Reporting Standards

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Reporting Standards applied​​​​​​​



Now in its seventh edition, the Consolidated Disclosure of Non-financial Information (hereinafter also “Non-Financial Information”, “Disclosure” or “NFI”) of the Brembo Group (hereinafter also “Brembo”, “Group”) illustrates the performances and actions taken in order to manage environmental, social and employee matters, respect for human rights, anti-corruption and bribery matters, so as to provide stakeholders with access to accurate, thorough and transparent view of the Company’s strategies, activities, performance and the Group’s results in its pursuit of economic growth and business development. 


This Disclosure, published annually, has been written in accordance with Italian Legislative Decree No. 254/2016 as amended and in compliance with the Sustainability Reporting Standards published by the Global Reporting Initiative - GRI 2021 (with reference to the most recent update thereof), which became effective as of 1 January 2023. These Standards are currently the most widespread and recognised on an international level regarding non-financial reporting. 


In the reporting process, with a view to a broader disclosure towards stakeholders, the Group has taken into account the indications contained in the “Measuring Stakeholder Capitalism: Towards Common Metrics and Consistent Reporting of Sustainable Value Creation” published in September 2020 by the World Economic Forum and the indicators put forward by the SASB standards. 


The information included in the non-financial report reflects the principle of materiality or relevance, an element provided for by reference standards and characterising the GRI standards: the issues discussed within the Disclosure have been identified following the analysis and assessment of the most significant impacts on economy, people and environment, including human rights. 


It is necessary to point out that a materiality analysis, to be valid for the purposes of the non-financial reporting of this financial year, does not take into account the Outside-in perspective (financial materiality ) since this procedure is on a totally voluntary basis and not subject to audit (ref. CSRD Directive). 


For disclosures published following 1 January 2023, Brembo must include in the NFI the information required by the so-called “EU Taxonomy” legislation with regard to environmentally sustainable activities carried out by the Group. In relation to this, please refer to paragraph “THE EU TAXONOMY REGULATION (No. 2020/852). In compliance with Article 10 of the Commission Delegated Regulation (EU) 2021/2178 of 6 July 2021, such information for 2023 relates to the proportion, with respect to the total, of turnover, capital expenditure and operating expenditure of the Group associated with Taxonomy-eligible and -aligned activities with reference to the objectives of climate change mitigation, climate change adaptation, the sustainable use and protection of water and marine resources, the transition to a circular economy, pollution and prevention control and the protection and restoration of biodiversity and ecosystems, as provided for by the Annexes to the Commission Delegated Regulation (EU) 2021/2139 of 4 June 2021, in addition to some qualitative information.



Taxonomy  


In line with the goals of the UN 2030 Agenda, with the aim of achieving climate neutrality by 2050, the European Union has defined a series of strategies and initiatives aimed at directing capital flows towards investments in assets and activities deemed sustainable. In this regard, European institutions therefore introduced the Regulation (EU) 2020/852 (hereafter also referred to as the “Regulation”), which aims at providing reliable and common criteria and tools to identify sustainable economic activities, and at ensuring financial institutions and investors greater comparability regarding the degree of environmental-sustainability of an investment associated with that activity. 


In particular, the Regulation introduced a unified classification system or “taxonomy”, of economic activities that, in order to qualify as “environmentally sustainable” must contribute to achieving one or more among the following six environmental objectives

- Climate change mitigation 

- Climate change adaptation 

- The sustainable use and protection of water and marine resources 

- The transition to a circular economy 

- Pollution prevention and control 

- The protection and restoration of biodiversity and ecosystems 


Specifically, according to the Regulation, economic activities are broken down into: 

- taxonomy-eligible: an economic activity is taxonomy-eligible if it is listed in the delegated acts of the Regulation, in correspondence with one or more environmental objectives. If taxonomy-eligible, the activity has the potential to contribute substantially to the objective of reference; 

- taxonomy-aligned: an economic activity is taxonomy-aligned if, in addition to being taxonomy-eligible, it is carried out in compliance with the technical screening criteria and the minimum safeguards. Accordingly, it has to: 

    - meet the substantial contribution criteria defined by the Regulation for each activity. On a scientific basis, they describe the conditions to be met to substantially contribute to reaching the environmental objectives; 

   - Do No Significant Harm (DNSH) to any of the other environmental objectives to which the economic activity does not substantially contribute; 

    - comply with the minimum safeguards, ensuring respect for human rights and international legislation on workers’ rights, taxation, fair competition and bribery. 


