ESG Policy

ESG At a Glance

Profile

EL BAT AD is an industrial company specialized in the recycling of lead-acid batteries and the production of refined lead, lead alloys, recycled polypropylene, and sodium sulfate. The company operates in a highly regulated sector related to hazardous waste management and metallurgical production.

International Market
Over 95% of the company’s clients are international partners. This requires a prominent level of predictability, compliance with legislation, and stability in long-term business relationships.

Approach
The company applies an integrated ESG approach that is part of the day-to-day management of its operations and key processes.

Systems
The company’s operations are supported by certified management systems:
ISO 9001:2015 – Quality Management
ISO 14001:2015 – Environmental Management
ISO 45001:2018 – Occupational Health and Safety

Governance
Corporate governance is based on the principles of transparency, compliance with legislation, and integrity. The company applies zero tolerance for corruption and maintains mechanisms for reporting and handling violations.

Operations
EL BAT has its own laboratory for quality and production process control and continuously invests in the modernization of its production capacities and environmental infrastructure.

Introduction

EL BAT AD is a Bulgarian industrial company with over three decades of experience in the recycling of lead-acid batteries and the production of refined lead, lead alloys, recycled polypropylene, and sodium sulfate. The company operates in one of the most highly regulated industrial sectors, related to hazardous waste management and metallurgical production, where standards for safety, control, and quality are critical to business reliability and long-term sustainability.

The business model of EL BAT follows the principles of the circular economy. Through technologically controlled processes, hazardous waste is transformed into secondary raw materials that are returned to the industrial cycle. This model has not only environmental significance but also strong industrial value: it ensures a predictable flow of materials, sustainable use of resources, and stability of supply chains for partners who rely on consistency and quality.

Through the recycling of lead-acid batteries, the company contributes to the recovery of valuable materials and to reducing the need for the extraction of primary natural resources. This is a key aspect of EL BAT’s ESG approach: sustainability is directly linked to resource optimization and to the responsible management of potential impacts in an environmentally sensitive sector.

Over the years, EL BAT has established itself as a regional industrial operator and a reliable partner for international companies. More than 95% of the company’s clients are located outside Bulgaria, which requires a high level of process control, clear management rules, transparency, and compliance with applicable regulatory frameworks and industry expectations. In this context, sustainability for EL BAT is not an abstract concept, but a factor that supports trust, predictability, and long-term partnerships.

The company considers sustainable development as an integral part of the management of its operations, rather than as a separate initiative. ESG principles are applied through a systematic approach that includes risk management, clearly defined internal rules and responsibilities, standardized processes, training and control, as well as mechanisms for continuous improvement.

This ESG Policy presents the principles and practices through which EL BAT applies its approach to corporate governance, environmental protection, and social responsibility. The document reflects and presents in a structured manner the philosophy and principles embedded in the company’s existing internal policies and management systems.

1. Governance & Ethical Conduct

1.1 Governance and Responsibility

Corporate governance at EL BAT is based on the principles of transparency, integrity, compliance with legislation, and accountability. Management is responsible for the strategic development of the company and for managing key risks associated with operating in a highly regulated industrial sector.

The integrated management systems under ISO 9001:2015, ISO 14001:2015, and ISO 45001:2018 provide a structured framework for process management. This framework supports consistency in execution, internal control, and the approach to improvement—through clearly defined responsibilities, periodic management reviews, and mechanisms for identifying non-conformities and implementing corrective actions.

1.2 Ethics and Integrity

The company’s ethical principles are defined in the Code of Conduct and the Anti-Corruption Policy. EL BAT applies a zero-tolerance policy toward corruption, bribery, fraud, and other forms of misconduct. Employees and individuals acting on behalf of the company follow established standards of professional and ethical conduct in all business relationships.

The company’s approach includes clear rules for preventing undue influence on business decisions, including principles related to gifts, invitations, and other forms of hospitality, as well as requirements for good faith conduct and compliance with the law.

1.3 Conflict of Interest

The company expects employees and members of management bodies to act in the best interest of the company and to avoid situations of actual or potential conflict of interest. In the event of such situations, mechanisms are applied for timely disclosure and risk management, ensuring that decisions are objective, transparent, and in line with internal rules.

1.4 Responsible Relationships with Partners

EL BAT builds its relationships with clients, suppliers, and partners on the principles of transparency, mutual respect, and fair competition. The company strives to maintain long-term partnerships based on trust, professionalism, and predictability.

At the same time, the company expects its business partners to comply with the law, generally accepted standards of social responsibility, and the fundamental principles of ethics and integrity.

1.5 Whistleblowing and Protection

The company maintains mechanisms for reporting violations and non-conformities, including the possibility to submit reports through established channels, in accordance with applicable procedures. Each report is reviewed objectively, and where necessary, appropriate corrective measures are taken within the framework of internal processes.

This element is key to trust and control: the ability to report supports prevention, timely response, and a culture of integrity.

1.6 Transparency and Accountability

Financial operations are documented in accordance with applicable accounting standards and regulatory requirements, ensuring traceability and transparency of information. The company considers accountability as part of sustainable management—both in financial terms and as a principle supporting predictability and trust in relationships with international partners.

Stable governance is the foundation upon which EL BAT builds its environmental and social responsibility and maintains the sustainability of its long-term business relationships.

2. Environmental Responsibility

2.1 Our Commitment

Environmental protection is an essential element of EL BAT’s operations. The company operates in an industry that requires a prominent level of technological control and environmental discipline. Environmental responsibility is part of the company’s industrial operating model and is implemented through systematic process control, management of impacts, and sustainable use of resources.

