

The Group has always paid great attention to constant dialogue with its stakeholders and the environment in which it operates on the issues deemed most relevant in sustainability.

Cembre's success, in over 50 years of activity, has been made possible thanks to the constant contribution of its stakeholders, who have cooperated constructively in the development of new ideas, projects, and increasingly innovative products.

Cembre intends to strengthen and consolidate over time its collaboration with its stakeholders because we believe that this will lead us to increasingly important and challenging objectives.

The company's activities are inspired by the ethical principles of legality, honesty, transparency, impartiality, and respect, which are at the foundation of the company's culture and reaffirmed with conviction in the Group's Code of Ethics.

Our culture is geared towards technological innovation, product quality, and reliability, with a flexible structure able to anticipate market developments and beffer interpret new needs.

Technological acceleration, climate change, and awareness of human resources' importance are among the main elements characterising the change taking place in our society.

We are living through a transition made even more complex and dramatic by the recent spread of the coronavirus (Covid-19) pandemic that is affecting the entire world.

In response to this emergency, we have acted promptly and decisively in all geographical areas of our Group to minimise our employees' infection risk and, at the same time, ensure the continuity of supply of our products in all Cembre's countries of operation.

The current materiality matrix, valid for the three years 2020-2022, expresses the commitment of the Cembre Group to consciously reduce the negative impact that all of the Company's activities may have on the environment and society, enhancing instead all the positive aspects that a company may guarantee to the social fabric in which it is rooted.

In 2020, Cembre also confirmed its commitment to developing several projects and initiatives supporting local communities in priority areas, such as respect for the

L

CEMBRE

environment, promotion and protection of the most disadvantaged, development of education and training, art, culture, and sports.

Cembre chose to appoint a Sustainability Manager to improve its ability to manage the broad issue of sustainability and to spread the culture of social, environmental, and economic responsibility in all the Group's locations.

Cembre intends to make sustainability one of the critical elements of its action to face new challenges successfully and create, together with our stakeholders, its new business model capable of focusing on innovation and circularity, developing a virtuous synergy between values, economy, and productive development, convinced that this is the way to create new and vital opportunities for growth.

The corporate identity and Group profile

Founded in 1969 in Brescia, CEMBRE is a European leader in the manufacture of compression connectors and related installation tools with a ten-year history of successes and growth.

  • 1969 CEMBRE (acronym for Costruzioni Elettro-Meccaniche BREsciane [Electro-MechanicalConstructions of Brescia]) is founded in Brescia.
  • 1977 Production is moved to the current office in via Serenissima, Brescia
  • 1986 CEMBRE Ltd. is established in Coleshill, Birmingham, UK.
  • 1988 CEMBRE S.a.r.l. is established in Bagneaux, Paris.
  • 1990 The CEMBRE S.p.A Quality Management System is certified by LRQA according to ISO 9000:2008 standard.
  • 1994 Establishment of CEMBRE España SL in Madrid, Spain.
  • 1995 Establishment of CEMBRE AS in Stokke, Norway.
  • 1997 CEMBRE GmbH is established in Munich, Germany. CEMBRE S.p.A. is listed on the Milan Stock Exchange.
  • 1999 OELMA s.r.l. is purchased, a company specialised in the production of cable glands and electrical materials in general. CEMBRE Inc. is established in Edison, New Jersey, USA.
  • 2001 CEMBRE S.p.A. enters the STAR segment of the Italian Stock Exchange MTA.
  • 2002 Establishment of General Marking s.r.l. and acquisition of a company specialised in the production of row markers and electrical components.
  • 2008 Certification of the CEMBRE S.p.A. Environmental Management System in accordance with ISO 14001:2004 standard.
  • 2011 Acquisition of 13,500 sqm of warehouses adjacent to the Brescia office.
  • 2012 Certification of the CEMBRE S.p.A. Occupational Health and Safety Management System and its Italian regional offices, in accordance with OHSAS 18001:2007 standard. Merger by acquisition of General Marking s.r.l. into CEMBRE S.p.A.
  • 2016 Closure of CEMBRE AS.
  • 2017 Certification of the CEMBRE Ltd Environmental Management System also in accordance with ISO 14001:2015 standard.
  • 2018 CEMBRE GmbH acquires IKUMA GmH & Co. KG, a company specialised in marketing electrical materials, and IKUMA Verwaltungs GmbH, a non-operating company that carries out administration and management activities for IKUMA KG. Both companies have registered office in Weinstadt, near Stuttgart.
  • 2020 Merger of IKUMA into CEMBRE GmbH.

In order to achieve this objective, CEMBRE S.p.A. hinges its work on the following principles:

  • · continuous increase of efficiency and effectiveness in process management;
  • · research and innovation to improve existing products and offer innovative products that stay one step ahead of market demands and our competitors;
  • · expansion of commercial penetration;
  • · heightened accountability, involvement and participation of, and listening to, its collaborators;

Mission

CEMBRE collaborates with its product users to develop the best possible technical and economic solutions in the field of electrical connections.

  • · environmental protection through the reduction of the environmental impact, energy consumption, and the production of pollutants, as well as the promotion of biodiversity;
  • safeguarding the health and safety of all staff working in CEMBRE and all those using our products through an analysis and systematic reduction of risks;
  • · continuous improvement of its Company Management System;
  • · compliance with relevant or subscribed provisions, whether from laws, national or international regulations or arranged by the parties themselves;
  • · respect and optimisation of the values set out in the Corporate Code of Conduct.

"The wealth of the range of products, the widespread nature and effectiveness of the sales network and the constant focus on customer needs, are further strengths boasted by the CEMBRE Group insofar as they are able to guarantee a significant commercial benefit in a global market that is evolving constantly. "

The CEMBRE Group Management team has set itself the aim of structuring the Company in a modern manner within the European and international market and supplying all corporate levels with the general rules and procedures necessary to guarantee the maintenance and improvement of product quality, the safeguarding of the environment and health and safety at work.

The Corporate Policy, prepared by the Management, sets out the aims and general guidelines to be pursued in maintaining and improving the Company Management System; these aims can be achieved through:

  • · the use of suitable resources:
  • · the dissemination within and, where envisaged, outside the CEMBRE Group, of the Corporate Policy, aims, indicators and targets envisaged;
  • · training of all staff on the Company Management System;
  • · the sensitisation of all collaborators towards the importance of satisfying both internal and external stakeholders' needs;
  • · compliance with laws, regulations, provisions and procedures;
  • · the regular review of the Company Management System.

The Corporate Policy, indicators and targets of the CEMBRE Group ensue from a careful, objective analysis of the internal situation, the results achieved and possible future developments, as well as of the external environment, customer demands and those made by other stakeholders.

The Company Management System, which is standardised following the provisions of standards ISO 9001:2015, ISO 14001:2015, and standard BS OHSAS 18001:2007 (in April 2021, the transition from the current OHSAS 18001 to ISO 45001 standard will take place), is the tool used to translate the principles of the Corporate Policy into goals and monitor their achievement.

The Group Management, the directors of the subsidiaries and all managers of the various company areas are involved in encouraging staff to participate more and ensuring the continuous improvement of the effectiveness and efficiency of processes, in order to satisfy the established objectives.

All activities carried out by the CEMBRE Group are focussed on ensuring both internal and external customer satisfaction; this is constantly monitored, not only on the basis of the analysis of the complaints received, but through the documented monitoring of the activities carried out and the regular measurement of the quality of the services offered.

The documentation collected is reviewed by the Managers in collaboration with the Company Management System Manager and the departments involved in the activities.

Group Structure

In 2020, following the merger of IKUMA into CEMBRE GmbH, the number of companies in the CEMBRE Group was reduced from 7 to 6 units. The parent company CEMBRE S.p.A., based in Brescia, is the largest production unit and directly owns 100% of all other Group companies.

In addition to serving its Italian and foreign customers, the parent company also supplies products that are marketed by the foreign subsidiaries in the respective national markets.

The Group's second-largest manufacturing unit is based in Sutton Coldfield near Birmingham in the United Kingdom and is mainly dedicated to the British market, while the other four companies are purely for distribution and are based in the vicinity of Paris (France), Madrid (Spain), Munich (Germany) and Edison (New Jersey, USA).

Following the merger of IKUMA into CEMBRE GmbH, the Stuttgart office is considered a regional office.

The direct presence in important countries of western Europe and the United States enables the Group to effectively reach the individual markets, increasing contact with the customer and assuring immediate, qualified, technical-commercial assistance.

0 CEMBRE

Group highlights

CEMBRE Group Governance

CEMBRE S.p.A. is organised according to a "traditional" administration and control model, with the presence of a Shareholders' Meeting, a Board of Directors and a Board of Statutory Auditors.

The CEMBRE corporate governance structure is based on the central role of the Board of Directors, as the body in charge of Company administration, which has chosen, from amongst its members, a Managing Director assigned full powers of Board management with the exception of those that cannot be delegated by law and the examination and approval of significant operations and related party transactions.

Within the Board, the Remuneration Committee, the Control and Risks Committee and the Related Party Transactions Committee, have been established. An independent auditing firm audits the Group's consolidated financial statements and the Parent Company's financial statements.

CEMBRE S.p.A. has been listed on the Telematic Stock Market (MTA) since 15 December 1997, and since 24 September 2001 in the STAR segment. The share capital is €8,840,000.00, subscribed and paid-in, divided up into 17,000,000 shares each with a face value of €0.52. As at the date of this report, the floating capital is 28.91%.

CEMBRE S.p.A. is controlled by Lysne S.p.A., a holding company based in Brescia.

Sustainability has always been viewed with great attention by CEMBRE; indeed, this is why the company has decided that it was best to keep the responsibility for these aspects with the Board of Directors.

The Group governance model is described within the "Report on Corporate Governance and Ownership Structures", prepared in accordance with the provisions of Art. 123-bis of the Consolidated Finance Act and published on the website www.cembre.com, to which reference is made for more details.

The sales network

In Italy, CEMBRE S.p.A. operates through a capillary distribution network, with its own offices and warehouses in Brescia, Turin, Milan, Padua, Bologna, Florence and Palermo; in the other regions, it operates through agents, organised for technical-commercial assistance and with warehouses for rapid deliveries.

CEMBRE is also present in the main countries across the globe, thanks to a network of representatives or correspondents, who can guarantee immediate, qualified technicalcommercial assistance and rapid deliveries of products from their warehouses.

As already described above, the growth in CEMBRE's business volumes and the consequent need to supply suitable support to foreign customers, over the years has led to the establishment of companies in the main European countries and in the United States of America.

The CEMBRE sales force worldwide numbers more than 100 functionaries dedicated to daily visits to customers.

Economic value generated and distributed and economic impact

In 2020, the economic value generated by the Group was EUR 137.1 million. The analysis given below shows the flow of resources sent to the various stakeholders, such as employees, suppliers of goods, services and capital and the Public Administration and general public, by means of external donations.

The table below shows the trend over the last three years, where the effect of the ongoing pandemic crisis is evident. The pandemic effects have severely affected the economic fabric, leading to a collapse in demand and a drop in investment. Although the Group experienced a reduction in its turnover, it could limit the crisis's effects, mainly thanks to the positive performance recorded in the fourth quarter of 2020.

As a result, the CEMBRE Group again recorded a positive financial result in FY 2020. For such reason, together with a solid capital base, is a guarantee for the company's continuity, even after exceptional events such as the one that has occurred in recent months.

Economic figures 2020 2019 2018
(thousands of euros)
Revenues from sales and services provided € 137.137 € 146.296 € 144,096
Other income and revenues, net of the use of provisions € 786 € 979 € 611
Losses on receivables (€ 220) (€ 53) (€ 26)
Capitalised internal construction costs € 1,207 € 1,055 € 958
Write-down of receivables (€ 94) (€ 28) (€ 89)
Financial income € 7 € 7 € 8
Foreign exchange gains (losses) (€ 171) (€ 81) (€ 82)
ECONOMIC VALUE GENERATED (A) € 138,652 € 148,175 € 145,476
Distributed to employees € 41,461 € 41,693 € 39,989
Distributed to suppliers € 60,916 € 69,448 € 70,120
Distributed to lenders € 134 € 170 € 57
Distributed to shareholders' € 15,068 € 15,048 € 15,048
Distributed to the public administration € 5,927 € 5,247 € 5,630
External donations € 106 € 35 € 31
ECONOMIC VALUE DISTRIBUTED (B) € 123,612 € 131,641 € 130,875
ECONOMIC VALUE WITHHELD BY THE GROUP € 15,040 € 16,534 € 14,601
Amortisation, depreciation, provisions and other
impairment
€ 11,133 € 9,892 € 6,914
Self-financing € 3,907 € 6,642 € 7,687
ECONOMIC VALUE WITHHELD BY THE GROUP € 15,040 € 16,534 € 14,601

1 For each year of reporting, the value of the dividends proposed for approval at the Shareholders' Meeting is assigned to the value distributed to shareholders (not recorded as liability at 31 December).

