Bilancio di
sostenibilità
Sustainability 
Report
2021

AFV BELTRAME GROUP
Viale della Scienza, 81
36100 Vicenza - Italy -
info.it@beltrame-group.com
www.gruppobeltrame.com
Sustainability Report

INDEX
1.
2.
3.
WHAT DO WE MEAN BY 
SUSTAINABILITY?
METHODOLOGICAL NOTE
AFV BELTRAME GROUP
CHAPTER 1
1.1 History and evolution
1 6
1.2 Mission e vision of AFV 
Beltrame Group
1 7
1.4 AFV Beltrame Group values
1 8
1.5 Corporate bodies
1 9
1.6 AFV Beltrame Group 
structure
1 4
SUSTAINABILITY IN AFV 
BELTRAME GROUP
CHAPTER 2
2.2 Materiality analysis
3 0
2.3 Materiality matrix 
3 1
2 9
PRODUCT SUSTAINABILITY: 
CIRCULAR ECONOMY, 
QUALITY AND INNOVATION
CHAPTER 3
3.1 Circular economy
4 2
3.2 Sustainable supply chain 
management and procurement 
policy
4 3
3.3 R&D and technological innovation
4 4
3.4 SRA injection project
4 2
4 7
3.5 A.I. Projects
4 8
3.6 Quality and product safety
4.1 Beltrame's commitment to 
responsible environmental management
5 4
5 8
5 4
4.4 Energy consumption
4.2 Policies and QHSE Management 
System
5 6
4.3 EPD certification
6 2
4.7 Water resource management
6 8
7 0
4.8 Raw and auxiliary materials and waste
7 2
4.9 Radiometric measurements
6 0
4.5 Air emissions management
4.6 Greenhouse gas management 
CHAPTER 4
8 4
5.1 Group human resources. People, 
relationships and value
5.2 The trend in employment levels
CHAPTER 5
5.4 The Academy for training
8 6
5.3 Human resources compensation
8 6
8 8
9 0
5.5 Industrial relations
9 2
5.6 Digitalisation
9 5
5.7 Training & Cybersecurity
9 6
5.8 Welfare in AFV Beltrame Group
9 7
5.9 Equal opportunities and respect 
for human rights 
1 0 0
5.10 Covid management
5.
ATTENTION TO
HUMAN CAPITAL
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2021 Sustainability Report
6.
CONNECTION WITH 
TERRITORY
CHAPTER 6
1 1 2
6.1 Territory and Community
1 1 4
6.2 Donations in favour of the territory
7.
SUSTAINABILITY
PERFORMANCE
1 4 0
INDIPENDENT AUDITORS’ REPORT
1 2 0
1 3 1
7.1 Sustainability performance 
7.4 Social sustainability parameters
1 3 6
7.5 Environmental sustainability 
parameters
1 2 4
7.2 Correspondence between the contents 
of the Report and the GRI indicators 
7.3 Economic sustainability 
parameters 
1 3 2
CHAPTER 7
1 6
1.3 Reference markets
2 0
1.7 Creation of value for 
stakeholders
2 2
1.8 Ethics, business integrity 
and compliance
2 4
1.9 Anticorruption Policy
2.5 Identifying and dialogue with 
stakeholders 
3 4
2.6 Creating stakeholder 
engagement 
3 6
3 2
2.4 UN Sustainable 
Developement Goals
5 0
3.7 Continuous improvement
1 0 2
5.11 The health and safety of 
employees
LETTER TO STAKEHOLDERS
2.1 Approach to sustainability
7 4
4.10 Conservation of biodiversity 
and territories
4.
ENVIRONMENTAL 
AWARENESS

I am pleased to introduce our second Sustainability Report, which continues 
our journey of transparency and the sharing of our work. 
We could not do otherwise because we believe sustainability means 
the protection of the environment and the territories that host us. 
We believe sustainability means standing at our people’s side and 
supporting our surrounding communities and economies. These activities 
ensure that saying “tomorrow will be better” doesn’t remain a beautiful 
intent, an inflated slogan, or greenwashing.
For us, sustainability means producing steel, rethinking industrial 
processes according to more virtuous models, and investing to make them 
happen.
It means working first-hand, above all as a company, to reverse a course 
that, as it stands, has shown all its inconsistencies, fragility, and risks. 
Sustainability is taking action in an increasingly profitable synergy with 
all stakeholders because sharing projects is the key to building the future 
together.
Yet it also means balancing the delicate nature of man versus nature in a 
zero-sum game. It enhances our know-how, letting those who look 
suspiciously at the iron and steel world know the excellent circularity of the 
value underlying it. 
It signifies promoting culture and a more respectful, inclusive, participatory 
mentality which can increase the sense of belonging to the cause of 
sustainability. Hence, without exception, we all feel called to act in favour 
of the environment. A duty that I feel above all towards the youngest.
In 2021, a year marked by the pandemic 
emergency, we have given concreteness to these 
objectives with various plans and investments, 
such as intensifying train transport between all 
group factories and managing over 1.1 million 
tons of steel by rail. Another sign of 
modernization has been the renovation of the 
entire production plant at our Swiss 
headquarters, which will allow us to increase 
productivity, significantly improve energy 
efficiency and reduce emissions with the 
installation of a new oven in the rolling mill. 
We’ve also installed new low-emission billet 
heating furnaces in the French and Romanian 
factories. Additional activities include the 
mapping of the total CO2 contribution of our 
production sites and subsequent identification 
of corrective solutions, the optimization of 
lamination processes through intelligence 
algorithms artificial, the replacement of burners 
with more efficient ladles, the revamping of 
electric motors with higher efficiency class, the 
use of polymers to replace coal. 
Our more than 125 years of history guide us in 
this endeavour and will continue to do so in the 
future. A noteworthy past in which we have 
received and handed down valuable infusions of 
inheritance made up of entrepreneurship that, 
nowadays, has to be more courageous in 
pursuing the integration of three well-known 
pillars: people, planet, profit as a driver of 
business development, not only in our sector but 
in all sectors that require integrated 
management of social aspects, environmental 
and financial aimed at a common goal.
After all, this is precisely what we are called to 
do: accept the challenges of a time that requires 
change and requires us to continue to be 
creators of well-being, progress, and trust. 
For us and others. In the workplace as well as 
at home. As individuals and as a community. 
As companies and as individuals. Without 
hesitance. Without fear. 
The keyword is sustainability and implies total 
dedication. 
Ours is all included in this document.
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2021 Sustainability Report
Letter to Stakeholders
Antonio Beltrame
President and Managing Director

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2021 Sustainability Report
Equal attention is paid to activities that promote an 
increasingly safe and healthy workplace, motivating in 
terms of professional growth, enhancing skills, and 
attracting and retaining talents. Corporate welfare 
initiatives and broad-spectrum and easy-to-use training 
proposals are at the centre of these efforts. 
The perception of the contribution to sustainable 
development that the entire supply chain can provide is 
clear, upstream and downstream of the cycles under the 
company’s direct control. Businesses must take on 
these challenges by involving and exchanging 
information with the actors of the various supply chains, 
creating virtuous paths of transport optimization and 
product choices with reduced impact. 
Another critical point is the company’s contribution to 
the well-being of local communities, thanks to 
continuous listening and discussion and collaboration in 
social activities. This aspect has found further fertile 
ground in the problematic pandemic period we are 
experiencing, highlighting the close interdependence 
between productive activities and the territory. 
The challenge is difficult, but the consolidated principles 
on which AFV Beltrame Group is based, which refer to all 
the aspects mentioned above, allow our company to 
face the moment’s complexity. The company maintains 
a clear vision of sustainable development that pursues 
effective governance and being socially responsible and 
attentive to environmental impacts. 
With the drafting of this Sustainability Report, the 
Group presents a summary of the activities carried 
out and the services achieved in the three ESG 
guidelines described here, of which sustainability is 
the common denominator, as well as its ambitious 
objectives, consistent with the expectations of its 
stakeholders. 
It might seem like a given question, but the ease in how 
we approach this concept begs a reflection on its 
meaning. 
It is evident how much complexity lies in the correct 
management of the aspects that contribute to making an 
organization sustainable. Companies must adopt a 
rigorous multidisciplinary approach to ensure that 
reporting and sustainability declarations find solid 
foundations in corporate management. Integrating the 
UN Sustainable Development Goals (SDGs) into the 
company’s business unravels to include the challenge of 
climate change. It starts with measures developed to 
reduce the environmental footprint of industrial 
processes, in particular those with high carbon intensity 
such as the iron and steel ones, defined as “hard-toredu-
ce.” Thanks to the promising technological 
development favoured by the European Green Deal and 
the development of offset projects, we can reach 2050 
with the “carbon neutral” perspective indicated by the 
European Union. 
Alternative material uses in processes, recycling, and 
resource valorisation exemplify many efforts of a circular 
perspective in the environmental field. 
The electric furnace is the leader in the steel industry by 
its intrinsic nature, grounded on the recovery of ferrous 
scrap.
Giovanni Battista Landra
Group EHS and Sustainability Director
What do we mean by 
sustainability?

Scope of the Sustainability Report analysis 
and reporting period
AFV Beltrame Group is present in Europe and operates 
through direct subsidiaries and a dense network of 
distributors, investee companies, agents, and direct sales 
forces. Over 2,250 employees are part of AFV Beltrame 
Group. The Group is made up of six production plants. 
Three are based in Italy (Vicenza, San Giovanni Valdarno 
(AR), San Didero (TO)); one in Switzerland, one in France, 
and one in Romania. 
This Report refers to the 2021 financial year (from 1 January 
to 31 December 2021) and proposes a comparison with the 
indicators of the previous two-year period (2019-2020). 
The scope of the data and the social and environmental 
information comprises companies belonging to the Group 
on 31 December 2021, consolidated using the integral 
method of consolidation of the financial statements in the 
Group Consolidated Financial Statements. This excludes 
Sipro Beltrame AG, Laminoirs du Ruau S.A., and Donalam 
Siderprodukte A.G. They are inconsequential entities to the 
contribution of the reported sustainability indicators. 
The companies included are: 
• AFV Acciaierie Beltrame S.p.A., Parent Company of the 
company based in Vicenza, and the following foreign 
subsidiaries of the Group: 
• Laminés Marchands Européens S.A., a French subsidiary 
based in Trith Saint Léger, part of the AFV Beltrame Group 
since 1994; 
• Stahl Gerlafingen AG, a Swiss subsidiary based in 
Gerlafingen, part of the AFV Beltrame Group since 2006; 
• Donalam Srl, a Romanian subsidiary based in Calarasi, 
part of AFV Beltrame Group since 2007. 
The document sections indicate any limitations to the 
specified reporting boundaries or clarification of 
calculation methods.
AFV Beltrame Group deals with sustainability issues along 
the entire value chain, committing itself to integrating them 
into its work activities. This choice is why the Group adopts 
clear and measurable indicators (KPIs) that all company 
departments must achieve. The company also defines the 
guidelines that allow the creation of an integrated systemic 
process. 
To encourage this integration, AFV Beltrame Group has 
indicated its sustainability policy, developing it on two key 
points: sustainability of production processes and 
enhancement of relations with internal and external 
stakeholders.
 
The strategic approach to sustainability
Methodological Note
AFV Beltrame Group drafted this Sustainability Report 
according to the reporting principles proposed by the GRI. 
The document was also subject to a limited assurance 
(“limited assurance engagement” according to the criteria 
indicated by the ISAE 3000 Revised standard) by the 
external auditing company Deloitte & Touche S.p.A. 
According to the procedures indicated in the “Report of 
the Independent Auditors,” this document was subject to 
verification. 
Therefore, assessments of revisions or comparisons with 
data provided previously are not applicable for 2019 data, 
nor checks on changes made to material topics or the 
identified perimeter.
AFV Beltrame Group does not fall within the scope of 
Legislative Decree No. 254/2016, inherent in the 
obligation to prepare a non-financial statement but has 
opted for this communication method to represent its 
performance in ESG areas. The publication is set on an 
annual basis.
Premise
The EHS Corporate Department coordinated the drafting of 
the 2021 Sustainability Report, involving the Group’s entire 
organizational structure and companies included in the 
reporting boundaries, each with its own Operational 
Sustainability Committee *. 
The contents of the Report, in general, have been prepared 
according to the reporting standards of the Global 
Reporting Initiative (GRI), Sustainability Reporting 
Standards of 2016, except for specific standards: 
• GRI 303 (Water and effluents) and GRI 403 
(Occupational Health and Safety) published in 2018; 
• GRI 306 (Waste) published in 2020. 
The Report has been prepared in accordance with GRI 
Standards according to the “in accordance - Core” option.
Drafting of the Report and 
References
Document Objectives
The reporting methodology was confirmed compared to the 
previous edition by the Operational Sustainability 
Committee * 
The process results were presented in a first version to the 
Sustainability Steering Committee ** and subsequently to 
the Board of Directors.
 
*Operational Sustainability Committee –OSC 
Operational Committee: supports operational activities, 
involves other functions in the sustainability project, 
collects the data and information to prepare the 
sustainability report. 
** Sustainability Steering Committee –SSC 
Steering Committee: develops the corporate 
strategy on sustainability. It also sponsors the 
project, defines and updates the areas of interest 
and action, and reshapes the objectives into a 
strategic function.
Document definition
 Following GRI Standards, ‘material’ information must be 
included in the Sustainability Report. Information is 
‘material’ when it has a significant impact on the 
organization’s economic, environmental, and social position 
and may affect stakeholders’ sphere of influence regarding 
expectations and decision-making processes. 
The standards also require the company to describe the 
process of identifying these reported ‘material’ aspects. The 
process followed by the Group was based on four central 
moments: identification of the factors according to an 
objective assessment based on a systemic approach, 
evaluation of the relevance for the stakeholders and the 
organization, with prioritization of the same, validation by 
the company board and review by an independent third 
party. 
Relevant materiality aspects on reporting 
period
The materiality matrix and the issues reported remain 
those of the previous edition (as approved by the SSC 
and obtained through an analysis of the relevance of the 
various aspects perceived by the stakeholders, according 
to their expectations), which followed the process of: 
• reference to the indicators provided for by the GRI 
Standards; 
• benchmark with national and international companies 
in the sector and through sector analysis; 
• comparison with trade associations (Federacciai, Eurofer, 
Worldsteel); 
• preparation of forms for the collection of qualitative 
information and quantitative data; 
• internal scouting and analysis of employee evaluations 
(internal stakeholders) obtained through an internal 
questionnaire; 
• identification of external stakeholders by the operating 
committee; 
• involvement and listening to all internal and external 
stakeholders using a digital questionnaire, in which 
participants proposed topics potentially relevant for the 
Group, and a similar evaluation was requested to order the 
importance attributed to them; 
• sharing a summary document with the list of new 
materiality topics and Group stakeholders of reference.
Definition Process of AFV Beltrame Group 
Materiality Analysis
The materiality analysis has attributed primary importance 
(high importance both for the Group and for the 
stakeholders) to the following main aspects: 
• Environmental impact of production activities; 
• Health, safety, and well-being of workers; 
• Energy efficiency; 
• Product and service quality and relationship with 
customers; 
• Economic sustainability; 
• Development and training of human resources; 
The Group didn’t perceive anything as irrelevant. The 
positioning of certain aspects in the lower quadrant of the 
matrix (e.g., human rights) does not imply the attribution of 
little relevance. Instead, it expresses the perception that the 
Group has appropriately managed the issue within the 
Group or it does not contribute to creating long-term value 
for the Company or stakeholders. 
The cut-off hypothesis was also taken from the previous 
edition. The issues that reported a level of interest lower 
than the value of 40/100 were not classified as material. 
The criteria for defining the external reporting boundaries 
have also remained unchanged from the previous edition.
Point of contact: 
Ing. Landra Giovan Battista, EHS & Sustainability Group Director: 
gb.landra@beltrame-group.com
Creation of the AFV Beltrame Group materiality 
matrix for the reporting period
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2021 Sustainability Report
This 2021 Sustainability Report is a communication tool to 
report AFV Beltrame Group’s annual results towards 
sustainability for our stakeholders. 
The reporting boundaries brings together the foreign 
companies of AFV Beltrame Group  (from now on called the 
Group) with the intent to prepare  a document/report at the 
Group level. 
You can find the details regarding the realities integrated 
into these boundaries in the paragraph “Scope of the 
Sustainability Report analysis and reporting period”.

AFV Beltrame Group
1

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2021 Sustainability Report
AFV Beltrame Group profile and history
Acciaierie Ferriere Vicentine: the name that repre-
sents the history of an enterprise born in 1896 due 
to the willpower of its founder, Antonio Beltrame, 
who arrived in Vicenza and chose to devote himself 
to the processing of hoops barrel, horseshoes and 
rims, coach wheels, and the move forward to me-
chanical repairs, minor carpentry with forge and the 
manufacturing of nails from wire rod. With his com-
pany’s initial growth, the founder immediately proved 
to be a careful innovator. He sensed the advantages 
of electrical energy instead of thermal energy. He in-
vested year after year in the growth of his workshop, 
adding foundry departments, a hardware store, and 
wire mills and points. 
Antonio Beltrame’s Prized Mechanical Plant with 
Electric Power Foundry established itself rather 
quickly for competence and quality in only a few ye-
ars. In the first decade of the twentieth century, the 
Beltrame plant produced steam engines, compres-
sors, pumps, bridges, roofs, transmissions, mills, and 
industrial plants. 
The plant soon opened to a broader market, with 
very much attention to its organizational model, in-
novations and technical progress, work ethics, and a 
primitive but effective form of corporate welfare. All 
these characteristics encouraged the growth and 
internationalization of the company and enabled the 
strong position we are in today. 
The correspondence between the name of the family 
and the company - which at the time also represen-
ted physical contiguity between factory and home- in 
addition to the participation and contribution of all 
family members, allowed to merge the culture of 
productivity, quality, and change with a deep-rooted 
spirit of belonging. 
This last aspect has led to the harmonious synthesis 
between the culture of the family business and the 
characteristics of the company management, which 
nourishes the spirit with which today Beltrame 
management interprets the business and its growth, 
combining tradition, progress, modernity, and 
improvement. 
Le Acciaierie Ferriere Vicentine Beltrame went through 
three industrial revolutions and today has become an 
international group: AFV Beltrame Group. A leading 
European steel company in the production of merchant 
bars and beams, steel for structural uses mainly in the 
construction sector, automotive sector, and heavy 
machinery to shipbuilding. With over €1 billion in 2019, 
more than 2,000 employees, ten rolling mills, and three 
electric furnace steelworks, the Group serves around 40 
countries in Europe and the Mediterranean basin. 
With more than 2,250 employees, ten rolling mills, and 
three electric furnace steelworks, the Group serves 
around 40 countries in Europe and the Mediterranean 
basin. The six plants located in Italy, France, 
Switzerland, and Romania make our presence and 
position on the reference market very strong and our 
constant policy of acquisitions, which since the 90s 
has led to both consolidations of business leadership 
and business diversification. 
Our plants’ geographical distribution is also favourable 
for the supply of raw materials, while our widespread 
presence in all European markets, through partnership 
companies, agents, and direct sales forces. 
Our leading position derives from strengthening the 
synergies created between the Group companies due to 
the wealth of know-how and professionalism that 
characterizes each country’s entire production and 
distribution network. 
This operating style has ensured AFV Beltrame Group’s 
success in terms of products and processes. 
In 1896, by the will of the 
forefather Antonio Beltrame, 
the “Award-winning Mechanical 
Plant with electric power with 
Antonio Beltrame Foundry” was 
born.
In 1994 the company acquired 
the French LME (Laminés Mar-
chands Européens S.A.), in 
2002 the Siderurgica Ferrero, 
in 2006 the Swiss Stahl Gerla-
fingen (2006) and in 2007 the 
Romanian Donalam.
Today AFV Beltrame Group is a 
multicultural reality that em-
ploys 2,258 people in its facto-
ries, coming from 44 European 
and non-EEC countries.
1.1 HISTORY AND EVOLUTION
The Foundation
The Group
The People

1.2 MISSION E VISION OF 
AFV BELTRAME GROUP
The production of merchant bars, beams, 
reinforced steel, and special steels for various 
uses: construction and structural steels, 
shipbuilding, machinery ground station, and 
automotive. This activity is the mission of AFV 
Beltrame Group. This leading European steel 
company strives daily to ensure inclusive 
business development by continuously impro-
ving virtuous relationships between sustainable 
productivity, social innovation, and collective 
value. A never-ending path composed of daily 
work, investment, training, sharing of values, and 
implementation of good practice at all levels of 
the Group.
We persevere in the creation of excellence and 
quality values. Fostering responsibility towards 
the local, national and international communities 
that we feel part of and work hand in hand with 
to create a more prosperous, equitable, and 
sustainable environment. An environment that is 
respectful of the differences, identities, and 
cultures of one another.
1.4 AFV BELTRAME GROUP VALUES
Values consistent with innovation and continuous improvement must be widely 
explained and communicated. The first level of the action takes place within the 
company, via the guidance of management, who are the foremost believers and 
work hard to implement change ranging from processes, robotics, logistics, 
training, growth, and services. The second step initiates outside factory walls 
and involves suppliers, customers, institutions, and training schools. To unite 
these two worlds organically, an evolutionary process that considers human 
resources as people engaged in innovation by leveraging values must be 
activated. 
To make all of this a reality, AFV Beltrame Group made explicit a set of shared 
values that are relevant to the soul of the Group and that do not neglect the 
emotional side. 
Internalizing these values will be the driving force behind creating new con-
nections between company and suppliers and new relationships between pro-
ducers and consumers: values that generate value. 
Competence, continuous improvement, and relia-
bility towards its partners: AFV Beltrame Group 
aims to create value for people and its reference 
market. The Group’s geographical distribution 
is advantageous regarding the areas of consu-
mption of products and those of raw material 
supply. This structure enables the Group to 
be present in all European and Mediterranean 
markets.
1.3 REFERENCE MARKETS
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2021 Sustainability Report
mission
AFV Beltrame Group
AFV Beltrame Group specializ-
es in producing merchant bars 
and unique profiles intended 
for different use areas: con-
struction, steel for structural 
activities, shipbuilding, earth-
moving, and automotive ma-
chinery.
vision
AFV Beltrame Group
The Group’s vision envisages 
the pursuit of business deve-
lopment jointly with that of 
people through the continuous 
improvement of the virtuous re-
lationship between sustainable 
production, social innovation, 
and shared collective value.
values
AFV Beltrame Group
Since its foundation, AFV 
Beltrame Group has been 
inspired by the principles guid-
ing each company and its dis-
tinctive 
function. 
Principles 
that the Group undertakes to 
promote among its stakehold-
ers through transparency, mu-
tual growth, and the sharing of 
values and objectives.

Struttura di AFV Beltrame Group al 31 Dicembre 2021.
1.5 CORPORATE BODIES
1.6 AFV BELTRAME GROUP STRUCTURE
71%
BOARD OF DIRECTORS
BOARD OF STATUTORY AUDITORS
There are seven Board of Directors members, five 
men and two women. 29% belong to the age group 
between 30 and 50 years, and the remaining 71% 
are over 50.
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2021 Sustainability Report
Antonio Beltrame, President and Managing Director
Patrizia Beltrame, Vice President and Board Member
Angiola Beltrame, Vice President and Board Member
Alain Creteur, Managing Director
Raffaele Ruella, Managing Director
Carlo Beltrame, Board Member
Carlo Carraro, Board Member
Andrea Valmarana, President
Dario Semenzato, Statutory Auditor
Massimo Mari, Statutory Auditor
29%
AFV Beltrame Group structure on 31 December 2021:
Holding company:
AFV Acciaierie Beltrame S.p.A. 
with headquarters and factory in Vicenza 
and plants in San Giovanni Valdarno (AR) 
and San Didero (TO), Italy
Subsidiaries:
75%
80,23%
78,78%
Donalam Siderprodukte A.G.
Based in Zurich, Switzerland
Laminés Marchands Européens S.A.
Based in Trith Saint Léger, Francia
Laminoirs du Ruau S.A.
Based in Monceau-sur-Sambre, 
Belgium 
Stahl Gerlafingen A.G.
Based in Gerlafingen, Switzerland
Donalam SRL
Based in Calarasi, Romania
Sipro Beltrame A.G.
Based in Zurich, Switzerland
100%
86,47%
50%
AFV Acciaierie Beltrame S.p.A. is not subject to ma-
nagement and coordination activities by the majority 
shareholder Beltrame Holding S.p.A. which holds a 
91.88% stake.

2020: 42.326 €/000
2021: 60.621 €/000
2020: 29.811	
2021: 57.663
2020: 99,2%
2021:  97,8%
1.7 CREATION OF VALUE FOR STAKEHOLDERS
Regardless of the size and production context in which 
it operates, each establishment is within an increasingly 
globalized network, impacting business. And the resour-
ces it uses, in particular natural ones, belong to a single 
environment, which everyone must commit to safeguar-
ding. 
But to conduct its business sustainably, the company 
must find innovative solutions that allow it to analyze, 
understand and give feedback on the complexity of the 
context in which it is active. Furthermore, it must build 
a structured and constant relationship with its stakehol-
ders. Only in this way will it move along a trajectory that 
unites economic growth, social development, and the 
safeguarding of natural heritage.
S H A R E  H O L D E R S’ 
E Q U I T Y 
N ° E M P LOY E ES
N °  P R O D U CT I O N
S I T ES
T U R N OV E R
N °  (Q H S S E ) 
C E RT I F I E D 
S I T ES
Highlights: 2021 AFV Beltrame Group
To be successful in this objective, however, you must 
adopt a systemic, inclusive, and transparent approa-
ch and improve your ability to measure business de-
cisions by analysing all the impacts (economic and 
otherwise) that they produce in the short, medium, 
and long term. 
Therefore, it is essential to maintain a constant, con-
structive dialogue with its stakeholders focused on
listening to their needs and requirements to lay the foun-
dations for a lasting trust relationship and active involve-
ment. Stakeholders represent a wide range of different 
interests: establishing and maintaining stable and la-
sting relationships following transparency, correctness, 
clarity, and completeness of the information provided is 
a crucial element for creating shared and long-term.
ST E E L 
P R O D U C E D
D I ST R I B U T E D 
EC O N O M I C 
VA LU E 
T R A I N I N G
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2021 Sustainability Report
G E N E R AT E D 
EC O N O M I C 
VA LU E
P E R M A N E N T 
C O N T R ACTS
T EC H N O LO G I CA L 
I N V EST M E N TS
N E T
I N C O M E
2020: 363.914 €/000
2021: 540.010 €/000
2020: (21.421) €/000
2020: 976.960 €/000
2021: 160.539
2021: 1.737.811 €/000
2020: 995.221  €/000
2021: 1.901.263 €/000
2020: 1.960.059 tons
2021: 2.279.102 tons
2020: 976.261  €/000
2021: 1.678.830 €/000
2020: 2.104
ISO 9001: 6	
ISO 14001: 5	
	
ISO 45001: 6
ISO 50001: 1
2021: 2.258
2020: 6	
2021: 6

1.8 Ethics, business integrity and compliance
Governance in AFV Beltrame Group
The companies of the Beltrame Group have adopted a Code of 
Ethics which sets out the fundamental principles that 
inspire all the activities of the Beltrame Group. The Code of 
Ethics can be downloaded from the download section of 
our website: www.gruppobeltrame.com
The organisatonal model of the Parent Company
The Board of directors of AFV Beltrame spa, to ensure the 
uppermost conditions of fairness, transparency, and legality in the 
conduct of its business activities, adopted by resolution of the 
Board of Directors of 15/12/2008, the model of Organization, 
Management, and Control in line with the requirements of 
Legislative Decree no. 231/2001, which regulates the 
administrative reasonability of the company for crimes committed 
by management, employees, and collaborators in the interest or 
for the benefit of the company itself. 
An integral part of the Organizational model is the Code of Ethics, 
approved following the model itself, which contains the principles 
and rules of conduct that guide all the activity of the Beltrame 
Group. 
It is important to recall that the code of Ethics depicts principles 
of behaviour ( legality, correctness, and transparency) that are 
suitable and applicable to prevent illicit behaviours referred to in 
Legislative Decree 231/2001, making this document relevant to 
the model therefore complementary to it. 
The purpose of the model is to construct a structured and organic 
system of procedures and control activities that will allow via 
monitoring actions on areas of activity at risk to take prompt 
action to prevent the committing of the types of crimes listed in 
the Legislative Decree 231/2001. 
The model is regularly updated to adapt to new crime cases taken 
into account by the legislature as preconditions for applying 
Legislative Decree no. 231/2001. The last update was made on 
22.12.2020. 
The company has appointed a supervisory body to oversee the 
operations and observance of the Organisational Model. The 
supervisory body has autonomous powers of initiative and control 
and reports directly to the Board of Directors.
Code of Ethics
The companies belonging to the Beltrame Group considered it essential to adopt a Code of Ethics that clearly and 
transparently sets out a series of values that inspire and encourage the Beltrame Group the compliance with and 
achievement of business objectives, essential for the reliability, image, reputation, and overall proper functioning of 
the Group and future growth of all our companies. 
The Code of Ethics contains the principles and rules of conduct that guide and inspire the activities of AFV Beltra-
me Group - including the legality, correctness, transparency - and expresses the commitments and responsibilities 
that bound the directors, workers, and collaborators of all the companies of the Group in conducting activities 
aimed at achieving the company’s objectives.
22
23
2021 Sustainability Report
The Code of Ethics 
contains the principles 
and rules of conduct that 
govern the activity of 
AFV Beltrame Group.