The company’s core activity is related to the recovery of valuable raw materials through the recycling of lead-acid batteries and their return to the industrial cycle. In this way, EL BAT contributes to the development of the circular economy and to reducing the need for the use of primary natural resources.

2.2 Systematic Control and Compliance

The management of environmental aspects is conducted through the certified management system under ISO 14001:2015 and through the implementation of the requirements of the issued Integrated Permit for the operation of production installations.

The company’s activities are carried out in accordance with applicable legislation and are subject to monitoring and control by the competent authorities. The results of environmental monitoring are reported to the relevant institutions, including the Regional Inspectorates of Environment and Water (RIEW).

The company conducts systematic monitoring of key environmental indicators related to emissions into the atmosphere, water, soil, and groundwater. Measurements are performed by accredited external laboratories, and the results are documented in internal registers and used to track compliance with the requirements of the Integrated Permit and the regulatory framework.

2.3 Investments and Technological Development

The company applies technological solutions and organizational measures aimed at the effective management of production processes and control of environmental impacts.

The development of production capacities and infrastructure is carried out in accordance with the requirements of applicable legislation, the Integrated Permit, and the standards of the management systems.

Technological control and process optimization are an important part of the company’s approach to the sustainable management of resources and production efficiency.

2.4 Water and Resource Management

Water flows generated from production activities are managed through controlled systems for collection, treatment, and management.

The company applies approaches for efficient use of resources and optimization of production processes. Where technologically feasible, the reuse of process water is applied, contributing to the reduction of natural resource consumption and to more efficient management of water flows.

2.5 Waste Management

The core activity of EL BAT is related to the recovery of valuable raw materials from hazardous waste. In this sense, waste management is at the core of the company’s production model.

Incoming materials are processed through technologically controlled processes and are transformed into secondary raw materials that are reused in the industrial cycle.

The company maintains traceability of incoming and outgoing material flows and applies internal practices for resource optimization and reduction of residual flows.

2.6 Preparedness and Risk Management

As an industrial operator in a regulated environment, EL BAT maintains procedures for risk management and response to emergency situations.

The company conducts periodic training sessions and drills related to emergency preparedness, and the internal emergency plan is updated when necessary in accordance with the development of activities and regulatory requirements.

The objective of this approach is to ensure process discipline, safety of the production environment, and readiness to respond to emergency situations.

2.7 Continuous Improvement

The company applies the principle of continuous improvement in the management of environmental aspects of its operations.

The results of monitoring, internal audits, and management reviews are used as a basis for improving processes and developing management systems.

Control over the quality of raw materials, products, and key production parameters is supported by EL BAT’s internal laboratory, which provides operational control of production processes. Environmental monitoring of emissions and other indicators required by the Integrated Permit and applicable legislation is carried out by accredited external laboratories.

3. Social Responsibility

3.1 Health and Safety

The health and safety of employees are a primary priority for EL BAT. The company applies a systematic approach to the management of occupational health and safety through the certified system under ISO 45001:2018.

The approach includes the identification of hazards, assessment of occupational risks, planning and implementation of preventive measures, training and instruction of employees, and continuous improvement of working conditions. In an industrial environment, this is a key element of sustainability: safety is a prerequisite for stable processes, predictability, and responsible operations.

The company promotes a culture of awareness and responsibility toward safety, in which employees can report risks and non-conformities through established internal mechanisms.

3.2 Development and Competence

The quality and sustainability of EL BAT’s operations depend on the professionalism and commitment of the people within the organization. The company encourages the development of employees’ knowledge, skills, and technical expertise through training and professional development.

Professional development is also an important factor in risk management: well-prepared teams operate more safely, more efficiently, and more consistently, which supports the quality and reliability of production processes.

3.3 Human Rights and Equal Opportunities

EL BAT applies the principles of equal opportunity and non-discrimination and does not allow discrimination on any grounds. The company does not allow forced or child labor and requires respectful treatment and professional conduct in the working environment.

These principles are part of the overall approach to social responsibility and are aligned with ethical standards and the requirements for integrity and responsible conduct.

3.4 Community Engagement

The company maintains open dialogue with stakeholders and institutions and strives to build sustainable relationships with local communities and partners. For an industrial operator in a regulated sector, trust is built not only through processes and control, but also through predictable, respectful, and responsible interaction with the environment in which the company operates.

As part of its corporate social responsibility, EL BAT supports social, educational, and public initiatives that contribute to the development of society and the environment in which the company operates.

3.5 Culture of Responsibility

Social responsibility at EL BAT is reflected in the daily adherence to safety rules, professional ethics, and mutual respect. The company views social sustainability as a combination of a safe environment, competent people, and a culture of integrity, which together create a stable foundation for long-term development.

Conclusion

This ESG Policy reflects EL BAT’s integrated approach to governance, environmental protection, and social responsibility. For the company, sustainability is not a separate initiative, but a natural extension of the way it manages risk, invests in development, and builds long-term partnerships.

In an environment with high regulatory requirements and international expectations, EL BAT considers transparency, compliance, and systematic control as the foundation of trust. Through the implementation of certified management systems, the development of technologies and processes, and a culture of integrity, the company strives to be a reliable and responsible industrial partner in the international market.

Our commitment is to continue developing our operations in a sustainable manner, balancing economic efficiency, environmental responsibility, and social stability.

Documentation Basis

This ESG Policy has been developed on the basis of EL BAT’s internal policies, procedures, and certified management systems.

The document is based on: