Sustainability

Enviri’s environmental program is executed by the Company’s 100+ member Environmental, Heath, and Safety (EHS) team, and supported by other Company functions and external consultants. The EHS team is responsible for implementing Enviri’s environmental policy and ensuring environmental compliance at Enviri sites. To support implementation, the EHS team utilizes an environmental management system to manage regulatory compliance, internally report environmental incidents across the Company’s operations, and manage corrective actions to address incidents. In addition, fifty-seven of our facilities around the globe are ISO 14001 certified, the leading environmental management standard in the industry. Key environmental issues monitored and managed by the EHS team include climate change and GHG emissions, energy use and management, air quality and management, waste and hazardous materials management, and water and wastewater management. 

Evaluation of environmental risks and opportunities are evaluated on a quarterly basis through Enviri’s enterprise risk management process and are reported to the Board of Directors’ Audit Committee at the Company’s quarterly board meetings. Oversight for ESG issues is provided by the Governance Committee of our Board of Directors. Environmental concerns are integrated into the Company’s decision-making processes, including the evaluation of new investments and mergers and acquisitions. We also perform audits of our operations’ environmental compliance and performance through our Internal Audit team and our Enviri Way Assessments, which target a review of every Enviri facility every two to three years.

Our vision is to be a global leader of environmental solutions. In recent years, we have moved to formalize our focus on environmental solutions and to reconfigure our portfolio through acquisitions and divestitures to transform into a global, market-leading, single-thesis environmental solutions platform. In 2019, we took two giant and simultaneous steps forward in that process. We announced a rebrand of our Metals & Minerals division into Harsco Environmental. The second major step was our acquisition of Clean Earth, one of the largest independent specialty waste companies in the United States. In April 2020, we made another strategic investment, acquiring Stericycle’s Environmental Solutions business, increasing our geographic scale and reach while enabling us to create a leading national hazardous waste management platform. With these changes, 100 percent of Enviri’s total revenue comes from environmental services, compared to just 67 percent in 2016. In 2019 and 2020, Enviri’s industry classification has been changed to waste management or environmental services by leading industry classification standards including the Global Industry Classification Standard and Industry Classification Benchmark.

Our treatment, recycling and repurposing of industrial waste and byproducts help accelerate the circular economy, preserve natural resources and reduce carbon emissions. For example, our Environmental division’s core business is focused on helping our steel and aluminum customers manage their environmental challenges and meet their environmental goals. Harsco Environmental’s solutions currently help our customers:

• Increase the recycled content in steel and aluminum production
• Reduce or eliminate material sent to landfill
• Reduce carbon emissions from the production process
• Reduce dust emissions, improve air quality, and use less water

We estimate the recycling activities and value-added products of Harsco’s Environmental division in 2021 contributed to the avoidance of over 6 million metric tons of carbon emissions. This benefit can be passed on to our customers and helps contribute to a lower-carbon, circular economy.

We strive to improve our environmental footprint through operational efficiency and continuous improvement efforts. In 2020, we set our first enterprise energy and carbon emissions reduction goal to reduce the energy and carbon intensity of our operations by 15% by 2025. In addition, our divisions set sustainability and environmental goals relevant for their businesses. For example, in 2019 the Continuous Improvement team in our Environmental division targeted a 2.5 percent reduction in diesel fuel use, the largest source of energy in its operations. The Environmental team in North America has implemented GPS tracking on large mobile equipment to reduce idling time and improve the efficiencies of material movements at our sites, reducing diesel fuel use and emissions by 10% in 2019. At our Ijmuiden site in Amsterdam, we have committed to a 15 percent greenhouse gas reduction target. Our Clean Earth division has set a number of sustainability goals as part of the ESG Report. 

We are also exploring opportunities to increase the usage of renewable energy across our business. In 2021, our total enterprise energy use was 2.7 million gigajoules (GJ), down 40% from 2019. All our renewable energy usage is associated with electricity use sourced from the grid. In 2019, we estimate that approximately 30% of our enterprise electricity use was derived from renewable sources. We are evaluating opportunities to increase the sourcing of electricity from renewable generation sources and opportunities to increase the electrification of our mobile assets.