Main types of risk

CEMBRE carries out a risk assessment every two years to update its risk map and define actions to be implemented to contain risks and identify opportunities for improvement.

The analysis takes into account the assessment of the risk perceived by the company's main stakeholders.

The mapping of these risks is in line with the approach to identify the main corporate risks (financial, strategic, governance, operational, digital, and compliance), which are continuously monitored through the company's internal auditing process.

In particular, the main risks identified are the following.

Environmental dimension:

environmental risks: the most restrictive environmental protection regulations require companies to take specific actions to minimise their environmental impact and safeguard biodiversity.

climate risks: material damage resulting from climate change could cause damage to assets and infrastructures, with the possibility of prolonged unavailability of these assets. This will be analysed in the next risk assessment due at the end of 2021.

Social dimension:

human capital risks: in a context of continuous change and evolution of technology and the labor market, new profiles with high professional skills become essential for companies that are managing the transition and have a wide geographical presence.

Organisations need to move towards new agile and flexible business models and diversity policies.

occupational health and safety risks: these risks are related to the performance of operational activities at the Group's units.

CEMBRE intends to limit and eliminate risks to workers' health and safety as much as possible by analysing the risks of company processes and identifying any hazardous situations. Under the Risk Assessment Document and to prevent or at least mitigate the risks identified, CEMBRE implements the required actions by modifying technological processes, adopting highly automated solutions, using Personal Protective Equipment (PPE), and promoting specific training opportunities.

local community-based risk: the presence in such a vast geographical area necessarily implies a comparison with different realities and a thorough knowledge of the territory and several stakeholders' needs.

Business and governance dimension:

business continuity risks: a partial or total interruption of operational and/or commercial activities could expose Cembre to risks of sanctions, losses, and reputational damage.

cyber attacks-related risks: the era of digitisation and technological innovation means that organisations are increasingly exposed to cyber attacks, which are becoming more numerous and sophisticated

The risk of intrusion into the corporate network is controlled by using a redundant firewall system and the setting of periodically expiring usernames and passwords to access the network.

Also, a data encryption system has been implemented on all portable devices.

digitization, IT effectiveness, and service continuity related risks: Cembre's IT structure is constantly being adapted to guarantee its constant correspondence to the company's needs and improve its ability to support new applications.

The availability of the systems is guaranteed even in the event of a power failure by redundant uninterruptible power supplies supported by several gensets set up to operate automatically.

The availability of adequately stored backup copies is a guarantee against the loss of information. Access to the connectivity and server distribution rooms is only allowed to specialised staff and is controlled by badge readers.

Specialised external companies carry out periodic security audits of systems and privileged users.

protection of personal data related risks: the Group's growth at a global level in terms of the number of customers and geographical areas implies a natural exposure to personal data protection risks. Also, the increasingly dense legislation on privacy, the nonimplementation of which may cause economic or financial losses and reputational damage.

> compliance risks:

CEMBRE first adopted Model 231 in 2008 and since then has ensured that the Model is correctly applied by periodically testing the protocols.

The Company continuously monitors regulatory developments, evaluating possible impacts/opportunities on the business. CEMBRE is aware that any violations of laws and regulations could expose it to the risk of incurring judicial or administrative sanctions, economic or financial losses, and reputational damage.

Concerning tax legislation, it carries out all activities deemed necessary to ensure adequate supervision.

Materiality analysis and stakeholder engagement

The CEMBRE Group non-financial report is focused on the importance of the various aspects relative to its business.

CEMBRE felt it necessary to define better the main parties directly affected by the company's activities (stakeholders) when updating this declaration. Following this, the materiality matrix was updated, conducting a series of analyses to refine the engagement process according to the points of attention identified.

Since dialogue with the company's primary stakeholders is considered fundamental, a process has been launched to survey the various company departments responsible for day-to-day stakeholder relations. The outcome of this process has led to the identification of 7 main categories of stakeholder, with whom CEMBRE has already established an active and constant dialogue over the years, both individually (visits, dedicated events in the company) and collectively (publications on websites, social media, participation in and organisation of conferences) based on values of fransparency and trust.

These involvement activities are primarily of an informative and consultative nature, while CEMBRE intends to initiate, in the coming months, more appropriate ways of consolidating an ongoing and mutually beneficial dialogue with the several stakeholders.

STAKFHOI D

The table below summarises the listening and engagement tools and expectations of all CEMBRE's stakeholders to whom it is required to respond.

CEMBRE Stakeholder Listening and engagement tools Stakeholder expectations and interests
towards CEMBRE
Investors · Shareholders' Meeting
· IR section of the website
· At least twice a year, participation in
conferences organised by Borsa
Italiana
other
professional
or
operators dedicated to institutional
investors and financial analysts.
· Listening and support
channels
offered by the Investor Relations
department.
• Meetings and video calls with analysts
and institutional investors on request.
· Visits to the company's headquarters
manufacturing
and
units
by
institutional investors and analysts
organised periodically or on request.
· CEMBRE Group shareholder value growth
• Reducing investment risks
· Transparency on Corporate Governance
structures, long-term strategy, objectives,
management operations,
business
development, and environmental and
social performance.
Customers · Daily activities and relations with
business units
· Institutional website and dedicated
email accounts
· Supplier evaluation questionnaires
· Customer service channels
· Support and training network for
customer repair operators
· Surveys of customer needs and
expectations
product
tor
new
development
· Events for costumers
· Product reliability and safety
· Reliability and flexibility of manufacturing
processes to ensure business continuity
and adherence to delivery schedules.
· Support for the joint development of
customized solutions
· Technical support to the network of repair
professionals and assistance in know-how
18
transfer.
· Continuous product innovation, also
concerning improving environmental
performance and care for product
design.
Industry companies
and competitors
· Participation in market-specific events
and round tables.
· Participation in work and thematic
committees of trade associations.
· Protection of free competition
Employees · Daily activities and reports of the
Human Resources and Organisation
Department.
· Channels for collecting reports of
violations of the Code of Ethics.
· Internal communication activities (e-
mail and notice boards).
• Training on organisational behaviour.
· Annual personal and corporate
performance assessment interviews.
• Safe
working environment,
where
people's health and psychophysical well-
being are protected.
· Employment stability.
· Opportunities
personal
tor
and
professional growth.
· Training
and
skills
development
pathways.
· Remuneration policies and merit-based
incentive systems.
• Inclusion and enhancement of diversity.
involvement
· Transparency
and
regarding the company's objectives and
performance.
Suppliers · Qualification and evaluation process.
· Daily activities and reports of the
Procurement Department.
· Timely and correct compliance with
contract terms.
· Supply continuity requests.
· Possibility
of developing
strategic
partnerships for the improvement of its
activities.

CEMBRE

Local communities · Orientation and involvement of high
school and university students and
related recruitment programmes.
· Discussion and dialogue tables with
the Public Administration.
· Initiatives to support the social and
cultural development of the territories
promoted by the Group.
· Media monitoring (press, web, social
networks).
· Donation of technological equipment
to schools.
• Support to the school world, also through
the availability to host students in school-
work training schemes.
· Collaboration with universities and
research centres in the development
and dissemination of engineering and
technical-scientific knowledge and skills.
· Provide job opportunities and protect
employment in the Group and the
related industries.
· Development of manufacturing and
logistics processes that safeguard the
environment and the health of people
living in the vicinity of CEMBRE's
production units and the Group's
suppliers.
· CEMBRE's participation in and support for
development
cultural
and
social
inclusion projects.
Institutions · Attention
to
awareness-raising
campaigns
environmental
by
associations and analyses by the
scientific community.
· Ensure full compliance and adherence to
applicable regulations.
· Control of the supply chain to manage
social and environmental risks throughout
the value chain.
· Combat · air pollution
and
global
warming.
· Conservation of natural resources and
circularity of the economy.
· Protection of ecosystems and natural
biodiversity.
· Contribution to the achievement of the
UN Sustainable Development Goals.

Therefore, the materiality analysis was updated according to the principles of the GRI (Global Reporting Initiative) sustainability reporting guidelines, aimed at identifying the matters that could considerably affect the Group's capacity to create value in the short-, medium- and long-term, and which are most relevant to the Group and its stakeholders.

The sustainability manager carried out the analysis process with the involvement of fop management and all the departments concerned with the various issues.

The matters identified as material are worthy of dedicated reporting as they can influence stakeholders' decisions and reflect the Group's social, environmental and economic impact.

The materiality analysis process was structured as follows:

Identification of material topics

  • · Research and analysis of internal sources (policies, procedures, etc.) and external sources (analysis of publications of standard setters and benchmarking with the main competitors);
  • · Preparation of a long list of potentially material topics;
  • · Review and approval of the lona list and screening of those topics to create a short list.

Evaluation of material topics

  • · Organisation of meetings with front-line personnel to evaluate the importance of each topic on the short list, from the perspective of the Company as well as stakeholders:
  • · Consolidation of the results of evaluation the and preparation of the relative materiality matrix.

Validation and review

  • · Approval of the short list of topics identified and evaluated in the previous phases;
  • · Review and verification of the Materiality Matrix arising from the evaluation of the various topics:
  • · Overall of the approval analysis.

The results of the materiality analysis are summarised and represented graphically in the "materiality matrix" (see graph below); more specifically, this matrix is a graphical representation of the importance attributed to each matter from Management's viewpoint (x axis) and that of the stakeholders (y axis).

Therefore, the higher up on the right the matter within the graph, the more important it is for both parties. The material matters emerging during the analysis are the starting point from which the Company has focused its non-financial information report.

Compared to last year, the method for setting the materiality threshold has changed to use a more conservative approach, including, among material matters, those issues that are only relevant to the company or its stakeholders.

The threshold was defined by averaging the scores related to internal and external relevance.

As foreseen in the procedure approved by the Board of Directors in November 2020, the materiality analysis was updated three years after the first reporting (2017). The materiality analysis will still be subject to annual assessment for its validity before the next three-year update.

The matters of "Relations with personnel," even though they been considered as of reduced relevance for CEMBRE, will also be reported as it is expressly required by Italian Legislative Decree no. 254/2016.

Management of environmental matters

Risks and opportunities

In line with international models and best practices (COSO Integrated Framework), the CEMBRE internal control system is based on company procedures that are relevant to the prevention and monitoring of operational risks, such as, for example, the Environmental Management System UNI EN ISO 14001.

Environmental risks are analysed in view of the environmental impact assessment, which is reviewed at least once a year or at different frequencies if new production processes are installed. The Company's main environmental risks are connected with the purification of water of the galvanic chemical plant, the management of some hazardous waste and the consumption of oils and chemical products.

In short, the main risks to which CEMBRE is subject, are:

  • · risk of environmental pollution due to inadequacy or malfunction of the water purification and disposal plants or incorrect handling, use and storage of hazardous substances, oils and chemical products;
  • risk of non-conformity of plants due to obsolescence, wear and tear or ● legislative changes.

CEMBRE has protected itself against the risk of environmental pollution by means of a constant control of its plants and through their regular maintenance. The use, preservation and disposal of hazardous and chemical substances is assured by applying rigorous procedures that are updated from time to time. These substances are kept in dedicated areas, segregated with respect to the other materials needed for the production process. The staff involved in the management are specifically trained and instructed.

Plant conformity is guaranteed through the continuous update of the management system, frequent, scheduled emissions monitoring, including with the support of specialised consultancy firms. Moreover, the continuous renewal of the production lines prevents the risk of obsolescence and wear and tear of machinery.

CEMBRE S.p.A. is a manufacturing unit and is located on the eastern outskirts of the city of Brescia in an industrial hub, with close access to the ring-road and underground and covers a total area of 121,000 sqm.

The area in which CEMBRE S.p.A. is located falls entirely within class V (predominantly industrial area) and borders on areas that are also class V or IV (areas of intense human activity); it is not subject to landscape constraints but is partly affected by the buffer zone for public waterways (Vescovada and Municipal irrigation canals) and rests on gravelly and clayey soil.

CEMBRE Ltd is located east of Birmingham at Sutton Coldfield in the Midlands in the United Kingdom with close access to motorway networks.

