FerroGlobe Resources Group Business Plan › Section 10 › ESG, Sustainability & Just Transition

10.1 ESG Philosophy

FGRG views ESG not as compliance overhead but as a core source of
competitive advantage. The decade ahead will see a fundamental
restructuring of global steel demand around carbon intensity — driven by
the EU Carbon Border Adjustment Mechanism (CBAM), increasing buyer-side
procurement preferences, and emerging carbon-tax regimes in major
markets. FGRG’s strategy is engineered to position the Company as a
low-carbon supplier from the outset: scrap-based EAF production,
integrated renewable energy, and rigorous Scope 1, 2 and 3
measurement.

10.2 Environmental Strategy

Carbon roadmap

• Scope 1: All owned greenfield production via EAF (electric arc
  furnace) — emits ~0.5 t CO₂/t steel vs ~2.0 t CO₂/t for blast-furnace
  route — a 75% reduction.
• Scope 2: Renewable energy targeted at 60% of electricity
  consumption by Year 7 through owned solar (200 MWp) and contracted
  wind/solar wheeling agreements.
• Scope 3: Active engagement with logistics partners to reduce
  shipping emissions; selective use of biofuel-blended bunker fuel; modal
  shift to rail where economical.
• Reporting: Full GHG Protocol-aligned reporting from Year 2; CDP
  submission from Year 3; Science Based Targets initiative (SBTi)
  validation by Year 5.

Resource & circularity

FGRG’s scrap-aggregation network secures domestic and regional scrap
supply, materially reducing virgin iron-ore consumption. Targeted
recycled content in own-production output is 75% in Year 4, rising to
90% by Year 7. Water consumption is minimised through closed-loop
cooling at all owned facilities, with mandatory water-stewardship plans
aligned to the Alliance for Water Stewardship (AWS) standard.

10.3 Social Strategy

FGRG is committed to making a measurable positive contribution to the
South African and broader African economies. Direct employment is
targeted at 1,200 by Year 7, with an additional 4,500 indirect jobs
through the supply chain and contractor base. Skills development —
through accredited learnerships, engineering bursaries, and trade-skills
programmes — is a core operational commitment. The Company will achieve
and maintain a Level 4 BBBEE rating from Year 2, advancing to Level 2 by
Year 5 through structured ownership, management-control, and
enterprise-development initiatives.

10.4 Governance Strategy

Governance is structured to institutional-investor standards from
inception. The Board of Directors comprises 9 members: 3 executive (CEO,
CFO, COO), 3 independent non-executive (chaired by an independent
Chairman), and 3 nominee directors representing major shareholders.
Mandatory Board committees include Audit & Risk, Remuneration &
Nominations, and Sustainability & Safety. Tier-1 audit (Big-4 or
equivalent international firm) and IFRS reporting are in place from Year
1. The Company commits to King IV Code on Corporate Governance.

10.5 Just Transition Alignment

South Africa’s Just Energy Transition Investment Plan (JET-IP)
recognises the social impact of decarbonising legacy industries. FGRG
aligns its strategy with JET-IP principles by (i) hiring preferentially
from regions affected by ArcelorMittal SA’s Longs Business wind-down and
other affected industrial communities; (ii) co-investing in re-skilling
programmes for workers transitioning from coal-based industries; and
(iii) ensuring that all greenfield investment incorporates
renewable-energy procurement and zero-carbon design intent. FGRG views
just-transition alignment as both ethically essential and commercially
valuable — strengthening social licence and unlocking concessional
capital from JET-IP funders.

Confidential — this business plan is provided to prospective investors and lenders for evaluation purposes only and may not be reproduced or distributed without the written consent of FerroGlobe Resources Group (Pty) Ltd.