If an activity is taxonomy-aligned, it may thus qualify as “environmentally sustainable”. 


Compliance assessment with the regulation


As of 2021, in accordance with the Regulation, Brembo discloses the information required associated with the proportion of the turnover, CapEx and OpEx related to taxonomy-eligible activities. 


In 2023, the Brembo Group continued the analysis of its taxonomy-eligible economic activities in order to assess their effective contribution to the aforementioned six objectives and understand if and which of these can also be considered to be taxonomy-aligned. Moreover, a mapping of any CapEx and OpEx was made in relation with the purchase of products or services referring to taxonomy-eligible and/or taxonomy-aligned economic activities and to individual measures enabling activities to maintain a low level of emissions. 


Eligibility analysis 


The analysis resulted in the identification of the following economic activities performed by Brembo, associated with the climate change objectives: 

- 3.8 Manufacture of aluminium

- 3.9 Manufacture of iron and steel

- 9.1. Close to market research, development and innovation


The activities identified, performed by Brembo at its sites, do not generate a direct turnover for the Group. 


Moreover, an analysis of any CapEx and OpEx was also made in relation with the purchase of products or services referring to taxonomy-eligible economic activities and individual measures enabling the activities to reduce their level of emissions. 


Alignment analysis 


In order to assess alignment with the climate change mitigation and climate change adaptation objectives, for each taxonomy-eligible activity identified analyses were thus carried out to check compliance with the substantial contribution criteria and the “Do No Significant Harm” criteria by each objective. Minimum safeguards Lastly, Brembo analysed compliance with the minimum safeguards, in accordance with the provisions of Article 18 of the Regulation. In particular, the OECD Guidelines for Multinational Enterprises, the United Nations Guiding Principles on Business and Human Rights and the principles and rights set out in the eight core conventions identified in the International Labour Organisation's Declaration on Fundamental Principles and Rights at Work and the International Charter of Human Rights were taken into consideration. 


Specifically, nine categories were assessed: human rights policies, human rights due diligence and risk assessment, human rights impact management, grievance mechanisms, consumer interests, anti-corruption, competition and taxation. 


Brembo ensures that the topics relating to minimum safeguards are dealt with through the adoption of specific tools such as the company policies, guidelines and organisational and operational mechanisms. Following this analysis, the Group verified that it had implemented all the safeguards provided for in Article 18 of the Regulation, while acknowledging the need to formalise some specific policy statements to ensure full compliance with the requirements of the OECD Guidelines and UN Guiding Principles.

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The Reporting Process​



The preparation of the Consolidated Disclosure of Non-Financial Information is a real annual reporting process, subject to inspection, analysis and approval by several parties. Following the approval by the Board of Directors of the material topics and the related impacts, the document is:  


• prepared by the Chief CSR Officer and the relevant work team, which coordinate and involve all the main company functions in the phase of collecting, analysing and consolidating data, with the task of checking and validating — each with regards to their respective area of competence — each information included in the Disclosure of Non-Financial Information, using the new software implemented by the Group;

• approved by the Board of Directors, which meets to approve the draft financial statements, after having been assessed by the CSR Committee which, through the Chief CSR Officer, presents it to the Audit, Risk & Sustainability Committee and, insofar as it is competent, to the Supervisory Committee for its examination and assessment. Brembo’s Directors are responsible for ensuring that the Consolidated Disclosure of Non-Financial Information is written and published in accordance with current legislation. Once it has been approved by the governing body and within the terms provided for the presentation of the draft Financial Statements, the draft Consolidated Disclosure of Non-Financial Information is made available to the auditors (Board of Statutory Auditors and Independent Auditors);

• submitted to limited audit by the auditing firm Deloitte & Touche S.p.A., meaning that responsibility for the data and information lies solely with the Brembo Group managers;

• made available to Shareholders and the public within the same terms and using the same methods provided for the presentation of the draft Financial Statements; • published on and downloadable from the corporate website.



 

Reporting Principles


The following principles have been taken into consideration in defining and reporting the contents of the Consolidated Disclosure of Non-Financial Information:


Sustainability Context ​ 

 

The report has to present information concerning the impacts of the Organisation within the broader context of sustainability, on the basis of how it contributes, or intends to contribute in future, to the improvement or worsening of economic, environmental and social conditions, developments and trends on a local, regional or global level. ​


Completeness ​


The report must cover the material topics and their perimeters to a sufficient extent to reflect impacts generated on economy, environment and people, including with regard to human rights, to enable stakeholders to assess them during the reporting period.​



Balance between positive and negative aspects  

 

The Organisation must report information in an impartial manner, providing a fair and balanced representation of the negative and positive impacts and so as to allow their weighted assessment. The report should avoid selections, omissions or presentation formats that could unduly or improperly influence the decision or judgment of the reader of the report.