The CEMBRE Ltd site is located within an industrial park, surrounded by agricultural land adjacent to the Birmingham Fazeley Canal.

Both CEMBRE S.p.A. and CEMBRE Ltd manufacturing units are located in areas where no IUCN Red List species are present. (GRI 304-1)

It is to be noted that the distribution companies of the Cembre Group are located entirely within urban areas, with a consequent negligible impact on biodiversity.

The policies applied by the CEMBRE Group

As seen from the CEMBRE materiality matrix, environmental matters are essential for the Group and are therefore included in its business practices.

As for all other matters, the Corporate Policy is established by the CEMBRE Group Management team and stems from a careful, objective analysis of multiple aspects, such as the analysis of the internal and external context, the results achieved, future objectives, and the demands of clients and relevant stakeholders.

The Corporate Policy is formalised by the CEMBRE Group Management team and subscribed by the CEMBRE S.p.A. Management team, within a document that is given out and presented to all Company staff; it is then disclosed to external stakeholders through publication on the website.

Following a careful assessment of the risks to the environment, associated with the activities carried out, indicators are chosen through which the level achieved can be quantified and verified, and any areas for improvement, identified.

In order to integrate this policy and attention paid to the environment in pursuing the Company's business, CEMBRE S.p.A. has implemented a Company Management System compliant with standard ISO 14001 for environmental management, tor which certification was obtained in 2008; this is updated on a regular basis to ensure that the Management System remains effective and improves continuously.

The same certification has also been extended to CEMBRE Ltd (UK), a company based in Great Britain and the second manufacturing unit of the CEMBRE Group. Legislative compliance is also assured through the verification and update of applicable laws and

regulations by means of a legislative verification programme, at least once a year, which is documented and disclosed to the company Management team. Verification of legislative compliance is audited both internally, by third party certifying entities.

The Company has envisaged different ways by which to monitor and manage environmental data:

  • once a month, consumption of energy, raw materials and water is monitored and compared with the hours of production and/or pieces produced, for each operative department, so as to obtain a series of clear, unique performance indicators. This data is highlighted by means of suitable graphs distributed to the Management and each Department Manager, so that it is disclosed to each individual operator;
  • . for the Italian plant, polluting emissions from flues and waste management are controlled annually, as required by the Environmental Management Department; more specifically, air-conditioning plants and the consumption of cryogenic gases are verified.
  • · waste water is controlled every day by the Department Manager and at least once a month by a qualified external company.

Customers' interest in environmental management in their supply chain is increasingly great. CEMBRE, in fact, receives various requests to fill in questionnaires connected with the management of environmental and social aspects and worker health and safety.

Over the various years, the company has undergone numerous customer audits, including run by Batenburg, DEKKRA, Rail for PRORAIL, DB, SNCF, etc., obtaining positive ratings.

Finally, in compliance with Italian Legislative Decree no. 102/2014 CEMBRE, in 2019, has carried out an energy diagnosis; consequently, various energy efficiency improvements have been planned and implemented, including: the installation and commissioning of a new geothermal plant, the construction of a new warehouse with photovoltaic panels, the adoption of "smart" control systems through which to reduce the incidence of air loss on the compressor network, used in the plant, and the analysis of residual consumption when the plant is not operating, collaboration with Sinergia Consulting to find how to reduce the incidence of air loss by the compressors used in the plant and reduce energy consumption when the plant is closed.

Intending to minimise the environmental impact, including indirect actions, Cembre, also this year, maintained an agreement with the Brescia Mobilità Group to guarantee its employees the possibility of using public transport when travelling to and from work and home, at special rates.

Non-financial performance

· Consumption by material type (GRI 301-1)

UoM 2020 2019 2018
Ferrous material kg 464,032 504.496 787.479
Non-ferrous material kg 4,267,933 4.609.179 4.871.053
Plastic kg 1,786,033 1,962,834 2,049,639
Total kg 6,517,998 7,076,508 7,708,172

The significant constriction of the volumes of material consumption in the three categories (ferrous, non-ferrous, plastic) is linked to the blocking of the leading manufacturing activities for part of the first quarter of the year due to the lock-down imposed by the Covid-19 pandemic.

• Consumption of hazardous, oily and lubrication substances (GR) 301-1)

UoM 2020 2019 2018
Chemical substances kg 74,438 78.448 90.255
Oil + lubricants kg 33,566 49.881 48.941
Total kg 108,004 128.329 139.196

The reduction in oil, lubricant and chemical consumption between 2019 and 2020 is always connected to a total or partial shutdown for some manufacturing departments during the lock-down period in the first part of the year

• Consumption of packaging material (GRI 301-1)

UoM 2020 2019 2018
Paper kg 64,646 58,868 60,574
Wood kg 158,250 210,572 203.968
Plastic kg 11,494 12.691 22.181
lotal kg 234,390 282,131 286,723

• Total energy consumption (GRI 302-1)

UoM 2020 2019 2018
Electricity MWh 9.341.74 9,440.26 9,557.75
of which self-produced and consumed
by the photovoltaic plant
MWh 253.95 212.73
of which self-produced and sold by the
photovoltaic plant
MWh 0.15 0.03
Energy from geothermal plant MWh 1653.12 1653,12*
Diesel MWh 2.787.74 3.424.29 3,356.67
Petrol MWh 621.73 888.44 877.41
Natural Gas MWh 4.439.83 4,090.63 4.288.66
Naphtha MWh 246.1 125.55 111.62
lota MWh 19,090.25 19622,29* 18,192.11

* the 2019 value has been modified following an update of the calculation method.

The following image shows the performance obtained in 2020 thanks to the panels installed at the Brescia unit.

This investment is a first step for CEMBRE towards a continuous reduction of its CO2 emissions.

The conversion factors used are as follows:

Source Conversion factor
Diesel 11.91 MWh/t
Petrol 11.89 MWh/t
Naphtha 12.36 MWh/t
Natural Gas 0.009800277 MWh/m³

The natural gas conversion factor is calculated starting from:

  • the calorific power of natural gas, as obtained from the table of standard national parameters of coefficients used for the inventory of CO2 emissions in the national inventory UNFCCC (average values 2017-2019), equal to 0.035281 GJ/stdm³
  • · and the conversion factor from GJ to MWh, which in technical literature is 0.27778
  • Energy intensity (GRI 302-3) ●
UoM 2020 2019 2018
Energy consumption MWh 19.090.25 19622,29* 18.192.11
Consolidated turnover €/000 137,137 146.296 144.096
Energy intensity 13.921 13,412* 12.625

*the 2019 value has been modified following an update of the calculation method.

Energy intensity is calculated as the ratio of total energy consumption, corresponding to the sum of direct consumption and indirect consumption, multiplied by one hundred and ine som of allect consomplion and indirect consomplion, information,
consolidated turnover in thousands of euros (Exergy consumption in Euro

Water collected by source*

UoM 2020 2019 2018
From aqueducts 14.668.029 15.626.941 16.234.606
From wells 20.066.000 15.953.000 16.864.000
lotal 34.734.029 31.579.941 33.098.606
of which water withdrawn from
water-stressed areas or sensitive
locations
32.357.800 28,986,050 30,483,477

*The information for the American subsidiary, CEMBRE Inc., is not available. The increase in water consumption observed in 2020 compared to 2019 and 2018 is due to the inclusion, for Cembre S.p.A., of well withdrawals for irrigation use which in 2019 and 2018 amounted to about 3,000,000 litres.

From this year, Cembre S.p.A. reports information relating to water withdrawals according to the new GRI 303-3 (2018) indicator. Therefore, the value for water withdrawn in water-stressed areas is also reported. Based on information from the online

Aqueduct tool (https://www.wri.org/), the Brescia plant and the distribution companies in France and Spain fall within the water-stressed area ("high" or "Extremely high" range).

All the water taken is discharged, after treatment, into the drains upon completion of the work cycles; the water withheld for the manufacturing process is also released into the drains after purification.

Direct emissions (Scope 1) UoM 2020 2019 2018
from Diesel t CO2e 738.46 907.08 893.39
from Petrol t CO2e 164.14 234.55 231.64
from Natural Gas t CO2e 898.81 819.26 865.86
from Naphtha t CO2e 64.9 33.13 29.46
from refrigerating gases t CO2e 58.73 13.57 134.22
lotal t Core 1.925.09 2.007.59 2.154.57

Direct (Scope 1) (GR) 302-1) and indirect emissions (Scope 2) (GRI 305-2)

Emissions from refrigerant gases in 2020 increased because of leaks due to faults at cooling plants.

Indirect emissions (Scope 2) UoM 2020 2019 20113
Electricity - Location based t CO2e 2.999.99 3.242.08 3.394.46
Electricity - Market based t CO2e 4.114.38 4.404.82 4.482.45

The coefficients used to calculate direct emissions are taken from the national standard parameters table of coefficients used for the CO2 emissions inventory in the UNFCCC national inventory, obtained from ISPRA 2021 data:

UoM Coefficients
Diesel t CO2e/t 3.155
Petrol t CO2e/t 3.140
Natural Gas t CO2e/dm³ 1.984

The coefficient used to calculate Naphtha emissions in 2018, 2019 and 2020, shown in the national standard parameters table of coefficients used for the CO2 emissions inventory in the UNFCCC national inventory (average values for 2017-2019), equal to 73.3 t CO2e/TJ.

² ndustrial water (water from the well) at the Italian facility is treated on site according to defined procedures and, only after successful completion of the controls, discharged into the drains.

By contrast, for refrigerating gases, the following global heating potentials were used (GWP), whose source is the Fifth Assessment Report of the Intergovernmental Panel on Climate Change (IPCC):

UoM GWP
Fgas - R410A Kg CO2e/kg 1,924
Fgas - R404A Kg CO2e/kg 3,943
Fgas - R407C Kg CO2e/kg 1,624

The emissions value was obtained by applying the formula:

tCO2 e = (kg refrig. gas x GWP) / 1000

On the other hand, with respect to indirect emissions:

  • · for the location based emission factors relating to electricity procurement the source is Terna;
  • · for market-based emission factors relating to the supply of electricity, the source is the Association of Issuing Bodies (AIB) for European countries and the Center for Resource Solutions for the USA.
Country UoM Location Based Market Based
Italy t CO2e/MWh 0.336 0.466
United Kingdom t CO2e/MWh 0.273 0.348
France t CO2e/MWh 0.056 0.043
Spain t CO2e/MWh 0.255 0.343
USA t CO2e/MWh 0.399 0.324
Germany t CO2e/MWh 0.449 0.609

• NOx and other significant emissions3 (GRI 305-7)

UoM 2020 2019 2018
NOx 0.946 1.021 0.391
VOC 0.449 0.524 0.886
PM 0.075 0.048 0.139

The data refer only to CEMBRE S.p.A. For the UK subsidiary, CEMBRE Ltd., data has not been recorded, because not required by the local legislation, whilst the other

• the theoretical operating hours

3Data has been calculated, considering:

· the concentration (expressed in mg/Nm³) of the element measured in the individual flues

· the nominal capacity of each flue, expressed in Nm³/h

· the days of operation of each flue

This allowed for the calculation of the annual tonnes of emissions of each element examined.

There are no SOx emissions. The calculation includes solely the emission points prescribed in the Single Environmental Authorisation, since identified as the most relevant by the local authority.

subsidiaries, which only carry out commercial activities, do not generate any significant emissions.

Nitrogen oxide values relate to the thermal plants, the negative trend in 2019-2020 is contextualised with the methods and measurement periods given that there are changes in value linked to the weather conditions during monitoring. Having said this, it should be stressed that all values recorded are fully in line with the limits prescribed by the Single Environmental Authorisation AUA 672/2019.

· Waste generated (GRI 306-2)

UoM 2020 2019 2018
Hazardous kg 360,413 331.590 344.550
Non-hazardous kg 1.350.875 1.445.643 1.344.269
Total kg 1,711,288 1,777,233 1,688,819

Concerning hazardous waste, the increase recorded in 2020, compared to 2019, was due to two significant deliveries: the first of 17,000 kg of saltwater from the washing machine in the cutting department and a second of 10,000 kg of galvanic mud from the tin plating department.