1.9 Anticurruption Policy
Anticorruption Policy
The policy aims to establish the principles of conduct to 
avoid and prevent the implementation of corruption and 
provide guidelines for compliance with existing anticorrup-
tion provisions. This policy applies to AFV Acciaierie 
Beltrame spa and its subsidiaries.
Recipients and scope of application
This policy is addressed to employees, directors, 
customers, suppliers, financial partners and all parties 
in business relationships with the Beltrame Groups. 
References
Almost all states have laws that prohibit corruption in their 
Public Administration. Many states (including Italy, France, 
and Switzerland) have enacted regulations that prohibit 
corruption between private individuals. 
For the drafting of the policy, the definitions provided by 
the Italian legislation have been taken into consideration 
because they are substantially comparable to those of 
other countries. 
External references: 
-The United Nations Convention against Corruption 
(Merida Convention); 
-The OECD Convention on Combating Corruption; 
-The Criminal code and the Civil code are in effect in the 
individual countries where the Group’s companies are 
based; 
-Specific reference rules for the individual countries 
where the Group companies are established or the 
activities that could be at risk are carried out;
-Internal references: 
-Code of Ethics; 
-Organization model and related protocol.
Corruption against the Public Administration occurs 
when a public official receives for himself or third-party 
money or other utility or accepts the promise of money 
or other utility to perform an act of his office (own cor-
ruption), or to omit or delay the completion of an act of 
his office or even to action contrary to his office (impro-
per bribery). The punished conduct is not only that of 
the corrupted public the official who receives funds or 
amenities but also of the corrupter providing these funds 
and amenities).
24
25
2021 Sustainability Report
Corruption of Public Official
Corruption between private individuals
Corruption between private individuals occurs when direc-
tors, general managers, individuals in charge of preparing
corporate accounting documents, statutory auditors, or 
company liquidators (or individuals subject to their ma-
nagement or supervision) receive for themselves or a 
third-party funds or other benefits or accept the promise of 
funds or other benefits in exchange for the performance or 
omitting of acts in violation of the obligations inherent in 
their office or the duties of loyalty, resulting in harm to the 
company.
Consequently, it is strictly prohibited to give, offer, promise 
directly or through third parties, money, or other active
corruption benefits to any of the above-mentioned per-
sons (active corruption). It is also forbidden to receive or 
consent to receive funds or other benefits for oneself or 
for third parties to perform or omit acts in violation of the 
obligations inherent in one’s office and the commitments 
of loyalty, causing harm to the company (passive corrup-
tion).
Specific principles
The corruptive behaviour, active or passive, towards the 
public Administration or between private individuals, as
previously mentioned generally consist of:
- Give or promise to give, receive or accept receive funds
- Give or promise to give, receive or agree to receive other 
usefulness
The concept of other utility refers to various cases, in-
cluding gifts, recruitment of personnel, the conclusion of 
contracts of consultation, discounts on products, etc. 
In line with its code of Ethics and Organizational Model, 
the Beltrame Group prohibits corruption in any form 
without exception. As a result: 
all forms of bribery against anyone, whether public or 
private, be it the direct or indirect bribery, be it active 
corruption (if you look at it from the point of view of the 
corrupter) or passive corruption (if you look at it from the 
point of view of the corrupted).
Guiding principles
General principles
The value of integrity is part of the Beltrame Group 
culture, where corruption, whether public or private, is 
not tolerated.
The Group prohibits any practice of corruptive nature 
and undertakes to guarantee corporate conduct based 
on the principles of transparency, honesty, and integrity. 
The Group prohibits this in all the countries in which it 
operates, additionally requiring full compliance with laws 
and regulations in these countries.
The Code of Ethics and Organizational model adopted, 
with the relevant protocols, constitute a regulatory body of 
reference to avoid corrupt practices.
This policy belongs to this context as an integrative and 
summary tool of the guidelines that apply across all 
company processes that may risk corruptive conduct.
In 2021, no cases of incidents caused by corruption, anti-competitive beha-
viour, antitrust and  monopolistic practices were recorded, nor was any 
entity of the Group subject to significant sanctions, monetary or otherwise, 
for non-compliance with laws or environmental regulations and in social and 
economic matters.
Implementation and Monitoring
To ensure the implementation of this policy, specific mea-
sures are carried out to audit and monitor compliance
with the indicated principles. Any individual who believes 
that there has been a violation of the tenets reported can
e-mail to the Internal Auditing department.
In compliance with its code of ethics, the AFV Beltrame 
Group is committed to operating in the market by adopting 
behaviours that follow the laws and regulations that pro-
tect free competition. Not only in connections with compe-
titors but also in relationships with customers, suppliers, 
and other third parties.
The AFV Beltrame Group believes that an open market and 
free competition constitute an added value for consumers
and businesses. Therefore, the group operates autono-
mously, using its entrepreneurial merits, safeguarding the 
principle of fair competition by respecting its competitors. 
With this in mind, an antitrust policy has been adopted 
which provides employees with the information in the 
regulatory context and the rules of conduct to be followed.
Antitrust policy
Based on the considerations mentioned above, it has 
therefore been identified as areas at risk concerning cor-
ruptive conducts, those covered by the following Protocols 
231:
We, therefore, reaffirm the obligation of strict compliance 
with the Organisational model and related Protocols that 
constitute a regulatory body of reference to avoid the com-
mission of corruptive practices.
Purchase
of goods 
and services
Consulting 
and 
Professional 
assignments
Human 
Resources 
Management
Expense 
Reimbursements
Monetary 
and 
Financial 
flows
Donations, 
sponsor-
ships, 
giveaways
Sales 
Management
1
2
3
4
7
6
5
Relationships 
with Public 
Officials and 
Revising Authorities
10

Sustainability in 
AFV Beltrame Group
2

Can sustainability be a strategic approach to business development? 
2.1 APPROACH TO SUSTAINABILITY
The AFV Beltrame Group has set up its busi-
ness according to the guidelines that govern 
the principles of sustainability, which are based 
on the three pillars: attention to profit, people, 
and the planet (so-called 3Ps).
Economic value creation is essential for 
business development, and a lot of 
consideration is rightly paid to it. The 
perspective with which this aspect is addres-
sed in financial management favours the 
components that contribute to the growth of 
the distributed economic value. It represents 
evidence of shared values generated by the 
subjects who contributed to producing it. 
Indeed, there is a strong awareness that the 
contributions of the various categories of 
stakeholders are interconnected and vital for 
the growth and development of the Group and 
its entire value chain.
Attention to human capital and people is a 
priority for the Group. Many resources are 
dedicated to training and professional and 
personal growth, offering innovative tools 
(such as the Beltrame Academy), enhancing 
the skills demonstrated by individuals, deve-
loping dedicated paths, and consolidating the 
ability to be a team and share the identical 
goals at the same time.
Despite their intrinsic "hostility" given the type 
of processes performed, work environments 
are subject to continuous scrutiny to improve 
their situations and ensure safe work environ-
ments for all employees. We ask employees to 
contribute proactively in this process to identi-
fy and report possible opportunities for 
improvement.
We give equal attention to the expectations of 
the communities and administrations that 
share the territory with the established organi-
zations through targeted meetings and tran-
sparency in communications.
The third pillar, care for the environment, has 
solid foundations in the Group, which dedicates 
considerable investments in applying the most 
advanced technologies to limit the environ-
mental impact of its products and reduce the 
carbon footprint of the processes employed.
In addition to the classic parameters linked to 
industrial costs and performance, we intro-
duced new sustainability indicators and fixed 
relative annual goals in 2021 and now periodi-
cally monitor and assess the abovementioned 
guidelines in line with the previous concepts. 
The intriguing aspects concern the consu-
mption of all energy carriers, the related CO2 
emissions, water consumption, the production 
of waste, and the rate of the same destined for 
recovery, the accident frequency index. In stra-
tegic terms, the Group has set itself some 
objectives to respond to and adhere to the 
program of initiatives proposed by the Europe-
an Commission to address emerging 
environmental risks and, at the same time, 
guarantee sustainable development.
28
29
2021 Sustainability Report
The value of sustainability 
is now universally recognized 
as an essential pillar 
for the world of tomorrow 
that we are called to build 
today. In the 17 Sustainable 
Development Goals that make 
up the 2030 Agenda, 
the United Nations 
themselves underline the 
essentiality of this approach to 
give a future to the planet and 
better living conditions for the 
world population.

2.2 Materiality analysis 
The Group's approach to sustainability has increased 
attention to relations between the company and its 
stakeholders, generating a complex framework of issues 
and aspects relevant to both the environmental and so-
cial fields and related to corporate performance. 
We speak of "materiality," intending to underline these 
elements' importance, consistency, traceability, and 
measurability. 
The graphic expression of the aspects, made explicit to 
the company's interests and those of its stakeholders, 
clarify the correlation and interdependence that emerged 
from the materiality analysis. 
Identifying the topics to be evaluated was based on the 
issues proposed by the GRI, integrating them with aspects 
highlighted by other organizations and companies opera-
ting in the steel industry. 
One of this analysis's main objectives consisted of 
identifying the relevant issues for the reporting process. 
We used a matrix to complement this objective and iden-
tify new paths and sustainability objectives, focusing at-
tention on the predominant impact factors and assessing 
their potential impact in terms of risks and opportunities. 
The Strategic Sustainability Committee assessed the 
adequacy of the matrix developed the previous year 
regarding the conditions present along the Group's value 
chain and confirmed its validity for the fiscal year 2021. 
The material aspects reported in the materiality matrix 
were therefore validated.
The critical issues reported in the AFV Beltrame Group materiality matrix align with the United Nations Sustainable Develop-
ment Goals (SDGs) and the objectives identified in the Agenda 2030 international agreement for sustainable development. 
The following graphic highlights the correlation between the main aspects of the Group's activity and sustainable develop-
ment goals, indicating 15 issues relating to various objectives.
2.3 Materiality matrix 
Environmental sustainability
 delle attività di produzione;
Economic sustainability
 delle attività di produzione;
Social sustainability
 delle attività di produzione;
For the defining materiality criteria, please refer to the indications in the methodological note.
30
31
2021 Sustainability Report
Topics below the materiality threshold but still relevant for AFV Beltrame Group
Health, Safety 
and well-being of 
workers;
Environmental impact
of production activities;
Product and Service Quality
 and customer relationships;
Energetic efficiency;
Economic 
Sustainability;
The pressing issues reported 
in the AFV Beltrame Group 
materiality matrix align with 
the United Nations 
Sustainable Development 
Goals (SDGs) and the 
objectives identified in the 
2030 Agenda, the 
international agreement for 
sustainable development.
HR development 
and training;
Health, safety and
well-being
Energetic efficiency
Procurement / 
Supply chain
Economic performance 
value creation
Environmental impact of
production / product
Human resources training 
and development 
Technological and
digital innovation
Quality and safety 
of products and 
client services
Ethical and transparent 
management 
Circular 
Economy
Workers Human Rights
Involvement of local
communities
Employment support
Inclusive, cultural and 
economic development
Territorial 
conservation
0
20
40
60
80
100
0
20
40
60
80
100
RELEVANCE TO EXTERNAL STAKEHOLDERS
INTERNAL GROUP RELEVANCE
MATERIALITY MATRIX

HEALTH AND 
WELL-BEING
QUALITY 
EDUCATION
CLEAN WATER 
AND HYGIENE
ACCESSABLE 
AND CLEAN
ENERGY
DECENT WORK AND 
ECONOMIC GROWTH
INDUSTRY, INNOVATION 
AND INFRASTRUCTURE
SUSTAINABLE CITIES 
AND COMMUNITIES
RESPONSIBLE 
CONSUMPTION AND 
PRODUCTION
WORKING FOR 
THE CLIMATE
The diagram below visually represents the connection betwe-
en Group key issues and a selection of the reference SDGs. 
This graph also clearly highlights the relationship between our 
industrial activity and the sustainable development goals. The 
chart also shows how we address the issue of sustainability 
in integrated terms. The 15 themes touch on various objecti-
ves. For simplicity, the most relevant to our production reality 
have been reported and selected from the 17 Sustainable 
Development Goals of the 2030 Agenda. Sustainability must 
integrate all aspects to ensure the development and 
maintenance of the company.
2.4 UN Sustainable Developement Goals
The 17 Sustainable Development Goals SDGs (SDGs) and 
the 169 sub-goals associated with them constitute the vital 
core of the 2030 Agenda. 
They take into account the three dimensions of sustainable 
development in a balanced way, namely economic, social, 
and ecological. A single policy document brings together 
sustainable development and the fight against poverty for 
the first time. 
The Sustainable Development Goals must be achieved by 
2030 globally by all UN member countries. Every nation on 
the planet is called to jointly contribute to tackling these 
significant challenges.
HEALTH AND WELL-BEING
•	Health, safety and well-being 
•	Local community 		
	
	 involvement 
QUALITY EDUCATION
•	Human resources training 	
	
	 and development
•	Ethical and transparent 	
	
	 management
CLEAN WATER AND HYGIENE
•	Health, safety and well-being 
•	Circular economy
•	Territorial conservation
DECENT WORK AND 
ECONOMIC GROWTH
•	Health, safety and well-being 
•	Workers Human Rights 
•	Ethical and transparent	
	
	 management 
•	Quality and safety of 	
	
	 product and client service 
•	Economic performance 	
	
	 and value creation 
•	Inclusive, cultural and	
	
	 economic development 
•	Employment support 
INDUSTRY, INNOVATION 
AND INFRASTRUCTURE
•	Energetic efficiency
•	Human resources training 	
	
	 and development 
•	Ethical and transparent 	
	
	 management
•	Digital and technological 	
	
	 innovation
•	Quality and safety of product 	
	 and client service
SUSTAINABLE CITIES AND 
COMMUNITIES
•	Circular economy
•	Ethical and transparent 	
	
	 management
•	Environmental impact of 	
	
	 production/product 
•	Inclusive, cultural and 	
	
	 economic development
•	Local community 		
	
	 involvement 
RESPONSIBLE CONSUMPTION 
AND PRODUCTION
•	Circular economy 
•	Environmental impact of	
	
	 production/product 
•	Procurement/Supply Chain
•	Territorial conservation
WORKING FOR THE CLIMATE
•	Circular economy 
•	Environmental impact of    	 	
	 production/service 
•	Inclusive, cultural and 	
	
	 economic development 
•	Territorial conservation
ACCESSABLE AND CLEAN 
ENERGY
•	Energetic efficiency
•	Environmental impact of 	
	
	
	 production/service
32
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2021 Sustainability Report

The Group, through dedicated fun-
ctions, pursues a proactive appro-
ach towards the plurality of interlo-
cutors with whom it 
constantly interacts in carrying out 
its business, promoting 
constant dialogue and 
acknowledging their needs.
2.5 Identifying and dialogue 
with stakeholders
The Group is strongly oriented toward the involvement of 
stakeholders, believing that the exchange of information, 
listening to their requests and expectations, and the 
satisfaction of mutual interests are conditioning factors 
of the business strategy, which can gain a competitive 
advantage from this course.
Since they can affect or be influenced by corporate 
decision-making processes, the internal and external 
stakeholders contribute to sounder identification and 
management of the risks and opportunities that derive 
from the joint action and contributions. The Group found 
the assessment of their expectations concerning 
business activities and processes to support integrating 
relevant issues, defining priorities, and planning 
sustainability activities implemented in the Group.
The mapping of the Group's stakeholders, conducted in 
2020 with the involvement of numerous direct players in 
the value chain (primary stakeholders) and secondary 
stakeholders, who do not directly contribute to the 
creation of value for the Group, was also confirmed for 
this accounting period.
The following entities are among the considered 
stakeholders: 
- Other companies in the area 
- Environmental associations 
- Trade associations 
- Competing companies 
- Shareholders and the Board of Directors 
- Banks, financiers, and insurance companies 
- Consumers / final customers 
- Local communities 
- Employees 
- Local infrastructure management organizations 
- National and local public controlled entities 
- Suppliers of goods and services 
- Public and private cultural institutions and groups 
- Local institutions and local government bodies 
- Media 
- Supervisory Bodies - Scientific / R&D Partners 
- Schools and Universities 
- Labour unions
35
2021 Sustainability Report
0 5
0 9
0 6
1 0
0 7
1 1
0 8
1 2
1 3
1 4
1 5
1 6
0 2
0 3
0 4
OT H E R  C O M PA N I E S 
I N  T H E  T E R R I TO RY
0 1
1 8
1 7
E N V I R O N M E N TA L 
AS S O C I AT I O N S
T R A D E 
AS S O C I AT I O N S
C O M P E T I TO R S
S H A R E H O L D E R S 
A N D  B O D
BA N KS, F I N A N C I E R S, 
A N D  I N S U R A N C E 
C O M PA N I ES
LO CA L  C O M M U N I T Y
C O N S U M E R S  / 
E N D  C U S TO M E R S
E M P LOY E ES
LO CA L 
I N F R AS T R U CT U R E 
M A N AG E M E N T 
O R GA N I Z AT I O N S
N AT I O N A L  A N D 
LO CA L  P U B L I C 
C O N T R O L L E D 
E N T I T I ES
S U P P L I E R S  O F 
G O O DS  A N D 
S E RV I C ES
P U B L I C  A N D 
P R I VAT E  C U LT U R A L 
I N S T I T U T I O N S  A N D 
G R O U P S
LO CA L 
I N S T I T U T I O N S 
A N D  LO CA L 
G OV E R N M E N T 
B O D I ES
M E D I A
S U P E RV I S O RY 
B O D I ES  – 
S C I E N T I F I C  / R  & D 
PA RT N E R S
S C H O O L S  A N D 
U N I V E R S I T I ES
L A B O U R  U N I O N S
34

The integration between a strategic bu-
siness approach and the stakeholders' 
perspective represents an essential tool 
for defining and developing sustainability 
priorities and continuing to generate sha-
red value in the short, medium and 
long term. 
This integration is expressed in the group's 
materiality matrix.
Listening
Growth
Sustainability
Improvement
Dialogue
Commitment
Innovation
2.6 Creating stakeholder engagement
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37
2021 Sustainability Report
We involved the relevant stakeholders (identified in 
paragraph 2.5) in preparing the materiality matrix. 
They completed a specific questionnaire which 
made it possible to identify essential issues and 
collect valuable feedback. 
Stakeholder engagement is the commitment to 
embrace the principle of inclusiveness, which 
means recognizing the stakeholders' right to be 
heard and accepting the burden, as an organization, 
to give an account of their activities and choices. 
The questionnaire administered to the relevant 
internal and external stakeholders, with the help of 
closed and open questions, made it possible to map 
essential material aspects and collect ideas for 
improvement and information regarding the 
perception of the current approach to sustainability 
of AFV Beltrame Group. 
We also organized workshops with the members of 
the Steering Sustainability Committee and other 
managers belonging to all the Group companies, 
identified by the company as "key" internal 
stakeholders, with a specific focus on issues 
considered "material" from the perspective of the 
generation of long-term value.

38
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2021 Sustainability Report
SWISSMEM
UNSIDER
EUROPEAN POWER NETWORK
IGEB
ENAW
INVESO
CONFINDUSTRIA ROMANIA
SOLOTHURNER HANDELSKAMMER
UNIROMSIDER 
SSHV
AREX
METAL.SUISSE
PÔLE ÉNERGIE
CONFINDUSTRIA
UNIDEN
FEDERACCIAI
CTPL
FEDERMECCANICA
GESIM
A.I.M.
UIMM
AIAS
A3M
AIDAF
AFV Beltrame Group participation in trade associations
AFV Beltrame Group adheres to a network of national and international associations relevant to its business 
through the companies of the Group. In particular, the company participates in activities within associations 
representing trade interests (e.g., Confindustria, Federmeccanica); Technical associations (e.g., Unsider, the Italian 
steel unification body for the dissemination of knowledge of international standards); VSM Switzerland Metallurgy 
to disseminate the science and technology of materials and their applications.
Furthermore, AFV Acciaierie Beltrame S.p.A. participate in technical and research committees (e.g., Reach Ferrous 
Slag Consortium). LME adheres to the CTPL  - Centre Technique et de Promotion des Laitiers sidérurgiques, Uniden - 
to the Union des industries utilisatrices d'énergie, A3M - to the Alliance des Minerais, Minéraux et Métaux, to Pôle 
Energie, to GESIM - Groupement des Entreprises Sidérurgiques et Métallurgiques and the IUMM (Union des 
industries et métiers de la métallurgie) - La Fabrique de l'Avenir. Stahl Gerlafingen adheres to: Interessengemein-
schaft Energieintensive Branchen IGEB; INVESO Industrieverband Solothurn und Umgebung; Solothurner Handel-
skammer; Schweizerischer Stahl- und Haustechnikhandelsverband SSHV; Metal Suisse; Swissmem; European Power 
Network; Energie-Agentur der Wirtschaft EnAW. Donalam adheres to: Confindustria Romania; Uniromsider e Asocia-
tia Romana a Exportatorilor – AREX.
I T
F R
I T
F R
I T
F R
I T
F R
I T
F R
I T
F R
F R
C H
C H
C H
C H
C H
C H
R O
C H
R O
C H
R O

Product 
sustainability: 
Circular 
Economy, 
Quality and 
Innovation
3

Circular economy
3.1 Circular economy
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2021 Sustainability Report
In 2020, The European Commission adopted a 
circular economy action plan which represents one 
of the primary constituent elements of the European 
Green Deal. It aims to promote sustainable growth, 
reduce pressure on natural resources, and contribute 
to the goal of achieving climate neutrality by 2050, 
halting the loss of biodiversity and creating new job 
opportunities. 
The electric furnace steel chain is by its nature 
already a driving force of circularity in managing 
steel products as it recycles close to 100% of steel 
products. It works with preconsumer residues (waste 
recovered downstream of industrial processes), 
whether they derive from separate collection activities 
or recovery from post-consumer cycles to include 
products with a short life cycle (e.g., packaging), 
medium (e.g., motor vehicles) and long life (e.g., 
construction products). 
Steel can be recycled countless times without losing 
its original properties, thus making it indistinguishable 
from the new material. 
Furthermore, the world of steel has always been at the 
forefront of the development of activities that 
support the transition from a linear development 
model (identified in the concept "from the cradle to 
the grave") to a circular one ("from cradle to cradle"). 
In the latter, the technical waste materials of its 
production cycles are destined to be recycled and 
reused or enhanced in other activities without 
ending up as waste and therefore definitively 
scrapped. 
AFV Beltrame Group steel production requires the 
research and supply of some well-defined categories of 
materials: 
- Iron scrap 
- Other expensive and important raw materials (electrodes, 
ferroalloys and refractories) 
- Auxiliary and maintenance materials 
- Services 
- Energy 
The acquisition of all these materials and services has been 
set for some time with analysis, research, the definition of 
technical characteristics, management of supply and 
suppliers, or sub suppliers, in terms of optimization of the 
quality/price ratio, sustainability and reliability and possibly 
certification. We carry out this process with the utmost 
attention to strategic suppliers' reliability requirements, the 
safety of service providers (partnerships), and equal 
attention to budgetary and circulating management needs. 
The selection criterion and possible rotation of the most 
important suppliers is constantly monitored to maintain 
materials quality and the service accuracy at the highest 
level and with continuous collaboration with internal users 
to obtain the best final outcome, which results in customer 
satisfaction. 
There is particular attention to strategic, essential suppliers 
who are more connected to the market conditions and are 
no longer local or national but now at a global level. In 
contrast, the partnership with above all local service 
providers are an added value that is constantly monitored 
and verified to avoid losing tension and attention to the 
desired result. 
In particular, concerning raw materials suppliers, the 
supplier's level of service is constantly monitored, product 
quality control and the analysis of market factors that 
change the economic conditions of the supply. 
Regarding the internal service providers, we paid the utmost 
attention to the possession of certified management 
systems (e.g., ISO 14001, ISO 45001) to ensure maximum
3.2 Sustainable supply chain management and 
procurement policy
compatibility in terms of behaviour, procedures and 
verifications of the operations with particular awareness 
of safety and environmental management.
Most of the transport suppliers have been selected and 
contracted to maintain a high and safe level of service as 
part of a customer service optimization process. Energy 
suppliers are chosen from among the largest and more 
reliable international operators who guarantee continuity 
and reliability of supply. 
An audit and periodic assurance procedure are functional 
on a good part of these suppliers and update meetings 
that allow a continuous relationship and a continuous 
exchange of ideas and suggestions to improve the safety, 
economic, and innovation aspects. 
For all new suppliers, the Group places compliance with 
regulations as a favored aspect, although not a mandatory 
requirement, and requests conformity to UNI EN ISO 
9001/14001/45001/50001 norms.
3.3 R&D and technological innovation
Attention to sustainability issues and the 
development of tools for modern corporate social 
responsibility are not the antitheses of the aim of the 
steel production sector, a strong and driving sector 
for the entire economy, but they are instead 
intrinsically linked to innovation and the Industry 4.0 
project. 
AFV Beltrame Group has always considered it a 
fundamental strategic technological innovation for its 
development. Since the 1970s, the company has 
been committed to applying the most modern 
technologies. Industry 4.0 represents a challenge for 
the Group to be grasped and used to raise its levels 
of efficiency and sustainability.
>90%
Water recycling 
ratio for cooling 
circuits
>90% Percentage waste 
sent to recovery
>95%
Recycled material 
content in               
finished products

44
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2021 Sustainability Report
3.4 SRA INJECTION PROJECT, 
secondary reducing agent 
 