Comparability ​


The Organisation must select, compile and report the information in a consistent manner. The information covered by the report must be presented in such a way as to enable stakeholders to analyse changes to the impacts of the Organisation over time and that could support an analysis relative to other Organisations.


Accuracy


The information provided in the report must be accurate and sufficiently detailed for the stakeholders to be able to assess the impacts of the Organisation.



Timeliness 


The Organisation must publish reports on a periodical basis so that the data is available in time for the stakeholders to make informed decisions.



Reliability​ 

 

The Organisation must collect, record, compile, analyse and present the information and processes employed in writing the report so that they can be examined and the quality and materiality can be defined.​



Clarity


The Organisation must make the data available in such a way that it is understandable and accessible to the stakeholders using it, through tools allowing to find information without unreasonable effort and avoiding the use of technical terms and abbreviations without an appropriate explanation. 


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GRI table of contents ‘in accordance’ – core option

GRI ID​ Disclosure ​
Page number or disclosure Omissions*
UN Global
Compact
​SDGs
GRI2: GENERAL STANDARD DISCLOSURES (2021) ​
​THE ORGANISATION AND ITS REPORTING PRACTICES
2-1​ Organisation details​ 26-27, 92-95; Corporate Governance and Ownership Structure Report; Annual Report
2-2
Entities included in the organisation’s sustainability reporting ​ 250-251; Annual Report
2-3​​ Reporting period, frequency and contact point
251-252. The 2022 Consolidated Disclosure of Non-Financial Information (pursuant to Legislative Decree 254/2016) was published on 20 March 2023
2-4​​ Restatements of information
251-252; Any changes to the information provided in previous documents have been duly identified in the text through related explanatory notes.
2-5​ External assurance
ACTIVITIES AND WORKERS
2-6
Activities, value chain and other business relationships
28-30,154-160,162-172; Annual Report
2-7​ Employees 12,18,128-130,134-137,227-229; Annual Report ​​

2-8​ Workers who are not employees​
229-230 Principle 6​ ​8, 10
GOVERNANCE
2-9​ Governance structure and composition​ 12,92-101,104-106, 226; Corporate Governance and Ownership Structure Report ​5, 16
2-10​ Nomination and selection of the highest governance body 98-99; Corporate Governance and Ownership Structure Report ​5, 16
2-11​​ Chair of the highest governance body ​
97; Corporate Governance and Ownership Structure Report
16​
2-12
Role of the highest governance body in overseeing the management of impacts 119-120; Corporate Governance and Ownership Structure Report
​2-13
Delegation of responsibility for managing impacts
114-116; Corporate Governance and Ownership Structure Report
2-14
Role of the highest governance body in sustainability reporting 98,100-101,226; Corporate Governance and Ownership Structure Report
​2-15
Conflicts of interest
​2-16​​ ​Communication of critical concerns 115-116​​
2-17​ Collective knowledge of the highest governance body​​​
​2-18​​ Evaluation of the performance of the highest governance body 99, 105; Report on the Remuneration Policy for 2024 and Remuneration Paid in 2023 of the Brembo Group ​​
​2-19
Remuneration policies
101-104; Report on the Remuneration Policy for 2024 and Remuneration Paid in 2023 of the Brembo Group
2-20​ Process to determine remuneration​ 101-104; Report on the Remuneration Policy for 2024 and Remuneration Paid in 2023 of the Brembo Group
2-21​ Annual total compensation ratio ​ Report on the Remuneration Policy for 2024 and Remuneration Paid in 2023 of the Brembo Group
The organisation is committed to provide this information as required by the GRI indicator by the date of publication of the 2024 NFI
2-22
Statement on sustainable development strategy
6-7​
2-23
Policy commitments 109-117
Principle 10​ ​16
2-24
Embedding policy commitments
109-117