Waste for recycling

UoM 2020 2019 2018
Hazardous kg 139.813 134.720
Non-hazardous kg 1,191,102 1,290,045
Total kg 1,330,915 1,424,765

Waste stored on site

UoM 2020 2019 2018
Hazardous kg 500 4.060
Non-hazardous kg 28,642 9.886
Total kg 29,142 13,946

· Waste for landfill disposal

UoM 2020 2019 2018
Hazardous kg 220,100 192.810
Non-hazardous kg 11,754 2,780
lotal kg 231,854 195,590

Waste sent for reuse

UoM 2020 2019 2018
Hazardous kg
Non-hazardous kg 870 2,500
Total kg 870 2,500

· Waste sent for energy recovery

UoM 2020 2019 2018
Hazardous kg
Non-hazardous kg 5,110 9,170
rotal kg 5,110 9,170

· Waste sent to incinerator

UoM 2020 2019 2018
Hazardous kg
Non-hazardous kg 108,582 114,283
Total kg 108,582 114,283

• Waste other types of destination

UoM 2020 2019 2018
Hazardous kg
Non-hazardous kg 4,815 16,979
Total kg 4,815 16,979

The data for 2018 are not shown in the table as, from 2019, a new method for collecting information on waste generated has been introduced, which provides greater detail regarding the disposal type adopted.

For 2018, the amount of waste generated was 1,688,819 (of which 344,550 was hazardous). Specifically, waste for recovery (recycling, reuse), disposal (landfill, energy recovery, incineration, other destination), and on-site storage amounted to 1,409,822 (of which 190,724 hazardous), 278,997 (of which 153,826 hazardous), and 3,660 (of which 2,500 hazardous), respectively.

Management of social and staff-related matters

Risks and opportunities

Following the spread of the coronavirus pandemic (Covid-19) in several parts of the world, in response to this emergency, CEMBRE has acted with promptness and determination in all the geographical areas of our Group to minimize the risk of infection and, at the same time, ensure the continuity of supply of its products.

CEMBRE has also established a Company Committee composed of the Employer, the Company Doctor, RSPP, and RLS to apply and verify the application of the Company Protocol's provisions for the Regulation of Measures to Combat and Contain the Spread of the COVID-19 Virus in the Workplace.

CEMBRE is today the leading Italian manufacturer and one of the largest European manufacturers of electrical compression connectors and related installation tooling. Extensive know-how in the field of electrical connectors, strong R&D activity and continuous innovation in manufacturing technologies and product specification, allow CEMBRE to respond quickly to an increasingly demanding market expectation for highquality products that are reliable, durable and safe. In order to maintain these production standards, highly qualified staff are required, specialised in different business activities.

For this reason, the Company needs to be able to retain staff with skills and experience that are fundamental to the business.

The loss of such resources could harm the company's development and growth.

Similarly, the Company is constantly looking for new staff with high potential or relevant professional profiles to be placed in critical positions in order to ensure the development and continuity of the Group. Moreover, the difficulties in obtaining staff on the labour market whose skills and profile match CEMBRE's organisational needs are ongoing challenges for the company.

In order to manage staff, CEMBRE must constantly monitor the following risk areas:

  • · implementation of appropriate staff management policies in terms of training, comparison and professional growth;
  • · adequate management of equal opportunities for men and women, discrimination in training, professional development and career and salaries;
  • · compliance with regulations governing employment and the protection of human rights, in particular in foreign countries where the company operates with its branches;
  • · the application of the terms of the National Collective Bargaining Agreements to avoid subpoenas, loss of reputation, payment of compensation.

To prevent these types of risks, the CEMBRE Group ensures that its personnel working in human resource management are constantly updated to guarantee compliance with applicable regulations and also engages top advisory firms to support internal staff in managing the most complex matters.

The policies applied by the CEMBRE Group

The value of people ●

The CEMBRE Group believes in the growth and optimisation of people, the protection of health and safety and the creation of a workplace that fosters human and professional growth. The Group offers all employees and collaborators equal career opportunities on the basis of merits, professional and managerial skills and active involvement in company development and improvement processes. This approach has allowed it to attract young talent and, at the same time, gain the loyalty of employees and collaborators already working in the Company, as is borne out by the data on the average length of service, in many cases, reaching 20/30 years.

The CEMBRE Group's workforce as at 31 December 2020 is 721 people.

More specifically, the employment trends recorded in 2020 regard:

  • hiring of 60 people; ●
  • · leaving of 59 people;

Approximately 97% of those working for the CEMBRE Group have a permanent contract of employment.

All of the Group's companies operate in countries in which matters linked to personnel management, occupational health and safety and the protection of workers' rights are highly regulated. Furthermore, the principles set forth in the Code of Conduct and defined in the Group Policy are also applied in all companies.

In order to sensitise all employees and collaborators towards the Corporate Policy on social matters, the Group Code of Conduct is given out to all new employees, clarifying the conduct and relations that are considered in line with the Company's vision. Human rights procedures and policies are reported to all employees and collaborators of CEMBRE S.p.A. through the delivery of the Organisation, Management and Control Model in accordance with Italian Legislative Decree no. 231/2001. Moreover, the CEMBRE Group's Code of Conduct also contains a specific section on human rights, called: "Social responsibility, human rights and discrimination".

The CEMBRE Group actively encourages respect for internationally-recognised human rights, working concretely to overcome all forms of discrimination.

The CEMBRE Group also refuses all types of child or forced labour and specifically bans any entertaining of business relations with organisations exercising this form of oppression or with organisations whose products come from regions in which there is notoriously a lack of suitable protection of human rights.

The Group does not tolerate any form of discrimination or unfair treatment based on gender, race, disability, ethnic or cultural origin, religion or beliefs, age or sexual orientation. The diversity policy adopted within the governance bodies is regulated by Article no. 15, paragraph 5 of the CEMBRE S.p.A. By-Laws. Contracts in general, purchase orders, letters hiring employees and agents, include all clauses to inform the counterparty of the adoption of the 231 Model and the Code of Conduct by CEMBRE S.p.A.; failure by the counterparty to comply with these clauses constitutes serious breach of contractual obligations.

Relations with social parties are regulated by respective applicable rules.

The contract of employment applied to all CEMBRE S.p.A. employees is the: "Italian National Collective Bargaining Agreement for the Metal-Mechanical Industry and Plant Installation". In compliance with the provisions of the national bargaining agreement, the company envisages a minimum notice period for its employees, if moved from one place to another, of twenty days.

The contracts of employment of the subsidiaries CEMBRE SARL (France) and CEMBRE España SLU (Spain) are stipulated in compliance with category collective bargaining agreements and regulations in force in the various countries. As regards France, the minimum notice period is set at 30 days, while it is 15 days in Spain.

The subsidiaries CEMBRE Ltd. (United Kingdom), CEMBRE GmbH (Germany), and CEMBRE Inc. (USA) stipulate contracts of employment with their employees on an individual basis. In the United Kingdom, the minimum notice period is usually 4 weeks, and can be extended to 12-24 weeks for personnel with a significant length of service. In Germany, unless established in the individual contract, the minimum notice period established by labour legislation is 4 weeks. By contrast, there is no such provision in the United States.

Training

In order to satisty the business needs and production standards, the Group makes sure to attribute the responsibilities, relative to the activities that affect product/service qualify, the environment and HSW, considering the competences, the degree of education, work experience and training supplied. All Group staff must be aware of the strategic role and importance of their work, so as to achieve the objectives set.

This awareness particularly regards the company policy, objectives, indicators and targets of the CEMBRE Group, respect for laws and provisions, the possibility of reporting ways by which to improve products, processes, health and safety in the workplace and the external environment, which may affect the processes, works and management of the Group.

Staff is sensitised through the continuous monitoring of processes, staff meetings, training, etc. The Company ensures that it trains employees according to their different duties and seniority levels: staff are trained when hired, if their duties should change and when procedures, works, machinery, technology and products or hazardous substances are updated or altered.

Finally, the Company ensures that it can offer a carefully-focussed training plan if shortcomings should be noted in staff experience or training.

The activities for which a specific qualification is required concern all performers of activities for which the law defines the need for specific information, education and training.

In general, the CEMBRE Group is committed to delivering all training, information and teaching required by the laws, rules and regulations in force. The process plan and competence sheets prepared for the main company departments set out the minimum requirements in terms of experience, training, preparation and teaching of staff, training, teaching and information methods and the related responsibilities defined for the various tasks.

The HR Office is in charge of recording training delivered and, where envisaged, verifying its effectiveness by assessing performance, experience and know-how, which on the one hand allow for the determination of the individual contribution to the organisation and the definition of progress made and, on the other, for the outlining of areas for improvement on which to intervene.

· Performance assessment systems

CEMBRE S.p.A. assesses the commitment and performance of employees using compensation policies that differ according to performance and professional and managerial skills, considering:

  • the responsibilities attributed;
  • the results achieved;
  • · the quality of the professional contribution and personal development potential.

The compensation systems are regularly updated by monitoring changes in the reference salary markets and applying criteria based on meritocracy and internal fairness.

Company welfare

In order to protect and foster the well-being of its employees, CEMBRE S.p.A. makes services and initiatives available that aim to conciliate everyday needs with working activities, considering the family and childcare, maintaining good psychological and physical health, the acceptance of everyday commitments that can take up time and cost money and the organisation of free-time activities and artistic-cultural initiatives. The initiatives promoted by CEMBRE S.p.A. include:

  • · the marriage premium for all employees choosing to get married;
  • · the birth premium for all employees who become parents;
  • · a sustainable mobility project in collaboration with "Brescia mobilità";
  • · the collaboration with a Tax Assistance Centre to offer employees the chance of making their tax returns at the Company's office, while also paying the predominant portion of the cost of the service;
  • · the collaboration with a Patronage to guarantee assistance in social security matters free of charge to employees.

The initiatives taken by CEMBRE S.p.A. in respect of families, include:

  • · concession of leave for family reasons, in order to take care or assist relatives;
  • · a "book package" for more information on school subjects for children of employees who successfully attend middle school;
  • · study grants to deserving children of employees attending secondary schools and university;
  • · distribution of toys to children of employees aged under 10 during the Christmas period in cooperation with CRAL.

Alongside its established initiatives, in 2020, CEMBRE S.p.A. took care of its employees and their families by implementing a series of extraordinary initiatives.

In order to support families during the months of suspension of educational activities and for the continuation of the health emergency, CEMBRE S.p.A. allowed work to be carried out from home by providing its employees with the necessary devices, thus ensuring that they could take care of their loved ones.

In June, July, and August 2020, CEMBRE S.p.A. drew up a financial programme to compensate 50% of the salary reduction linked to the redundancy fund during the six weeks of company closure, imposed by the government, by providing more than €300,000 to its employees.

In June 2020, CEMBRE S.p.A. entered into a partnership with the Fondazione Poliambulanza Istituto Ospedaliero in Brescia, offering all employees the opportunity to undergo a free serological test for anti-Sars-CoV-2 antibodies directly at the Company's office. A total of 370 tests were provided.

In October 2020, CEMBRE S.p.A. also launched an anti-flu vaccination campaign, which was borne entirely by the company. The 275 doses of the anti-flu vaccine were administered at the Company in collaboration with Poliambulanza under the company doctor's supervision.

The participation in the serological testing initiative and the vaccination campaign was a voluntary gesture of social responsibility shown by most employees.

Also, in 2020, as an additional safety measure in contact with Covid-19 cases, 53 swab tests were carried out with the Istituto Fondazione Poliambulanza in Brescia on employees returning from national and international trips.

· Relations with the local community

CEMBRE S.p.A. promotes several social, medical, and educational initiatives and projects linked to the local community, intending to impact the area in which the company operates positively.

CEMBRE S.p.A. has been collaborating for years with professional institutes throughout the province and with the universities, offering students curricular traineeships, both in office jobs and on the production line.

During 2020, despite restrictions related to Covid-19, 3 students (2 remotely) were hosted for school and university internships.

In order to strengthen the link with local educational institutions, in 2020, the Company made cash donations and supplies of material to be used in the laboratories, amounting to €13.180.80.

In November 2020, CEMBRE S.p.A. also offered a scholarship worth €6,800 to a student of the Digital Transformation Master at Digital Universitas in Brescia.

Through the Education Department of the Municipality of Brescia, CEMBRE S.p.A. donated 20 tablets in 2020, which were given to compulsory school students in the city's comprehensive schools as support for distance learning.

Other charitable initiatives supported by CEMBREinclude donations to Save the Children, Telefono Azzurro, Fondazione Comunità Bresciana Onlus, Fondazione Poliambulanza, Italian Red Cross and COSP Mazzano for a total of €106,000.

Promoting a constructive dialogue with institutions and fostering discussion between the industry's leading players are the two essential aspects for CEMBRE to strengthen its brand on the market and increase its competitiveness.

CEMBRE S.p.A. is a member of several trade associations and is committed to working together as a system to grow, accelerate innovation and make progress in the general interest.