The SRA (secondary reducing agent) injection project is ongoing at the Vicenza plant. 
The project aims to inject polymeric material in partial substitution of anthracite coal 
to: 
a) Provide energy input during the melting phase of the scrap; 
b) Reduce the oxides in the slag by favouring the foaming of the slag during 
refining; 
c) Reduce the carbon footprint of the steel produced. 
Being SRA certified as a secondary raw material, it respects the cornerstones of the 
circular economy and the green economy.
Characteristics of the material:
The Bluair Flakes polymeric material produced and supplied to us by I.blu is a 
secondary reducing agent. The UNI10667-17 standard regulates the material. The 
material is a blend of polyolefins (PE, PP, PS) with an average carbon content of 75% 
and hydrogen of 15%. The material has a percentage of the biogenic carbon content 
of 20% (according to UNI EN15440), which can therefore be disregarded for CO2 
emissions quotas (ETS).
Instead of coal as a 
"reducing agent" 
in steel production, 
recycled polymers 
are used, obtained 
by processing part of 
unrecyclable 
plastics that remain 
after separate waste 
collection. These 
polymers drastically 
reduce pollutants 
developed during steel 
mills processes and 
CO2 emissions by a 
third. They additio-
nally consume less 
electricity.
1. Climate change mitigation: reduce or 
avoid greenhouse gas emissions or 
improve their absorption;
Test results:
Using a polymer in place of coal permitted a 
reduction of injected anthracite consumption 
between 35% and 50% during the tests carried out 
with a pilot plant without negatively affecting the 
process or environmental parameters. We 
estimate that the use of the polymer at full 
capacity could allow: - a reduction of CO2
emissions between 10% and 15% compared to 
emissions directly related to anthracite coal only 
(Green Economy); 
-reduction of between 35% and 50% of the use of 
anthracite coal obtained from fossil sources; - use 
of a secondary raw material (Circular Economy). 
The new EU regulation 2020/852 of June 18, 
2020, regulates the subject of taxation, clarifies 
the obligations, the contents to be disclosed and 
the criteria for defining an economic activity as 
eco-sustainable. 
In particular, this regulation defines in Article 9 six 
environmental objectives: 1) climate change 
mitigation: to reduce or avoid greenhouse gas 
emissions or improve their absorption; 2) climate 
change adaptation: reducing or preventing the 
damaging effects of current or future climate or 
the risk of adverse effects.; 3) Sustainable use and 
protection of water and marine resources; 4) 
transition to a circular economy focused on the 
reuse and recycling of resources; 5) pollution 
prevention and control; 6) protection and 
restoration of biodiversity and ecosystems. 
The Polymer Injection Project contributes to 
achieving the objectives set out in points 1 and 4 
and is a considerably eco-sustainable project.
2. Climate change adaptation: reducing 
or preventing the adverse effects of 
current or future climate or the risk of 
harmful effects;
3. Sustainable use and protection of water 
and marine resources;
4. A transition toward a circular economy 
focused on the reuse and recycling of 
resources;
5. Pollution prevention and control;
6. Protect and restore biodiversity and 
ecosystems.
Current stage
The monitoring phase of the "EAF secondary 
reduction agent (SRA) injection" project showed 
that the polymer is injectable and allows a 
reduction in the consumption of fine carbon 
without EAF process criticality, allowing the 
formation of foamy slag. We have achieved an 
average 40% reduction in fine coal consumption 
compared to smelting without SRA.
Objective
In light of the results obtained, in 2022, the 
installation of an industrial-scale plant is planned 
that will allow the same reduction of fine coal 
obtained during the tests: a 40%-50% reduction in 
coal consumption (GRI305-1) and consequently 
of 4% of the total CO2 emissions of the steel 
plant, with also an economic saving. 
Future developments 
After installing the industrial plant, there is a plan 
to reduce the coal injection further and optimize 
the use of the SRA polymer by extending the 
process to the various sites of the Group. 
The new UE 2020/852 regulation dated 18 June 2020 requires:

Simultaneously with production process efficiency and safety 
in the workplace, AFV Beltrame Group also invests in 
installing robotic systems. The various projects activated are 
divided into the various countries where the Group is present. 
In addition to the use of robots capable of conferring high 
standards of repeatability and accuracy linked to the various 
phases of the production process, projects that envisage the 
use of artificial intelligence as an added value to the already 
consolidated technical knowledge of the personnel and are 
gradually becoming normal operations in the various areas of 
each production site. 
The main areas affected by the insertion of robots are those 
related to the production cycle and, more precisely, steel mill 
and rolling mill. 
Many efforts have been concentrated in the steel plant 
where, simultaneously with the presence of liquid steel, 
robots or machines with very high automation content are 
increasingly being used to protect operators. Gradually, 
the introduction of new robotic systems requires that, at 
the same time, the staff acquire more and more technical 
knowledge that allows them to manage the systems 
themselves. 
In designing and installing the robots, priority was given to 
the safety of the operators, and to some operations that in 
the past were "purely manual." There was a synergy with 
repeatability and reliability in the execution of the functions 
themselves. 
At the Group level, a dozen robots have been installed today, 
including anthropomorphic systems and systems capable of 
automatically executing specific sequences of the production 
cycle without the supervision of the operator. 
Among the most common uses are: 
• Temperature measurement on liquid steel; 
• Specimen collection on liquid steel; 
• Cleaning of the melting furnace slag door; 
• Labelling of semi-finished and finished products; 
• Extension and replacement of graphite electrodes for EAF 
and LF furnaces. 
Despite the complexity of integrating the new systems into 
the existing production process, from the first stages of 
installation and start-up, the operators understood their 
strategic importance for their safety and for the continuous 
improvement of the process itself. 
They proposed ideas and concepts aimed at optimizing the 
integration itself. 
The positive outcome of the installations already active is not 
currently seen as a point of arrival but as a stimulus to 
pursue this path by developing new applications that 
gradually press on all areas of the production departments.
3.5 A.I. Projects
46
47
2021 Sustainability Report
The automatic coupling system consists of a male unit 
called a "manipulator" installed in the turret and a female 
unit installed on the ladles. 
The mechanism allows you to automatically connect the 
hydraulic fluid and cooling air needed to move the ladle 
drawer without manually intervening in the vicinity of the 
ladle containing the liquid steel. 
The improvements made thanks to the coupling of the CC2 
turret compared to the traditional system, up to now used 
in the steel plant, allows eliminating manual operations to 
connect the hoses under pressure (P = 200bar), moving 
the operator away from the liquid steel and thereby 
eliminating the likelihood of serious accidents. 
The automatic cycle also reduces ladle change times in the 
pouring position and drawer opening with a reduction in the 
risk of losing the production sequence (1 minute vs 2 minu-
tes in case of manual system use). 
The manufacturer has patented this system.
1
Liquid steel 
temperature 
measurement
Liquid steel 
specimen 
collection 
2
Semi-finished and 
finished product 
labelling
4
3
Melting furnace 
slag door cleaning
5
Extension and 
replacement of graphite 
electrodes for EAF and 
LF furnaces
Easy Coupler System project

48
49
3.6 Quality and product safety 
48
49
2021 Sustainability Report
In 2021, investments in new technologies relating to the quality sector involved the acquisition of 
the new Keyence VHX-7000 digital optical microscope for the Vicenza plant, which incorporates 
4k technology and allows the steel products to be described from a minimal point of view. The 
microstructural aspect of steel is a fundamental element that strongly influences the mechanical 
performance of hot rolled products.
The innovative Japanese instrumentation is equipped with a 27-inch display and an integrated 
computer capable of carrying out image analysis directly on carefully prepared laboratory sam-
ples.
More rapidity and accuracy in measurements, such as counting the grains of which the crystalline 
matrix is composed using intersecting segments. It also allows you to perform the quantitative 
analysis of non-metallic inclusions for quality steels or on specific products, always ensuring 
compliance with the reference standards.
The new digital microscope is also used for low magnification measurements suitable for di-
mensional control of profiles. Thanks to the stand and the motorized plate on the three axes, it is 
possible to reconstruct a 3D model and carry out a targeted check of tolerances, thus allowing us 
to provide the customer with increasingly professional and timely support, increasing efficiency in 
the management of any claims.
A laboratory tool in line with the times that, used in a manner appropriate to its characteristics, 
allows you to undertake new projects and new challenges in the quality of Beltrame products.
2021 was a year of consolidation and new 
challenges for the AFV Beltrame Group. 
We closed some projects started in previous 
years and continued with others still in progress. 
Additionally, new opportunities have led to a 
decisive change of mentality, which has 
projected the Group towards a completely diffe-
rent field. 
These changes include developing and 
consolidating, jointly with the leadership in the 
construction steel market, the production of qua-
lity steel for the stamping and chrome plating 
market. 
AFV Beltrame Group wants to obtain a leader-
ship that is based on concrete foundations, 
strategic projects and investments in human 
resources and technologies that aim to increase 
knowledge, potential and ideas and bring the en-
tire Group structure to have the skills to express 
their potential to the fullest. 
The Group has been strengthening the concept 
of “team”, such as the standardization of proces-
ses at the various production sites in Italy and 
Europe and sharing challenges and ideas. 
AFV Beltrame Group adhered right away to the 
critical points of the EN ISO 9001: 2015 stan-
dard, and this has allowed the Group to structure 
the processes methodically and consolidate the 
results. 
The Vicenza quality laboratory is continuously 
renewing its technologies according to the new 
needs that the market imposes. This year, 
alongside the new high-resolution 4K digital 
electronic microscope, the entire metallographic 
sample preparation system will be renewed to be 
able, in much shorter times, to prepare many 
more samples with optimal surfaces. 
At the Swiss site of Gerlanfingen, the quality 
department is renovating all the equipment to 
control raw materials, such as the new Crusher, 
Mill, Press, separator and XRF Spectrometer. 
Following the increase in volumes in market lar-
ge dimension structural steel, it was necessary 
to purchase a new Pendulum of Charpy 4.0 
interconnected to the company system and the 
testing processes. 
In 2021, our French site in Trith Saint Lèger saw 
the expansion of the product range with the 
production of reinforcing bars and related items 
obtaining of product certifications for sale on all 
European markets. 
Finally, the quality department of the Romanian 
plant in Calarasi has successfully obtained the 
EPD (Environmental Product Declaration) certifi-
cation, which is a document that describes the 
environmental impacts associated with the 
production of a specific quantity of product or 
service: for example, consumption energy and 
raw materials, waste production, emissions 
into the atmosphere and discharges into water 
bodies. 
The collaboration, then, with local universities 
always allows for the creation of know-how 
exchanges between the world of work and 
teaching. 
Like every year, in 2021, the Vicenza Quality 
Department hosted an intern from the Faculty of 
Materials Engineering in Padua to draft his 
degree thesis. The graduate student had the op-
portunity to experience a significant production 
reality, integrating practice with theory. 
The latest challenge faced by the Group's Quality 
Department was to maintain consolidated 
relations with the UK market after Brexit, quickly 
obtaining the mandatory UKCA certification for 
the export of steel materials from January 2023. 
Keyence VHX-7000 digital optical microscope

Continuous improvement is the vision that AFV Beltrame 
Group has set to grow in every business area. 
The Group has equipped itself with a central Group 
structure based on two pillars: OpEx (Operational 
Excellence) and APC (Action Plan and Control), to pursue 
this vision. 
(Op. Ex.) Operational Excellence's mission provides project 
management methodology to team leaders, who can see 
their application in every process, not just in production, but 
also in guaranteeing the customer the quality that fully 
satisfies their requests. 
Team leaders trained in the logic of Lean Six Sigma work to 
improve everyday activities, focusing on the awareness that 
the causes of inefficiencies are not people but processes 
organisation. 
Many functions have been involved in this improvement 
program. 
Over the six-year OpEx program, over 390 projects involving 
all aspects of our organization have been managed and 
completed. The projects have contributed to bringing 
tangible economic benefits and improving the way of 
working in the company. 
The main characteristic of an OpEx project is to want to 
solve a problem that has a significant economic impact 
and for which the solution is not yet known. The problem is 
approached in a structured way according to the DMAIC 
method by a dedicated workgroup. 
The DMAIC method is developed in 5 phases, regulated by 
ISO 13053-2, simplified with the acronym DMAIC:
- define the problem, the goal, the working group and the 
economic impact; 
- measure the problem and the possible causes; 
- analyse the data collected, identifying the root cause; 
- implement the solution; 
- check the solidity of the solution, formalise it and 
verifying it over time. 
Over 140 specialists in the group have been trained in the 
DMAIC method and know a relevant set of essential tools in 
the project management phase. 
The hierarchy of OpEx specialists is internationally 
organized similarly to martial arts, whereby there are white, 
yellow, green and black belts. 
The second pillar on which the Group's Continuous 
Improvement is based is Action Plan and Control (APC). It is 
the structuring of action plans and projects with which we 
support the group's activities. 
The goal is to maximize the effectiveness of all meetings 
within the Group. Each meeting must conclude with 
identifying actions to be implemented, defining who is 
responsible for their execution and the expected timeframe 
to implement each activity. In addition to supporting the 
drafting of action plans, the APC function “keeps the beat” by 
regularly verifying that the planned actions are progressing 
smoothly. Furthermore, if necessary, it develops, analyses 
and guides activities to achieve the expected results within 
the scheduled time frame. 
3.7 Continuous improvement
50
51
2021 Sustainability Report
DMAIC
A method that develops in 5 
phases, regulated by ISO 
13053-2, simplified with the 
acronym DMAIC
D
A
I
M
C
Define the problem, the 
goal, the working group 
and the economic impact;
Measure the problem and 
possible causes;
Analyze the collected data, 
identifying the root cause;
Implement the solution;
Check the solidity of the 
solution, formalise it and 
verify it over time.
390
The number of projects managed 
and completed in five years of 
the OpEx program. 
These projects have involved all 
aspects of our organization and 
have brought tangible economic 
benefits, and improved the way 
of working in the company.
140
The number of specialists 
belonging to the group trained 
on the DMAIC method. These 
specialists know a relevant set 
of essential tools in the project 
management phase.
6
The number of years since the 
OpEx program in AFV Beltrame 
Group was launched.

4
Environmental 
awareness

4.1 BELTRAME’S COMMITMENT TO RESPONSIBLE ENVIRONMENTAL MANAGEMENT
The Group hasn’t registered any non-conformities or sanctions for violating 
environmental laws and regulations.
Iron and steel activities present potential interferences 
towards numerous environmental sectors, which must 
be addressed carefully. AFV Beltrame Group has 
equipped itself with an environmental management 
system that has made it possible to highlight the leading 
ecological characteristic of its plants. This same system 
enforces management and prevention actions consistent 
with the results obtained from assessing the potential 
impacts concerning the matrices environmental. 
First of all, the Group constantly follows the evolution of 
the best available techniques (BAT - Best Available 
Techniques), which represent the reference point for 
plant engineering updates and for the application of 
operational and management procedures aimed at 
limiting the impacts of its activities, in the perspective of 
prevention. 
In 2021, the Group’s plants were the subject of numerous 
internal audits to confirm legislative compliance on all 
environmental aspects and identify the potential for 
improvement, according to the classic PDCA cycle. The 
inspections conducted by the control bodies (ARPA, 
DREAL, AFU, Ministry of the Environment) in the various 
countries in which the Group is present also confirmed 
the correct management of the provisions given by the 
environmental authorizations and the requirements 
established internally, which become mandatory for the 
Group. 
As part of the environmental management system, the 
Group constantly monitors its performance also through 
tools that favour the visual approach. With data and 
infographics dashboards, they are easy and quick to read. 
Through parametric analyses, they integrate the 
significant impacts in a single numerical indicator (called 
eco-index). 
Therefore, the eco-index represents the environmental 
performance level of the plants through the aggregation 
of a dozen parameters, each of which is assessed 
against target values, defined by legal and authorization 
requirements, budget targets, and internal targets. The 
main parameters considered are inherent to the 
emissions of dust and CO2 into the atmosphere, water 
consumption and discharges, the rate of waste recovery, 
and the specific consumption of natural gas in the 
heating furnaces.
54
55
Bilancio di Sostenibilità 2021
With a view to a circular economy, AFV Beltrame Group 
also pursues the criterion of minimizing the production of 
waste destined for disposal, favouring recovery and 
enhancement. In particular, the Group does this for the 
black slag produced in the EAF melting furnaces and then 
transformed into a certified product (called BELTRECO in 
Italy and ROUGH in Switzerland). This product can be 
widely used in building and infrastructural works. Finally, 
the Group industrialized the internal recycling process of 
the white slag produced in the steel refining phase in the 
Vicenza plant.
4.2 Policies and QHSE Management System 
The Group has adopted an integrated management 
system to guarantee the principles of the code of 
ethics and the policy on quality, health and safety, and 
environment (QHSE). 
This system facilitates the identification, registration 
and evaluation process of the QSA results to conduct 
the continuous improvement process. Attaining 
certification by a third party is a consistent step 
toward implementing a management system. The 
goal is to have accredited and independent feedback 
on the Group’s commitment. 
The international standards adopted at the Group level 
are: 
• ISO 9001: 2015 - quality management systems; 
• ISO 14001: 2015 - environmental management 
systems - Requirements and guidelines for use; 
• ISO 45001 - occupational health and safety 
management systems - Requirements; 
• ISO 50001: 2011 - energy management systems - 
Requirements with guidance for use. 
Obtaining the certifications has fostered the 
evolution of performance, facilitated the performance 
measurement and ensured control of business 
processes. In 2021, the Group extended the quality 
management system certification to the San Giovanni 
Valdarno plant. 
The table below shows the company’s plants’ certifications obtained at the date of closure of operations in 2021.
In particular, in 2021, the Group has: 
• confirmed environmental management systems certification for all sites (ISO 14001), except for the plant in 
San Giovanni Valdarno; 
• ISO 9001 quality management system certification extended to all Group plants; 
• confirmed, following the surveillance and certification audits, the Energy management system compliance to the ISO 50001 
standard at the Trith Saint Léger site; 
• completed the migration of the safety management system certification according to ISO 45001 for all sites 
of the Group. 
The ISO 45001 standard offered the factories numerous ideas for management improvement, being part of a high-level system 
(HLS-High Level Structure) already present in the other system standards (ISO 14001 for the environment and ISO 9001 for 
quality), which can now be seamlessly integrated into a single management system.
LAMINÉES MARCHANDS 
EUROPÉENS LME
-
-
-
-
-
Company
Quality 
Management 
System
Site
Environmental 
Management 
System
Health and 
Safety 
Management 
System
Energy 
Management 
System
AFV ACCIAIERIE BELTRAME SPA
S.C. DONALAM SRL
STAHL GERLAFINGEN AG
Vicenza (VI)
San Didero (TO)
San Giovanni Valdarno (AR)
Gerlafingen (CH)
Trith Saint Léger (F)
Calarasi (RO)
EN ISO 9001
EN ISO 14001
EN ISO 45001
EN ISO 50001
-
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X

4.3 EPD certification
The Environmental Product Declaration (known as EPD® - Environmental Product Declaration) is a voluntary 
product certification scheme developed in the application of ISO 14025 (Type III environmental labelling), according 
to the International EPD System Program and validated by independent third parties.
56
57
These declarations relate to the environmental impacts 
that can be associated with the life cycle of the product 
and which are assessed through the analysis of the life 
cycle (LCA - Life Cycle Assessment) to guarantee 
transparency, objectivity and comparability of the results 
expressed, relating to the environmental performance of 
products. The facts contained in the EPD are of an 
informative/communicative nature on environmental 
performance, and there are no prescriptive performance 
thresholds. 
The Group has developed a life cycle analysis and 
prepared an environmental product declaration of the 
hot-rolled merchant profiles produced in the Italian and 
French factories and the reinforced concrete rebar in 
coils created by our Swiss subsidiary. 
In 2021, the study on the SBQ profiles life cycle produced 
in the Donalam srl plant in Calarasi was also completed, 
which today are attributable to a specific environmental 
product declaration. 
We took the energy vectors conversion parameters and 
other information on the emission factors from 2019 
data from the “Reliable Disclosure Systems for Europe - 
Phase II” (RE-DISS II) 2019 project, while the values 
relating to the upstream processes and those relating to 
transport were obtained from Ecoinvent v. 3.6. 
The EPD declarations of the Group’s products have been 
validated and registered under the primary international 
schemes (International EPD® System and IBU - Institut 
Bauen und Umwelt). 
Concerning the assessments of the impacts that 
emerge from the life cycle analysis traced back to 
standard indicators, the Group uses the EPD as 
operational support in the continuous improvement 
process. It allows the identification of areas of 
intervention in the various production process phases, 
supply chain and customer supply. 
This declaration is also a starting point for identifying 
the carbon footprint of products (GWP - Global Warming 
Potential). The Group has begun the evaluation of this 
indicator concerning the reference standards. 
In the Italian context, the environmental product 
declaration validation has received confirmation from 
ICMQ, with relative publication at the national Program 
Operator EPDItaly© to meet the requests of some 
national customers connected to “socially responsible” 
public purchases and supplies. Products destined for 
use in construction require a minimum-level 
Environmental criterion of Type III Environmental Product 
Declaration (EPD) certification compliant with UNI EN 
15804 and ISO 14025, such as EPDItaly © or equivalent.
Program Operator EPDItaly© Membership 
In the Italian context, the AFV Acciaierie Beltrame 
environmental product declaration has obtained 
validation by ICMQ for subsequent publication at the 
national Program Operator EPDItaly©. 
The registration of the environmental product declaration 
in EPDItaly© also makes it possible to satisfy customer 
requests related to “socially responsible” public 
purchases and supplies. As part of the minimum 
ecological criteria envisaged for products intended for 
construction, the existence of compliance with the 
environmental requirements of the materials is 
recognized when these have a Type III environmental 
product declaration (EPD), compliant with the standard 
UNI EN 15804 and ISO 14025, such as EPDItaly © or 
equivalent. All documents have been updated with the 
data for the year 2021.
EPDItaly© certification
wEPD certification is an information and communication 
tool between producers, distributors and consumers that 
has multiple objectives, the main ones being: 
- communicate detailed information on the environmental 
impact of their products by providing helpful information 
to make informed purchasing choices; 
- implement a system of continuous improvement of the 
environmental quality of the products themselves.
AFV Beltrame Group 
firmly believes in the 
sustainability path 
undertaken. It identifies 
the environmental 
product declaration 
(EPD) as a tool with 
multiple advantages: 
from external 
communication to 
product marketing 
support up to the 
assessment of 
environmental 
performance.
2021 Sustainability Report

<  Stops due 
    to breakdown
Energy for the AFV Beltrame Group plays a role of primary 
importance as it is the second-highest company cost: leaving 
out raw material scrap. Energy represents between 20% and 
40% of all the other Group expenses. More than half of this per-
centage is covered by electricity, about 45% by methane gas, 
while the remainder is represented by oxygen and other techni-
cal gases used in processes. The Group’s annual consumption 
is around 1.2 TWh / year of electricity and about 109,000,000 
Sm3 / year of natural gas.
For these reasons, the strategy of the Group and the Energy 
office moves in three directions:
1. Achievement of the best supply conditions;
2. Constant monitoring of consumption;
3. Implementation of energy efficiency projects.
The Group joins the Metal Interconnector consortium and provi-
des the quick load Interruptibility service to the network mana-
ger to achieve the best supply conditions. The energy office 
also plays an active role in purchasing from energy suppliers 
and monitoring daily market trends, which are increasingly insi-
dious and complex. In 2021, wholesale electricity and natural 
gas prices increased by 200%, respectively and 400% compared 
to the minimum levels reached during the most critical phase 
of the Covid-19 pandemic, thus impacting businesses. During 
the year, therefore, together with the management, the energy 
office has assumed an increasingly central role in adapting the 
corporate strategy to the current market situation.
Over the years, the Group has implemented an energy monito-
ring system that today can count on a network of about 300 
meters, most of them located in the three major plants, Vicenza, 
Trith Saint Léger and Gerlafingen. Thanks to them, it was pos-
sible to develop energy performance indices and analyse daily, 
weekly, monthly, and annual consumption trends.
Reports are drawn up monthly which, discussed with the fore-
persons of each plant, aim to raise awareness among staff on 
the issue of energy saving.
Finally, the energy office collaborates closely with the mainte-
nance and production departments to identify, study and imple-
ment energy efficiency projects within the plant processes. The 
energy efficiency interventions, in addition to optimizing pro-
duction costs, also obtain other often overlooked significant 
advantages which are of fundamental importance: these are 
NEBs (Non-Energy Benefits) such as: 
- Cost reduction: maintenance, personnel, environmental and 
taxes; 
- Reduction of direct or indirect CO2 emissions depending on the 
savings obtained on natural gas or electricity; - Competitiveness: 
greater reliability and productivity, better process control; 
- Quality improvement: reduction of defects, product improve-
ment, greater customer comfort; 
- Improvement of corporate image, an increase of employee 
professionalism, improvement of employee comfort; 
- Risk reduction: lower risks of legislative and environmental 
compliance, lower risks on interruptions or other production 
problems, lower safety risks. 
Regarding the last point, the Group’s attention is maximum 
since, in all energy efficiency projects that impact machinery 
and operational management, the processes and procedu-
res are analyzed to improve and possibly rethink whether it is 
possible to increase the safety of operators. In recent years, 
between the installation of new systems, optimization of exi-
sting systems and internal activities aimed at reducing consu-
mption, the energy efficiency projects launched in the Group 
have been around 80.
58
+ 50% Ampère savings
>   Lamination 
     stability
<  Harmonics in the network
59
4.4 Energy consumption
The steel plant’s smoke system was partially revamped at the Vi-
cenza site to ensure overall greater intake and energy savings on 
the tail fans. Some operational and management practices are still 
being studied concerning the smoke plant reducing compressed air 
consumption for cleaning the bag filter.
1 – Revamping of the smoke plant of the steel plant at the Vicenza site:
2 – The French site of Trith Saint Léger has carried out numerous initiatives, including:
Revamping the compressed air system of the rolling mill: install-
ing three new compressors, two of which are at variable speed, 
leading to a 15% reduction in electricity consumption. The pe-
culiarity of this project is the signing of a performance contract 
with a maintenance company. 
The economical amount is related to the degree of efficiency of 
the machines.
An energy mix improvement in the melting furnace: electricity con-
sumption has been significantly reduced, as has the use of coal; 
these actions have enabled a savings of approximately 7,000 MWh 
/ year in terms of electricity and 3,500t CO2 in terms of direct emis-
sions. An energy mix improvement in the melting furnace: electrici-
ty consumption has been significantly reduced, as has the use of 
coal;  these actions have enabled a savings of approximately 7,000 
MWh / year in terms of electricity and 3,500t CO2 in terms of direct 
emissions. Furthermore, among the secondary interventions, we 
can mention:
- Installation of approximately 450 new lamps for annual savings 
of 1,250 MWh. The intervention also resulted in an improvement in 
visual comfort as well as in plant safety;
- Replacement of 24 AC motors with new high-efficiency IE4 motors 
for an annual electricity saving of approximately 590 MWh; thanks 
to this revamping, maintenance costs have also been significantly 
reduced.
 
