Environmental
management

Corporate environmental issues are strategic issues in the aerospace industry as a whole, and especially in the company, as well as a key aspect of our commitment to the environment.

The Environmental Policy, integrated with the Occupational Health and Safety Policy, approved by the Board of Directors, includes the commitment to comply with the applicable environmental legislation in force and to minimize the environmental impact that could be caused. This text defines the people's life and health, and the environmental quality as one of the key pillars of Aciturri's operations, and supports the fulfillment of Human Rights, especially with regard to Article 3 ("Everyone has the right to life, liberty and security of person").

Aciturri minimizes its environmental footprint through the sustainable use of natural resources, thanks to efficient and controlled manufacturing processes.

This policy is public internally, through Nexo, and presented in the welcome processes, and externally, through the website.

Specifically, contractors who access Aciturri's facilities receive it through the access management application.

The company has an Environmental Management System, designed and implemented in accordance with the UNE-EN-ISO 14001:2015 standard, covering all companies and facilities (certified by a third party in 90% of the working centers). This management system allows for systematically managing the environmental variable, ensuring compliance with applicable legal requirements and self-imposed impact minimization commitments, assigning responsibilities at different levels of the organization. It includes a series of operating procedures, which allow the integration of the commitments of the Environmental Policy into the day-to-day operations of the organization.

The company operates with an Environmental Management System, designed and implemented in accordance with the UNE-EN-ISO 14001:2015 standard, covering all companies and facilities.

The participation of the entire workforce is sought, through the necessary information and training so they are aware of and carry out safe and responsible practices, with the aim of promoting a true preventive and environmental culture, focused on the continuous improvement of both working and environmental conditions. Likewise, the Safety, Health and Environment Committees actively participate in environmental objectives, policies and actions, as stated in the Health and Safety section.

Aciturri extends the principles of its Environmental Policy to subcontractors and the supply chain, as stated in the text itself, providing its support and knowledge in preventive and environmental management, in those operations derived from its relationship with the company.

In the context of the environmental management system, following the procedure established for the identification and evaluation of environmental aspects, an evaluation of environmental impacts and risks is performed every year. For those aspects and impacts that are significant or not assumable, mitigation plans are designed and implemented. The results of the 2022 assessment are shown in the table.

Identification and assessment

of environmental aspects

Facility	Significant environmental aspects	Significant environmental risks
Ayuelas	Consumption of Ardrox 9813, Ardrox 9881, Ardrox 9703, Ardrox9PR5, acetone, universal solvent water-based paint. Chromium water wastes, machining sludge, painting booth filters and sealants and adhesives. Chloride and conductivity discharges.	Risk of non-compliance with discharge limits.
Berantevilla	Diesel oil and isopropyl alcohol consumption. Nitrate discharges.	spillover.
Logistics	Diesel oil consumption.	No significant environmental risk.
Boecillo	Isopropyl alcohol, liquid release agent, solvent, paint and water-based paint consumption. VOC emissions and noise.	No significant environmental risk.
Tres Cantos	Natural gas consumption. Painting booth filters residues. VOC emissions.	No significant environmental risk.
Assembly	Paint booth filter wastes and urban solid wastes. VOC emissions.	No significant environmental risk.
Additive	No significant environmental issues.	No significant environmental risk.
Orón	Resin waste.	spillover.
Ircio	Solvent waste.	spillover.
Getafe	Release agent, paint and thinner consumption.	No significant environmental risk.
Aerópolis	Isopropyl alcohol, toluene, diestone, paint and thinner consumption.	No significant environmental risk.

According to this analysis, there are no impacts on biodiversity or protected areas, so no specific actions aimed at restoring or preserving them have been implemented.

Aciturri's Environment Department has the necessary resources for adequate environmental management. Specifically, a coordinator, an environmental technician assigned to the plants in Castilla y León, Álava and Madrid, and another one for Seville (with 25% of his working day dedicated to this task). All the plants have, within the emergency organization, resources designated for the action and containment of possible spills or environmental accidents.

During 2022 no fines or penalties were imposed for non-compliance with environmental regulations.

Aciturri's activity is covered by the scope of Law 26/2007 on Environmental Responsibility. According to TEC Order/1023/2019, of October 10, the Ayuelas facility is within priority group III, so a risk assessment was carried out to determine the amount of the financial guarantee to be established.

Following the methodology of the reference regulations and using the tools implemented by the Ministry of Ecological Transition and the Demographic Challenge, the IDM (Environmental Damage Index in spanish) was calculated. The result of this calculation was 646,122 € for the reference scenario (loss in APQ, storage of chemical products). Thus, taking into account the exclusions defined in article 28 of the Environmental Liability Law, it was not necessary to establish a financial guarantee, since the company has an Environmental Management System certified according to ISO 14001.

During 2022 there have been no fines or penalties for non-compliance with environmental regulations.

"Let's talk about carbon" project has allowed the environmental area to think with the rest of the company's departments about the climate change impact of our decisions.

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