Association Main objectives
Brescia Industrial Association
(since 2021 CONFINDUSTRIA
BRESCIA)
They represent the manufacturing and service industries active in Italy,
promoting the protection of their legitimate interests in relations with
institutions, public administrations, and financial, political, trade union,
and social organisations.
ANIE Federation They are one of the largest trade organisations in the Confindustria system
in terms of weight, size, and representativeness of the electrotechnical
and electronic sector.
The member companies, suppliers of cutting-edge technological systems
and solutions, are an expression of Made in Italy technological
excellence, resulting from significant annual investments in Research and
Innovation.
Federmeccanica They protect the interests of the Italian manufacturing and mechanical
engineering industries in labor law and industrial relations in particular.
They represent and promote the Mechanical Engineering industry in
dealings with public opinion and Italian and European institutions.
Cifi They promote the examination and study of scientific, technical,
financial, and legislative issues relating to land transport, intervene for the
best solution to these issues both with public opinion and with Italian
institutions, public administrations, and private bodies.

The table below lists the main associations to which CEMBRE is a member:

· Commitment to the fight against Covid-19

By joining the initiative launched by Isinnova in March 2020, CEMBRE S.p.A. has manufactured and delivered "Dave" and "Charlotte" valves for the transformation of a particular type of snorkeling face masks into a mask for lung ventilation, contributing and supporting the action of doctors and healthcare personnel in the fight against Covid-19.

To contain and combat COVID-19, the Group incurred approximately €214,000 in costs related to the purchase of goods, assets, and services (vaccination campaign, serological campaign, surgical or FFP2 masks, gloves, sanitising gel, thermo-cameras, temperature control service from an external company, infrared thermometers, solvency nasopharyngeal swabs, etc.).

Non-financial performance

The data given in the table below does not include the Group's temporary workers, who, as at 31/12/2018, numbered 34, whilst as at 31/12/2019, there were 41 and as at 31/12/2020, there were 38.

• Staff by company (GRI 102-8)

UoM 2020 2019 2018
CEMBRE Spa no. 453 452 447
CEMBRE Gmbh no. నికి 54 34
CEMBRE Ltd. no. 105 105 111
CEMBRE Sarl no. 32 30 26
CEMBRE SLU no. 42 42
CEMBRE Inc. no. 31 35 33

*The number of staff at IKUMA in 2018 and 2019 was added to the number of staff at CEMBRE GmbH.

The figure refers to the precise number of employees as at 31/12/2020.

. Staff by category (GRI 405-1)

20920 2019 2018
UoM Female Male Total Female Male lotal Female Male lotal
Managers no. O 20 20 O । ୧ 16 O 16
Executives no. 15 19 21 17 20
White collars no. 107 256 363 101 250 351 94 230 324
Blue collars no. 70 249 319 77 255 332 76 257 333
Total no. 181 540 - 721 182 538 720 - - 173 520 693

The CEMBRE Group sees diversity as a corporate asset and does not tolerate any form of discrimination based on differences in gender, age, health, nationality, political opinion or religious belief. The Company respects everyone's dignity, guaranteeing equal opportunities in all phases and for all aspects of employment. 25% of the workforce of the CEMBRE Group are women.

Members of the Board of Directors

UoM 2020 2019 2018
Female Male Total Female Male Total Female Male Total
<30 years 0 0 0 - 0 - 1 0
30-50 years z - - ന്നും അ
>50 vears Z - - 4 4
Total N 1 - 3 - 3 - 1 - 5 - 5 - 1 - 8 - 1 - 3 - 5 - 1 - 8 - 1 - 3 - 1 - 8 - 1 - 3 - 1 - 3 - 1 - 3 - 1 - 3 - 1 - 3 - 1 - 3 5

• Staff by age bracket (GRI 405-1)

2020 2019 2018
UoM Female Male Total Female Male Total Female Male Total
<30 years 82 196 - 96 - 1 - 15 ============================================================================================================================================================================== 104 104 - 104 118
30-50 years no. no. 307 414 - 414 109 - - - 299 408 - 1 105 - - 272 377

>50 years 58 54 144 198
Total no. no. no 181 - - - 540 721 182 - - - 538 173 - - 520 693

• Staff by age bracket and category (GRI 405-1)

UoM 2020 2019 2018
Female Male Total Female Male Total Female Male Total
Managers
<30 years no. 0 0 0 0 0 0 0 0 0
30-50 years no. 0 7 7 0 6 6 0 5 5
>50 years no. 0 13 13 0 10 10 0 11 11
rota no. 0 20 20 0 16 16 0 1 ୧ 16
Executives
<30 years no. 0 0 0 0 0 0 0 0 0
30-50 years no. 3 8 11 3 10 13 1 7 8
>50 years no. 1 7 8 1 7 8 2 10 12
lotal no. 4 15 19 4 17 21 3 17 20
White collars
<30 years no. 13 35 48 14 41 ર ર 13 45 58
30-50 years no. ୧୮ 150 215 62 138 200 ಲೆಕ 122 180
>50 years no. 29 71 100 25 71 ું જ 23 રેરિકેટ રેસ્ટિને સ્વિન્ડ 86
rota no. 107 256 363 101 250 351 94 230 324
Blue collars
<30 years no. 1 47 48 1 રેર રે રે 1 59 60
30-50 years no. 39 142 181 44 145 189 46 138 184
>50 years no. 30 ୧୦ 90 32 રે રે 87 29 60 89
Total no. 70 249 319 77 255 332 76 257 333

• Incoming staff (GRI 401-1)

2020 2019 2018
UoM Female Male Total Female Male lotal Female Male Total
<30 years no. 4 21 26 33 36 বাবা
30-50 years no. 21 26 15 35 50 6 20 26
>50 years no. o 13 8 10 5 10 15
Total no. 16 বীৰ 60 24 69 93 19 ୧୧ 85
Hiring rate 8.8% 8.1% 8.3% 13.2% 12.8% 12.9% 11.0% 12.7% 12.3%

• Incoming staff by geographical area (GRI 405-1)

2020 2019
UoM Fem
ale
Male Total Femal
e
Male lotal Femal
e
Male Total
Italy no. 5 16 21 က 24 27 6 30 36
Rest of Europe no. = 26 37 17 37 54 11 30 41
Rest of World no. 0 2 2 - 8 12 2 6 oo
lotal no. 16 60 93 19 - 66 85

• Outgoing staff4 (GRI 401-1)

2020
2019
UoM
Male Total Female
Male
Female
Total Female

10
14
18
22
2

no.
6
17
23
30
o
21
o
no.
15
7 -
22
15
19


no.
2018
Male Total
31
<30 vears 13 15
30-50 years 22
>50 years 18 22
Total no. 17 42 59 17 54 71 15 53 68
Turnover rate % 8.7% 9.8%

• Outgoing staff by geographical area (GRI 401-1)

UoM 2020 2019 2018
Female Male Total Female Male Total Female Male Total
Italy no. 13 20 18 5 22 27
Rest of Europe 10 10 1 1 23 33 - - - = 28 o 27 36
Rest of World no. 16 - 6 - 6 - 6 - 6 - 1 - 6 - 1 - 6 - 1 - 1 - 1 - 1 - 1 - 1 - 1 - 1 - 1 - 1 - 1 - 1 - 1 - 1 - 1 - 1 - 1 - 1 - 1 - 1 - 1 - 1 - 1 - 1 - 1 - 1 - 1 - 1 - 1 - 1 - 1 - 1 - 1 - 1 - 1 2 - 2 - 1 8 10 5
lotal no. 17 53 - - 68

• Staff by contract type (GRI 102-8)

UoM 2020 2019 2018
Female Male Total Female Male Total Female Male Total
Full time no. no. 531 152 529 515
Part time no. no. 31 40 - - -
30 -
9 39 - - 29 5 34
Total no. no. no. a 181 182 - - 538 173 520

41 should be noted that, in 2019, the Company introduced a new calculation method which considers employees who left as at 31 December of the reporting year in the workforce at year-end.

• Staff by contract term (GRI 102-8)

2020 2019 2018
UoM Female Male Total Female Male Total Female Male Total
Permanent 177 165
Fixed term no. no. and 17 - 17 - 21 - 17 - 1 5 21 2 26 2 2 2 8 8 41 41 49
Total no. 182 173

• Total average per capita training hours

UoM 2020 2019 2018
Female H 3.8 6.8 7.5
Male H 8.2 21.5 13.4
Total н 7.1 17.8 11.9

• Training hours by topic

UoM 2020 2019 2018
Manaqerial (inter-company general management, new courses to improve soft skills, etc.)
Managers h 0.0 40.0 69.0
Executives h 0.0 42.0 67.0
White collars h 846.0 299 5 2,118.0
Blue collars h 8.0 51.0 156.0
Total h 854.0 432.5 2,410.0
Plant maintenance and knowledge of technical systems
Managers h 0.0 42.0 0.0
Executives h 0.0 121.5 1.5
White collars h 86.0 1,190.0 186.5
Blue collars h 251.0 351.5 1,865.5
Total h 337.0 1,705.0 2,053.5
Technical-professional dedicated to knowledge of processes and systems
Managers h 65.0 221.0 5.0
Executives h 196.5 371.0 34.5
White collars h 1,232.0 4,075.0 543.5
Blue collars h 1,318.0 3,601.5 179.0
Total h 2,811.5 8,268.5 762.0
Compliance (code of conduct, model, internal control system on the corporate disclosure, etc.)
Managers h 5.0 ਰੇ 5 13.0
Executives h 8.0 11.0 69.0
White collars h 176.0 275.0 559.5
Blue collars h 18.0 138.0 93.4
Total n 207.0 433.5 734.9

Worker Health and Safety, Environment, Quality
Managers h 67.0 3.0 19.0
Executives h 21.5 42.0 48.5
White collars h 279.5 806.0 786.0
Blue collars h 554.0 1,106.0 1,449.8
Total h 922.0 1,957.0 2,303.3
Other
Managers h 0.0 0.0 0.0
Executives h 0.0 0.0 0.0
White collars h 0.0 0.0 1.0
Blue collars h 0.0 0.0 3.0
Total h 0.0 0.0 4.0
Total
Managers h 137.0 395.5 106.0
Executives h 226.0 507.5 220.5
White collars h 2,619.5 6,645.5 4,194.5
Blue collars h 2,149.0 5,248.0 3,746.7
Total h 5,131.5 12,796.5 8,267.7

With regard to human capital, the values refer to the situation as at 31/12/2020.

With respect to 2019, the total volume of training (the number of interventions, hours delivered, participations) has increased significantly in line with the strategic objectives of continuous improvement. In fact, 5,131.5 hours of training were provided in 2020, a decrease of compared to 7,665 hours in 2019, as only the mandatory safety training hours and the training hours of already active courses were provided.

It was not possible to add to the official data the hours of training carried out through the various free webinars offered on the network, as disseminating this information was not systematic.

The CEMBRE Group has never recorded any findings with regards to failure to respect human rights; all activities undertaken are carried out in compliance with the provisions of the Code of Ethics, which acknowledges respect for the person and their dignity as an essential principle of paramount importance in working for the Cembre Group.

Product labelling

(GRI 417-2)

In 2020, there were no cases of non-compliance with regard to information and labelling of products and services.

Health and safety management

Risks and opportunities

Health and safety in the workplace has, in recent years, become increasingly important. The growing sensitivity of businesses, also stimulated by some rather dramatic events that have shaken up public opinion, has led to the implementation of a series of procedures and the installation of tools able to reduce the risk of injuries and incidents at work, as far as possible. In addition to the dutiful attention paid to limiting danger situations, the importance of well-being in the workplace has been recognised, both in terms of protecting the worker and enhancing the efficiency of the business activity.

Careful attention is paid to the to the safety and health of both the worker and the customer using the products manufactured by the company: product quality is not measured purely in terms of the capacity to fulfill its purpose, but also in the capacity to prevent any injury to the user and guarantee comfortable use.

The CEMBRE Group has embraced this philosophy fully, seeking to mitigate the effects of the risks typical in this area:

  • · risk deriving from unsuitable working conditions in terms of worker health and safety, with the consequent risk of injury and occupational diseases;
  • · risk deriving from summonses to court, loss of reputation, payment of compensation, sanctions due to an unsafe workplace;
  • · risk of unsuitable control for the supervision of worker health and safety procedures and instructions;
  • · risk deriving from summonses to court, loss of reputation, payment of compensation, sanctions due to unsafe products;
  • · risk of hostile relations with workers with consequent strikes and downtime in production.