3 – The Swiss site Gerlafingen has implemented numerous initiatives including:
< intake
< energy saving
- 15% electrical energy
+ 360 Mwh / year of savings
Improvement of auxiliary 
shutdowns
+7,000 MWh / year savings
-3,500 tCO2 emissions
+ 590 MWh savings
+ 1,250 MWh of savings
In the summer of 2021, some rolling racks were revamped at the 
Donalam plant. We modified the electrical and automation part, re-
placing the old drives with the latest generation drives.
This work has resulted in a significant improvement from the point 
of view of:
- Energy-saving of about 50%, passing from 7500 Ampère to 3872 
Ampère for the K3 rolling stack and from 6000 Ampère to 3296 Am-
père for the K4 stacks;
- Reduction of stops due to electrical failure;
- Reduction of harmonics introduced into the network;
- Greater lamination stability.
4 – Revamping of rolling racks at the Romanian site of Calarasi:
2021 Sustainability Report
3.445.297
3.378.285
3.845.018
4.210.420
4.130.424
4.659.325
0
1.000.000
2.000.000
3.000.000
4.000.000
5.000.000
2019
2020
2021
ORIG IN OF CONSUM ED ENERG Y 
EXPRESSED IN G J
Natural Gas
Electric energy purchased

The control and reduction of atmospheric emissions are 
an aspect on which the Group has always focused, 
obtaining significant results, certified by monitoring the 
concentration values of the various pollutants, 
significantly lower than the authorized legal limits.
Comparing the specific local laws of the states where the 
Group’s plants are located allows the development of 
control and investment policies toward common 
prevention objectives. All plant investments are evaluated 
to ensure consistency with the best available techniques 
reported in the European documents (BREF - BAT 
Reference Document).
All production plants are subject to monitoring and 
control plans defined and verified by the control bodies. 
The emissions of the melting plants (EAF furnaces) are 
also subject to continuous monitoring to determine the 
flow rate and the concentration of particulate matter 
leaving the chimneys located downstream of the flue gas 
treatment plants. In 2021, the smoke abatement systems 
installed in the various plants were improved to optimize 
their performance: 
• at the Vicenza site, the silo transport systems for the 
dust captured in the bag filter were replaced and made 
more efficient; 
• the dosing system of the adsorbent material present on 
the Trith Saint Legér smoke plant was optimized to 
reduce the emissions of organic micropollutants;
• at the Gerlafingen site, changes were made to the steel 
mill smoke abatement system, with the addition of 
numerous filter elements, ensuring greater efficiency. 
Furthermore, alarm management systems allow 
immediate repairs to be carried out in the event of 
system failures. A preventive maintenance program is 
applied in all plants to guarantee that the systems are 
fully efficient.
Dosing systems for adsorbent material (activated carbon) 
to control organic micro-pollutants are installed along the 
flue gas duct to guarantee emission levels much lower 
than the stringent European limits. 
Technical-procedural methodologies are also applied to 
reduce emissions diffused from the handling processes 
of raw and auxiliary materials, often through water 
misting systems or localized aspirations in the 
loading/unloading areas.
60
61
4.5 Air emissions management 
Site in Vicenza, 
Italy
Site in Trith Saint 
Legér, France
Site in Stahl Gerlafingen, 
Switzerland
In 2021, the silo transport systems 
for the dust captured in filter bags 
were replaced and made more 
efficient.
In 2021, the dosing system of the 
absorbent material present in the 
flue gas system was optimized to 
reduce emissions of organic 
micropollutants. 
In 2021, changes were made to the 
steel plant smoke abatement system, 
with the addition of numerous filter 
elements, ensuring greater efficiency.
Several European standards deal with the regulation of atmospheric emissions. On one side, they 
regulate industrial emissions, and on the other, they control air quality and the environment. 
Regarding the emissions limitation for industrial plants, the central reference is the directive 
2010/75/EU, the so-called IED directive (Industrial Emission Directive).
2021 Sustainability Report

Main features of phase four of the ETS 
(2021-2030)
The legislative framework of the EU ETS for the phase 4 
trading period was revised in early 2018 (Directive 
2018/410 / EU) to enable it to meet the EU emission 
reduction targets by 2023, in line with the policies 
developed to combat climate change in line with the 
Paris agreement signed in 2015. 
The new directive 2018/410 / EU includes the 
following changes: 
- increase in the linear reduction factor to 2.2% (i.e., a 
sharper annual decrease in emission quotas), with a 
forecast reduction of 43% compared to 2005 levels (and 
55% compared to 1990 levels) for the sectors concerned;
 
- revision of the methods of free allocation of emission 
quotas to focus on the industrial sectors with the highest 
risk of relocation to non-EU countries benefiting from 
lower carbon costs (so-called carbon leakage); 
- strengthening the market stability reserve (MSR - 
Market Stability Reserve), a mechanism established to 
reduce excess emission quotas in the market, thus 
conditioning the trading price (upwards) and 
encouraging investments to limit emissions. 
The greenhouse gas emissions relating to the Group are
summarized below and expressed in tCO2 eq:
4.6 Greenhouse gas management
62
63
The Gerlafingen plant does not fall within the scope of the 
ETS (Emission Trading System), while it is subject to 
compliance with Swiss Law no. 641.71, “Federal law on the 
reduction of CO2 emissions”. Estimated emissions in 2021 
are equal to 100657 tons. The issue of the ETS will be 
strongly influenced, in the coming years, by what was 
announced by the European Commission in the Green Deal 
package.
Emission Trading System (ETS)
The Group’s Italian, Romanian, and French plants are 
covered by the Emission Trading System (ETS) 
mechanism, provided for by the European Union Directive 
2003/87, to report and verify greenhouse gas emissions 
(CO2). 
The EU ETS emissions trading system is one of the tools 
that the European Union has identified to reduce 
greenhouse gas emissions through a mechanism for 
allocating allowances to industrial installations or aircraft 
operators and the establishment of an exchange market 
of the same. 
The number of plants involved exceeds 11,000 units 
and covers about 40% of the EU’s greenhouse gas 
emissions. 
The ETS works through a “cap and trade” principle, 
according to which a maximum limit is set on the total 
quantity of certain greenhouse gases that the plants 
covered by the system can emit. It also introduces a 
reduction coefficient on the total allocations of 
allowances available decrease over time. 
There is also an exchange of shares between operators 
and traders operating on European registers. These 
operators and traders can also exchange their shares 
with others.
40%
The number of 
plants involved in 
the ETS exceeds 
11,000 units and 
covers approximately 
40% of the EU’s 
greenhouse gas 
emissions. 
(Source ISPRA)
Emissions focus for 2021
Production and 
emissions details
Billet production 
Rolled products 
production
Total production
CO2 emissions from 
process (steelworks)
CO2 emissions from 
combustion (rolling 
mills)
Total CO2 emissions
Unit of measurement
t
t
t
t CO 2
t CO 2
t CO 2
AFV  Vicenza
1.063.390
680.945
1.744.335
73.380
35.128
108.508
AFV  San Didero
n.a.(*)
141.390
141.390
n.a.(*)
12.391
12.391
AFV San Giovanni 
Valdarno
n.a.(*)
53.947
53.947
n.a.(*)
6.133
6.133
Donalam
n.a.(*)
161.822
161.822
n.a.(*)
22.773
22.773
LME
528.596
450.282
978.878
34.790
32.660
67.450
Stahl Gerlafingen
687.116
657.371
1.344.487
54.844
46.337
101.181
Total
2.279.102
2.145.756
4.424.858
163.014
155.422
318.436
Breakdown of 
emissions
CO2 emissions from 
process (steelworks)
CO2 emissions from 
combustion (rolling 
mills)
CO2 emissions from 
process (steelworks)
CO2 emissions from 
combustion (rolling 
mills)
Unit of measurement
%
%
t CO 2  / t of steel
t CO 2  / t of steel
AFV  Vicenza
68%
32%
0,069
0,052
AFV  San Didero
n.a.(*)
100%
n.a.(*)
0,088
AFV San Giovanni 
Valdarno
n.a.(*)
100%
n.a.(*)
0,114
Donalam
n.a.(*)
100%
n.a.(*)
0,141
LME
52%
48%
0,066
0,073
Stahl Gerlafingen
54%
46%
0,079
0,071
Total
51%
49%
0,072
0,072
NOTE:
(*) n.a.: not applicable as they are lamination plants - stand alone
Percentage emissions related to the 
Reporting boundary
Unit of measurement
AFV Vicenza
LME
Stahl Gerlafingen
Process emissions 
(steelworks)
%
45%
21%
34%
2.279.102
2.145.756
0
500.000
1.000.000
1.500.000
2.000.000
2.500.000
Billet production
Rolled products production
TOTAL PRODUCTION IN TONS
2021
51%
49%
CO2 emissions split between steelworks and rolling mill
2021
CO2 emissions from process
(steelworks)
CO2 emissions from combustion
(rolling mills)
45%
21%
34%
CO2 emissions of the three mills compared to the total from the 
Group's semi-product production 
2021
AFV Vicenza
LME
Stahl Gerlafingen
40%
2020
2021
Allocations
Emissions
AFV
Donalam
AFV
LME
Donalam
106.653
70.569
13.008
87.056
58.159
12.796
101.572
60.524
17.116
127.032
67.450
22.773
LME
Sources: 
European Commission - Energy, Climate change, Environment - 
The Intergovernmental Panel on Climate Change (IPCC)
2021 Sustainability Report

64
65
European regulatory context
On 11 December 2019, the European Commission 
officially presented the communication relating to the 
“European Green Deal.” 
The European Green Deal includes an action plan aimed 
at: 
• promoting the efficient use of resources by switching 
to a clean and circular economy; 
• restoring biodiversity and reduce pollution. 
The document outlines the necessary investments and 
funding instruments available and explains how to 
ensure a just and inclusive transition. Each EU member 
country must prepare a targeted action plan to meet the 
proposed sustainable growth goals. 
The EU intends to achieve climate neutrality in 2050 and 
achieve a net internal reduction of greenhouse gas 
emissions of at least 55% (compared to 1990) by 2030. 
For this reason, states but also individual economic 
entities must operate to aim for the intended objectives. 
In July 2021, the “Fit for 55” package was published by 
the European Commission, containing the action plan for 
achieving the objectives set by the Green Deal, including 
reducing the count to reduce CO2 emissions by 55%. 
This package includes, among other things, some 
proposals to amend the ETS directive, the revision of 
energy and electricity products taxation, and the 
development of renewable sources.
In this context, the Commission has reached an 
agreement (general approach) on the regulation of the 
Carbon Border Adjustment Mechanism (CBAM), which 
will support (and in the long term may replace) the ETS 
system. Today, it requires specific categories of 
companies to yield the emission quotas inherent to 
their production process each year against an annual 
allocation attributed free of charge to prevent the risk 
of relocating activities to countries without regulations 
on emissions of greenhouse gases. 
Based on the assessments carried out by the EU, the 
ETS system as currently configured is no longer in line 
with the commitment to reduce greenhouse gases 
proposed by the Union. Therefore, the Carbon Border 
Adjustment Mechanism (CBAM) was introduced, which 
will gradually replace the free allocation system.
Therefore, the CBAM will represent a mechanism 
designed to create conditions of equality in the 
production costs incurred by companies within the EU 
and for products imported from non-EU countries. The 
CBAM will be introduced on a transitional basis between 
2023-2025. It will initially involve imports of iron and 
steel, aluminium, cement, electricity and fertilizers, 
without the imposition of financial obligations but 
exclusively information-based. 
Following this period, from January 2026, if confirmed, 
imports of the products mentioned above will be subject 
to authorization by the competent national authorities. 
Importers from non-EU countries will have to purchase 
CBAM certificates, which will be linked to ETS emission 
allowances (EUA, EU Allowances). 
NOTES:
(a) Parameters used in the calculation of direct emission from transport:
Fuel
tCO 2 /t
kg/L (15°C)
Diesel
3,169
0,84
Unleaded petrol
3,152
0,75
LPG
3,026
0,52
Source: ISPRA 2021
(b) Full details on Scope 2 in the dedicated section on page 67
AFV Vicenza
23%
Percentage emissions related to to the 
reporting boundary
Unit of measurement
Combustion emissions 
(rolling mills)
%
AFV San Didero
8%
AFV San Giovanni Valdarno
4%
Donalam
14%
Donalam
299
LME
21%
Stahl Gerlafingen
30%
Breakdown of emissions
CO2 emissions from combustion 
internal transport (Scope 1)(a)
Unit of measurement
t CO2
AFV Acciaierie Beltrame
1.209
LME
375
Stahl Gerlafingen
2.219
Total
4.102
322.538
CO2 emissions Scope 1
t CO2
128.241
23.072
67.825
103.400
23%
8%
4%
14%
21%
30%
CO2 emissions from rolling mills
2021 
AFV Vicenza
AFV San Didero
AFV San Giovanni Valdarno
Donalam
LME
Stahl Gerlafingen
128.241
23.072
67.825
103.400
Scope 1 emissions expressed in t CO2
2021
AFV Acciaierie Beltrame
Donalam
LME
Stahl Gerlafingen
117.315
3.787
2.063
10.105
16.334
46.555
Scope 2(b) location-based emissions expressed in t CO2e
2021
AFV Vicenza
AFV  San Didero
AFV San Giovanni Valdarno
Donalam
LME
Stahl Gerlafingen
252.331
8.145
4.438
8.941
18.860
Scope 2(b) market-based emissions expressed in t CO2
2021
AFV Vicenza
AFV San Didero
AFV San Giovanni Valdarno
Donalam
LME
Green Deal
Plastics 
Tax
Energy Taxation 
Directive (ETD)
Carbon Border 
Adjustment Mechanism (CBAM)
Emissions Trading System (ETS)
•	Net zero emissions - 2050 (to be legislated)
•	50-55 percent emissions reductions from 1990 levels by 2030
•	Revenue collection based on non-recycled plastic consumption
•	10-15 mejor economies will be levied
•	Each to design own Plastic Tax - different state taxes
•	•	Revision of the current ETD 
•	Review of exemptions for various sectors
•	Role of hydrogen in future fuels policy
•	•	Four options for reducing the risk of carbon leakage
•	Aim: to ensure equivalent carbon costs between imports and locally produced    	
	 goods
•	Pricing of carbon inside the EU
•	Some sectors regulated through the ETS - floating carbon price
2021 Sustainability Report

Beltrame group activities
The Beltrame Group carefully monitors the evolution of this 
legislation and the possible risks and opportunities that 
arise from these reforms and has assembled a specific 
body within the Group. 
In the context of the Strategic Committee, a discussion was 
started on the Group’s decarbonisation objectives and on 
the strategies to be implemented to reach the proposed 
level. 
A study was commissioned to identify the benchmarks 
currently applied in the carbon footprint reduction process, 
the planned activities, and the communication approaches 
used by the leading players in the global steel industry to 
strengthen the Groups position - placement in the “best in 
class” audience. The Group also intends to quantify and 
certify greenhouse gas emissions at an organisational level, 
along with the entire supply chain, according to ISO 14064-1 
certification provisions. To this end, it has structured a 
monthly calculation procedure and related emissions 
reporting under its direct control (Scope 1, limited for now 
to process emissions from stationary and mobile 
combustion) and indirect ones generated by the 
production of electricity consumed (Scope 2). 
Furthermore, as identified in the GHG Protocol, we 
undertook to map components that contribute to the 
indirect emissions of Scope 3, an international standard 
for accounting and reporting corporate greenhouse gas 
emissions. As part of the assessment of Scope 3, the 
emissions deriving from transport activities upstream 
(procurement of goods) and downstream (shipment of 
semi-products, supply of finished products and waste 
management) are being identified and quantified, as 
well as the emissions generated from employee 
commuting and work missions. 
A further contribution to Scope 3 stems from emissions 
deriving from purchased goods (e.g., raw and auxiliary 
materials, packaging, lubricating oils, refractories) and 
services used. 
The process started will be completed by the middle of 
2022.
66
67
Source: GHG Protocol: Technical guide for the calculation of Scope 3 emissions - Carbon Leadership Forum
The calculation of Scope 2 emissions, which concerns the 
indirect contribution of emissions deriving from the 
generation of electricity consumed by the Group, was 
based on the overall energy consumption of the plants. 
It was also based on the following emission factors specific 
to the countries to which they belong (defined as “location-
based “) and dependent on the national mix of energy sour-
ces.
The Market-based is related on the CO2 emissions emitted 
by the energy suppliers from which the organization purcha-
ses, through a contract, electricity and can be calculated 
considering: Energy Guarantee of Origin certificates and 
direct contracts with suppliers, factors emission factors spe-
cific to the supplier, emission factors relating to the “residual 
mix”, i.e. energy and non-monitored or unclaimed emissions
(methodology used, with emission factor source: AIB - Eu-
ropean Residual Mixes, 2021). The Location-based method 
is based on average emission factors relating to energy 
generation for well-defined geographical borders, including 
local, sub-national or national borders (methodology used, 
with emission factor source Greenhouse gas emission inten-
sity of electricity generation by country- EEA and with source 
“Umweltbilanz Strommixe Schweiz 2018” - BAFU for Switzer-
land). Scope 2 emissions calculated with the Market-based 
method are expressed in tons of CO2, as the percentage of 
methane and nitrous oxide has a negligible effect on the to-
tal emissions of greenhouse gases (CO2 equivalent) as can 
be inferred from the reference technical literature. The Scope 
2 2021 emissions evaluation led to the following results, 
which are expressed both in absolute terms and as an index:
The contribution of Scope 2 emissions is approximately 
38% of the total direct and indirect emissions (with the 
exclusion of those inherent to the supply chain, Scope 3) 
and is directly related to the types of electricity production 
plants installed in the country of reference.
Note (*): For 2021, the plant purchased electricity entirely 
covered by guaranteed “non-fossil” origin. The markedbased 
Scope 2 figure for the Swiss plant is therefore zero. 
The central departments of the EHS Group/sustainability, 
energy, finance and the Central Technical Function (CTF) 
monitor and review all development and investment projects 
to define transition requirements and specify partnerships 
capable of framing the various projects within the pillars 
provided by the Green Deal. These departments are central 
to accessing the subsidized finance and funds that the EU 
has available. 
(a)
- AFV Vicenza, LME, Stahl Gerlafingen: tons of billets
produced;
- AFV San Didero, AFV San Giovanni V.no, Donalam: tons of 
laminate produced.
Italy
France
Switzerland
Romania
213,4
299,5
Country
Location-based 
emission factor (gCO2e/kWh)
Market-based 
emission factor (gCO2/kWh)
51,1
128,0
458,6
265,2
58,5
30,3
AFV
LME
Stahl Gerlafingen
Donalam
Total
123.165
16.334
46.555
10.105
196.159
Scope 2
Market based (CO2 in tons)
264.914
18.860
0 (*)
8.941
292.715
Factories
Scope 2 Location based 
Emissions ( CO2e in tons)
AFV Vicenza
AFV San Didero
AFV San Giovanni V.no
LME
Stahl Gerlafingen
Donalam
0,110
0,026
0,038
0,036
0,065
0,062
0,237
0,057
0,082
0,035
0 (*)
0,055
Factories
Scope 2 Location-based 
Emission Intensity (t CO2/t steel (a) ) 
Scope 2 Market-based 
Emission Intensity (t CO2/t steel (a) )
2021 Sustainability Report

68
69
Concerning water consumption, the Group pursues 
the goal of limiting the use of water resources throu-
gh cutting-edge treatment technologies and the 
application of management criteria aimed at saving. 
The good practices applied are based on evaluations 
related to: 
• Purpose of the water used and identification of the 
equipment to be cooled; 
• Possible need for water pre-treatment. 
• Purification processes downstream of use; 
• Identification of the various user flows and related 
circuits; 
• Quantitative data of circulating capacity, recircula-
tion rate, and treatment efficiencies; 
• Continuous control of the treated water quality;
• Rational use of chemicals. 
The Group’s factories’ water use is essentially linked 
to the cooling of components of the production plan-
ts, which takes place both through exchangers (indi-
rect cooling) and through direct contact (for example, 
in continuous casting and rolling plants). 
The water supply derives from extraction from the 
subsoil in the Italian plants and the one in Calarasi. 
In contrast, water from surface watercourses is 
mainly used in the Trith Saint Léger and Gerlafingen 
plants. 
The Vicenza plant cooling network is equipped with 
differentiated circuits but placed in cascade to each 
other and has been updated by installing a new 
battery of cooling towers characterized by better 
thermodynamic, sound and energy performance. 
At the Trith Saint Léger plant, the construction of the 
rainwater treatment plant continued. It filters water 
from the steel mill area and releases it to the surface 
water. We installed a new rolling mill wastewater 
collection network and meters in various sections of 
the water supply network to better monitor the 
effectiveness and study the technical-economic 
impact to identify actions to reduce water 
consumption. 
At the Gerlafingen plant, we launched a study to 
optimise the entire water cycle, aimed at separating 
the circuits belonging to different types of water (in-
dustrial, civil, weather), which will consist of various 
application phases on a multi-year basis.
Finally, industrial water is discharged into the sewer 
system or into surface water. The companies carry 
out water analyzes, through external bodies, in order 
to monitor that the quality complies with the regula-
tory requirements of the various countries.
4.7 Water resource management
2021 Sustainability Report
4.663
4.532
4.866
0
1.000
2.000
3.000
4.000
5.000
6.000
2019
2020
2021
T OT A L W A TER W ITHDRA WAL 
EXPRESSED IN M EG ALITRES 
Total freshwater withdrawal
Surface 
freshwater
47%
Ground-
freshwater
51%
Third-party 
water
2%
WATER WITHDRAWAL ORIGIN

9%
91%
TOTAL WASTE GENERATED
Hazardous
Non-hazardous
71
A scrap pre-selection plant is in operation in the 
Group’s French plant, which allows the selection of 
highly performing ferrous materials for the electric 
furnace, guaranteeing high yields and reduced energy 
consumption. The resulting material from the scrap 
piece has a significant number of non-ferrous me-
tals, which are recovered and enhanced in proces-
sing cycles outside the site. 
The steel production process also provides the 
addition of subsidiary materials, which add energy 
and chemical value to the liquid steel bath present in 
the furnace (with reducing, fluxing, etc. functions). 
They are typically represented by lime, dolomite, coal 
and other slagging agents necessary for forming an 
adequate quality slag to protect the works and their 
subsequent use. 
The Group has identified alternative materials and 
substitutes for some raw material flows in line with 
product and processes circularity. In particular, some 
types of residues, which originate from internal 
processes, are reused as slag, helping to reduce the 
consumption of lime and, therefore, the exploitation 
of non-renewable natural resources. 
We perfected the refining slag recovery plant in 
Vicenza, which allows part of it to be reused after 
appropriate treatment in the scrap’s melting process. 
In 2021, approximately 3,000 tons of this by-product 
were recovered and removed from the landfill. 
The same material is used in cement factories 
(particularly in France), which use it as a substitute 
for raw materials, also obtaining the result of redu-
cing the carbon footprint of the generated binder. 
Also, in Vicenza, the industrial experimentation of 
polymers, deriving from the recovery cycle of the 
plastic fraction of separate waste collection, was 
completed with very positive results in partial repla-
cement of the coal blown into the EAF furnace. The 
results showed excellent metallurgical performances 
associated with a conspicuous saving of natural 
resources and reducing CO2 emissions into the 
atmosphere. 
The industrial plant will be installed in 2022, and si-
milar tests with recycled materials will be conducted 
at the Trith Saint Legér site, which has a similar plant 
configuration in Vicenza. 
The Group is also focused on identifying recovery 
paths for other waste streams produced and has 
activated contacts towards specific supply chains 
(for example, cement and concrete production or 
infrastructural works), which have shown interest in 
the recycling of black slag and industrial aggregate 
in their processes. 
The latter is marketed in Italy and Switzerland with 
CE marking per European product standards and 
managed according to a factory production system 
(FPC) certified by third parties. 
In France, EAF slag is commonly used in con-
structing roads, and building works, consistently with 
what is reported in the SETRA ministerial guidelines. 
A further example of the circular practice is recove-
ring the zinc present in the powders that originate 
from the smoke filtration treatment of the smoke 
abatement steel plant. 
The recovery process is carried out in external plants 
through thermal processes and makes it possible to 
avoid the approximately 40,000 tons of hazardous 
waste in landfills every year. 
The ferrous scale that descends from the rolling 
process is used to produce counterweights in 
cement factories, glass factories or initial smelting 
steel plants. 
The Group’s annual waste production is around 
500,000 tons, of which about 90% has been classi-
fied as nonhazardous. 
In line with the project called AWaRe (All Waste 
Recovered), which aims to optimise the recovery of 
waste produced on the sites starting from their 
internal reuse, in the year 2021, we respected the 
recycling and valorisation objective of at least 90% 
of the waste produced in the Group.
AFV Beltrame Group pays great attention to en-
suring that its activities have a reduced impact 
on the environment and are consistent with sta-
keholders’ expectations, including by limiting the 
use of raw materials and natural resources. For 
this purpose, the Group implements continuous 
research on techniques and operating methods 
that make it possible to replace natural materials 
with byproducts of industrial origin and products 
deriving from waste recovery flows and optimise 
its production plants’ efficiency. 
The Group’s steel mills use the technology based 
on an electric arc furnace (EAF), which involves 
using selected ferrous scrap of predetermined 
quality that is part of the steel production flow at 
the end of their relative life cycle. This scrap can 
be from the industrial sector (processing waste, 
classified as preconsumer) or downstream every-
day use (so-called post-consumer). The material 
content deriving from recycling functions in the 
Group’s finished product is higher than 95%. The 
ferrous scrap that enters the plants can be clas-
sified indifferently as a product deriving from a 
recovery cycle (so-called “end of waste” accor-
ding to the European regulation EU 333/2011) or 
as waste and must comply with strict purchase 
specifications as well as rigorous confirmation 
and classification protocols at the entrance to 
the scrapyard.
The Group’s steel mills use electric arc furna-
ces (EAF) technology. On average, the mate-
rial content deriving from recycling operations 
present in the Group’s finished product is hi-
gher than 95%.
M A T E R I A L  C O N T E N T  F R O M 
R E C Y C L I N G  O P E R A T I O N S
The Group’s annual waste production is 
around 500,000 tons, of which approximately 
90% has been classified as not hazardous.
W A S T E  C L A S S I F I E D  A S 
H A Z A R D O U S
90%
70
4.8 Raw and auxiliary materials 
and waste
95%
We respected the recycling goals and valori-
sed at least 90% of the waste produced in the 
Group again in 2021.
R E C Y C L E D  A N D  V A L O R I S E D 
W A S T E
90%
2021 Sustainability Report
134.850
31.644
39.243
359.809
389.990
392.421
0
50.000
100.000
150.000
200.000
250.000
300.000
350.000
400.000
450.000
2019
2020
2021
TOTAL WEIGHT OF WASTE GENERATED EXPRESSED 
IN IN TONNES AND BROKEN DOWN BY DESTINATION
Waste diverted from disposal
Waste directed to disposal
90%
10%
DESTINATION OF WASTE DELIVERED
Waste diverted from disposal
Waste directed to disposal
8%
81%
1%
9%
DESTINATION OF WASTE 
Hazardous waste diverted from disposal
Non-hazardous waste diverted from disposal
Hazardous waste directed to disposal
Non-hazardous waste directed to disposal

