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ESRS E2 – Pollution

ESRS E2 – Impact, risk and opportunity management ESRS E2-1 / ESRS E2-2 – Policies, actions and resources related to pollution ESRS E2-3 – Targets related to pollution ESRS E2-4 – Pollution of air, water and soil

Pollution

We take comprehensive precautions to prevent soil contamination and the formation of microplastics.

Interzero’s facilities and processes meet high quality and safety standards. Nevertheless, during the sorting of recyclable materials and the production of plastic recyclates, substances may be released into the environment. To date, no violations of applicable regulations have been reported in either area.

ESRS E2 – Pollution

ESRS E2 – Impact, risk and opportunity management

Description of material impacts, risks and opportunities

Interzero operates multiple facilities for sorting recyclables and for the production of plastic recyclates. Despite comprehensive precautionary measures being taken, there is the risk that these processes may release emissions into the environment. The topics of soil pollution and microplastics have therefore been classified as material for Interzero. No violations have been identified in either area to date. Corresponding financial risks – such as potential compliance costs – are currently considered immaterial.

Interzero Group operates sites at which impacts may occur that are considered material because of soil pollution and the creation of microplastics at the following locations: Walldürn, Braunschweig, Leipzig, Berlin, Marl, Eisenhüttenstadt, Aschersleben, Aukrug, Duisburg, Liebenau, Barsinghausen, Sarstedt, Oberhausen and Dekani (Slovenia).

These sites carry out the following business activities:

Sorting of secondary raw materials
Handling of secondary raw materials
Recycling of secondary raw materials
Transportation of secondary raw materials

As part of these activities, the following types of pollution may be caused:

Pollution of soil:
- Foil/film swept away by wind or lost in transit
- Dust swept up by wind or emitted in transit
Microplastics:
- Microplastics from tyre abrasion
- Microplastics from production processes

As a supplement to the overview provided in ESRS 2 SBM-3, the table below presents the material IROs in the Pollution category that Interzero has identified in the course of its DMA.

ESRS E2 – Pollution: material impacts, risks and opportunities

(Sub-)Sub-topic	Interzero IROs	IRO	+/-	A/P	Value chain	Time horizon
Pollution of soil	Production and processing facilities can release (poisonous) substances into the natural local surroundings that contribute to soil pollution, which can negatively impact the local environment as well as human society.	I	-	A	OO	S, M, L
Microplastics	Microplastics are created when producing plastic recyclates. These substances can contaminate water and soil, harm aquatic and terrestrial animals, and enter the human food chain, which can result in problems for human health. Microplastics can also contribute to long-term pollution and disruptions to ecosystems.	I	-	P	U, OO, D	S, M, L

Legend:

I = impact, R = risk, O = opportunity, + = positive, - = negative, A = actual, P = potential

Value chain: U = upstream, OO = own operations, D = downstream

Time horizon: K = short-term (one financial year), M = medium-term (one to five years), L = long-term (more than five years)

ESRS E2-1/ESRS E2-2 – Policies, actions and resources related to pollution

Business activities at Interzero aim to mitigate climate change and protect resources, and thus preserve a liveable environment for present and future generations alike. Negative environmental impacts – resulting from soil pollution or the creation of microplastics, for example – are to be avoided wherever possible. All legal requirements are also fulfilled and permits complied with according to the German Federal Immission Control Act (Bundes- Immisionsschutzgesetz – BImSchG). Compliance is monitored by unannounced audits from regulators.

High-quality standards are also assured by the external certification of sites according to the German Waste Management Company Ordinance (Entsorgungsfachbetriebeverordnung – EfbV) and in some cases according to ISO 14001 (Environmental Management Systems). An Efb certificate is a recognised seal of quality in the circular economy sector as it specifies the quality requirements that a company or business needs to fulfil. All certificates are publicly viewable and are monitored annually as part of an external audit (certificates can be accessed from Download-Center | Interzero - zero waste solutions).

Interzero is subject to strict regulations for the reduction and avoidance of negative impacts in relation to pollution. Legal requirements in this context include the following actions:

Use of de-dusting systems for the treatment of exhaust air from sorting and treatment plants
Activated charcoal filters for the treatment of exhaust air (odours) from sorting plants
Erection of fencing up to six metres high to suppress the escape of foils/films

All production facilities also work with external service providers to reduce the escape of foils/films and the input of secondary raw materials into the company’s own or adjacent undeveloped land. Roadways, storage areas and access roads to premises are cleaned regularly by road sweepers.

Plants operated by Interzero Group are integrated into maintenance and servicing systems. Alongside continuous visual inspections and functional testing by company personnel, maintenance is also outsourced to specialist teams. This helps to avoid failures and the emergency situations that can arise as a result.

In both its own treatment plants and throughout the entire value chain, Interzero makes every effort to comply with legal requirements, transparency and quality. As one example, the company only supplies certified waste management companies that are themselves subject to external controls.

ESRS E2-3 – Targets related to pollution

On the topics of soil pollution and microplastics, Interzero pursues the objective of fulfilling to the letter all legal standards and regulations from the respective permits according to the BImSchG. As described in ESRS E2-1, these include keeping adjacent areas of land clean, complying with parameters for particulate dust in exhaust gas chimneys (e.g. Oberhausen facility) or the continuous operation of an activated charcoal filter system (e.g. Marl facility). Periodic measurements are conducted by external appraisers.

As of this writing, the company has not set any internal targets that exceed regulatory targets.

ESRS E2-4 – Pollution of air, water and soil

The business activities of Interzero do not involve any pollutants listed in Annex II of Regulation EC No 166/2006 of the European Parliament and of the Council. Interzero does not use or process any microplastics as an input material in its production facilities. The company does not record quantity data on microplastics from production processes or tyre abrasion.

In 2023 and 2024, there were two recordable incidents (fires) at the Leipzig and Braunschweig sites. In both cases, secondary raw materials stored in bales caught fire for unknown reasons and were extinguished by the fire service. All regulatory demands were met without delay and the corresponding actions were taken. Plastic debris and extinguishing water were properly disposed of and the damaged storage facilities were reopened after repairs.

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