Enviri’s diverse, global work force is a source of pride, and Inclusion is one of our Core Values. We value our differences and welcome the unique contributions, perspectives, and ideas of every employee. Wherever we do business, we work together in a spirit of collaboration, respect, and inclusion, and know that many perspectives can produce the best solutions.

Enviri is an equal opportunity employer; our policies, including the equal opportunity and affirmative action policy, prohibit unlawful discrimination. Enviri’s Code of Conduct includes our policy against harassment in all forms. Enviri does not tolerate harassment, whether sexual or non-sexual in nature, and whether committed by a Enviri employee or someone with whom we do business.

Our human capital strategy is led in partnership between Enviri’s Chief Human Resources Officer and leaders within our divisions. Enviri employs a matrix organization structure, assigning clear ownership of specific responsibilities around human capital strategy and workforce management across the business.

Employee Care is one of our Core Values. We provide our employees with market-leading financial, health and wellness, and career development benefits. Specific benefits vary worldwide and are based on regional needs, but some common features of our benefit program, available to all employees globally, include recognition, opportunity, involvement and reward.

The Company has established a comprehensive development framework, including training, implemented globally for all employees. Our leadership programs are built around our Core Values.  

We conduct a global engagement survey of all employees on an annual basis. The survey results are cascaded through the organization with voluntary employee team struck to address items at the local level.

Consistent with our values, Enviri believes every human being has the right to safe, healthy working conditions, and to be treated with dignity and respect. Our Human Rights policy is guided by the U.N. Guiding Principles for Business and Human Rights and outlines our human rights commitments. We expect our agents, contractors, consultants, distributors, suppliers and vendors (collectively "Business Partners") to share our commitment to human rights. As part of our procurement process, all business partners are required to acknowledge Enviri’s Business Partner Code of Conduct. In compliance with the UK Modern Slavery Act of 2015, we have provided our statement outlining our actions to ensure that slavery and human trafficking are not taking place in our business or global supply chains.  All employees receive training on our human rights policy through our required Code of Conduct training.     

It is the policy of Enviri and its subsidiaries or affiliated entities (collectively, “Enviri”) to conduct business in compliance with laws that require publicly-traded companies to disclose their use of “conflict minerals” originating in the Democratic Republic of the Congo (“DRC”) or an adjoining country. Conflict minerals include columbite-tantalite (coltan), cassiterite (tin), wolframite (tungsten), and gold, (collectively, “3T&G”) and any of their derivatives. We encourage our suppliers to adopt similar policies and management systems with respect to conflict minerals and to drive those efforts throughout their supply chain to ensure that the specified metals are being sourced only from (1) mines and smelters outside the DRC or an adjoining country; or (2) mines and smelters within the DRC or an adjoining country which have been certified by an independent third party as “conflict free.” Enviri has engaged Crowe Horwath, an international accounting and consulting firm, to assist with our conflict minerals due diligence. You can email questions to Harsco.ConflictMinerals@crowehorwath.com.

Enviri Corporation - Form SD and Conflict Minerals Report 2019

Our goal is to provide our customers with products of the highest quality. Nearly all of our major manufacturing facilities globally are ISO 9001 certified. For example, with Harsco Rail’s “Quality At The Source” strategy, every employee assumes responsibility for the performance, consistency, safety and value of our products. Customer focus is the backbone of Harsco Rail’s ISO 9001-certified integrated management system. On this basis, all processes are regularly monitored, and process effectiveness and efficiency are continuously improved. This enables us to offer our customers first-class products and services that meet and exceed our customers' expectations.

Safety is of paramount importance in everything we do. Our vision to eliminate workplace injuries and illnesses is embedded in our Employee Care value and drives a sustainable safety culture designed to protect our employees, customers, work environment, and communities. Our commitment to workplace health and safety is grounded in our belief that all workplace injuries and illnesses are preventable. All Enviri employees and contractors are responsible for their own safety, and that of their colleagues and others in the workplace. Our Health & Safety policy applies across all Enviri divisions, subsidiaries, third party businesses, contractors, and visitors. The Company’s safety policies and operational controls are overseen by a cross-functional Safety Committee composed of senior leaders from every division. The Committee reports to Enviri’s Chairman and Chief Executive Officer.