72
73
In the steel industry and at an international level, specific directives provide for metal scrap 
radiometric control to prevent accidental melting of radioactive sources, leading to contamination of 
industrial matrices and the environment and creating radiation risks for workers and the population. 
For years, the Group has implemented a series of radiometric surveillance procedures for scrap metal 
and other subsidiary materials and stringent control over all the batches of steel produced or 
procured. 
All plants have road and railway vehicle radiometric detection systems near the weighing equipment. 
There are also instruments for measuring the radioactivity of steel specimens and environmental 
radioactivity. 
In 2021, the complete overhaul of the monitoring and reporting systems for the levels of radioactivity 
present in the loads entering and leaving the Group’s plants began, with particular attention paid to 
the control of scrap loads. 
The revamping process started from the Trith Saint Legér site, also following the accidental melting, 
which occurred in October 2021, of a small radioactive source, presumably present inside a cargo of 
scrap and not identified by the portal control during screening. 
The episode was handled following the prescriptions of the French authorities and did not cause 
significant impacts on workers, the population and the surrounding environment. 
Thanks to their extensive surface area and the new data processing software, the new plant 
configuration envisaged the total replacement of the measurement panels with systems capable of 
more perceptiveness. 
Similar improvements are also being assessed for the Italian and Swiss plants. In particular, for the 
latter, in 2021 all the portals for the control of entry by truck and rail were replaced and evaluations 
are underway for further improvements in 2022.
Finally, we also acquired new portable measuring instruments to improve field monitoring in the pre-
sence of radiometric anomalies. 
4.9 Radiometric measurements
2021 Sustainability Report

The principle of circularity of steel is primarily due to its characteristic of being 
recyclable repeatedly. But if the logistic solution foreseen for transporting 
scrap, semi-finished or finished products is by road, the ecological advantage 
diminishes with each trip. The “steel on rails” project was born from this 
observation, supported by the detailed analysis of numbers and volumes 
inscribed in a strategic path towards maximizing intermodality. AFV Beltrame 
Group carries out many initiatives in this direction. All the group plants are 
oriented towards a unified approach of attention to the environment and 
certainly to costs. Rail transport, in particular, makes a significant contribution 
to the path towards increasingly sustainable mobility. It is also among the most 
efficient transport systems in terms of energy and climate-altering emissions. 
The current year is expected to move about 1 million tons by rail throughout the 
group, with a growth of 70% compared to three years ago.  
.
PROJECT: Steel in rail cars
Investments:
The main investment is taking 
place in Italy. In particular, 
the Vicenza railway 
junction was extended 
with the restoration of the 
double track that serves 
the laminates warehouse 
with the simultaneous 
reactivation of the attached 
weighbridge. In San Giovanni 
Valdarno the existing link, 
inactive since 2009, was 
reactivated and adapted. 
Thanks to this 25,000 tons of 
steel passed from road to rail 
in 2021, with a potential of 
35,000 tons.
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75
4.10 Conservation of biodiversity and 
territories
2021 Sustainability Report
And finally, in August 2021, the San Didero junction has been 
expanded, allowing 18-wagons trains to be accommodated in 
the plant against the 15 of the past, with the consequent logi-
stics costs optimization and further reduction of the environ-
mental impact. 
So, 220 thousand tons of steel have travelled by carriage, the 
equivalent of 8 thousand fewer trucks on the roads. The pur-
chase and handling of scrap by rail have increased at least 
25%, and this quantity is destined to grow. 
In total, in the Italian handling alone, between scrap semi-fini-
shed products and finished product, approximately 460 thou-
sand tons have travelled by train in 2021: double the average 
of the last three years. Also, in this case, there were 16,000 
fewer trucks on the roads.
We recently approved further investments to double the train 
lines dedicated to billet loading, thus increasing the exchange 
of semi-finished products between factories by rail. Circularity 
is guaranteed precisely by the interchange between locations: 
if semi-finished products leave Vicenza for the Group's 
factories, the trains involved in the delivery then return loaded 
with scrap. No journey is made without a load. In addition, this 
organization has allowed all the subsidiaries of the AFV 
Beltrame Group to integrate the range with products that are 
mutually supplied (only inter-company exchanges amount to 
40 thousand tons per year). This exchange required logistical 
and organizational adjustments to enhance the connection in 
terms of wagon traffic. The environmental advantage is 
obvious. The economic one depends, among other things, on 
the excellent balance between the flows. The partnerships 
with the railway transport company MIR (Mercitalia Rail) and 
DB Cargo and with the management companies of the internal 
connections, particularly Logyca UMF, are fundamental in the 
process and therefore strengthened.
Not only Italy
All the Group's plants are connected, not only in Italy.
The Group has also developed an agreement between Stahl 
Gerlafingen, the Swiss-based subsidiary that produces rebar 
and its derivatives for construction, and SBB Cargo, the back-
bone of the Swiss economy for rail freight transport. The 
agreement provides for the logistics control entirely on the rail 
of 100,000 tons of steel scrap destined for the Swiss factory. 
Stahl Gerlafingen works approx. 800,000 tons of scrap per 
year. More than 20% of these come from abroad. Half of this 
20% is moved by road (the rest were already on rail). Until 
recently, this handling resulted in 4,000 trips per year by truck: 
approximately 15 per day. Thanks to the agreement, the 70 
trucks that ploughed the country's roads each week are now 
reduced to two trains. These new connections include another 
strategic partner, Ultra Brag, which manages the temporary 
storage - crucial to the project - and the steel scrap loading 
and have invested in structures and improvements to accom-
modate the loads. At the terminal port of Birsfelden on the 
Rhine, the scrap is stored and subsequently loaded onto 
the wagons towards Gerlafingen. Overall, the entire organiza-
tion also allows for better planning, more punctual deliveries 
and precise tracking. Together, the three companies have cre-
ated a virtuous system for optimizing the supply chain. Not to 
mention the finished product which in 2021 in Stahl Gerlafin-
gen reached about 280 thousand tons transported by rail. Let's 
not forget Donalam, where for our production of special steels 
in 2021 we have sent about 160 thousand tons to our Calarasi 
plant by a train of semi-finished products for processing. 
Other flows: intermodal and widespread transport 
The more structured customers, especially abroad and in 
Northern Europe, are already organized with internal 
railway connections. This mode is called transport widespre-
ad. Wagons dedicated to a specific customer are 
loaded directly from the Vicenza office, which receives 
them "comfortably" at the destination site, having the 
structure set up to do so. To give you an idea of the 
increase of this system and the consequent reduction in 
CO2 emissions, consider that in 2016 300 tons of steel 
travelled per year. The forecast for 2021 is 30 thousand 
tons. When this method is not possible the so-called intermo-
dal transport is applied, whereby the steel travels by road only 
for those short stretches necessary to reach the railway 
junction. This intermodal method has borne its fruit: data 
confirms that over 150,000 tons of steel have been 
removed from the road every year, with an annual increase 
of 10% achieved in the last five years.
The synergies of transport 
Circularity, therefore, also involves transport. Flexible and mo-
dular systems must maximise cost-effectiveness and acces-
sibility by favouring renewable or lower impact energy sources 
to develop a sustainable and decarbonised freight transport 
chain. Integrating ships and trains and port infrastructures 
with railways is necessary. To use an environmental metaphor, 
we need to reproduce green corridors that connect ports, 
railway junctions and processing sites and then destination 
markets. However, a combination that requires substantial 
planning and investment commitment is favoured by the 
widespread use of digital technologies to manage arrivals and 
departures and loading and unloading of warehouses to be 
economically sustainable in the long term. A mix of efficien-
cies has been implemented to protect the environment and 
profitability. The advantages of which are increasingly 
understood by all the players involved in the supply chain. 
The geographical aspect of the territory in which AFV Beltrame 
Group is located is not a facilitating element. Still, we obser-
ved that the acceleration of the Group had been momentum 
for the entire system. Customers are increasingly projected 
towards efficiency and attention to the environment, conside-
ring them linked closely. Therefore, investments in this sense 
are desired by all companies at various levels. Consequently, 
infrastructures and states are also adapting to this trend. The-
re is still a long way to go, but the route has been mapped out.

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77
2021 Sustainability Report

Planting a tree is not enough to make one, although 
it’s a great start. 100 thousand Trees for Piedmont 
is a program AFV Beltrame Group has joined, aimed 
at creating a reforestation project by increasing the 
region’s green by creating more areas capable of 
reducing the presence of CO2. An initiative mainly 
structured in awareness-raising actions and follow 
up in which the Paulonia association, focused on 
protecting the environment, has identified a series 
of areas suitable for hosting plants in the Piedmont 
region. 
The parameters for selecting the areas mainly con-
cern the proximity to urban centres, areas of high 
traffic flow and perimeter areas of cities or areas 
subject to high concentrations of air pollutants. 
The project aims to establish a carbon sink and 
related sequestration of CO2 and the consequent 
improvement in the quality of air and life. 
Paulonia, known for its beauty and the marvellous 
white or lilac flowers it produces (the name derives 
from that of the Russian noblewoman Anna Pavlovna, 
hence the nickname “tree of the princesses”), grows 
quickly and has a very appreciated wood in the 
construction of furniture, musical instruments and 
structure. From its flowers, loved by bees for the high 
amount of nectar, beneficial substances are also 
obtained for medicines. Just think that one hectare 
of Paulonia can guarantee over 700 kg of honey with 
excellent nutritional characteristics. 
The majestic foliage with large leaves covered with 
light hair can capture dust from the air. Above all, it 
can quickly absorb large quantities of CO2, restoring 
oxygen, and for this reason, it is also known as an 
anti-smog tree. 
Very suitable for phytoremediation, it is perfect in 
industrial areas. For this reason, together with the 
association, the Group planted over 800 trees in the 
spring of 2021. Part of these was grown in areas 
surrounding the headquarters of San Didero in Pied-
mont, and a portion was donated to neighbouring 
municipalities. 
Finally, AFV Beltrame Group, always in collaboration 
with the Municipality of San DIdero, has also willing 
to plant the donated plants in the locations indicated 
by the municipal authorities, supporting all the costs.
78
79
Bilancio di Sostenibilità 2021
PROJECT: 100 thousand trees for Piedmont 
Paulonia plants absorb CO2 up to 10 times more than other trees. They 
grow quickly. Their flowers are lavender and fragrant and very popular 
with bees. The leaves are good nourishment for poultry and have a wood 
widely used in the production of furniture, floors and musical instruments 
because it is light and insects don’t attack them.

This project is in line with biodiversity protection 
and the restoration of green corridors through the 
reforestation of areas adjacent to the Trith Saint 
Leger plants, where the French plant of the group is 
based. We aim to restore and protect the 
ecosystem and its biodiversity. Protection at the 
French site also includes adopting responsible 
practices in maintaining green spaces. In fact, since 
spring 2021, these areas have been “under the care” 
of herbivorous animals (goats, sheep and donkeys) 
in eco-pasture. Thanks to these animals, even the 
most challenging areas are effectively reached, and 
invasive plants are eradicated naturally with zero 
environmental impact. 
Dedicated enclosures have also been created, whi-
ch also house ditch goats, an endangered species 
(in France, there are only 900 specimens). 
An appointed external company carries out the 
maintenance and care visits. 
Still, to protect biodiversity and to favour pollination 
processes, two hives have been installed, which are 
added to the 8 present also in Switzerland. Both 
bees and grazing animals will be the protagonists of 
awareness-raising activities dedicated to the 
community and children as soon as the pandemic 
context allows it.
For over 100 million years, 
bees have been essential 
for maintaining 
ecosystems on Earth. 
They are essential for the 
development of 
biodiversity, guaranteeing 
almost 80% of the 
pollination of plant species.
Eco-pasture in LME allows 
us to respond to various 
problems: 
• Maintaining hard-to-reach 
spaces; 
• Eradicate invasive plants, 
especially the Japanese 
knotweed; 
• Reduce the environmental 
impact; 
• Preserve endangered 
breeds.
Bees are an excellent indicator of the environmental 
healthiness of the area, allowing you to draw up an 
inventory of pollution and the quality of the local envi-
ronment. The hive preparation is a concrete action in 
favour of biodiversity. It is also about making employe-
es aware of biodiversity and sustainable development 
challenges and mobilizing them around a virtuous and 
federating project
Eco-care is an alternative method for landscape maintenance in urban or 
peri-urban areas. From May to October, a flock of sheep, goats, or donkeys 
settle in certain regions to graze the lawn. As the name suggests, this 
practice is environmentally friendly as it reduces noise, pollution, and the 
use of chemicals. In addition to protecting existing biodiversity, it also 
represents an actual reduction in the maintenance costs of green spaces.
81
PROJECT: Eco-pastures and beehives, when biodiversity en-
ters the company
80
LME produces jars of honey 
and kits for candles with 
beeswax that are given 
to employees. A similar 
project is also underway at 
the Stahl Gerlafingen plant.
2021 Sustainability Report

Attention to
human capital
5

Attention to human capital
The management and relationship with our people are undoubtedly based on the 
principles enshrined in our Code of Ethics and the Group’s Sustainability policies, in 
full compliance with local regulations and collective agreements. Still, it is based on 
the honourable relationships we build with our collaborators.
84
85
In a company like ours, the specialization in some 
professions is very high. The training of specific 
figures takes months, sometimes even years, and 
attention to human resources is essential. 
The criticality arises in the attracting talents phase, 
given the competition with companies and more 
attractive sectors than ours for potential candidates. 
It is, therefore, necessary to propose something 
additional, trying to offer the new high school or 
university graduate, as well as the now established 
professional, what is expected from a leading 
company and market leader. 
We are present at job fairs and career days for recent 
graduates. We organize visits to the company for 
schoolchildren and associations. We are active in the 
leading professional social networks. We manage the 
research, selection, and onboarding process 
professionally and structured, trying to win over 
candidates before letting them win us over. 
Given the difficulty in training and shaping the most 
specialized profiles, it is a priority to retain people 
once in the company and adequately manage the 
inflow and outflow. 
We are developing welfare and total compensation 
systems that offer employees something more than a 
simple salary to help with retention. We try to satisfy 
employees through work hours and then shift 
flexibility. We bring services to the company that we 
would otherwise be saught externally—in their time, 
focusing on prevention, health and investing as a 
company to make sure that everything possible is 
done in this direction. Some colleagues have worked 
in the company for generations. Whenever possible, 
they proudly continue introducing their children to 
work for the Group, for which they have developed so 
much passion. And this is in our DNA. There is no way 
to build such a sense of belonging merely through 
marketing methodologies or work psychology but 
through decades of attention and centrality of the 
individual.
The enhancement of human 
capital has always been one of 
the company’s priorities and one 
of the fundamental challenges 
imposed by the Covid-19 
pandemic. 
Digital transformation remains 
the key to restarting, and 
companies need to seize this 
opportunity, which is also an 
excellent modernization 
opportunity to bring about new 
growth.
2021 Sustainability Report
5.1 Group human resources. People, relationships and value
30.556
443
2.178
11.036
301
2.895
5.227
5.027
TRAINING HOURS BY TOPIC
Safety
Cyber S ecurity
English language
Specific to industrial
department
Continuous Improvem ent
Departme nt-specific
Soft skills
Other
500
14.327
42.836
TRAINING HOURS BY CATEGORY
Executive
M anager and W hite Collar
Blue Collar

5. 2 The trend in employment levels
The steel sector is one of the main productive sectors 
of the national industrial system. Its supply chain 
contributes to job creation e wealth and sees 
downstream a plurality of manufacturing sectors for 
which steel is the primary raw material. 
From the production of crude steel to its 
transformation into primary products and derivatives, 
the steel sector, according to Federacciai * data, 
employs 70,000 direct employees in Italy, which with 
the related industries reaches 140,000 people, with an 
estimated indirect employment impact of three times 
as much. 
Steel is used in various strategic manufacturing 
sectors: from construction to mechanics, cars to 
medical and food, and shipbuilding. However, the 
leading industry of use remains that of building with a 
share, according to Federacciai data, equal to 36.5%. 
In 2020 the steel industry of the Old Continent 
provided direct employment to 326,000 people and 
indirectly to over 2.7 million along the entire supply 
chain and related activities. ** 
Regarding the specific AFV Beltrame Group, the 
number of employees at the Group level has grown in 
the last three years, reaching 2,258 units. 
The employment policy continues to be concentrated on 
significant investments in development and training 
activities, dedicated induction courses (e.g., Induction 
Week), and training activities in collaboration with the 
institutions of the territories in which the Group operates 
(e.g., Giovani d’Acciaio).
* https://www.promozioneacciaio.it/UserFiles/File/pdf/
eventi2019/FEDERACCIAI-RAPPORTO-SOSTENIBILI-
TA_2019.pdf
**  https://ftp-siderweb.s3.eu-west-1.amazonaws.com/
speciali/Speciale_Il%20futuro%20dell%27industria%20
siderurgica%20europea_2022.pdf
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87
5. 3 Human resources compensation
The implementation of AFV Beltrame Group’s remuneration 
policy called “Corporate Compensation Policy” intends to 
establish the reference framework and guidelines to be 
followed by the “Countries” in the development of 
remuneration programs, taking into account the specific 
regulatory provisions of each country. We must align the 
standards of the remuneration policy with the business 
objectives, financial results and economic sustainability 
of the Group. The approach to be adopted must adhere to 
international regulatory requirements and be connected with 
individual and collective performance in the interest of all 
stakeholders. The remuneration policy must be inspired by 
the principles of fairness and transparency in compliance 
with the corporate mission and values. 
The purpose of the Corporate Compensation Policy is to 
encourage the growth and motivation of human resources in 
a sustainable way and line with the company’s results and 
strategies. The Corporate Compensation Policy applies to all 
Group companies and regards the remuneration of all 
categories of employees, managers, white collars and blue 
collars. 
AFV Beltrame Group’s remuneration policy must follow the 
following principles: Clear and transparent management of 
remuneration programs; Adherence to regulatory 
requirements and principles of reasonable professional 
conduct, continuous benchmarking of trends and practices 
in the labour market to ensure the balance between internal 
and external salaries; Compliance with the principle of 
internal equity, both at the individual “Country” level and the 
Group level; Sustainable remuneration is linked to the 
company’s results. 
The remuneration policy aims to retain employees, with 
particular attention to talents and resources with critical 
skills. The benefits policy does not provide for differentiation 
between full-time and part-time and temporary employees. 
As regards insurance coverage, some countries have stipula-
ted specific health insurance policies.
G U A R A N T E E  O F 
E Q U A L  R I G H T S  A N D
 P R O T E C T I O N
The federal law on equality between women and men in Switzerland
Switzerland’s federal law on equality between women and men was recently revised. 
The law was supplemented with the obligation for employers to conduct an internal analysis of equal pay. 
The amendment seeks to strengthen the constitutional right to equal compensation for similar work and work 
of equal value. Recently, an external consultancy firm checked out AFV Beltrame Group’s Swiss site. At Stahl 
Gerlafingen, the staff are delighted that the company fully complies with these provisions.
Wage equality in Switzerland has been registered in the Federal Constitution since 1981 (Art. 8 para. 3 Cst.). 
It is also specified in the Federal Law on Gender Equality (LPar), which entered into force in 1996. Equal pay is an 
obligation that applies in all employment relationships, both in employment relationships under private Law and in 
those of public Law. From 1 July 2020, employers with at least 100 male and female workers are subject to new 
obligations regarding equal pay. Regardless of the employment rate, all male and female employees are included in 
the calculation of male and female workers, excluding apprentices. 
In concrete terms, the new provisions envisage three obligations for employers and employers: to analyse, verify 
and inform.
Analyse (July 1, 2020, to June 30, 2021)
From July 1 2020, private and public employers and employers will have one year, i.e., until June 30 2021, to analyse 
their wage practices to identify any unequal treatment between women and men. 
Employers and employers are free to choose the method to carry out the analysis. However, the technique must be 
scientific and compliant with the law (art. 13c para. 1 LPar). 
Check (July 1, 2020, to June 30, 2021)
Once the analysis has been carried out, employers and employers must have it verified by an independent body 
(Article 13d LPar). 
Inform (July 1, 2020, to June 30, 2021)
Employers and employers are obliged to inform workers about the equal pay analysis results in writing within one 
year from the conclusion of the audit (art. 13g LPar). 
If the wage parity analysis indicates that it is respected, no further investigation is necessary. If not, the study must 
be repeated four years later. 
The Swiss company Stahl Gerlafingen of the Beltrame Group has obtained the Certification certifying full complian-
ce with all relevant regulations. 
E Q U A L  P A Y
100%
E Q U A L  T R E A T M E N T 
B E T W E E N
M E N / W O M E N
100%
100%
=
2021 Sustainability Report

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89
C YB E R S E C URITY
E NG LIS H LANG UAG E
L EA DER SHIP 
P ROB LE M S OLV ING
D IG ITAL S KILLS
SA FETY
P E OP LE
MANAG E ME NT
S E C URITY
AWARE NE S S
MO DEL L O  231
0 4
0 8
0 1
0 5
0 9
0 2
0 6
1 0
0 3
0 7
1 1
The AFV Beltrame Group Corporate Academy was born in a general con-
text where changing scenarios, which generate complexity and inde-
terminacy, require companies like ours to realign strategies and conti-
nually adapt training to maintain competitiveness constantly. 
Our goal is to ensure our people’s professional, cultural and human 
growth by creating value, supporting change processes, ensuring the 
alignment of corporate matters, and strengthening the competitive 
position in the market.
C OURS E  IN
LAMINATION
5.4 The Academy for training
AFV Beltrame Group launched high quality ‘on demand’ 
training in 2021 with its own Learning Management 
System. It is a digital and online Academy that offers 
interdisciplinary activities for the training and development 
of the skills of all managers, employees and internal 
collaborators and the enrichment of the company’s 
business. 
AFV Beltrame Group’s goal is to provide continuous training 
on managerial, technical and linguistic content, through a 
dedicated and customized platform, with courses lasting up 
to 4 hours and viewable every day and at any time, from any 
device (pc, tablet, smartphone). 
In this way, a tangible online knowledge library is available 
to the Group, from which to draw skills not only when 
required by the company but also based on the wishes and 
needs of employees in a self-training perspective. 
The project is active in all the Group’s offices: Italy, France, 
Switzerland and Romania. 
We engage participants through periodic reminders, and a 
bulletin board exhibits the training proposal in three of the 
Group’s languages, Italian, French, and German. There are 
training courses of a more technical nature, such as 
lamination and security, up to courses dedicated to current 
issues, such as sustainability and finance, and language 
courses. The multimedia contents, cards, reports, and 
presentations, can be downloaded and develop various 
themes. There is also the possibility that each country 
embeds its contents independently. 
In total, there are over 500 basic training pills created and 
distributed by Skilla in collaboration with Niuko, a training 
company of Confindustria Vicenza, dedicated to the socalled 
“soft skills”, in addition to those on technical sector 
training, digitized by Festo Consulting / Academy with 
contents created by internal experts. 
Speexx instead deals with language training, which includes 
one-to-one courses in the various languages of interest and 
basic training in English. Oltrematica has provided the 
Tutorami platform for the management and consultation of 
content, with a configurator that allows you to prepare 
training sessions based on materials, videos, lessons, and 
know-how the company provides.
Some of the issues addressed in the AFV Beltrame Group digital academy: 
RE S ULTS  ORIE NTA-
TION
2021 Sustainability Report

90
91
Industrial relations in AFV Beltrame Group are based on 
clear and transparent communication between the 
company and the workers’ representatives. To follow this 
approach, we organise periodic meetings in all countries 
between the HR Departments and the trade unions or 
employee representatives, in which the following issues 
are analysed: 
- results and improvement policies on health, safety and 
the working environment; 
- economic and industrial results of the Group, of the 
country and each plant; 
- a point on the market situation and the general prospects 
for next year, for the country and the Group; 
- human resource management strategies. 
In Italy, these periodic meetings are called “observers”. 
They are organised quarterly in each plant and generally 
once a year on a national basis. 
Observers represent an innovative tool in the panorama of 
industrial relations. The company and the workers’ 
representatives cooperate in reviewing results and 
determining actions to be implemented to improve the 
company’s general performance in all areas and benefit all 
in good times and more difficult ones. It is a highly 
innovative approach based on transparency and 
responsibility that aims to create a cohesive system where 
all the social partners, each with their role. They come 
together to share the results and discuss the company’s 
prospects. 
The minimum notice period for operational changes is 
consistent with national contracts and laws and 
proportionate to the extent of the changes required. 
As part of the activities carried out by AFV Beltrame Group, 
along the entire value chain, there are no elements of risk 
that could limit the right to freedom of association and 
collective bargaining.
5.5 Industrial relations 
L A B O U R  U N I O N S 
A N D / O R 
W O R K E R S
R E P R E S E N T A T I V E S
H E A L T H , 
S A F E T Y  A N D  W O R K 
E N V I R O N M E N T
H R  M A N A G E M E N T
G R O U P , 
C O U N T R Y, 
F A C T O R Y 
M A R K E T  A N D 
G E N E R A L 
P E R S P E C T I V E S  B Y 
C O U N T R Y  A N D 
G R O U P
S T R A T E G I E S  O N 
T H E  M A N A G E M E N T 
O F 
H U M A N 
R E S O U R C E S 
2021 Sustainability Report

5.6 Digitalisation 
By analyzing the HR processes, we realized that there was 
room for improvement and optimization. To develop these 
aspects, we chose the route of digitalization. Where paper is 
not required by law, we have tried. We are still trying to 
transfer the entire cycle of the employee’s professional life 
into a digital format, with a view to sustainability, 
simplification, and a unique added value given to content 
activities compared to repetitive and insignificant ones. 
The advantages were evident from the beginning of the 
project: Staff satisfaction involved in the process, which saw 
an increase in the level of their contribution to the activities, 
the reduction of human errors in execution and forgetfulness, 
the standardization and reduction of timing. These are just 
some of the aspects that we have seen emerge, but also, the 
greater ease in data extraction and processing is completely 
changing the way we approach information. Data that 
previously filled paper files, forcing people to be physically 
present to fill in the forms, and whose contents had to be 
manually transferred to the system, or worse still, remain on 
paper without being processed, is now available for 
consolidation and analysis. From the Exit questionnaires 
(forms administered to resigning employees followed by an 
interview with HR managers about the reasons for the 
change), we can, for example, extract the causes of the most 
frequent resignations. 
We can do it by period, area of belonging, or any other traced 
criterion, intervening promptly when necessary. The same 
thing happens with the annual appraisal reviews (staff 
evaluations carried out by managers on their collaborators 
followed by an interview and the collaborator’s feedback 
questionnaire). This process has already been successfully 
tested in the Swiss office, and with the management of the 
end questionnaires—we administered the trial period online to 
new hires and managers. Even requesting job instruments for 
new hires has become an online checklist that human 
resources and managers fill out in the Italian offices. This 
process generates a series of automatic emails for all the 
corporate bodies involved to optimize the activities carried out 
in the past manually with a massive waste of time and no 
added value. 
Corporate digitalization 
starts from a change in 
mentality, adapting all 
internal processes to the 
modern and current needs 
imposed by a digital age. 
Speed of execution and 
efficiency are essential.
92
93
A new digital approach
AFV Beltrame Group is a manufacturer of large quantities of 
products. This position translates into an equally significant 
amount of data generated, which, if properly governed, 
allows for maintaining high-quality standards. The company 
carries out digitisation projects on all business units that 
favour increasingly optimal management of resources by 
providing higher customer services. Digital projects mainly 
have a Group connotation. They are designed to be 
implemented in all our Italian and foreign countries. This 
trivial aspect is not if we consider that the Group is a multibu-
siness in which the logic differs from company to 
company. This approach in digital projects has made it 
possible to generate a common mindset in the people 
belonging to the Group, which, supported and supported by 
digital collaboration platforms, has made interactions more 
fluid and accessible, contributing to “simplification” in 
operational management. On the customer and third party 
front, regardless of the country, multilingual digital services 
have been implemented, such as web portals that have 
allowed the use of information and documentation remotely 
and 365 days a year. The Group also connected customers 
interested in benefiting from digitised management of the 
order process via EDI (Electronic data interchange), 
eliminating faxes and emails and optimising data entry in 
the various interconnected systems. On the other hand, the 
Group companies’ processes have been analysed in the 
different company areas to reduce the use of paper and 
encourage the use of IT platforms for document 
management. Digital projects have been a driving force for 
cultural integration, contributing to the amalgamation of 
international teams, strengthening their cooperation and 
collaboration, and obtaining exciting results.
2021 Sustainability Report