2-25
Processes to remediate negative impacts 111-114,137-140,142-145,165-167,178-181
2-26
Mechanisms for seeking advice and raising concerns
115-116,137
Principle 10​ ​16
​2-27
Compliance with laws and regulations 245 Principle 7, 8​ ​16
2-28
Membership associations 9, 71-74
​2-29​ ​Approach to stakeholder engagement ​ 67-70,133-134,172-177​
2-30
Collective bargaining agreements 59, 137​
GRI 3: MATERIAL TOPICS 2021
​​​​​3-1​ ​ Process to determine material topics​​ 75-76​
​3-2​ List of material topics ​ 77-80, 253-258
CATEGORY: ECONOMIC PERFORMANCE ​​ 
TOPICS: SUPPORT TO LOCAL COMMUNITIES
3-3
Management of material topics ​ 77-82, 210-213210-213
201-1
Direct economic value generated and distributed 211
8, 9​
TOPICS: ETHICS AND INTEGRITY
3-3
Management of material topics ​ 77-82 77-82, 109-120 5, 16​
​201-4
Financial assistance received from government ​​ 211

205-2
Communication and training about anti-corruption policies and procedures
114-117; Corporate Governance and Ownership Structure Report ​Principle 10
16​
205-3​ Confirmed incidents of corruption and actions taken 116
Principle 10​ 16​
206-1​ Legal actions for anti-competitive behaviour, anti-trust, and monopoly practices 111
​16
415-1
Political contributions In 2022, Brembo did not grant political or financial contributions, nor contributions in kind. ​ ​Principle 10
16​
MATERIAL TOPIC: HUMAN RIGHTS
3-3
Management of material topics ​ 77-82, 114, 124, 158
202-2​ Proportion of senior management hired from the local community 137
Principio 6 8
MATERIAL TOPIC: SUSTAINABLE SUPPLY CHAIN
3-3
Management of material topics ​ 77-82, 124, 156-169 8, 12​
204-1​ Proportion of spending on local suppliers 155


308-1
New suppliers that were screened using environmental criteria 157 Principle 7, 8
414-1
New suppliers that were screened using social criteria ​​157
​Principle 2, 4, 5
8, 16
CATEGORIA PERFORMANCE AMBIENTALE ​ ​​ 
MATERIAL TOPIC: ENERGY EFFICIENCY 
MATERIAL TOPIC: PROTECTION OF WATER RESOURCES 
MATERIAL TOPIC: PROTECTION OF BIODIVERSITY
3-3
Management of material topics​​ 77-82, 123, 162-163, 165, 188-193, 201-202, 207 ​
302-1 Energy consumption within the organisation
194
Principle 7, 8​ 7, 8, 12, 13​
302-4
Reduction of energy consumption193
Principle 8, 9​ 8, 12, 13​
303-1
Interactions with water as a shared resource​ 201-202 ​Principle 7, 8
6, 12
​303-2
Management of water discharge related impacts 201-202
​Principle 8
6​
303-3
Water withdrawal ​202
Principle 8
6
303-4
Water discharge
203-204 Principle 8​ 6​
303-5
Water consumption
204; Water storage does not have a significant impact in relation with the use of water resources Principle 8
6
304-2
Significant impacts of activities, products and services on biodiversity
207 Principle 15​ 15
MATERIAL TOPIC: GREENHOUSE GAS EMISSIONS 
MATERIAL TOPIC: POLLUTING EMISSIONS
​3-3
Management of material topics
77-82, 123, 162-163, 165, 188-190, 195-196,198, 20
20
305-1 Direct (Scope 1) GHG emissions​ 196-197
​Principle 7, 8
12, 13, 14, 15
305-2 Energy indirect (Scope 2) GHG emissions
196-197
Principle 7, 8 ​​ ​12, 13, 14, 15
305-3
Other indirect (Scope 3) GHG emissions
196-197
Principle 7, 8 ​ ​12, 13, 14, 15
305-5
Reduction of GHG emissions 188, 192, 195
Principle 8, 9​​ 14, 15
305-7
Nitrogen oxides (NOx), sulfur oxides (SOx), and other significant air emissions
200​​​ Principle 7, 8 ​​ 12, 14, 15
MATERIAL TOPIC: WASTE MANAGEMENT
3-3 ​ ​Management of material topics​ 77-82, 122-123, 205-206
306-1​ ​Waste generation and significant waste-related impacts 205-206
6, 11, 12

306-2​ Management of significant waste-related impacts
205-206
​Principle 8
​6, 8, 11, 12​
306-3 ​​ Waste generated​​ 206
​​Principle 8
3, 6, 8, 11, 12​
306-4​ Waste diverted from disposal
206

