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Environment

Access to a

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Rules & Regulations

Directive

Group-wide

Rules and Regulations

Contents

A

General Information

3

A.1

Subject matter & objective

3

A.2

Scope of application

3

A.3

Validity

3

A.4

Implementation

3

B

Principles

4

B.1

Environmental Regulations and Permits

4

B.2

Pollution Prevention and Resource Efficiency

4

B.3

Hazardous Substances

4

B.4

Solid Waste

6

B.5

Air Emissions

6

B.6

Materials Restrictions

7

B.7

Water Management

7

B.8

Energy consumption and greenhouse gases

9

B.9

Product Circularity and EcoDesign

9

C

Approval

11

dormakaba Guidelines Basic Elements

02/15

Rules and Regulations

Directive Environment

A. General Information

A.1 Subject matter and objective

dormakaba is committed to fostering sustainable development along our entire value chain in line with our economic, environmental and social responsibilities. As stated in the dormakaba Code of Conduct, the environment builds the natural living conditions of all beings.

dormakaba recognizes that environmental responsibility is integral to producing world class products. In manufacturing operations, adverse effects on the community, environment and natural resources are to be minimized while safeguarding the health and safety of the public.

We focus on improving our management of environmentally related processes and on monitoring and reducing our energy consumption, carbon emissions, water consumption and increasing recycling rates. We practice good management and pollution control of hazardous materials, wastewater and waste, reducing these wherever possible.

Taking the life-cycle perspective, we continually aim at improving the environmental performance of our products and services while increasing material efficiency and adhering to materials restrictions regulations.

This Directive regulates the minimal business standards as regards the environment for product development and manufacturing and/or service processes at local level. Where local laws and local management systems are less stringent than this Directive, dormakaba is guided by the more stringent standard.

A.2 Scope of application

The provisions outlined in this Directive are applicable to all fully consolidated operations of dormakaba Holding AG worldwide, including those of direct and indirect subsidiaries.

A.3 Validity

This Directive comes into force from 1 September 2021 onwards and remains valid until further notice.

A.4 Implementation

The provisions in this Directive are focused on local, site-level management of environmental topics. In alignment with the requirements laid out in the dormakaba Sustainability Charter, local management is responsible for implementing the Directive into local (electronic) workflows and processes. Accountability for conformance and planning the required resources for conformance lies with the Site Head or equivalent function. Specific individuals or group of individuals must be formally appointed to manage all requested activity needed to ensure that dormakaba entities are always fully compliant with the Directive requirements.

Where a dormakaba entity is certified according to ISO9001:2015 and ISO14001:2015 (and/or ISO50001), the principles and procedures indicated in this Directive should be integrated within the related management system.

Further, local management should make reasonable efforts to ensure the involvement and participation of all personnel in order to fully share this Directive and the consequent business objectives, for the development of a culture oriented to the principles of this Directive.

Data Classification: C1 - Public

03/11

The most recent version of these rules and regulations published within dormakaba Inside is applicable. In case of doubt the English version shall apply.

Rules and Regulations

Directive Environment

B. Principles

B.1 Environmental Regulations and Permits

Local management is to act responsibly, in compliance with environmental legislation.

All required environmental permits (e.g., discharge monitoring), approvals and registrations are to be obtained, maintained and kept current and their operational and reporting requirements are to be followed. Specifically, required environmental permits, approvals registrations and licenses include those related to, e.g.

  • Operating permit
  • Air emissions
  • Wastewater discharge
  • Storm water exposure
  • Hazardous materials storage and use
  • Generation of waste (solid and hazardous)

Current copies of all hazardous waste vendor licenses and/or approvals must be kept on file. Environmental noise levels are to be within regulatory limits.

B.2 Pollution Prevention and Resource Efficiency

Emissions and discharges of pollutants and generation of waste are to be minimized or eliminated at the source or by practices such as adding pollution control equipment; modifying production, maintenance and facility processes; or by other means.

The use of natural resources, including water, fossil fuels, minerals and virgin forest products is to be conserved by practices such as modifying production, maintenance and facility processes, materials substitution, re-use, conservation, recycling or other means.

Engineering and administrative systems for improved resource efficiency should adhere to the hierarchy of resource efficiency (see below) when feasible, showing preference (in order) for the following functions:

  1. Prevention: Unnecessary consumptive processes are eliminated
  2. Minimization: Process efficiency is improved
  3. Substitution: Using a more environmentally benign or renewable resource
  4. Reuse, recycling, recovery: In that order, in order to maximize the benefit of resource consumption

Adequate and effective programs to identify, manage, minimize or eliminate at the source emissions and discharges of pollutants, generation of waste and conserve the use of natural resources must be in place including:

  • Risk and impact assessment: identification of significant environmental aspects
  • Programs for monitoring and control of these aspects
  • Clear objectives and targets are set for each identified significant environmental aspect, demonstrating annual progress not entailing excessive cost that
    o Reduce resource consumption
    o Reduce waste and pollution generation
    o Capture or reuse materials that would otherwise enter waste streams

B.3 Hazardous Substances

Chemical, waste and other materials posing a hazard to humans or to the environment are to be identified, labelled and managed to ensure their safe handling, movement, storage, and use.

Data Classification: C1 - Public

04/11

The most recent version of these rules and regulations published within dormakaba Inside is applicable. In case of doubt the English version shall apply.

Rules and Regulations

Directive Environment

Required procedures

Adequate and effective procedures must be in place for their:

  • Reception and categorization
  • Storage
  • Dispensing
  • Use and Handling
  • Disposal

Adequate and effective processes must be in place to inventory, track, review, and approve the use of all hazardous substances and obtain required governmental approvals for all new purchases of hazardous chemicals/materials prior to use. The selection processes for all new hazardous substances must include a thorough evaluation of less hazardous or nonhazardous alternatives.

Hazardous material information [labels and safety data sheet (SDS formally MSDS)] or characterization (in the case of hazardous waste) must be available at the points of use and storage in a language understood by the responsible employees. Training on safe use and handling is required for the employees working with or coming into close contact with these materials. All training needs to be properly documented and repeated at least once a year.

Inspection records of hazardous substances and their points of storage and use are maintained and available for review. Copies of hazardous substances inventory, manifests and shipping papers are maintained and available for review. These may be related to:

  • Air emissions
  • Process wastewater storage
  • Hazardous materials storage and use
  • Hazardous waste storage

Control and employee exposure

Access to hazardous substances is controlled such that only trained workers have access. Potential employee exposure methods are to be adequate and effective including through proper:

  • Segregation
  • Secondary containment
  • Ventilation
  • Fire protection and
  • Use of appropriate storage cabinets

Reporting

For locations with > 20 employees, there must be an adequate and effective process to track and report hazardous waste types and volumes as well as disposal methods per hazardous waste type. This must be reported into the Group-wide environmental reporting database timely at the established deadlines (On financial year basis, 6-month,10-month and 12-month deadlines).

Reduction program

An adequate and effective hazardous substances reduction program must be in place to consist of:

  • Annual objectives
  • Regular objective tracking
  • Progress monitoring
  • Adjustments made if off track

Data Classification: C1 - Public

05/11

The most recent version of these rules and regulations published within dormakaba Inside is applicable. In case of doubt the English version shall apply.

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DORMA+KABA Holding AG published this content on 03 January 2022 and is solely responsible for the information contained therein. Distributed by Public, unedited and unaltered, on 03 January 2022 09:38:04 UTC.