2021 Sustainability Report
94
95
Bilancio di Sostenibilità 2021
Some data on human resources in AFV Beltrame Group:
94
The Group’s IT strategy is based on five macro-areas 
coordinated by the Business Relationship Management 
activity. 
Two of these are represented by Digitization and 
Cybersecurity. 
These sectors, closely related to each other, have 
undergone an exponential increase in every industrial sector 
in recent years. It is easy to understand how the growth in 
digital and information technologies in business benefits 
and performance has increased the risks of exposure to 
cyber-attacks and so-called Cyber Crime. 
The steel sector is not immune to these threats. 
Like companies in other manufacturing sectors, those in the 
steel industry also run the risk of cyber-attacks for extortion 
of money, the risk of attacks by activists and the risk attacks 
for damaging competition. 
Furthermore, the recent events involving Russia and Ukraine 
and the related cyberwar that is taking place these days (hid-
den from most people but persistent and dangerous) 
have made it even more critical and urgent to monitor this 
topic. It is a matter that has been on the desk of every CIO 
(Chief Information Officer) worldwide for some years now. 
A cyberattack can block the entire IT system of a company 
and, therefore, also of a steel mill. 
Without a computer system, it is not possible to manage 
customer orders. Production cannot be scheduled, and 
orders cannot be sent to suppliers. You don’t have field data 
or your equipment visibility. An attack can paralyze the 
company for several weeks, even if existing backups are 
restored. In addition to these, there may also be offensives 
directed at production systems. 
Cyber-attacks (including recent ones) that were successful 
in the various industrial sectors and not least in the steel 
sector have had consequential impacts: 
- plants or services stops (and therefore lost money); 
- requested ransoms amounting to several tens of millions 
of euros. 
The companies involved are important international groups 
with structured information systems that have invested 
time, resources and money in IT security. Therefore, no one 
can or must consider themselves immune to cybersecurity. 
AFV Beltrame Group is very attentive to this issue and has 
increased investments in IT and Cybersecurity to increase 
the security and protection of the company from 
cybercrime. 
The Group has undertaken and applies constant monitoring 
and remediation activities in areas sensitive to Cybersecuri-
ty. Antivirus, antispam, patching and upgrade of 
obsolete systems, password complexity, multifactor 
authentication, backup systems, WAF, disaster recovery 
systems, vulnerability assessment and penetration test are 
tools we use, to name a few. 
In 2021, the Group equipped itself with a SIEM (Security 
Information Management and Security Event Management): 
a system that automates the process of collection and 
orchestration of system logs and which therefore makes it 
possible to monitor IT events and, in particular, those 
potentially dangerous from the point of view of 
Cybersecurity. 
In 2021, the Group also equipped itself with a SOC (Security 
Operations Centre) service. The SOC is the organizational 
unit that has the task of supervising and managing the 
security of information systems. This group monitors IT 
events 24 hours a day. It can report any suspicious event 
withing the company perimeter (for example, access to the 
system at night or not usual, access to prohibited areas, 
suspicious behaviour, anomalous events, etc.).
Finally, despite the significant investments, efforts and 
measures taken from a technical point of view, over 80% of 
the attacks are successful. A reason is due to human error: a 
a password that is easy to guess, an unreasonable click on a 
link, the use of an unverified USB key, access to a 
compromised website, the response to a fraudulent SMS. 
The above events can compromise the security of an 
establishment o of the entire Group. We introduced a 
persistent Cybersecurity Training campaign for all Group 
employees based on the KnowBE4 multimedia platform, 
collaborating with the HR and the Training department. 
Among the most relevant issues on which the Group gave 
the training, we highlight: 
• Security Awareness 
• Phishing Fundamentals 
• Creating Strong Password 
• Ransomware 
• Social Media “Stay secure in a connected world.” 
• European GDPR 
• Social Engineering 
• Credential Harvesting Attack 
The human factor remains one of the weakest areas in these 
scenarios and, therefore, one of the most formidable 
principles if well trained and informed. 
5.7 Training & Cybersecurity
Cyber 
attack
Suspicious event 
detection
Training and 
blocking threat
2.036
2.104
2.258
0
250
500
750
1.000
1.250
1.500
1.750
2.000
2.250
2.500
2019
2020
2021
NUM ERO T OT A LE DI DIPENDENT I
2.036
2.104
2.258
0
250
500
750
1.000
1.250
1.500
1.750
2.000
2.250
2.500
2019
2020
2021
T OT A L OF EM PLOYEES
839
529
552
338
0
100
200
300
400
500
600
700
800
900
I T A L Y
F R A N C E
S W I T Z E R L A N D
R O M A N I A
T OT A L EM PLOYEES 
BY G EOG RAPHICAL A REA
2021
27
2.049
28
154
P A R T - T I M E
F U L L -T I M E
T OT A L E M PLOYEES 
BY T YPE  OF E M PLOYM ENT
2021
Male
Female
1.651
390
35
27
152
3
B L U E  C O L L A R
M A N A G E R  A N D  W H I T E  C O L L A R
E X E C U T I V E
T OT A L EM PLOYEES BY CA T EGORY
2021
Male
Female
289
1.137
650
34
104
44
< 3 0
3 0 - 5 0
> 5 0
T OT A L E M PLOYEES BY A G E G ROUP 
2021
Male
Female
43
2.033
7
175
P E R M A N E N T
T E M P O R A R Y
T OT A L E M PLOYEES 
BY T YPE  OF CONT RA CT
2021
Male
Female

5.8 Welfare in AFV Beltrame Group
AFV Beltrame Group is a company historically susceptible 
to the well-being of its employees and the territory in 
which it operates, having belonged to the same family for 
generations and having employees who, in turn, have 
worked in the company for as many generations. In the 
past, the Group applied it for “spontaneous” welfare 
initiatives, whereby the property personally met the needs 
of the employees in an unstructured but extremely human 
and effective way. Since this is no longer possible, with a 
view to ever closer to the needs of employees, the 
company has decided to focus recent initiatives on two 
invaluable values: time and health. Trying to offer 
employees in the company services that they would 
otherwise have to go looking for externally saves people 
personal time (and travel, with costs and all that goes with 
it). More free time means being able to devote themselves 
to their interests and loved ones. 
The Group safeguards time and health by administering 
flu vaccines, usually in autumn, in all Italian offices. In 
association with availability supplied by the local health 
authorities, the Group administered vaccines free of 
charge to all those who wished to be vaccinated by a 
doctor available in the infirmaries. 
An initiative favouring health and prevention that has been 
greatly appreciated is also the one proposed as a 
nowtraditional gift to colleagues on the occasion of Women’s 
Day so that all female employees in Italy can take advantage 
of a free check-up in an affiliated laboratory. Additionally, we’d 
like to point out the effort made by the company to improve 
the canteen by offering balanced meals according to the 
guidelines of an expert nutritionist and dietician, making them 
healthier, and distributing free fruit in the offices and the 
factory in Vicenza. 
Other prevalent initiatives at the Vicenza office are ordering 
online and receiving organic shopping directly in the car park 
at the end of the work shift and a laundry service at 
discounted prices that collects items at our offices.
Employees of the parent company can also call a 
contracted mechanic who assists directly in the company 
parking lot, avoiding employees having to go to the 
workshop or call the tow truck in case of breakdowns in 
their car. 
In the immediate future, the Group will make a further 
effort toward flexible or remote working, which will 
exponentially increase the serenity and well-being of the 
employees who will use it. All these initiatives also bring a 
considerable advantage in terms of sustainability, 
reduction of social costs, and benefits for the 
environment. 
Welfare is in the DNA of AFV Beltrame Group. 
In the thirties, Cesira Beltrame, daughter of the founder 
Antonio, gave interest-free loans as an advance on salary 
and subsidies in particular cases of illness. The company 
had already equipped itself with a canteen service for 
workers. The benefits included an internal health 
insurance fund and accessible medical, pharmaceutical 
and hospital assistance. 
The after-work organization also organized marine and 
mountain trips and stays. Even then, people’s well-being 
was fundamental. 
Giancarlo Beltrame himself, at the helm of the company in 
the sixties, having at heart people and the territory, has 
always carried out initiatives to support them. Over time, 
these initiatives have strengthened a strong sense of 
belonging, well-being, and sharing of objectives within the 
company. Today AFV Beltrame Group has become a 
significant international Group. It includes multiple actors 
with different territorial and regulatory needs, but the training, 
welfare and empowerment solutions continue to consider all 
our workers to accompany, support and meet their needs. 
96
97
Equal gender opportunities
The company promotes personnel development based 
on totally merit-based criteria. There is no space for 
gender or other discrimination, neither in the selection 
phase nor during the internal path of workers. 
AFV Beltrame Group wants to create a work envi-
ronment where everyone, regardless of gender, can 
fully express their potential in the enhancement of its 
people. Diversity is a fact, but drawing value from it and 
promoting inclusion requires concrete actions. 
The company is committed to promoting a culture of 
merit and talent in all processes and actions. Our 
efforts are concrete to ensure that this merit finds the 
proper support. For example, offering equal career 
opportunities, parenting support, agreements that help 
employees with services that allow for a more excellent 
balance between work and private life, comparable 
training investments, and the fight against violence or 
harassment. 
With this specific goal in mind, on 25 November of 
each year, an awareness-raising event against violence 
against women is organized in all the Group’s plants.
5.9 Equal opportunities and respect for human rights
Human rights
Human rights are the essential prerogatives of human 
beings, the basis of freedoms and justice, and the 
foundation of just and peaceful societies. 
Respect for human rights is a universal value that must 
inspire the principles of conduct even if the state has not 
issued specific rules to protect them. 
AFV Beltrame Group has drawn up a specific policy on 
this issue to establish the principles of conduct to 
ensure respect, protection and promotion of human 
rights during company activities. 
This policy applies to AFV Acciaierie Beltrame SpA and 
all subsidiaries. 
The recipients are all individuals and interest-bearing 
groups who could suffer the positive or negative effects of 
our Group’s activities or who could exert some influence 
on them. These individuals are workers, directors, 
shareholders, customers, suppliers, financial partners, 
trade associations, trade unions, and public institutions. 
Our policy is in line with the international treaties and 
European regulations indicated below and applies their 
fundamental principles: 
External references: 
- Universal Declaration of Human Rights of the United 
Nations; 
- European Convention on Human Rights; 
- OECD guidelines for multinational companies; 
- Fundamental Convention of the International Labour 
Organization ILO (No. 29, No. 87, No. 98, No. 100, No. 105, 
No. 111, no. 138). 
Internal references: 
- Ethical code; 
- Organizational Model and related Protocols. 
AFV Beltrame Group respects and promotes human rights, 
committing itself not to violate them and not to carry out 
activities that could negatively impact them, counteracting 
this impact should it occur. 
Considering that activities detrimental to human rights can 
consist of both actions and omissions, the following 
human rights have been identified on which the Group’s 
activities may have an impact:
GENERAL RIGHTS OF HUMANITY:
1) Rights to life, freedom of thought and opinion; 2) Rights 
of community; 3) Right to privacy; 4) Right to safety 
and health of the Person and respect and protection of the 
Environment. 
SPECIFIC RIGHTS OF WORKERS
1) Forced or compulsory labour; 2) Freedom of 
association and the right to organize and collective 
bargaining; 3) Equal pay and discrimination in 
employment or profession; 4) Health, safety and respect 
for the Environment; 5) Child labour; 6) Right to leisure 
and rest.
Well-being
Vaccinations
Free Check-ups
Citizens of the world
Professional training
Energy efficiency
Intra-group synergies
Human Rights
Intra-group training
Recycling
During the reporting year, 
no episodes of discrimination 
were reported, and consequently, 
it was not necessary to 
take corrective measures.
2021 Sustainability Report

Youth policies
The National Institute of Applied Sciences (INSA) is a 
section of Hauts-de-France’s Polytechnic University (UPHF), 
present in the Valenciennes and Maubeuge offices. 
It arises from the merger of 3 UPHF components: 
- the Institute of Science and Technology of Valenciennes 
(ISTV); 
- the National School of Engineers in Computer Science, 
Automation, Mechanics, Energy and Electronics (ENSIAME); 
- the Faculty of Sports Sciences and Professions (FSMS). 
It is one of 204 French engineering schools accredited since 
September 2020 to issue an engineering degree. 
The school’s goal is to train engineers in the fields of 
modelling, numerical simulation and experimental validation 
of complex phenomena related to mechanics, energy, 
mechatronics and associated advanced materials. 
For engineering training, INSA Hauts-de-France offers three 
courses: the student course, the apprenticeship course and 
continuous training. 
In 2021 LME entered into a partnership with INSA. 
The purpose of this collaboration is to carry out various 
pedagogical training, professional training activities, 
support for students’ work projects and, at the same time, 
provide financial support to the Institute. 
LME offers future INSA engineers the opportunity to put 
themselves to the test in the field, working on essential 
projects and encouraging them to seek practical solutions 
to the problems that arise. 
The partnership with INSA also intends to be a vital selection 
and recruitment pool for LME for the most deserving 
students to offer a career path in the company. 
AFV Beltrame Group believes in apprenticeships as a 
training model and is committed to developing long-term 
planning for young interns in all its locations. 
The possibility of offering an internship or apprenticeship 
path is a strategic lever for all the Group companies. It 
represents a concrete opportunity for professional and 
personal enrichment for young people, overcoming the 
difficulties in accessing young people to the world of Work. 
It is a question of rediscovering that essential synergy 
between the education system and the world of professions 
to respond to the needs and expectations of the younger 
generations. 
The offer of an internship within AFV Beltrame Group has 
functional characteristics both of a training structure in a 
broad sense and of the implementation of a learning method 
aimed at enhancing design-managerial autonomy and the 
assumption of responsibility in the field. 
For example, in 2021, at the Trith Saint Léger site, we hired 
24 apprentices at the end of the contract, one of which in the 
design office and one in the safety department. The Group’s 
French plant expects to hire a further 27 apprentices by 
2022. Last year at the Swiss headquarters, at the end of an 
internship project that involved ten apprentices at the end 
the course, 3 of them were hired by the company. 
In addition, LME collaborates with AFPI (Centre de formation 
in the Nord Pas-de-Calais area) and has been present since 
last year at their career day.
98
99
The partnership with the National Institute of Applied Sciences (INSA) of Valenciennes.
Investing in resource talent: interns and apprenticeships
2021 Sustainability Report

5.10 Covid management
Since the onset of the pandemic, the Group has 
established measures to counter the spread of Co-
vid-19 by setting up a crisis committee. This com-
mittee aimed to create a standard set of guidelines 
aimed at ensuring the health of workers and business 
continuity, sharing actions and measures to be taken 
in different countries, analysing the various issues, 
and proposing solutions. 
In 2021, the Group shared guidelines and the already 
accepted safeguard measures across companies. 
Some of the policies adopted were suspending busi-
ness trips and transfers. We used audio/video confe-
rencing tools for business meetings. We didn’t allow 
external staff (customers/suppliers/consultants) to 
enter our premises. 
We asked all our employees who, for professional or 
personal reasons, have travelled to inform the compe-
tent human resources management immediately. The 
implementation of primary measures for the pre-
vention of contagion (such as washing your hands 
frequently, keeping a safe distance, staying at home if 
you have flu symptoms, etc.). 
We continued to distribute relevant information to all 
employees and external companies, activating preven-
tive measures to allow access to the plan by transpor-
ters. 
Working from home was used extensively, and we 
distributed personal protection devices profusely to 
staff. 
The procedures for accessing the canteen and chan-
ging rooms have also been changed to maintain a safe 
distance. Some of these measures (for example, the 
latter mentioned) have been progressively and further 
strengthened with the progression of the pandemic 
and the relative communication of virus spread data 
provided by certified government media. 
We continued to sanitise the most frequently used 
premises within the company throughout 2021, accor-
ding to the shifts indicated by individual Plant mana-
gers. 
Lastly, rapid swabs were available at each plant’s 
infirmary for any employees who requested them 
following contact with family members who were posi-
tive for covid-19.
2021 will be 
remembered as the year 
of viral virus variants 
responsible for a surge 
in illnesses across 
Europe and around the 
world. The greater 
transmissibility of the 
new variants has 
resulted in more 
significant number of 
infections in absolute 
terms, thus also 
determining an increase 
in the number of severe 
cases.
100
101
2021 Sustainability Report
227.265 lt
Litres of the disinfectant gel used in all 
AFV Beltrame Group locations in 2021
584.200
Masks distributed in all AFV Beltrame Group 
locations in 2021

5.11 The health and safety of employees.
A health facility with a nursing service is available in all main 
facilities in the Group. These facilities are qualified to provide 
immediate care and medications in a minor accident or illness.	
102
103
2021 Sustainability Report
Fatal injuries
0%
High-consequence injuries 
(excluding fatalities)
2%
Total recordable injuries
98%
EMPLOYEES INJURIES
18%
37%
9%
36%
MAIN TYPES OF INJURIY
Stumbles
Crushes
Cuts
Others
Activities relating to the protection of health and sa-
fety at work are among the main assets of the Group. 
Training interventions, worker information and 
training, plant and work environment evolution and 
constant improvement of the company’s Health 
and Safety Management system are fundamental 
to achieving its maximum optimization and com-
mitment. Activities on the protection of health and 
safety at work continued throughout 2021. 
All Group sites are equipped with a Health and Safety 
management system implemented and certified in 
compliance with the international reference stan-
dard. 
The application of systems in line with ISO 45001 
standards favoured analysis and organisation in the 
various operating contexts and the needs and 
expectations of the interested parties as “prepa-
ratory” requirements for the correct setting of the 
entire SGSS (health and safety management sy-
stem). The rule is clear in outlining the purpose of 
these new activities, whose essential objective is to 
understand the most critical issues of the context 
that can influence, positively or negatively (risks/op-
portunities), how the company faces its responsibi-
lities in terms of health and safety. For this purpose, 
the context analysis aims to provide the organisation 
with a set of knowledge that it must use, both at a 
strategic and operational level, to guide its efforts 
to implement and continuously improve the SGSS. 
Like the context, the points related to leadership and 
consultation and participation of workers are also 
vital aspects of ISO 45001, which are reflected in the 
participatory management for safety in place in the 
Group.
Accident phenomenon and occupational 
disease
As regards accidents, we note that the accident 
phenomenon in the Group has recorded a progressive 
improvement over the last few years. Still, in 2021 it went 
against the trend, with an increase in the frequency index 
(LTIFR), a parameter that includes all accidents resulting 
from an absence from the workplace for at least one day. 
In 2021, 97 injuries were recorded with consequent loss 
of working days (LTI) and 66 injuries that did not involve 
loss of working days (MI). The frequency index at the 
Group level, calculated on the basis of LTI injuries, is 
equal to 24.7.
The analysis of the causes of accidents (LTI) showed 
that the leading causes are attributable to: 
- unsafe behaviour or actions for 69% of cases; 
- technical causes or dangerous situations in 18% of 
cases; 
- organizational deficiencies in 13% of cases; 
The main types of accidents in 2021 are related to 
collisions and crushing (about 37%) and trips and slips 
(about 18% of cases), often in situations unrelated to 
process operations. 
All the events were also analysed and discussed with the 
injured person upon returning to work to identify the 
causes, implement remedial actions, and increase 
sensitivity to a safe approach to the various work pha-
ses. 
In 2021 there were no cases in which the Group 
definitively declared liability concerning occupational 
diseases or causes of mobbing.

Main interventions
104
105
The Group launched an action plan in 2021 to reduce the accident phenomenon, 
which has shown a growing trend in the last period, which the Group intends to coun-
ter. 
The plan was called SHARP, indicating a series of actions aimed at reducing injuries 
(Safety and Health Actions for injury Reduction Plan) and implying the need for drastic 
and immediate action. 
This action plan introduces or consolidates some golden rules aimed at a substantial 
reduction of accidents in the Group’s plants and aims to raise awareness and stren-
gthen awareness of safety at all levels. 
The steps put in place in 2021 were the following:
1. focus on safety or short training breaks at the beginning or during the work shift 
(socalled “safety pills”) by the shift managers, dealing with specific topics or contin-
gent issues related to the safe approach of Department;
2. safety meetings in the production departments, involving EHS with shift managers 
and department managers, for a periodic examination of the accidents that have oc-
curred and their causes, of near-misses, of reports received on dangerous situations 
or behaviours;
3. accurate and timely analysis of accidents and near-misses with the functions con-
cerned, identifying the root causes of the event using specific methodologies (RCA). 
Approach to each cause identified with radical and targeted action without neglecting 
any element that may have contributed to the event;
4. dissemination of press releases and information brochures on incidents or acciden-
ts, sharing causes and possible everyday actions between the Group’s sites (Serious 
Event Review);
5. planning of periodic interactive visits to the production departments by managers, 
with EHS representatives to make it clear that the priority on safety belongs to all 
hierarchical levels and organizational functions (Visible felt leadership); 
6. resuming and strengthening behavioural audits (SWAT), according to the Group’s 
standard, through an observational approach and the direct involvement of the opera-
tors;
7. evaluation and collecting the reports that arrive from the workers with plans for a 
resolution and feedback; 
8. dissemination of safety slogans by installing panels containing safety messages in 
the work areas;
9. periodic work procedures review concerning technical-organizational changes and 
correct application in the field;
10. definition of a medium-term training program on behavioural safety and aware-
ness according to international standards.
The common good is sustained 
foremost by protecting the individual. 
Respecting the needs of our people 
and communities corresponds to 
taking care of the territory. 
We are a company and society, 
but we are also an ecosystem.
2021 Sustainability Report

SPOSTARE GRAFICO 
NELLA PAGINA DOPO
106
107
Investments in health and safety
The primary investment projects for environmental 
management, health and safety in 2021 concerned: 
• Improvement of plant and machine tool safety (MASAI 
Project - Machine Safety Improvement); 
• Replacement of overhead cranes for semi-products and 
finished products; 
• Preparation of a new product storage area chemists in 
Gerlafingen; 
• Installation of new fire detection systems near hydraulic 
power units; 
• Installation of automated production support systems 
for risk reduction; 
• Subdivision and segregation of pedestrian paths near 
plants; 
• Optimization of safety devices for billet heating furnaces; 
• Improvement of radio communication devices; 
• Updating the operating machinery fleet; 
• Installation of new radioactivity measurement systems in 
Trith Saint Legér and San Giovanni Valdarno.
Una delle sfide del nostro 
tempo è la transizione 
verso un’economia capace 
di essere socialmente 
inclusiva e sostenibile per 
l’ambiente, amplificando le 
opportunità di benessere 
e crescita per tutti. È in 
corso una profonda presa 
di coscienza da parte delle 
aziende e delle persone 
in ottica di condivisione 
della conoscenza e 
collaborazione per un 
obiettivo comune guidato 
dal senso di responsabilità 
verso gli altri e il sistema 
sociale.
Safety first
EHS Roadmap of the Group
In 2021, the “EHS Roadmap for Excellence” program 
continued in all Group plants with the following 
main activities: 
• implementation of the Group standards on EHS, 
eleven standards defined, applied and monitored: 
1. H&S Reporting and Investigation and 
Environmental reporting (management of reports 
relating to accidents and accidents and information 
relating to monitoring environmental parameters); 
2. Mobile Equipment (mobile vehicles and risk of 
pedestrian/vehicle interference); Work at Height; 
3. Housekeeping and 5s implementation (order/
organization and cleaning in the workplace); 
4. Contractor Safety Management (safe 
management of contractors); 
5. EHS Audit - EHS Scorecard (audit between the 
various companies); 
6. Energy Isolation and LO.TO.TO. (Isolation of 
energy sources before maintenance operations); 
7. Liquid steel (risk management related to liquid 
steel and slag in all phases of handling and 
transport); SWAT program (behavioural audit); 
8. JSA - Job safety analysis for risk assessment of 
non-routine operations. 
9. Definition of a specific improvement plan for 
each site (EHS Road map); 
10. Monthly meetings of the EHS Committee in all 
companies; 
11. Monthly calls for coordination and sharing 
between the companies. 
The Group also launched a benchmarking program 
on the leading personal protective equipment (PPE) 
used, particularly regarding safety shoes, helmets, 
and protective goggles, to standardize and optimize 
the devices and reduce residual risks. of work 
activities.
The Group also analysed work clothing to 
standardize its technical characteristics and unify 
the supply and washing service of the garments. 
The conclusion of this path is expected by 2022.
EHS Cross Audits
Despite the restrictions on travel and interpersonal 
exchanges due to the pandemic emergency, we 
maintained a constant exchange of information and 
checks. The Group conducted comparisons between 
Group plants carried out on a virtual platform on the 
aspects of legislative compliance and operational 
management aimed at sharing best practices and 
identifying ideas for improvement. 
The Group organized remote meetings monthly with all 
the Group’s EHS managers, often in shared form between 
plants, for a continuous discussion on various aspects 
of the Health, Safety, and Environmental Management 
System regarding the state of the application and the 
implementation activities in progress in the Group’s 
plants: 
• EHS Management System 
• Occupational Health and Safety 
• Accident / Injury and Near-Miss Reporting 
• Pollution prevention and control 
• Suppliers, Contractors and Visitors 
• Working at heigh elevations 
• Internal logistics and circulation plan 
• Isolation of energy sources (LOTOTO) 
• Machine Safety 
• Order, cleanliness and organization of the workplace 
• Management of temporary workers 
• Lifting of loads (use of overhead cranes and lifting 
accessories) 
• Use of Forklifts 
• Emergency management 
• Safety of isolated workers 
• Confined spaces 
• Risks associated with the presence of liquid steel/incan-
descent slag 
• Legionnaires’ disease prevention 
• Health surveillance 
• Waste collection and separation.
2021 Sustainability Report

108
109
2021 Sustainability Report
Event investigation
The Group records and analyses both the events that 
led to an injury and the accidents without conse-
quences for the workers, using a methodology that 
makes it possible to identify the root cause analysis 
(RCA - root cause analysis). 
Identifying the causes of events, both direct and indi-
rect, is a fundamental tool for the definition and 
implementation of adequate improvement plans to 
prevent the recurrence of such events. 
Reports received from the departments are analysed 
and managed according to their priority, giving fee-
dback on the actions taken, and this is very impor-
tant to the Group.
SWAT (Safety Walk and Talk)
Interactive safety visits (SWAT) are based on obser-
ving unsafe acts and conditions and on the action 
required to correct them. 
The SWAT program allows us to reinforce key safety 
behaviours, promote the development of a 
preventive culture in our organization, and encourage 
all participants to aim for accident-free work. 
All the workers of the Group’s plants are involved in 
exchanging information also on EHS issues, updating 
results and programs, and disseminating a culture 
on EHS matters embedded into daily actions. EHS 
communication is implemented through various 
communication channels, such as monitors, bulletin 
boards, intranets, LinkedIn.
USE PPE
Personal 
protective 
equipment
PROCEDURES AND 
INSTRUCTIONS 
Respect proce-
dures and safety 
instructions
REPORTING
Near-miss, 
behaviours
and dangerous conditions
LOTOTO
(lockout/tagout/tryout)
Machine 
safety and
Pre-intervention 
systems
PROHIBITIONS
Smoking, alcohol 
and drugs, restri-
ction and correct 
use of the mobile 
phone
1
2
3
4
5
The 5 basic rules of safety
Awareness campaigns 
In addition, one has begun in the Group’s factories 
awareness campaign using images and signs displayed 
in areas with more significant traffic to the production 
departments. The messages were addressed to the 
inherent concepts: 
Five basic rules underlying the prevention program 
routine for all of our sites. 
These rules are:
1. Use of PPE (personal protective equipment); 
2. Respect procedures and safety instructions; 
3. Reporting of near misses, dangerous behaviours 
and conditions; 
4. Safety of machines and systems before 
maintenance, zero energy status (LOTOTO: lockout/
tagout/tryout);
5. Compliance with prohibitions (smoking ban, alcohol 
and drug regulations, restrictions and correct use of 
mobile phones);
6. Invitation to reflect before acting (STOP rule).
Safety leadership
AFV Beltrame Group proposes leadership for safety 
in their managers and supervisors who are called to 
implement concrete actions to improve the safety 
conditions of the persons under their responsibility. At 
each site, there is a committee to guide activities and 
programs in health and safety. A "Safety awareness" 
workshop was remotely organised to consolidate our 
approach to security in December 2021, which involved 
all Group functions and local contacts, in which guideli-
nes and actions were discussed and shared to increase 
awareness and culture of safety.