To mitigate and prevent these risks, the CEMBRE Group has implemented procedures and instructions within its Integrated Management System that take account of these effects under the OHSAS 18001 standard (the transition from the current OHSAS 18001 to ISO 45001 standard will take place in April 2021). This management system is monitored through internal and external audits and through the Management Review.

The policies applied by the CEMBRE Group

The CEMBRE Group aims to limit and eliminate risks to workers' health and safety as far as possible.

Following the Risk Assessment Document and preventing or at least mitigating the risks identified, CEMBRE implements the activities necessary to reduce such risks, such as the adoption of Individual Protection Devices (PPE) and the promotion of specific training opportunities.

CEMBRE, according to international models and best practices (CoSO Integrated Framework), has implemented its Management System to ensure risk prevention and monitoring, obtaining certification to the OHSAS 18001 standard for Workers' Safety (LRQA certification obtained by CEMBRE S.p.A. in 2012).

In addition to the legal requirements, the CEMBRE Group also pays careful attention to the workplace so as to ensure that work can be carried out in a safe, comfortable environment. Such attention specifically regards: management and maintenance of infrastructures and vehicles, cleaning, tidiness and hygiene at the workstations, definition of emergency and fire-fighting plans, training and information to employees on safety and the use of personal protection equipment of internal and external staff to ensure that they are aware of the importance of their work and their contribution towards maintaining and improving working conditions and the workplace.

CEMBRE calculates and constantly verifies indicators relating to near miss, incidents and injuries. These reports are collected and analysed to identify and implement corrective actions and monitored during the Management Review. As regards injuries, all reports are analysed with the aim of identifying a solution by which to limit dangerous situations and, if possible, avoid any recurrence of the injury. In this case, once a year (during the Management Review and Annual Worker Health and Safety Meeting), injury data is processed as required by standard UNI 7249:2007 and brought to the attention of the Management and internal and external entities with an interest in regard to the Company.

CEMBRE, under the principles set out in the Group's Code of Ethics, has developed a series of procedures and operating instructions to prevent accidents and injuries, such as the constant maintenance and replacement of machinery and facilities used to ensure a safe and comfortable working environment. In addition, fire and emergency plans are defined within the plant.

As regards its products, and therefore the health and safety of the end consumer, controls, checks and validations have been formalised and prescribed during the design stage, which can guarantee a response to customer needs (for example in terms of: fitness for purpose, practicality of use, ergonomics, safety, etc.) and compliance with the provisions of the law/applicable regulations (e.g. electromagnetic compatibility, noise, vibrations, etc.). The controls, which are established in all phases of the production processes, guarantee that the products developed are only released if compliant with project provisions.

No cases of non-conformity with the laws and/or regulations have been reported in the three-year period, in connection with products and services supplied by the CEMBRE Group.

Non-financial performance

• Injuries at work, injury rates

UoM 2020 2019 2018
Injuries at work no. 9 26 34
of which serious injuries no. O O 2
of which fatal injuries no. O O O
Hours worked no. 1,187,603 1,257,368 1,218,294
Injury frequency index ర్థం 7.58 20.68 27.90
Serious injury frequency index ರ್ಕಾ O O 1.64
Fatal injury frequency index ర్థి O O O

In 2020, there was a significant decline in the number of work-related accidents recorded within the Cembre Group. This was due to the effects of the Covid-19 pandemic on work, which caused both a decrease in the number of hours worked on site or plant and some plant shutdowns. These two aspects combined have led to a decrease in accidents.

The injury frequency index is calculated as the ratio of the number of injuries and the hours worked, multiplied by one million (-------------------------------------------------------------------------------------------------------------------------------------

There were 9 incidents (near misses) involving employees and contractors in 2020.

Most of the accidents that occurred during the period under review occurred on the footpath on the way from the ward to the exit of the company and therefore did not relate to the typical risk of the employee's job; in other cases, they involved minor injuries (bruises, cuts), which were treated inside the plants by the staff frained in first aid or by the company doctor.

The Cembre Group also uses external staff, whose commitment in 2020 amounted to 50,497 hours worked. It should be noted that only one accident occurred in 2020 in this category of employees.

In 2020, there were no cases of accidents on the road for transport organised by the Cembre Group.

Serious injuries are events that entailed a prognosis exceeding 6 months. There were no cases of serious accidents in 2020.

No fatal accidents occurred during the three-year period.

The CEMBRE Group does not have risk conditions higher than those in most engineering companies, the main ones of which are:

Overhead work, falling from heights

Circumstance that determines the presence of risk: Access and parking at raised work stations of machines / machinery and the relevant access steps. Use of portable steps. Occasional use of extensible moveable bridge.

Measures in place: mental and physical fithess certificate issued by the competent doctor. Information, training, education by external authorised companies and appointment of Employer. Work and emergency procedures. Special personal protective equipment periodically checked by an authorised external firm. Appropriate equipment. Adequately protected raised work stations.

Assisted handling of materials

Circumstance that determines the presence of risk: Handling of materials through electric pallet jacks or forklift trucks (risk of accident, crushing, collision, etc.).

Measures in place: Observance of the capacity of the equipment used. Anti-collision device of electric pallet jacks. Flooring suited to the nature of the processing which is not uneven or coarse. Adequate internal lighting. Suitable transit and operation areas for pallet jacks/forklift trucks. Regular maintenance checks by qualified personnel. Employee information, training and education. Work and emergency procedures.

· Moving machine parts - dangerous movement of machinery components during processing. Cuts and lesions

Circumstance that determines the presence of risk: Contact with dangerous moving parts of machine tools; risk of confinement in robotic islands and work areas accessible by machines.

Measures in place: Adequate safety devices (emergency buttons, safety micro-switches, protective casing, energy recovery protection devices, etc.). Suitable signage. Information, training, education. Periodic logged scheduled maintenance. Suitable personal protective equipment and work tools. Work and emergency procedures.

· Repetitive movements of the upper limbs and posture

Circumstance that determines the presence of risk; work activities that involve the risk from repetitive movements and efforts of the upper limbs.

Measures in place: in the activities subject to risk there is the possibility of switching work positions (seated, upright) to reduce the risk from fixed and prolonged postures. Pace of work determined autonomously by the worker.

There are adequate work breaks and recovery time during assembly activities. Information, training, education. Work procedures.

• Falling material from heights (lifting and handling of materials with overhead travelling crane).

Circumstance that determines the presence of risk: risk present during the phase of lifting and handling of materials with crane or during the handling of materials using pallet jacks from warehouses.

Measures in place: signage. Employee information, training, education (annual revaluation for the reconfirmation of internal certificate). Regular maintenance of lifting equipment, of limit switches, safety, coupling and harness devices. Periodic legal checks and periodic verification of lifting accessories. Respect for lifting capacities. Work and emergency procedures. Prohibition of parking in the operation areas of lifting equipment. Suitable Personal Protective Equipment.

Electrical

Circumstance that determines the presence of risk: risk of direct contact with live parts.

Measures in place: plant compliance with state of the art. Actions only on disconnected machines/systems: actions on machines/live systems reserved to specialised personnel with the necessary Personal Protective Equipment. Safety signage: electrical panel operations only permitted to authorised personnel, electrical panel hazard when live. Regular controls of the electrical equipment of machines by qualified personnel. Periodic checks of the earthing system. Work and emergency procedures.

As part of the improvement measures, in 2020, CEMBRE commissioned a qualified external technician to carry out a thermographic analysis to prevent electrical and fire risks using the infrared thermography method under the UNI EN ISO 9712 standard. The analysis was carried out on the plant's electrical transformer rooms, departmental electrical panels, and machinery/plants considered to be strategic (about 100 thermographs taken). The equipment analysed was found to be in good condition.

Management of the fight against corruption

Risks and opportunities

The fight against corruption is a duty for all businesses; indeed, all players should aim to guarantee that the market operates according to economic rules and is not influenced by opportunistic actions that do nothing else but increase the social costs of the business. The main risks connected with the failure to prevent corruption are:

  • · risk deriving from summonses to court, loss of reputation, payment of compensation, sanctions due to corruption committed by company functionaries:
  • risk of stipulating contracts at disadvantageous conditions, followed by corruption accepted to the benefit of company functionaries.

To limit the risk of acts of corruption occurring, the CEMBRE Group has established a multilevel authorisation system for payments and the management of financial resources, which places limits on the possibility of carrying out monetary transactions, beyond which approval by a superior is required. Every transaction is carried out against an approved expense document.

The policies applied by the CEMBRE Group

The Board of Directors defines the guidelines to the Internal Control and Risk Management System, intended as the set of processes aiming to monitor the efficiency of the company operations, the reliability of the financial information, compliance with laws and regulations and the safeguarding of company assets. In line with international models and best practices (COSO Report), CEMBRE's Internal Control System is based on the following key elements:

  • · Control environment: this is the environment in which the individuals operate and it represents the culture relative to control permeated within the organisation. It consists of the following elements: company organisation chart, system of delegations and powers of attorney, organisational provisions, public disclosure procedure of Inside Information, procedure for significant operations and with Related Parties, procedure for the fulfilment of Internal Dealing obligations, Administrative-Accounting Control Model and the Organisation, Management and Control Model pursuant to Italian Legislative Decree no. 231/2001, including the Code of Conduct, which is an integral part thereof.
  • · Control activities: it is the set of control rules and procedures put in place to allow the monitoring and control of corporate risks to reduce them to an acceptable level and ensure the achievement of corporate objectives. The activities are managed through the adoption of administrative and accounting control procedures: set of corporate procedures for the preparation and disclosure of accounting information (e.g. Group accounting manual, related administrative and accounting procedures and in particular financial statements and reporting in general, managerial accounting forms);

ಗರಿ

  • · Information and communication: is the process created to ensure the accurate and timely collection and communication of corporate information. With regards to the financial disclosure, the Administrative-Accounting Control Model adopted by the Company in accordance with Italian Law no. 262/2005 regulates the rules and procedures for the correct preparation of the accounting disclosure.
  • · Monitoring activities: is the set of activities necessary to verify and evaluate periodically the adequacy, operational efficiency and efficacy of internal controls.

The CEMBRE S.p.A. Risk Management System is described in the Corporate Governance Report. The Company takes an integrated approach to the risk of regulatory noncompliance. For the measures envisaged it such should occur, reference is made to the Organisation, Management and Control Model in accordance with Italian Legislative Decree no. 231/2001, which aims to prevent specific crimes from being committed by Company managers and all workers under their management and/or supervision, employees and/or collaborators, in the interests or to the benefit of the Company.

CEMBRE appoints the Supervisory Body to assess the adequacy and effectiveness of the Model, or rather its actual capacity to prevent the crimes and monitor the function and correct observance of the protocols adopted. At the request of said body, the Company has promptly updated the Model 231/01 and adjusted the control structure supervising it, according to the regulatory evolutions of the time.

At each Model update, a specific communication is made to all employees in this respect; the contractual clauses usually included in each contract with suppliers of goods and services envisage specific reference to the Code of Conduct, published on the company website.

The Code of Conduct defines the ethical standards and values upheld and embraced by the Group and which, accordingly, must be upheld and embraced by all subjects with which the CEMBRE Group operates. In general, as regards the methods identified for training, there is a specific paragraph in the Model 231, which regulates training and information of employees in respect of the Model, using both classroom training and elearning methods, with final learning test/questionnaire.

CEMBRE has also defined its own Accounting-Administrative Control Model in compliance with Italian Law no. 262/05, within which indications are given as the rules adopted to manage risk and internal control in respect of the financial disclosure process, as an integral part of the company internal control system.

In line with the Group's Code of Conduct, all subsidiaries adopt anti-corruption risk policies, in particular by limiting the circulation of money and applying centrally defined procedures. The Group companies are periodically subject to internal auditing activities to verify compliance with and the functioning of the controls required by the procedures.

Non-financial performance (GR) 205-3)

As also confirmed by the Supervisory Body, no acts of corruption have been recorded within the Company CEMBRE S.p.A., nor within any of its subsidiaries, nor have any reports been made in this respect.

Supply chain management

Risks and opportunities

The specificity of the products, intended for a market of highly-specialised users, and the need for the rigorous respect of high quality standards in the procurement of products and services, are characteristics that often lead to the need for a commercial relationship with a limited number, in some cases even just one, of suppliers. CEMBRE's aim is to minimise the risk deriving from sudden shortages of supply by means of a continuous search for alternative "sources" and constantly expanding upon its technical and production potential.

CEMBRE carefully makes sure that all players in the supply chain operate in complete compliance with workers' rights and environmental problems, thereby opting, for companies operating in social contexts and geographic areas in which there is a greater sensitivity towards these matters.