​3, 11, 12
306-5
Waste directed to disposal
206
3, 6, 11, 12, 15
CATEGORY: SOCIAL PERFORMANCE ​ ​​ 
MATERIAL TOPIC: TRAINING AND DEVELOPMENT OF PERSONNEL
MATERIAL TOPIC: WELLBEING OF PERSONNEL
3-3
Management of material topics
12, 77-82, 124-125, 128-132, 230-231

401-1
New employee hires and employee turnover
129-130, 230-231
Principle 6​
8, 10
404-1
Average hours of training per year per employee
139
​Principle 6​
4, 5, 8, 10
404-3
Percentage of employees receiving regular performance and career development reviews
140-141
Principle 6​
8, 10
MATERIAL TOPIC: HEALTH AND SAFETY
3-3
Management of material topics
12, 77-82, 113, 124-125, 142-151, 232-237, 240-245

​​
403-1 ​ Occupational health and safety management system
12, 142-151, 240-245
8​
403-2
Hazard identification, risk assessment, and incident investigation ​ 142-145
​​ 8
​​403-3​ Occupational health services
143-144, 149-150
8
​403-4​ Worker participation, consultation, and communication on occupational health and safety 149​ ​8, 16
​​403-5
Worker training on occupational health and safety​​ 146-148

8
​403-6​ Promotion of worker health 137, 148-150
3
​​403-7
Prevention and mitigation of occupational health and safety impacts directly linked by business relationships​​ 151
​​
8
403-8
Workers covered by an occupational health and safety management system
143

8​
403-9
Work-related injuries
145-146, 232-233, 235-236 3, 8, 16
403-10
Work-related ill health ​​
146, 235, 237​
3, 8, 16
MATERIAL TOPIC: DIVERSITY, EQUITY AND INCLUSION​
3-3
Management of material topics ​ 12, 77-82, 134-137, 226
​Principio 6

405-1​ Diversity of governance bodies and employees 12, 100-101, 134-136, 226
226
Principio 6
​5, 8
406-1​​​ Incidents of discrimination and corrective actions taken​ 115-116, 137​​ Principio 1, 2, 6
5, 8
TOPIC: PRODUCT SAFETY ​
3-3​​​ Management of material topics 13, 77-82, 178-181​​
​​416-1
Assessment of the health and safety impacts of product and service categories
178-181

16
MATERIAL TOPIC: LOSS OF SENSITIVE DATA
MATERIAL TOPIC: DIGITAL TRANSFORMATION ROADMAP
3-3​ Management of material topics 10-11, 20-23, 77-82
418-1
​Substantiated complaints regarding breaches of customer privacy and losses of customer data
111​​ 16
​MATERIAL TOPICS THAT ARE NOT COVERED BY GRI INDICATORS ​ ​
MATERIAL TOPIC: ENVIRONMENTALLY SUSTAINABLE PRODUCT ​ ​ ​
3-3​ Management of material topics​ 77-82, 162-172
*For omissions, please provide the omitted information, the reason and explanation.
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​SASB and WEF​

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​   SASB - Auto parts
Topic​​ SASB ID​ Disclosure​ 2022 NFI page number or other disclosure​​
Energy Management​​​TR-AP-130a1​ (1) Total energy consumed,
(2) percentage grid electricity,
(3) percentage renewable​

194​
Waste Management​​TR-AP-150a.1​(1) Total amount of waste from manufacturing,
(2) percentage hazardous,
(3) percentage recycled

205​
​   WEF Measuring Stakeholder Capitalism - Core metrics​
Topic​​
Disclosure​​  Page number of disclosure

Quality of governing body​


Governance body composition​

98-101


Ethical behaviour​

Anti-corruption​​ 109-110, 114-117, 125​​

Protected ethics advice and reporting mechanism​115-116, 137
Risk and opportunity oversight​
Integrating risk and opportunity into business process ​ 122-125​​

Climate change​​

 ​ Greenhouse gas (GHG) emissions​196-198​​​
​ ​ TFCD implementation​​248-249
​​Freshwater availability​​
Water consumption and withdrawal in water-stressed areas​201-202
​Dignity and equality​
Diversity and inclusion​
92, 98-99, 136, 226​​​
Community and social vitality​
Total tax paid​
117-118, 238-239, Paragraph Section “Performance of Brembo Companies” included in the Directors’ Report on Operations


​​​Employment and wealth generation​



Absolute number and rate of employment​
128-129, 228-230

Economic contribution​
211

Financial investment contribution​
211




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