Connection with 
territory
6

6.1 Territory and Community
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2021 Sustainability Report
AFV Beltrame Group has always acknowledged the 
fundamental principle that business activities cannot 
disregard interaction with its territory and communities. 
It has always played a closely linked role in social, 
educational, and cultural aspects. This approach has led 
to the construction of a stakeholder network in all the 
Group’s countries. A careful dialogue and exchange of 
opinions take place to achieve the objectives.
Support for local sport
The Group favours and sponsors some sports 
associations, from runners to cyclists, which help team 
building, sharing, and well-being. 
In Italy, the company sponsors two amateur clubs: A.S.D. 
AFV Beltrame runners and the AFV Acciaierie Beltrame 
1986 Cycling Society. 
Despite COVID 19, our "Blacks” runners did not spare 
participating in most of the organised races held in 
compliance with regulations mandated for such an 
exceptional period. Therefore, we only report the main 
events below. 
In March 2021, in Brugnera, in the province of Pordenone, 
the Brugnera and Alto Livenza Marathon took place. Four 
“Blacks” athletes repeated the 7-kilometre circuit three 
times, and three runners reached the podium. 
The "Ultrabericus" followed in May. 
In mid-June, our team participated in the traditional “Ju-
liet and Romeo Half Marathon” in Verona, where A.S.D. 
AFV Beltrame won a category podium. Also, in June, the 
“Blacks” attended the 10 km Strabacino, a competitive 
event for charity held in Villaverla (VI). 
At the beginning of July, the team was in Fara di Primiero 
for the "First Dolomites Marathon" and at the "Corsa del 
Trenino": about twenty kilometres of ups and downs that 
start in Asiago in a suggestive alpine setting that put 
even the most experienced runners to the test. Also, 
on this occasion, A.S.D. AFV Beltrame won a category 
podium. 
There was no shortage of “Blacks” in September at the 
"Venice Night Trail", a night race through the streets of 
Venice. And again, on the 24th of September, the team 
split up for two simultaneous races: "La Mezza del Bren-
ta" in Bassano and the "Padova 10 km" race. The "Trenta 
Trentina" saw a category podium at the end of the 
summer. 
In autumn, the "StrArzignano 10 km," the "Mezza di 
Treviso", the "Venice Marathon", and finally the "Mezza 
dei 6 comuni,” a half marathon through six municipalities 
on the Asiago mountain plane ended up with two 
category podiums. 
In a Christmas atmosphere, the "Maratonina Città 
Murata" took place in Cittadella (PD) which always 
attracts numerous participants, not only from Veneto. 
Among the “Blacks”, there has been a shower of 
"Personal Best" and a category podium. 
Running
Cycling
 Baseball
Football
Basketball
But our athletes also have participated in some races 
beyond national borders: "The Valencia Marathon", "The 
Lisbon" half-marathon, and the “Nice” Marathon. 
In 202, the "Run Project" was also noteworthy. This event 
was a format supported by AFV Beltrame Group and 
dedicated to running enthusiasts and the new generation 
of runners, with a complete program of structured sports 
activities, group training and training evenings. 
The foreign countries of the Group also have sports at 
heart. They are committed to financing sports clubs or 
promoting local city teams in which employees 
compete. 
This year in France, for example, Laminés Marchands 
Européens also supported the baseball team of 
Valenciennes, called “Les Vipères” founded in 1989 and 
the handball club “Red Swans”. These are local sports 
clubs which can support themselves, hire athletes, get 
promoted, attract new athletes, and promote sports 
thanks to the financial donations they’ve received. In 
Switzerland, Stahl Gerlafingen AG supports the local 
football team, while the Romanian Donalam Srl supports 
the mini basketball Clubul Sportiv "Temerarii" Calarasi.

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2021 Sustainability Report
Meyer Paediatric Foundation:
The Meyer Paediatric Hospital Foundation was 
born as support for communication, marketing and 
fund-raising activities for Meyer, the Children's 
Hospital located in Florence, and is a reference 
point for national paediatrics for research, 
methodologies, innovative care and childcare. The 
Florentine hospital represents health excellence. 
The foundation supports it with high "added value" 
actions that qualify it more from a technicalscienti-
fic point of view and make it increasingly 
appreciated and dear to public opinion. There are 
many hospitality projects aimed at children that 
allow them to play in a comfortable environment 
full of colours and curiosities, experience the many 
activities of the educational workshops in the 
playroom, listen to music with parents, and share 
the playfulness of clowns and experience "pet 
therapy."
Città della Speranza Foundation:
The Città della Speranza Foundation was founded 
in 1994 thanks to the commitment of Franco 
Masello, a man with a vision and a dedication such 
as to move, involve and unite citizens and 
institutions to improve the conditions of young 
Oncoematological patients concretely.
Over time, many people joined his solidarity 
project, making Città della Speranza grow and 
achieve incredible results. 
Città della Speranza Foundation is now a national 
and European reference point for pediatric 
funding research, the formulation of early 
diagnoses, the identification of therapies and 
innovative care for children. It welcomes the 
support of a dense network of volunteers whose 
support has helped save many lives over the 
years
Veneto Eye Bank Foundation:
The Banca degli Occhi del Veneto Onlus 
Foundation has been working for 30 years to 
restore the joy of seeing through transplanta-
tion, research, and cures for eye diseases. 
It was born from the idea of professor Giovanni 
Rama - ophthalmologist surgeon - and the 
entrepreneur/Knight of Labour Dr Piergiorgio 
Coin, founded by the Veneto Region and started 
operating in 1989. It is a non-profit organization 
and a non-profit organization of social utility 
(ONLUS), and now a regional reference centre 
for corneal transplants in Veneto and Friuli 
Venezia Giulia cooperates to collect ocular 
tissues for transplantation with the Autono-
mous Provinces of Trento and Bolzano. 
First Bank in Europe for the number of corneas 
collected and distributed, thanks to the great 
sensitivity of many families and the tireless 
work of many operators, every year assembles 
over 4000 eye tissues for transplantation and 
works to promote the culture of corneas dona-
tion, collection, processing and distribution of 
corneal tissues for transplants and the treat-
ment of pathologies of the anterior segment of 
the eye. It is also constantly engaged in resear-
ch to improve transplantation techniques and 
the treatment of other eye diseases. It is among 
the first centres in the world capable of distri-
buting flaps of corneal stem cells reconstructed 
in vitro for the treatment of incurable eye disea-
ses that with cornea transplant alone.
It is also constantly engaged in research to 
improve transplantation techniques and the 
treatment of other eye diseases. It is among 
the first centres globally capable of distributing 
flaps of corneal stem cells reconstructed in vi-
tro to treat incurable eye diseases with corneal 
transplants alone. 
The Foundation is the first Italian bank regi-
stered in the list of Tissue Banks certified by 
the National Transplant Centre that operates 
following the "Guidelines for the collection, 
processing and distribution of tissues for tran-
splantation". From 2002 to 2008, it was the only 
European member accredited by the Associa-
tion of American EyeBanks. In 2005, he received 
the Gold Medal of Merit for Public Health.
In 2021, AFV Beltrame Group continued its charitable 
endeavours, financing generous projects in favour of local 
non-profit organizations and associations with the aim of 
social solidarity, especially in the cultural and health 
sectors, in favour of children. 
Last year, the company supported: 
ASD Delfini 2001:
The company is not for profit and exclusively pursues the 
goal of enhancing and assisting disabled people, who, 
through sport and integration with non-disabled people 
working within the organization, receive adequate 
psychophysical support. The company carries out 
educational and rehabilitative activities for children and 
young people who have motor, psychic and psychic 
problems caused by congenital or acquired disabilities 
and proposes competitive and recreational sports 
activities, purely for amateur intents, through the 
participation and promotion of tournaments, events, 
competitions, wheelchair basketball competitions and 
other sports for the disabled, in particular, those provided 
for by the Italian Paralympic Committee, in the province of 
Vicenza in the Veneto region, in Italy and abroad, covering 
all age groups (children, teenagers, young people, adults, 
seniors). 
Vicenza for Children:
The association was born from the united forces of many 
families and many volunteers who offer time, 
commitment, enthusiasm and experience to stand 
alongside sick children and support their families. The 
activity mainly concerns the San Bortolo Hospital in 
Vicenza and the San Bassiano Hospital in Bassano del 
Grappa. Vicenza for Children is a voluntary association 
that collaborates with the General Management of UlSS 8 
Berica and operates in the Paediatric ward, the 
Oncoematological Day Hospital and the Tin (Neonatal 
Intensive Care). In synergy with health personnel, the 
association offers children, and their families support, 
mainly emotional and affective. It also supports families 
in difficulty, even economically, and helps to guarantee 
children an additional service through greater comfort 
given by the purchase of specific medicines and electro-
medical instruments for the Vicentine hospitals of 
reference. In addition, as part of projects agreed with 
hospitals, it strives to carry out renovations of hospital 
spaces to make the environments more functional and 
welcoming, continually improving services for children.
6.2 Donations in favour of the territory
To support the communities 
in which it operates, 
AFV Beltrame Group supports 
projects that promote shared 
value to create a place where 
the interests of individual 
actors are positioned and 
intertwined.

Art4sport Association: 
Art4sport is an association that helps children and 
young people with prostheses to achieve their sporting 
dream. 
The members of the art4sport team are children with 
disabilities and limb prostheses who have asked their 
parents to be able to join the association's projects to 
start a sports journey or to resume practising the sport 
they did before their disability. 
It does not matter which sport they choose or the 
"competitive" level they reach, the important thing is 
that they can have fun again with other kids and if 
sporting successes also arrive ... so much the better! 
Sport is essential for children and young people with 
prostheses. It gives them great motivation and 
satisfaction, is extremely aggregating, keeps the body 
fit and allows them to acquire greater awareness of 
their body. These children often need sports prosthe-
ses and much specific equipment and aids (wheel-
chairs, lifts, overalls, etc.) to practice sports. 
But prostheses and sports equipment are costly aids 
and are not subsidized by the National Health System. 
They must be studied and designed from time to time 
according to the type of amputation of each child and 
the sport he wishes to practice. 
If we also consider the need to change them or replace 
them often to follow the child's natural growth, the high 
cost that families have to face is evident, which is 
therefore covered thanks to funds from art4sport. 
Another problem is the lack of adequate local sports 
facilities and the difficulties for individual sports clubs 
in procuring the equipment suitable for a disabled per-
son to practice sports. 
For this reason, the Association follows projects 
dedicated to the adaptation of sports facilities where 
necessary. 
Piemontese Foundation for Cancer Research:
The Foundation was established to contribute significantly 
to the defeat of cancer by creating an oncology centre in 
Piedmont that knows how to combine scientific research 
with clinical practice and makes the best human and 
technological resources available today available to 
cancer patients. 
Today this centre exists and operates: it is the Candiolo 
Institute. To fulfil its mission, the Foundation undertakes 
to complete the construction of the same and equip it with 
the best technologies available.
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2021 Sustainability Report
116
It also directly manages oncology research activities 
and promotes related study projects, which, in 
connection with the activities carried out in the 
national and international field, lead to an expansion of 
the scientific community's knowledge and the 
improvement of the quality of life of those affected. 
The Foundation is responsible for finding the 
economic resources necessary to realise its goals 
directly through structured fundraising activities and 
organises all the required initiatives and events to 
achieve this goal.
Società del Quartetto:
The Quartetto Company di Vicenza is a non-profit 
association that has organized and promoted seasons 
of concerts, festivals, and individual concerts for over 
a century. It is also committed to spreading the 
knowledge of music in kindergartens and primary 
schools. AFV Beltrame Group supports the 
"Encounters on the Fifth Floor" project promoted by 
the Association in collaboration with the S. Bortolo 
Hospital in Vicenza. 
The "Encounters on the fifth floor" are very informal 
live performances. The music is brought to an 
extraordinary place on tiptoe, the Oncology ward, 
offering patients, their families, and medical and 
paramedical staff moments of serenity and hope 
through musical notes.
University of Padua Engineering 
Department:
Donation of a metallographic optical microscope 
for didactic purposes.
Social solidarity is also active in the Group's forei-
gn offices. 
In October 2021, a month usually dedicated to dise-
ase prevention affecting women, the French branch 
of AFV Beltrame Group supported the "Ruban 
Rose" association, responsible for funding resear-
ch and raising awareness of the early diagnosis of 
breast cancer.
CSR can be intertwined at 
every company level and 
aspect. First of all, it is a 
value we include in 
our corporate culture. 
Secondly, we render each 
commitment a reality to 
communities and the 
territory through projects 
and initiatives aimed at 
mutual growth and 
development.
In addition, to combat discrimination and help 
young people integrate into professional life, LME 
has partnered with the APEI - an association that 
welcomes adults with intellectual disabilities or 
who suffer from an alteration of adaptive beha-
viour through practical and enriching actions. 
The company offers these people the possibility of 
job placement and the tools to do so. The people 
hired feel gratified and valuable in carrying out a 
job in line with their skills. 
The Romanian branch of the Group supported the 
local Red Cross project as part of the "Good 
Deeds Auction" event. It aims to reduce school 
dropouts and provide a hot meal to poor children 
in the Valea Jiului area, where the badger unem-
ployment and dropout rates are highest in South-E-
astern Europe. "The Good Deeds Auction" was the 
first event in Romania dedicated to the charity 
that brought together six charitable foundations 
to improve the social, educational and, last but 
not least, emotional situation of a large number of 
marginalized children and young people. 
Other social solidarity activities of Donalam in 
Romania involved the donation of medical equip-
ment and supplies to the Calarasi hospital, spon-
sorship to equip laboratories in local high schools, 
and technical tools for the University. 
And yet again, the sponsorship of the exhibition: 
"Italian Excellences", an international collection of 
illustrations for children and the donation to the 
Inspectorate for Emergency Situations "Barbu 
Ştirbei" of Calarasi to which the Group donated 
high-quality personal protective equipment and 
performance and accident prevention material 
necessary to carry out the interventions of the fire 
brigade.

Sustainability
performance
7

Boundary of material issues
The following table shows the Group’s issues defined as material for the Group. The “Where the impacts occurred” 
column shows the subject that can generate an impact for each problem, both internally and externally to the Group. 
In addition, the “Type of impact” column indicates the role of the Group concerning the impact generated for each 
material issue, i.e. whether the organization directly causes the effect, contributes to its generation or is directly 
connected to the result through a business relationship.
Where they have occured
Type
Environmental impact of production/product
301 - Materials
303 - Water and Effluents (2018)                                  
305 - Emissions
306 - Waste (2020)
307 - Environmental Compliance
AFV Beltrame Group
Created by AFV 
Beltrame Group
Energetic efficency
302 - Energy
 AFV Beltrame Group, Suppliers 
of products, services and energy 
carriers
Created by AFV 
Beltrame Group
Health, safety and welfare
401 - Employment
403 - Occupational Health and Safety (2018)            
405 - Diversity and Equal Opportunity
AFV Beltrame Group
Created by AFV 
Beltrame Group
Economic performance and value creation
201 - Economic performance
AFV Beltrame Group
Created by AFV 
Beltrame Group
 Product quality and safety and customer service
Na
AFV Beltrame Group, Clients
Created by AFV 
Beltrame Group
Circular economy
Na
AFV Beltrame Group
Created by AFV 
Beltrame Group
 Training and development of human resources
404 - Training and Education
AFV Beltrame Group
Created by AFV 
Beltrame Group
Ethical and transparent management
205 - Anti-corruption
206 - Anti-competitive Behavior                                    
307 - Environmental Compliance
419 - Socioeconomic Compliance
AFV Beltrame Group
Created by AFV 
Beltrame Group
Procurement/Supply Chain
308 - Supplier environmental assessment
AFV Beltrame Group, Supply 
chain
Created by AFV 
Beltrame Group
Digital and technological innovation
Na
AFV Beltrame Group
Created by AFV 
Beltrame Group
Human rights of workers
402 - Labor/management relations                              
406 - Non-discrimination
407 -Freedom of association and collective 
barganing 
412 - Human rights assessment
AFV Beltrame Group
Created by AFV 
Beltrame Group
Where they have occured
Type
Employment support
401 - Employment 
AFV Beltrame Group
Created by AFV 
Beltrame Group
Territory preservation
307 - Environmental Compliance
AFV Beltrame Group
Created by AFV 
Beltrame Group
Engagement with the local communities
413 - Local communities
AFV Beltrame Group
Created by AFV 
Beltrame Group
Inclusive, cultural and economic development
201 - Economic Performance
AFV Beltrame Group
Created by AFV 
Beltrame Group
Material themes identified by AFV Beltrame 
Group
GRI Standard Topic
Perimeter of impacts
Non material themes but still dealt with by AFV 
Beltrame Group
GRI Standard Topic
Perimeter of impacts
The following are the critical indicators considered essential 
for the assessment of sustainability performance. 
All reported data refer to the Beltrame Group boundaries, 
including the companies AFV Acciaierie Beltrame Spa (site 
in Vicenza, San Didero and San Giovanni Valdarno), Laminés 
Marchands Européens SA, Donalam Srl and Stahl Gerlafin-
gen AG. 
The Group developed seventy-three indicators for the three 
years from 2019 to 2021. 
In particular, we selected the following: 
- 4 economic sustainability indicators; 
- 40 environmental sustainability indicators; 
- 29 social sustainability indicators. 
These indicators are extracted from the many data sets 
collected and analysed for business management. The 
collected data are periodically updated, reviewed and reexa-
mined in the context of the specific meetings held at the 
different sites of the Beltrame Group. 
Concerning the Group’s financial performance, please refer 
to the Consolidated Financial Statements available on the 
website: www.gruppobeltrame.com. 
7.1 Sustainability performance 
ECONOMIC SUSTAINABILITY:
Ensuring economic efficiency and income for the 
enterprise
SOCIAL SUSTAINABILITY:
Ensuring quality of life, safety and services for 
citizens
ENVIRONMENTAL SUSTAINABILITY
Ensuring natural resource availability 
and quality
GRI 300
N. KPI
References
301‐1
1
Materials used 
302‐1
5
Energy consumption
303‐1
3
Water management
303‐2
1
Management of impacts related to water discharge
303‐3
2
Water withdrawal
305‐1
5
Direct emissions of GHG
305‐2
6
Indirect GHG emissions
305‐7
2
Significant Emissions
306‐1
1
Waste management
306‐2
2
Waste-related impacts
306‐3
2
Waste generated
306‐4
4
Recovered diverted from disposal
306‐5
4
Waste directed to disposal 
307‐1
1
Non-compliance with environmental laws
308‐1
1
Supplier evaluation
N. indicators
40
120
121
2021 Sustainability Report
GRI 400
N. KPI
References
401‐1
2
Hiring and turnover
401‐2
1
Benefits
402‐1
1
Minimum notice periods
403‐1
2
Occupational health and safety management 
system
403‐2
4
Hazards, risk assessment, and incident investigation
403‐3
1
Occupational health services
403‐4
2
Participation consultation 
403‐5
1
Training on occupational health and safety
403‐6
2
Promotion of worker health
403‐7
1
Prevention of occupational health
403‐9
4
Work-related injuries
404‐1
1
Training
405‐1
2
Diversity
406‐1
1
Non-Discrimination
407‐1
1
Freedom of association
412‐1
1
Human rights
413‐1
1
Local communities
419‐1
1
Non-compliance with laws and regulations
N. indicators
29
GRI 200
N. KPI
References
201‐1
1
Economic Value 
205‐3
2
Risks of corruption incidents
206‐1
1
Anti-competitive behavior
N. indicators
4

122
123
The activities described in the previous chapters frame in detail the involvement of the Group in the development of con-
crete actions in favor of sustainability and show the pursuit of a continuous improvement in performance in ESG issues.
To this end, a path has been undertaken that will lead in 2022 to the consolidation of the indicators representative of su-
stainable management, integrated into the traditional company performance parameters and which will allow the relative 
targets to be defined. The sustainability improvement objectives have been divided into five pillars, subject to a trend as-
sessment starting from the year 2020, to which the related indicators and future objectives are associated. The areas of 
interest and related indicators are as follows:
Scope 
Indicator
Reducing energy consumption of steel mills
kWh / ton semi-product (billets)
Reducing energy consumption of rolling mills
kWh / ton finished product
Reduction in natural gas consumption of steel mills
Sm3 / ton semi-product (billets)
Reduction in natural gas consumption of rolling mills
Sm3 / ton finished product
Increase in the share of renewable energy used
RES percentage of energy supply
Reduction of Scope 1 carbon dioxide emissions from steel mills Ton CO2 / ton semi-product (billets)
Reduction of carbon dioxide emissions from Scope 1 rolling 
mills
Ton CO2 / ton finished product
Reduction of Scope 2 carbon dioxide emissions from steel mills Ton CO2 / ton semi-product (billets)
Reduction of Scope 2 carbon dioxide emissions from rolling 
mills
Ton CO2 / ton finished product
Optimisation of water use processes and reduction in water 
consumption
m3 H2O / ton finished product
Valorisation and recovery of waste produced
Percentage of waste delivered for recovery operations (including 
internal recycling)
Injury frequency index with lost days (LTIFR)
Injury and medication frequency index (TIFR)
Reduction in accident rates
Each Group site is committed to identifying the actions to be implemented to pursue the strategic objectives that will be 
defined by the Steering Committee and approved by the Board of Directors within the first half of 2022.
In order to optimize the operational activities that will be proposed in the improvement project, an organization has been 
defined in which the Sustainability function will be supported by a structure that will coordinate the Group’s decarbonization 
plan, which is currently being developed. 
Improvement goals
2021 Sustainability Report

124
125
7.2  GRI content index
GRI standard
Disclosure
KPI description
Document section
Page
102-45
Entities included in the consolidated 
financial statements
102-46
Defining report content and topic 
Boundaries
102-47
List of material topics
Materiality analysis
Sustainability performance
30-31
121
102-48
Restatements of information
102-49
Changes in reporting
102-50
Reporting period
102-51
Date of most recent report
102-52
Reporting cycle
102-53
Contact point for questions regarding the 
report
102-54
Claims of reporting in accordance with the 
GRI Standards
102-55
GRI content index
GRI Content Index
124-130
102-56
External assurance
Report by a third-party assurance
140-142
GRI standard
Disclosure
KPI description
Document section
Page
103-1
Explanation of the material topic and its 
Boundary
Materiality analysis
Sustainability performance
30-31
121
103-2
The management approach and its 
components
103-3
Evaluation of the management approach
GRI 201:
Economic
performance
201-1
Direct economic value generated and 
distributed
Creation of value for Stakeholder
Sustainability performance
20-21
131
103-1
Explanation of the material topic and its 
Boundary
Materiality analysis
Sustainability performance
30-31
121
103-2
The management approach and its 
components
103-3
Evaluation of the management approach
GRI 205:
Anti-corruption
205-3
Confirmed incidents of corruption and 
actions taken
Anticorruption Policy
24
103-1
Explanation of the material topic and its 
Boundary
Materiality analysis
Sustainability performance
30-31
121
103-2
The management approach and its 
components
103-3
Evaluation of the management approach
GRI 206:
Anti-competitive
behavior
206-1
Legal actions for anti-competitive behavior, 
anti-trust and monopoly practices
Anticorruption Policy
24
10-11
Creation of value for Stakeholder
20-21
GRI 103:
Management
approach
Economic performance
GRI 103:
Management
approach
Anti-corruption
GRI 103:
Management
approach
Anti-competitive behavior
Anticorruption Policy
24-25
Anticorruption Policy
24-25
Reporting practice
GRI 200: Economic
Methodological note
Methodological note
10-11
GRI 102:
Generale
disclosure
The table shows the indicators selected for this sustainability report and the correspondence with what is reported by the Global 
Reporting Initiative (GRI) where relevant. 
The contents of this document have been prepared in accordance with the Global Reporting Initiative’s (GRI) Sustainability 
Reporting Standards of 2016, with the exception of the specific Standards: GRI 303 (Water and effluents) and GRI 403 (Occupa-
tional Health & Safety) published in 2018; GRI 306 (Waste) published in 2020.
The Report was prepared in accordance with the GRI Standards: according to the “in accordance - Core” option
GRI standard
Disclosure
KPI description
Document section
Page
102-1
Name of the Organization
Methodological note
10
102-2
Activities, brands, products and services
History and Evolution
14-15
102-3
Location of headquarters
102-4
Location of operations
102-5
Ownership and legal form
Methodological note
10
102-6
Markets served
AFV Beltrame Group structure
19
102-7
Scale of the Organization
Creation of value for Stakeholder
Sustainability performance
20-21
132
102-8
Information on employees and other 
workers
Sustainability performance
132
102-9
Supply chain
Sustainable supply chain management 
and procurement policy
42-43
102-10
Significant changes to the organization and 
its supply chain
AFV Beltrame Group structure
19
102-11
Precautionary Principle or approach
Ethics, business integrity and 
compliance
Anticorruption Policy
22-23
24-25
102-12
External initiatives
UN Sustainable Developement Goals
Equal opportunities and respect for 
human rights
32-33
97
102-13
Membership of associations
Creating stakeholder engagement
36-39
102-14
Statement from senior
decision-maker
Letter to our Stakeholder
6-7
102-16
Values, principles, standards
and norms of behavior
Mission, Vision and Value
Ethics, business integrity and 
compliance
16-17
22-23
102-18
Governance structure
Corporate Bodies
18
102-40
List of stakeholder groups
Identification and dialogue with 
stakeholders
34-35
102-41
Collective bargaining agreements
Sustainability performance
132
102-42
Identifying and selecting stakeholders
102-43
Identifying and dialogue with stakeholders
102-44
Key topics and concerns raised
General disclosure
Organizational profile
Startegy
Ethics and integrity
Governance
Stakeholder engagement
Identification and dialogue with 
stakeholders
34-39
GRI 102:
Generale
disclosure
Methodological note
AFV Beltrame Group structure
10                  
19
2021 Sustainability Report