In this area, the greatest risks to which CEMBRE is exposed are:

  • . risk deriving from suppliers that do not respect and maintain suitable environmental sustainability standards and whose production process has significant effects on the environment;
  • . risk deriving from suppliers that do not comply with the ethical standards and standards of conduct required by the Company, such as failure to respect human rights or social standards required by the business;
  • . risk of involving the Company in unlawful deeds (corruption) by company staff, including in supplier complicity.

To prevent these risks, the CEMBRE Group limits its relationships with companies involved in violations or presumed violations of regulations in force on workers' rights, respect for the environment and anti-corruption.

Orders and supply contracts specifically require compulsory adhesion to and compliance with the CEMBRE's Code of Conduct, which is published on our official website. Failure to comply with the provisions of the Code of Conduct results in the immediate termination of contracts and the revocation of any orders in place.

The policies applied by the CEMBRE Group

Group procurement takes place in compliance with procedures prepared to guarantee the uniformity and repetitiveness of the activity, as well as supplier compliance in terms of quality and respect for ethical standards and environmental protection.

More specifically, the Purchasing Office has the task of identifying potential new suppliers to be included in the procurement process, so as to guarantee CEMBRE competitiveness, continuity of supply and high product quality.

All potential suppliers to the Company, both services, and products, are subjected to an initial "qualification" process through a "prior assessment checklist" to determine the supplier's ability to meet all requirements.

More specifically, the aim is to highlight the supplier's ability to ensure transparent processes with suitable standards of environmental sustainability, respect for the ethical principles and conduct required by CEMBRE, such as respect for human rights, anticorruption or social standards imposed by the business, and enjoy an adequate reputation in the media.

Where possible, preference is given to suppliers with environmental or safety management systems that meet international standards or are certified.

The information collected during this phase is used in obtaining the final result of supplier approval.

From the time of supplier approval, specific audits may be scheduled to verify continuity in compliance with qualification principles and standards. Alternatively, suppose the Head of the Integrated Management System or the Head of the Procurement Department deems it necessary. In that case, they may request the performance of extraordinary audits if elements that contradict or prejudice what is evaluated during the validation phase emerge to minimize the associated risks.

The conformity of the REACH Directive, i.e. the integrated management system of chemical substances, is validated and monitored by means of a computerised work flow of assessment and approval prior to the first procurement of the actual product.

A specific automated electronic archiving procedure of the Safety Data Sheets allows for constant monitoring of the obsolescence of said sheets and guarantees that they are available to product users for rapid consultation, where needed.

Archiving also involves the entry of data relative to the product, such as: the using department, the methods of use, the quantity used and the date of archiving, which determines the period for which the Safety Data Sheets are valid, beyond which the supplier must be asked to update the documentation (validity is set to 3 years).

Most of the procurement takes place through companies operating in the EU and with a consolidated financial position; these facts help limit the risks relating to the exploitation of child labour, failure to respect gender differences and environmental problems.

CEMBRE S.p.A. uses tin in its manufacturing process, which comes under the scope of materials potentially coming from zones of conflict. In order to avoid this situation, CEMBRE has decided to adopt the definitive rules on "Conflict Minerals." Under the principles of social responsibility, human rights and discrimination set out in the Code of Ethics. The CEMBRE Group is committed to ensuring that the metals it purchases are "conflict-free."

Non-financial performance

UoM 2020 2019 2018
Procurement expenses 56,137,530 66,619,283 77,443,880
of which local suppliers 37,698,818 45,269,777 55,594,100
Local percentage of total % 67.15% 67.95% 71.79%
UOM 2020 2019 2018
Procurement expenses 12,337,747 14,436,181 15,317,995
of which local suppliers 2,944,020 3,197,723 3,815,518
Local percentage of total % 23.86% 22.15% 24.91%
UoM 2020 2019 2018
Procurement expenses 7,310,007 8,185,028 7,927,489
of which local suppliers 1,211,431 1,152,108 1,337,321
Local percentage of total 76 16.57% 14.08% 16.87%
2018
7,103,999
529,132
7.45%
UoM 2020 2019 2018
10,938,397
of which local suppliers 839,486 1,544,670 2,582,945
Local percentage of total 76 6.89% 14.3% 23.6%
UoM 2020 2019 2018
Procurement expenses 4,789,968 7,009,036 8,390,603
of which local suppliers
%
720,618 795,354 519,866
Procurement expenses
of which local suppliers
Local percentage of total
Procurement expenses
UoM


%
2020
7,565,229
637,273
8.42%
12,177,137
2019
7,990,053
426,938
5.34%
10,811,816

Local suppliers are companies whose business is located in the same country as the CEMBRE Group companies to which the table data is referred.

Management of legal and fiscal matters

Risks and opportunities

CEMBRE is subject to a series of regulatory obligations and precepts issued by the supervisory authorities of the countries in which the Group operates; there is a risk of non-compliance with regulations with repercussions in terms of sanctions and loss of reputation.

In order to have better visibility of the relevant regulations to which CEMBRE is subject and required to comply, as well as to assess possible business impacts/opportunities, a "Group Legal and Corporate Affairs Office" was set up in January 2020. This Office is also responsible for coordinating the Group's legal advisors in the various countries where it operates and for monitoring legal compliance at the Group level.

CEMBRE takes all the necessary steps to ensure adequate supervision and timely compliance with these regulations with specific regard to tax regulations. To this end, each Group company is organised in such a way as to have independent administrative and tax management at a local level with administrative staff employed by every single company who also work with local tax consultants in order to be able to be promptly updated and comply with the tax regulations of every single country in which the Group operates.

The policies applied by the CEMBRE Group

CEMBRE is an industrial Group whose main activity is the design, manufacture, and sale of its products; business considerations and not fiscal reasons gear the choice of countries in which the Group operates.

The Group's values are in line with its sustainability strategy; the Group acts according to the values of honesty and integrity in the management of tax activities, being aware that tax revenues are one of the primary sources of contribution to the economic and social development of the countries in which it operates. The Cembre Group's whistleblowing can also be used to report any critical issues arising from unethical or illegal conduct or episodes that undermine the organization's integrity in tax matters.

All Group companies must comply with the principle of legality, promptly applying the tax legislation of the countries in which the Group operates; this ensures that it dictates the spirit and purpose that the law or order provides for the subject matter being applied is observed.

To date, the Cembre Group has not received any particular solicitation from its stakeholders regarding taxation. If this were to happen, these reports would be handled by the corporate departments responsible for managing tax compliance matters.

Relations with tax authorities are based on correctness principles and compliance with specific regulations applied in each of the Cembre Group countries. It should also be noted that the Group does not engage in any tax advocacy activities.

Non-financial performance

• Country by Country Tax Reporting (GRI 207-4)

CEMBRE SpA CEMBRE GmbH CEMBRE Ltd CEMBRE Sarl CEMBRE SLU CEMBRE Inc
Assets Manufacturing
and distribution
Commercial Manufacturin
g and
distribution
Commercial Commercia Commercial
number of
employees
453 રેક 105 32 42 31
(euro '000)
Revenues from
sales to third
parties
€ 73,578 € 15,587 € 16,688 € 9,557 € 11,107 € 10,620
Intragroup
revenues
€ 27,831 € 75 € 1,518 € 192 € 5 € 43
Profit/loss before
tax
€ 21,217 € 380 € 1,772 € 379 € 666 € 595
Tangible assets € 74,108 € 2,822 € 4,444 € 405 € 2,583 € 531
Income taxes
cash criterion
€ 3,518 € 155 € 268 € 165 € 300 € 30
Income tax on
profits/losses
€ 4,926 € 8 € 268 € 138 € 175 € 126

Methodological note

The Consolidated non-financial declaration of the CEMBRE Group has been prepared in accordance with Italian Legislative Decree 254/2016 as amended and according to the GRI Sustainability Reporting Standards published in 2016 by the Global Reporting Initiative (GRI) - In accordance approach - Core.

The GRI Standards envisage that the Declaration shall contain information on the aspects considered as material, as they may have significant impacts on the organisation from a social, economic and environmental viewpoint and may substantially influence stakeholder considerations and decisions.

The collection of data and information required to prepare this Document, was carried out by various different company departments, according to the following principles laid down by the GRI Standard:

  • · accuracy: the data and information included in the Declaration has been verified by the respective department managers, so as to validate its accuracy and authenticity;
  • · timeliness: the Consolidated non-financial declaration will be published once a year, at the same time as the Annual Financial Report;
  • · comparability and clarity: in preparing the Consolidated non-financial declaration, clear, concise language was used, along with tables and graphs, so as to ensure that it is understood by all stakeholders. The information included in the report refers to the period running between 01/01/2020 and 31/12/2020. Where available, the data relating to the previous years has been included, so as to allow for an assessment of the trend of Group operations over the medium-term. Any alsence of such a comparison is due to the lesser relevance of the performance over the years or the impossibility of recovering information relative to previous years. Finally, as regards the quantitative information given in the Declaration for which estimates were used, this detail is duly noted in the various chapters;
  • · balance: the data and information given in the Declaration has been portrayed realistically and in a timely manner; indicators reflect the Group's performance in the reporting period;
  • · reliability: the Consolidated non-financial declaration has been prepared by a specifically-formed working party, whose members have been identified from the various Group company departments and who have validated the contents with respect to their areas of competence. The final document, as a whole, was presented to and discussed and approved by the Board of Directors on 11 March 2021.

The Consolidated non-financial declaration has been subject to a limited audit by the independent auditing firm, EY S.p.A.

Unless otherwise specified in each chapter, the data and information of this Declaration refer to the Companies belonging to the CEMBRE Group as at 31 December 2020, fully consolidated within the Annual Financial Report. The Italian offices and warehouses used exclusively for commercial purposes have been excluded from the perimeter of reporting, as their impact on said indicators is not relevant.

Within the document, where necessary, specific notes are made regarding changes to the 2018 and 2019 data.

The Group has prepared a formalised procedure for the Consolidated Non-Financial Declaration, which will define the roles, responsibilities and method of information collection for the drafting of said Statement. The procedure was approved in November 2020.

The contact person for the NFD of Cembre S.p.A. located in Brescia at Via Serenissima, 9 is Luigi Vitelli ([email protected]), a copy of the 2020 NFD is available on the website www.cembre.com

Please note that the last document published, prior to this document, is the 2019 Consolidated Non-Financial Declaration (NFD).

Brescia, March 11, 2021

FOR THE BOARD OF DIRECTORS OF THE PARENT COMPANY CEMBRE S.P.A. Chair and Managing Director

Giovanni Rosani

APPENDICES

Table of correlation between the CEMBRE material topics and GRI aspects

Scope of impacts
Theme of
Italian
Legislative
Decree no.
254/2016
Material theme Topic specific GRI
Standard
Impacts
inside the
Group
Impacts outside the Group
Raw materials
management
GRI 301 - Materials
Energy efficiency GRI 302 – Energy
Water and waste
management
GRI 303 - Water Entire Group
Emissions
management
GRI 305 - Emissions (particularly
CEMBRE Spa
Suppliers
Environmental Compliance and
risk management
GRI 307 -
Environmental
compliance
and CEMBRE
Ltd)
Waste GRI 306 - Effluents
management
Management of
the effects of the
activity on the
ecosystem.
and waste
GRI 304 - Biodiversity
CEMBRE Spa
and CEMBRE
Ltd
Social Economic value
obtained and
distributed
GRI 201 - Economic
performance
Entire Group
Economic value
due to taxes
GRI 207 - Taxes Entire Group
Compliance and
risk management
GRI 419 - Socio-
economic
compliance
Entire Group
Customer health
and safety
GRI 416 - Customer
health and safety
Entire Group Sales network
Product labelling GRI 417 - Marketing
and labelling
Entire Group Sales network
Sustainability of
the supply chain
GRI 204 -
Procurement
practices
Entire Group
Relating to
staff
Human resources
management
GRI 401 - Employment
GRI 102 - General
disclosures
Personnel framing
and
development
GRI 404 - Training and
education
Entire Group
Protection of
diversity
GRI 405 - Diversity
and equal
opportunity
GRI 406 - Non-
discrimination
Worker health
and safety
GRI 403 -
Occupational health
and safety
Entire Group Suppliers

Respect for
human rights
Human rights GRI 406 - Non-
discrimination
Entire Group Suppliers
Fight against
corruption
Anti-corruption
procedures and
policies
GRI 205 - Anti-
corruption
Entire Group Suppliers and Sales network

The matter of Sustainable Governance is transversal to all areas of Italian Legislative Decree no. 254/2016 and all GRI Standards and is dealt with in this Declaration with reference to General Disclosure 102-18.