Excellence in corporate governance is fundamental to how we manage and operate Enviri. See the Corporate Governance page of our website to learn more about our governance principles, including Board composition and structure, Board Committees, and Compensation. Additional corporate governance information can be found in our latest proxy statement found on our Investor Relations site.

Enviri has a dedicated Global Compliance & Ethics program that reinforces our uncompromising commitment to doing business the right way. Enviri’s values are memorialized in our Code of Conduct, which is available in over 20 languages on our public website. The Code of Conduct applies to all Enviri operations, including subsidiaries. Its principles are further memorialized in our Business Partner Code of Conduct, which applies to all third parties that do business with Enviri. All employees and contractors are required to complete Code of Conduct training upon joining Enviri; this training is frequently reinforced in other ongoing Compliance trainings and communications. Further, Enviri’s Internal Control Framework – available in 15 languages – applies to all employees and is provided to new employees.   

Enviri’s global compliance program is led at the executive level by our Chief Compliance Officer, and is overseen ultimately by the Audit Committee of our Board of Directors. Enviri’s Vice President of Global Compliance executes and drives compliance initiatives, such as ongoing trainings, communications, and investigations of misconduct, consistent with the expectations of the U.S. Department of Justice. Enviri’s global compliance program works closely with our corporate partners in Human Resources, Internal Audit, and Finance to specifically tailor initiatives to the various risks inherent in Enviri’s businesses, to test relevant policies and controls, and to ensure appropriate risk mitigation regarding Enviri’s third-party business partners.   

Ownership of compliance and ethics by the business is an important principle in Enviri’s global compliance program. For example, recently launched “Compliance Councils” within each business, composed of cross-functional leaders, discuss “A-Z” compliance issues, such as seeking continuous improvement for targeted trainings and communications, and ensuring that misconduct is prevented, detected, and swiftly remediated.   

Further, Enviri’s global compliance program monitors – via a third party vendor – our Integrity Line, which is a mechanism to anonymously and confidentially report misconduct, 365 days a year, 24 hours a day, and in multiple languages.  Retaliation in any form against good-faith reports of misconduct is not tolerated.  In addition to addressing reports of misconduct, Enviri’s global compliance program takes an active role in identifying control or policy gaps for purposes of root cause analysis.  

Enviri also has a robust Anti-Bribery and Anti-Corruption Policy, consistent with the requirements of the U.S. Foreign Corrupt Practices Act and the UK Bribery Act. The policy includes stringent requirements for interactions with government officials, such as pre-approvals and detailed expense documentation, is reinforced via frequent trainings and communications, and prohibits facilitation payments. The policy is also reflected in Enviri’s due diligence program that screens potential business partners and other third parties that seek to do business with Enviri. Further still, Enviri’s written agreements include numerous anti-bribery/anti-corruption provisions that Harsco actively monitors for compliance and enforcement.   

We encourage our employees to volunteer contributions of time, talent and money to support causes that are important to them. This includes political candidates and campaigns. Our policies related to political activities, formalized in our Code of Conduct, prohibit Enviri employees from using Enviri funds, assets, resources, time or the Enviri name to support political activities. All lobbying activities on behalf of Enviri must first be approved by the Enviri General Counsel.

Management of Enviri's global suppliers and supply chains is critical to support Enviri's operations around the world. Supply chain management is led by the Vice President of Procurement in our Harsco Environmental division, the Vice President of Global Integrated Supply Chain in our Harsco Rail division and the Vice President of Procurement in our Clean Earth division. These roles are responsible for oversight of Enviri's procurement and supplier relationships.

Enviri's Code of Conduct and Business Partner Code of Conduct applies to all Enviri suppliers and third parties that do business with Enviri, setting our expectations that these organizations share our commitment to human rights, compliance with labor laws, implementing sound environmental, health and safety practices, and ethical business practices. Our suppliers are required to acknowledge Enviri's codes of conduct as part of the contracting and procurement process.