The matter 'Research and development of sustainable products' is the only non-GRI matter in the NFD.

The reporting is not extended to the scope outside the Group.

GRI Standards correspondence table

GRI Standard Disclosure Description Page Omissions - Notes
GRI 102 -
General
disclosures
102-1 Name of the organisation Cover page
102-2 Activities, brands, products
and services
6-7
102-3 Location of headquarters Back cover
102-4 Location of operations 8
102-5 Ownership and legal form 10
102-6 Markets served 11-12
102-7 Scale of the organisation 9
102-8 Information on employees
and other workers
39-42
102-9 Supply chain 52
102-10 Significant changes to the
organisation and its supply
chain
7 No significant
changes were made
to the organisation
102-11 Principle of prudence 14
102-12 External initiatives 37
102-13 Membership in Associations 38
102-14 Statement by a senior
executive
3-4
102-15 Key impacts, risks and
opportunities
14-15-16, 59
102-16 Values, principles, standards
and norms of behaviour
3-4, 6
102-18 Governance structure 10
102-40 List of stakeholder groups 17-19
102-41 Percentage of total
employees covered by
collective bargaining
agreements
34
102-42 Identification and selection of
stakeholders
17
102-43 Stakeholder engagement
modalities
17-19
102-44 Key issues and critical points
raised
19-21
102-45 Entities included in the
organisation's consolidated
financial statements or
equivalent documents
There are no
differences in scope
102-46 Defining report content and
topic boundaries
28
102-47 List of material topics 19-21, 59
102-48 Review of information 28
102-49 Changes in the list of material
topics and related scope
19-21, 59
102-50 Reporting period 57
102-51 Date of most recent report 59
102-52 Reporting cycle Annual

(10) CEMBRE

GRI Standard Disclosure Description Page Omissions - Notes
102-53 Contact details for enquiries
regarding the report
59
102-54 Claims of reporting in
accordance with the GRI
Standards
57
102-55 GRI content index 61
102-56 External assurance ୧୧ Audit report of the
independent auditors
GRI 201 - Economic
performance 2016
103-1
103-2
103-3
Management approach 13, 20-21
201-1 Direct economic value
generated and distributed
13
GRI 204 -
Procurement
103-1
103-2
103-3
Management approach 20-21, 52-
ર્ટિક
practices 2016 204-1 Proportion of spending on
local suppliers
54
GRI 205 - Anti- 103-1
103-2
103-3
Management approach 20-21, 49-
50
corruption 2016 205-3 Confirmed incidents of
corruption and actions taken
51 There were no
confirmed incidents of
corruption in 2020
103-1
103-2
103-3
Management approach 20-21, 55-
ર્ફર્
GRI 207- 207-1 Tax approach 55-56
2019 Taxes 207-2 Tax governance, control and
risk management
55-56
207-3 Stakeholder involvement and
management of tax concerns
55-56
207-4 Country-by-Country Report ર્સ્વિ
GRI 301 - Materials
2016
103-1
103-2
103-3
Management approach 20-24
301-1 Materials used 55
GRI 302 - Energy 103-1
103-2
103-3
Management approach 20-24
2016 302-1 Energy consumption within
the organisation
26
302-3 Energy intensity 27
GRI 303 - Water 2018 103-1
103-2
103-3
Management approach 20-24
303-1 Interacting with water as a
shared resource
27-28
303-2 Management of impacts
related to water discharge
27-28
303-3 Water withdrawal 27
GRI 304 - Biodiversity 103-1
103-2
103-3
Management approach 20-24
2016 304-1 Operational sites owned,
leased, operated in (or
22-23

(10) CEMBRE

GRI Standard
Disclosure
Description Page Omissions - Notes
adjacent to) protected areas
and areas of high biodiversity
value outside protected areas
103-1
GRI 305 - Emissions
2016
103-2
103-3
Management approach 20-24
305-1 Direct (Scope 1) GHG
emissions
28
305-2 Indirect (Scope 2) GHG
emissions
28
305-7 Nitrogen oxides (NOx), sulphur
oxides (SOx) and other
significant air emissions by
type and weight
29
GRI 306 - Effluents
and waste 2016
103-1
103-2
103-3
Management approach 20-24
306-2 Waste by type and disposal
method
30-31
GRI 307 -
Environmental
compliance 2016
103-1
103-2
103-3
Management approach 20-24
307-1 Non-compliance with
environmental laws and
regulations
In 2020 no non-
compliance with
environmental laws
and regulations was
detected
GRI 401 -
Employment 2016
103-1
103-2
103-3
Management approach 20-21, 32-
34
401-1 New employee hires and
employee turnover
40-41
GRI 403 -
Occupational health
and safety 2018
103-1
103-2
103-3
Management approach 20-21, 44-
46
403-1
403-2
403-3
403-4
403-5
403-6
403-7
Management approach 43. 44-48
403-9 Injuries at work 46
GRI 404 - Training
and education 2016
103-1
103-2
103-3
Management approach 20-21, 34-
37
404-1 Average hours of training per
year per employee
42-43
GRI 405 - Diversity
and equal
opportunity 2016
103-1
103-2
103-3
Management approach 20-21, 32-
34
405-1 Diversity of governance
bodies and employee
categories
39-41
GRI 406 - Non-
discrimination 2016
103-1
103-2
103-3
Management approach 20-21, 32-
34

(1) CEMBRE

GRI Standard
Disclosure
Description Page Omissions - Notes
406-1 Incidents of discrimination
and corrective actions taken
No cases of
discrimination were
reported in 2020
GRI 416 - Customer
health and safety
2016
103-1
103-2
103-3
Management approach 20-21. 45-
46
416-2 Incidents of non-compliance
concerning the health and
safety impacts of products
and services
There were no
incidents of product
non-compliance in
2020
GRI 417 - Product
labelling
103-1
103-2
103-3
Management approach 20-21. 45-
46
417-2 I abel information non-
compliance
There were no cases
of non-compliance in
2020.
GRI 419 - Socio-
economic
compliance 2016
103-1
103-2
103-3
Management approach 20-21. 45-
46
419-1 Non-compliance with laws
and regulations in the social
and economic area
There were no cases
of non-compliance
with social and
economic regulations
in 2020
Non-GRI matters Disclosure Description Page Omissions - Notes
Research and
development of
sustainable products
103-1
103-2
103-3
Management approach 20-24

EY S.p.A. Corso Magenta, 29 25121 Brescia

Tel: +39 030 2896111 Fax: +39 030 295437 ey.com

Independent auditors' report on the consolidated disclosure of nonfinancial information in accordance with Article 3, par. 10, of Legislative Decree 254/ 2016 and with Article 5 of CONSOB Regulation adopted with Resolution n. 20267 of January 18, 2018

(Translation from the original Italian text)

To the Board of Directors of Cembre S.p.A.

We have been appointed to perform a limited assurance engagement pursuant to Article 3, paragraph 10, of Legislative Decree 30 December 2016, n. 254 (hereinafter "Decree") and article 5 of CONSOB Regulation adopted with Resolution 20267/ 2018, on the consolidated disclosure of nonfinancial information of Cembre S.p.A. and its subsidiaries (hereinafter the "Group" or " Cembre Group" ) for the year ended on December 31, 2020 in accordance with article 4 of the Decree and approved by the Board of Directors on March 11, 2021 (hereinafter "DNF").

Responsibilities of Directors and Board of Statutory Auditors for the DNF

The Directors are responsible for the preparation of the DNF in accordance with the requirements of articles 3 and 4 of the Decree and the " Global Reporting Initiative Sustainability Reporting Standards" defined by GRI – Global Reporting Initiative (hereinafter "GRI Standards" ), identified by them as a reporting standard.

The Directors are also responsible, within the terms provided by law, for that part of internal control that they consider necessary in order to allow the preparation of the DNF that is free from material misstatements caused by fraud or not intentional behaviors or events.

The Directors are also responsible for identifying the contents of the DNF within the matters mentioned in article 3, par. 1, of the Decree, considering the business and the characteristics of the Group and to the extent deemed necessary to ensure the understanding of the Group's business, its performance, its results and its impact.

The Directors are also responsible for defining the Group's management and organization business model, as well as with reference to the matters identified and reported in the DNF, for the policies applied by the Group and for identifying and managing the risks generated or incurred by the Group.

The Board of Statutory Auditors is responsible, within the terms provided by the law, for overseeing the compliance with the requirements of the Decree.

Auditors' independence and quality control

We are independent in accordance with the ethics and independence principles of the Code of Ethics for Professional Accountants issued by the International Ethics Standards Board for Accountants, based on fundamental principles of integrity, objectivity, professional competence and diligence, confidentiality and professional behavior. Our audit firm applies the International Standard on Quality Control 1 (ISQC Italia 1) and, as a result, maintains a quality control system that includes documented policies and procedures regarding compliance with ethical requirements, professional standards and applicable laws and regulations.

Auditors' responsibility

It is our responsibility to express, on the basis of the procedures performed, a conclusion about the compliance of the DNF with the requirements of the Decree and of the GRI Standards. Our work has been performed in accordance with the principle of "International Standard on Assurance Engagements ISAE 3000 (Revised) - Assurance Engagements Other than Audits or Reviews of Historical Financial Information" (hereinafter "ISAE 3000 Revised"), issued by the International Auditing and Assurance Standards Board (IAASB) for limited assurance engagements. This principle requires the planning and execution of work in order to obtain a limited assurance that the DNF is free from material misstatements. Therefore, the extent of work performed in our examination was lower than that required for a full examination according to the ISAE 3000 Revised ("reasonable assurance engagement") and, hence, it does not provide assurance that we have become aware of all significant matters and events that would be identified during a reasonable assurance engagement.

The procedures performed on the DNF were based on our professional judgment and included inquiries, primarily with company's personnel responsible for the preparation of the information included in the DNF, documents analysis, recalculations and other procedures in order to obtain evidences considered appropriate.

In particular, we have performed the following procedures:

    1. analysis of the relevant matters in relation to the activities and characteristics of the Group reported in the DNF, in order to assess the reasonableness of the selection process applied in accordance with the provisions of article 3 of the Decree and considering the reporting standard applied;
    1. analysis and evaluation of the criteria for identifying the consolidation area, in order to evaluate its compliance with the provisions of the Decree;
    1. comparison of the economic and financial data and information included in the DNF with those included in the Cembre Group's consolidated financial statements;
    1. understanding of the following aspects:
    2. o Group's management and organization business model, with reference to the management of the matters indicated in the article 3 of the Decree;
    3. o policies adopted by the Group related to the matters indicated in the article 3 of the Decree, results achieved and related key performance indicators;
    4. o main risks, generated or suffered related to the matters indicated in the article 3 of the Decree.

With regard to these aspects, we obtained the documentation supporting the information contained in the DNF and performed the procedures described in item 5. a) below

  1. understanding of the processes that lead to the generation, detection and management of significant qualitative and quantitative information included in the DNF. In particular, we have conducted interviews and discussions with the management of Cembre S.p.A. and we have performed limited documentary evidence procedures, in order to collect information about the processes and procedures that support the collection, aggregation, processing and transmission of non-financial data and information to the management responsible for the preparation of the DNF.

Furthermore, for significant information, considering the Group activities and characteristics:

  • at Group level

  • a) with reference to the qualitative information included in the DNF, and in particular to the business model, policies implemented and main risks, we carried out inquiries and acquired supporting documentation to verify its consistency with the available evidence;
  • b) with reference to quantitative information, we have performed both analytical procedures and limited assurance procedures to ascertain on a sample basis the correct aggregation of data.
  • for the site of Brescia of Cembre S.p.A., that we have selected based on its activities, relevance to the consolidated performance indicators and location, we have carried out remote interviews during which we have had discussions with management and have obtained evidence about the appropriate application of the procedures and the calculation methods used to determine the indicators.

Conclusion

Based on the procedures performed, nothing has come to our attention that causes us to believe that the DNF of the Cembre Group for the year ended on December 31, 2020 has not been prepared, in all material aspects, in accordance with the requirements of articles 3 and 4 of the Decree and the GRI Standards.

Brescia, March 24, 2021

EY S.p.A.

Signed by: Stefano Colpani, Auditor

This report has been translated into the English language solely for the convenience of international readers.

CEMBRE SpA

Via Serenissima, 9 · 25135 Brescia ITALY Ph +39 030 3692.1 • Fax +39 030 3365766 www.cembre.com · [email protected]