126
127
GRI standard
Disclosure
KPI description
Document section
Page
103-1
Explanation of the material topic and its 
Boundary
Materiality analysis
Sustainability performance
30-31
121
103-2
The management approach and its 
components
103-3
Evaluation of the management approach
GRI 301:
Materials
301-1
Materials used by weight or volume
Sustainability performance
136
103-1
Explanation of the material topic and its 
Boundary
Materiality analysis
Sustainability performance
30-31
121
103-2
The management approach and its 
components
Energy consumption
Air emissions management
Policies and QHSE Management 
System
58-59 
60
54-55
103-3
Evaluation of the management approach
Energy consumption
Air emissions management
58-59 
60
GRI 302:
Energy
302-1
Energy consumption within the organization Sustainability performance
136
103-1
Explanation of the material topic and its 
Boundary
Materiality analysis
Sustainability performance
30-31
121
103-2
The management approach and its 
components
103-3
Evaluation of the management approach
303-1
Interactions with water as a shared resource
303-2
Management of water discharge-related 
impacts
303-3
Water withdrawal
Sustainability performance
137
103-1
Explanation of the material topic and its 
Boundary
Materiality analysis
Sustainability performance
30-31
121
103-2
The management approach and its 
components
103-3
Evaluation of the management approach
305-1
Direct (Scope 1) GHG emissions
305-2
Energy indirect (Scope 2) GHG emissions
305-7
Nitrogen oxides (NOX), sulfur oxides (SOX), 
and other significant air emissions
Sustainability performance
137
Beltrame's commitment to responsible 
environmental management
Raw and auxiliary materials and waste
54-55
70-71
GRI 303:
Water and Effluents
GRI 103:
Management
approach
Materials
GRI 103:
Management
approach
Energy
GRI 103:
Management
approach
GRI 300: Environmental
Water and Effluents
Emissions
GRI 103:
Management
approach
Water resource management
68-69
Greenhouse gas management 
Sustainability performance
63-67
137
GRI 305:
Emissions
Air emissions management
Greenhouse gas management
60
62
Water resource management
Policies and QHSE Management 
System
68-69
  
54-55
GRI standard
Disclosure
KPI description
Document section
Page
103-1
Explanation of the material topic and its 
Boundary
Materiality analysis
Sustainability performance
30-31
121
103-2
The management approach and its 
components
103-3
Evaluation of the management approach
306-1
Waste generation and significant waste-
related impacts
306-2
Management of significant waste-related 
impacts
306-3
Waste generated
306-4
Waste diverted from disposal
306-5
Waste directed to disposal
103-1
Explanation of the material topic and its 
Boundary
Materiality analysis
Sustainability performance
30-31
121
103-2
The management approach and its 
components
103-3
Evaluation of the management approach
GRI 307:
Environmental 
Compliance
307-1
Non-compliance with environmental laws 
and regulations
Beltrame’s Commitment to 
Responsible Environmental 
Management
54-55
103-1
Explanation of the material topic and its 
Boundary
Materiality analysis
Sustainability performance
30-31
 121
103-2
The management approach and its 
components
103-3
Evaluation of the management approach
GRI 308:
Supplier Environmental
Assessment
308-1
New suppliers that were screened using 
environmental criteria
Sustainable supply chain management 
and procurement policy
42-43
GRI 103:
Management
approach
Environmental Compliance
Raw and auxiliary materials and waste
70-71
138
GRI 306:
Waste
Waste
Sustainability performance
GRI 103:
Management
approach
Supplier Environmental Assessment
GRI 103:
Management
approach
Sustainable supply chain management 
and procurement policy
42-43
Beltrame’s Commitment to 
Responsible Environmental 
Management
54-55
2021 Sustainability Report

128
129
GRI standard
Disclosure
KPI description
Document section
Page
103-1
Explanation of the material topic and its 
Boundary
Materiality analysis
Sustainability performance
30-31
121
103-2
The management approach and its 
components
103-3
Evaluation of the management approach
401-1
New employee hires and employee turnover Sustainability performance
132
401-2
Benefits provided to full-time employees 
that are not provided to temporary or part-
time employees
The trend in employment levels
86
103-1
Explanation of the material topic and its 
Boundary
Materiality analysis
Sustainability performance
31
121
103-2
The management approach and its 
components
103-3
Evaluation of the management approach
GRI 402:
Labor/Management
Relations
402-1
Minimum notice periods regarding 
operational changes
Industrial relations
90
103-1
Explanation of the material topic and its 
Boundary
Materiality analysis
Sustainability performance
30-31
121
103-2
The management approach and its 
components
The health and safety of employees
102-107
103-3
Evaluation of the management approach
Safety first
106-109
403-1
Occupational health and safety 
management system
Policies and QHSE Management 
System
54-55
403-2
Hazard identification, risk assessment, and 
incident investigation
403-3
Occupational health services
403-4
Worker participation, consultation, and 
communication on occupational health and 
safety
403-5
Worker training on occupational health and 
safety
The Academy for training
88-89
403-6
Promotion of worker health
The health and safety of employees
102-109
403-7
Prevention and mitigation of occupational 
health and safety impacts directly linked by 
business relationships
Safety first
106-109
403-9
Work-related injuries
Sustainability performance
133
103-1
Explanation of the material topic and its 
Boundary
Materiality analysis
Sustainability performance
30-31
121
103-2
The management approach and its 
components
103-3
Evaluation of the management approach
GRI 404:
Training
and Education
404-1
Average hours of training per year per 
employee
Sustainability performance
134
GRI 103:
Management
approach
GRI 403:
Occupational Health
and Safety
Attention to human capital
84-85
The health and safety of employees
102-109
Employment
GRI 103:
Management
approach
GRI 400: Social
Attention to human capital
84-85
GRI 401:
Employment
88-89
95
Occupational Health and Safety
GRI 103:
Management
approach
Training and Education
GRI 103:
Management
approach
The Academy for training
Training & Cybersecurity
GRI standard
Disclosure
KPI description
Document section
Page
103-1
Explanation of the material topic and its 
Boundary
Materiality analysis
Sustainability performance
30-31
121
103-2
The management approach and its 
components
103-3
Evaluation of the management approach
GRI 405:
Diversity and Equal
Opportunity 
405-1
Diversity of governance bodies and 
employees
Corporate Bodies
Sustainability performance
18
134
103-1
Explanation of the material topic and its 
Boundary
Materiality analysis
Sustainability performance
30-31
 121
103-2
The management approach and its 
components
103-3
Evaluation of the management approach
GRI 406:
Non-discrimination
406-1
Incidents of discrimination and corrective 
actions taken
Equal opportunities and respect for 
human rights
97
103-1
Explanation of the material topic and its 
Boundary
Materiality analysis
Sustainability performance
30-31
121
103-2
The management approach and its 
components
103-3
Evaluation of the management approach
GRI 407:
Freedom of
Association and
Collective Bargaining
407-1
Operations and suppliers in which the right 
to freedom of association and collective 
bargaining may be at risk
Industrial relations
90
103-1
Explanation of the material topic and its 
Boundary
Materiality analysis
Sustainability performance
30-31
121
103-2
The management approach and its 
components
103-3
Evaluation of the management approach
GRI 412:
Human Rights
Assessment
412-1
Operations that have been subject to human 
rights reviews or impact assessments
Equal opportunities and respect for 
human rights
97
103-1
Explanation of the material topic and its 
Boundary
Materiality analysis
Sustainability performance
30-31
121
103-2
The management approach and its 
components
103-3
Evaluation of the management approach
GRI 413:
Local Communities
413-1
Operations with local community 
engagement, impact assessments, and 
development programs
Connection with territory
112-117
103-1
Explanation of the material topic and its 
Boundary
Materiality analysis
Sustainability performance
30-31
 121
103-2
The management approach and its 
components
103-3
Evaluation of the management approach
GRI 419:
Socioeconomic
Compliance
419-1
Non-compliance with laws and regulations 
in the social and economic area
Ethics, business integrity and 
compliance
22-23
GRI 103:
Management
approach
Socioeconomic Compliance
Equal opportunities and respect for 
human rights
97
Equal opportunities and respect for 
human rights
97
Connection with territory
112-117
Ethics, business integrity and 
compliance
22-23
Freedom of Association and Collective Bargaining
GRI 103:
Management
approach
Human Rights Assessment
GRI 103:
Management
approach
Local Communities
Equal opportunities and respect for 
human rights
97
GRI 103:
Management
approach
Diversity and Equal Opportunity
Non-discrimination
GRI 103:
Management
approach
Equal opportunities and respect for 
human rights
The federal law on equality between 
women and men in Switzerland
97
87
GRI 103:
Management
approach
2021 Sustainability Report

The economic value generated by the Group and consequently distributed to the stakeholders is represented by the scheme 
of the generated, retained, and distributed value reported below. This value is determined by the value generated in the 
reference period by the sale of services and products and by other income (financial income, other income, etc.) net of 
depreciation and write-downs, and the value redistributed, in various forms, to the Group’s stakeholders. 
The Group calculated this value based on the items in the income statement used in the Group’s consolidated financial 
statements at 31 December 2021.  
EVG & D model items (€/1000)
2021
ECONOMIC VALUE GENERATED
1.901.263
Revenue
1.901.053
Financial income and charges
210
ECONOMIC VALUE DISTRIBUTED
1.702.831
Operating costs
1.474.505
Employee wages and benefits
149.006
Payments to providers of capitals
7.921
Dividends distributed to shareholders (a)
24.001
Payments to the Public Administration
47.217
Community investment
181
ECONOMIC VALUE RETAINED
198.432
NOTES:
 - The values shown in the table are expressed in thousands of Euros.
 - (a) The figure for "Dividends distributed to shareholders" was approved by the Shareholders' Meeting on 19 May 2022
130
131
7.3  Economic sustainability parameters 
GRI standard
Disclosure
KPI description
Document section
Page
103-1
Explanation of the material topic and its 
Boundary
Materiality analysis
Sustainability performance
30-31
 121
103-2
The management approach and its 
components
103-3
Evaluation of the management approach
103-1
Explanation of the material topic and its 
Boundary
Materiality analysis
Sustainability performance
30-31
 121
103-2
The management approach and its 
components
103-3
Evaluation of the management approach
103-1
Explanation of the material topic and its 
Boundary
Materiality analysis
Sustainability performance
30-31
121
103-2
The management approach and its 
components
103-3
Evaluation of the management approach
R&D and technological innovation
Continuous improvement
43
50-51
Material issues unrelated to specific disclosures of the GRI Standards
Product quality & safety and customer services
Quality and product safety
48-49
GRI 103:
Management
approach
Circular economy
Digital and technological innovation
Circular economy
42-43
2021 Sustainability Report

132
133
7.4  Social sustainability parameters 
New hires during the reporting period, by age group and gender of the 
employee
<30
30-50
>50
Total
<30
30-50
>50
Total
<30
30-50
>50
Total
Male
n°
95
113
31
239
82
99
31
212
144
160
46
350
Female
n°
8
11
2
21
11
10
3
24
19
24
5
48
Total
n°
103
124
33
260
93
109
34
236
163
184
51
398
Male
%
40,1
10,7
5,3
12,7
32,0
9,2
5,1
10,9
49,8
14,1
7,1
16,9
Female
%
33,3
11,7
5,4
13,5
42,3
10,6
7,9
15,1
55,9
23,1
11,4
26,4
Total rate
%
39,5
10,8
5,3
12,8
33,0
9,3
5,3
11,2
50,5
14,8
7,3
17,6
Terminations of employment contracts during the reporting period, broken 
down by age group and gender of the employee
<30
30-50
>50
Total
<30
30-50
>50
Total
<30
30-50
>50
Total
Male
n°
52
95
63
210
28
55
64
147
55
100
66
221
Female
n°
4
7
5
16
6
11
4
21
8
9
6
23
Total
n°
56
102
68
226
34
66
68
168
63
109
72
244
Male
%
21,9
9,0
10,7
11,2
10,9
5,1
10,6
7,6
19,0
8,8
10,2
10,6
Female
%
16,7
7,4
13,5
10,3
23,1
11,7
10,5
13,2
23,5
8,7
13,6
12,6
Total rate
%
21,5
8,9
10,9
11,1
12,1
5,6
10,6
8,0
19,5
8,8
10,4
10,8
Total number of turnovers in the reporting period, by geographical area
Italy
n°
Romania
n°
Switzerland
n°
France
n°
Total
n°
GRI 401-1 New employee hires and employee turnover
2019
2020
2021
73
Employees recruited Employees who left 
the company
Employees 
recruited
Employees who 
left the company
Employees 
recruited
Employees who 
left the company
73
69
79
47
105
74
40
27
57
54
129
64
95
70
90
53
97
244
52
60
10
14
67
33
260
226
236
168
398
Total of employees
Male
Female
Total
Male
Female
Total
Male
Female
Total
Total number of employees
n°
1.881
155
2.036
1.945
159
2.104
2.076
182
2.258
Employees by type of contract and gender
Male
Female
Total
Male
Female
Total
Male
Female
Total
Permanent (Perm.)
n°
1.855
150
2.005
1.933
154
2.087
2.033
175
2.208
Temporary (Temp.)
n°
26
5
31
13
4
17
43
7
50
Employees by contractual hours and gender
Male
Female
Total
Male
Female
Total
Male
Female
Total
Full-time
n°
1.860
128
1.988
1.923
131
2.054
2.049
154
2.203
Part-Time
n°
21
27
48
23
27
50
27
28
55
Employees by type of contract and geographical area
(Perm.)
(Temp.)
Total
(Perm.)
(Temp.)
Total
(Perm.)
(Temp.)
Total
Italy
n°
751
24
775
802
5
807
828
11
839
Romania
n°
270
0
270
273
0
273
338
0
338
Switzerland
n°
492
0
492
527
2
529
552
0
552
France
n°
492
7
499
485
10
495
490
39
529
External employees
Male
Female
Total
Male
Female
Total
Male
Female
Total
Interns
n°
0
0
0
0
0
0
1
0
1
Temporary workers
n°
69
5
74
50
4
54
57
3
60
Total
n°
69
5
74
50
4
54
58
3
61
Employees covered by a national collective agreement
Male
Female
Total
Male
Female
Total
Male
Female
Total
Executive
n°
30
3
33
34
4
38
33
3
36
Manager and White collar
n°
366
132
498
363
137
500
390
152
542
Blue collar
n°
1.485
20
1.505
1.548
18
1.566
1.651
27
1.678
Total
n°
1.881
155
2.036
1.945
159
2.104
2.074
182
2.256
2019
2020
2021
GRI 102-8 Information on employees and other workers
GRI 102-41 Collective bargaining agreements: 99.91% of workers are covered by collective bargaining agreements in the various countries where AFV Beltrame Group operates
GRI 402-1 Minimum notice period for operational changes:  the minimum notice period is determined by the CCNL
2019
2020
2021
2021 Sustainability Report
2019
2020
2021
Employees injuries
Fatal injuries
n°
0
0
0
High-consequence injuries (excluding fatalities)
n°
6
6
4
Total recordable injuries (LTI+MI)
n°
132
94
163
Other workers injuries
Fatal injuries
n°
0
0
0
High-consequence injuries (excluding fatalities)
n°
0
0
0
Total recordable injuries (LTI+MI)
n°
15
8
9
Main types of injuriy - Employees
Stumbles
n°
31
20
29
Crushes
n°
26
31
61
Cuts
n°
9
10
14
Others
n°
66
33
59
Main types of injuriy - Other workers
Stumbles
n°
5
2
3
Crushes
n°
6
6
3
Cuts
n°
0
0
1
Others
n°
4
0
2
Employees worked hours
Total
h
3.332.231
3.223.610
3.934.370
Safety indicators - Employees
Fatal injuries rate
(°)
-
-
-
High-consequence injuries rate (excluding fatalities)
(°)
1,80
1,86
1,02
Total Recordable Injury Rate (LTI+MI) (TIFR)
(°)
39,61
29,16
41,43
NOTES:
(a)
INJURIES:
 - Injuries to temporary employees are also included.
 - Includes occupational injuries involving an absence from work of more than one day (LTI) and medication (MI).
 - Injuries en route are only included when transport has been organised by the organisation.
 - Injuries with serious consequences refer to injuries that have caused more than 180 days of absence.
OTHER WORKERS:
 - Workers of the main contracting companies present at the Group's Italian and foreign sites.
ACCIDENT RATE
 - (°) The rate is calculated as the ratio between the number of accidents and the total number of hours worked in the same period, multiplied by 1.000.000.
GRI 403-9 Work-related injuries (a)

134
135
2021 Sustainability Report
Average per capita training hours
Male  (per capita)
Female (per capita)
Total (per capita)
Male  (per capita)
Female (per capita)
Total (per capita)
Male  (per capita)
Female (per capita)
Total (per capita)
Executive
h
37
19
36
24
14
23
13
11
13
Manager and White collar
h
31
44
35
15
21
16
26
26
26
Blue collar
h
33
43
33
13
29
13
25
34
26
Total average
h
33
43
34
14
22
14
25
27
26
GRI 404-1 Average hours of training per year per employee
2019
2020
2021
Type of training
Safety and Environment
h
%
19.624
35
18.952
57
30.556
52
Informatics
h
%
54
0
1.156
3
443
1
Languages
h
%
4.147
7
920
3
2.178
4
Industrial
h
%
22.705
40
3.502
10
11.036
20
Opex
h
%
417
1
0
0
301
1
Department-specific
h
%
4.854
9
4.278
13
2.895
5
Transversal skills
h
%
2.664
5
3.446
10
5.227
9
Other training courses
h
%
2.065
3
1.208
4
5.027
8
Total
h
%
56.530
100
33.462
100
57.663
100
GRI 404-1 Annual training hours per type
2019
2020
2021
Employees by classification and gender
Male
Female
Male
Female
Male
Female
Executive
%
1,5
0,1
1,6
0,2
1,6
0,1
Manager and White collar
%
18,0
6,5
17,3
6,5
17,3
6,7
Blue collar
%
72,9
1
73,6
0,9
73,1
1,2
Total
%
92,4
7,6
92,4
7,6
91,9
8,1
Employees by classification and age
<30
30-50
50>
Total
<30
30-50
50>
Total
<30
30-50
50>
Total
Executive
%
0,1
0,8
0,7
1,6
0
1
0,9
1,8
0
0,7
1
1,7
Manager and White collar
%
2,4
14,2
7,9
24,5
2,3
13,6
7,8
23,8
2,5
13,8
7,7
24
Blue collar
%
10,6
41,6
21,8
73,9
11,1
41,6
21,8
74,4
11,8
40,5
22,1
74,3
Total
%
13,1
56,5
30,4
100
13,4
56,1
30,5
100
14,3
55,0
30,7
100
Employees by gender and age
<30
30-50
50>
Total
<30
30-50
50>
Total
<30
30-50
50>
Total
Male
%
11,6
51,9
28,8
92,4
12,2
51,7
28,6
92,4
12,8
50,4
28,8
91,9
Female
%
1,2
4,6
1,8
7,6
1,2
4,5
1,9
7,6
1,5
4,6
1,9
8,1
Total
%
12,8
56,5
30,6
100
13,4
56,1
30,5
100
14,3
55
30,7
100
2019
2020
2021
GRI 405-1 Diversity in governing bodies and among employees
Total
1,6
24,5
73,9
100
1,7
24
74,3
100
Total
Total
1,8
23,8
74,4
100
Parental leave
Male
Female
Total
Total number of employees who took parental leave, by gender.
n°
768
77
845
Total number of employees who took parental leave, by gender
n°
2
8
10
Number of whom returned to work during the reporting period after parental leave 
n°
1
2
3
Number who were still on parental leave at the end of the reporting period
n°
1
6
7
Total number of employees who returned to work after taking parental leave and remained 
employed by the organisation for 12 months after returning, by gender
n°
2
3
5
Parental leave
2021

137
2019
2020
2021
Division of Materials
Raw materials (Scrap and Cast Iron)
t
2.225.280
2.189.869
2.548.203
Ferroalloys
t
29.257
28.421
34.076
Fluxes
t
117.683
115.916
140.806
Electrodes
t
2.541
2.484
2.946
Oxygen
1.000 m3
74.532
72.711
86.838
Subdivision Fluxes
Lime
%
71,9%
72,4%
73,1%
Fluidifying agents
%
5,0%
4,6%
4,8%
Carbons
%
23,0%
23,0%
22,1%
Productions
Semi-finished products and billets
t
2.005.866
1.960.059
2.279.102
Rolled profiles
t
2.019.554
1.897.891
2.145.756
2019
2020
2021
Energy consumptions by type of fuel
Natural Gas
GJ
3.445.297
3.378.285
3.845.018
Diesel
GJ
39.739
39.747
52.117
LPG
GJ
2.067
1.880
2.614
Gasoline
GJ
1.516
1.315
1.472
Electric energy purchased
GJ
4.210.420
4.130.424
4.659.325
Total
GJ
7.699.040
7.551.652
8.560.545
of which from renewable energy sources
GJ
9.921
1.323.821
1.309.350
of which from non-renewable energy sources 
GJ
7.689.119
6.227.831
7.251.195
2021
Natural Gas
m3/t
50,8
Electric energy purchased
kWh/t
603,2
 - (b) The following conversion factors were used to calculate energy consumption in GJ:
Natural gas: equal to 35.281 GJ/1000sm3 (source ISPRA 2021);
Diesel: equal to 42.873 GJ/t (source ISPRA 2021);
LPG: equal to 45.858 GJ/t (source ISPRA 2021);
Petrol: equal to 43.128 GJ/t (source ISPRA 2021);
Electricity: constant equal to 0.0036 GJ/kWh.
NOTES:
GRI 302-1: Energy consumption within the organization (b)
Specific energy consumption per tonne of steel produced (Rolled profiles)
 - (a) The materials shown in Table 301-1 are non-renewable. Following the improvement of the data collection process, the data for electrodes and rolled profiles for the 
years 2019 and 2020 were also included.
136
7.5  Environmental sustainability parameters
2019
2020
2021
Surface water
Megaliters
2.337
2.244
2.312
Groundwater
Megaliters
2.256
2.226
2.479
Seawater
Megaliters
0
0
0
Produced water
Megaliters
0
0
0
Third-party water
Megaliters
70
62
75
Total Water withdrawal 
Megaliters
4.663
4.532
4.866
2021
Industrial water
m3/t
2,23
2019
2020
2021
Emissions
NOx
Value kg
344.454
419.512
417.573
SOx (e)
Value kg
180.700
99.710
105.160
Particulate Matter (PM)
Value kg
16.773
10.787
15.006
2021
Specific CO2 emissions per tonne of steel produced (Rolled profiles)
Direct CO2 emissions (Scope 1) (f)
t CO2/t
0,15
Indirect CO2 emissions (Scope 2 - location-based)
t CO2e/t
0,09
NOTES:
 - (f) The figure for 2021 also includes direct emissions from mobile combustion
 - (e) Calculated as the sum of the values of the plants in Vicenza, Trith Saint Léger, Gerlafingen and Calarasi
 - (c) With regard to water withdrawals in water-stressed areas, AFV Beltrame Group used the Aqueduct Tool developed by the World Resources Institute (WRI) to identify 
areas potentially at risk. According to this analysis, company sites and plants were not found to be located in water stress areas. The WRI tool is available online at: 
https://www.wri.org/our-work/project/aqueduct. For the analysis, the results in the "baseline water stress" column were taken into account.
Water-stressed areas are defined as those with an Extremely High risk.
All water sampled is fresh water (≤1,000 mg/l total dissolved solids).
 - (d) More details on how emissions are calculated can be found in section 4.6 Greenhouse Gas Management.
GRI 305-7 Nitrogen oxides (NOx), sulfur oxides (SOx), and other significant air emissions (d)
Industry-specific water consumption per tonne of steel produced (Rolled profiles)
Source refered to all areas
GRI 303-3: Water withdrawal (c)
2021 Sustainability Report

138
139
Total monetary value of significant fines
Total number of non-monetary sanctions 
Cases brought through dispute resolution mechanisms
Scrap purchase
by road
by rail
by ship
Total
Finished products delivered
by road
by rail
by ship
Total
NOTES:
 - (l) Intermodal transport has been included under the heading 'by train'.
Significant fines and non-monetary sanctions for non-compliance with environmental laws and/or regulations
GRI 307-1 Non-compliance with environmental laws and regulations
0
0
0
0
0
0
0
0
€
n.
n.
0
2019
2020
2021
%
%
76
5
100
%
%
%
%
%
5
100
67
7
100
78
20
2
100
79
16
5
100
78
19
3
100
Transport details (l)
%
20
22
26
73
2019
2020
2021
Total weight of waste generated
Hazardous
t
%
38.167
7
38.757
8
48.392
9
Non-hazardous
t
%
527.071
93
455.366
92
464.381
91
Total 
t
%
565.238
100
494.123
100
512.772
100
Total weight of waste diverted from disposal
Hazardous
t
%
36.127
10
37.274
10
41.900
11
Non-hazardous
t
%
323.682
90
352.717
90
350.521
89
Total
t
%
359.809
100
389.990
100
392.421
100
Hazardous
t
%
36.127
10
37.274
10
31.842
9
Preparation for reuse 
t
%
5
0
2
0
0
0
Recycling
t
%
10.409
3
10.657
3
10.857
3
Other recovery operations
t
%
25.713
7
26.615
7
20.985
6
Non-hazardous
t
%
323.682
90
352.717
90
306.734
91
Preparation for reuse 
t
%
4.036
1
16
0
2
0
Recycling
t
%
150.034
42
206.696
53
156.321
46
Other recovery operations
t
%
169.612
47
146.005
37
150.412
45
Total
t
%
359.809
100
389.990
100
338.576
100
Total weight of waste directed to disposal
Hazardous
t
%
2.022
1
1.417
4
4.506
11
Non-hazardous
t
%
132.829
99
30.227
96
34.737
89
Total
t
%
134.850
100
31.644
100
39.243
100
Hazardous
t
%
2.022
2
1.417
4
4.506
11
Incineration (with energy recovery)
t
%
89
0
62
0
537
1
Incineration (without energy recovery)
t
%
145
1
109
0
81
0
Landfilling
t
%
1.783
1
1.236
4
2.452
6
Other recovery operations
t
%
5
0
10
0
1.436
4
Non-hazardous
t
%
132.829
98
30.227
96
34.737
89
Incineration (with energy recovery)
t
%
406
0
456
2
696
2
Incineration (without energy recovery)
t
%
0
0
0
0
0
0
Landfilling
t
%
132.311
98
29.398
93
33.390
85
Other recovery operations
t
%
112
0
373
1
651
2
Total
t
%
134.850
100
31.644
100
39.243
100
NOTES:
 - (h) More than 9% of non-hazardous waste was sent to on-site recovery operations during 2021
 - (i) All waste was disposed of outside the Group's facilities
2021
Waste directed to disposal by disposal operation
GRI 306-3 Waste generated
GRI 306-4 Waste diverted from disposal (g) (h)
2019
2020
2021
2021
2020
2019
Waste diverted from disposal by recovery operation
GRI 306-5 Waste directed to disposal (g) (i)
2020
2019
 - (g) The discrepancy between the amount of waste produced and the amount of waste delivered is due to the accumulation in areas within the Vicenza, Trith Saint Léger and 
Gerlafingen sites of industrial aggregate from the processing of electric furnace slag, as indicated in the respective permits, awaiting commercialisation.
2021 Sustainability Report

140
141
2021 Sustainability Report
 
 
Deloitte & Touche S.p.A. 
Via N. Tommaseo, 78/C int. 3 
35131 Padova 
Italia 
Tel: +39 049 7927911 
Fax: +39 049 7927979 
www.deloitte.it 
 
 
INDEPENDENT AUDITOR’S REPORT 
ON THE SUSTAINABILITY REPORT 
 
 
To the Board of Directors of 
AFV Acciaierie Beltrame S.p.A. 
 
 
We have carried out a limited assurance engagement on the Sustainability Report of the AFV Acciaierie 
Beltrame Group (hereinafter also “the Group”) as of December 31, 2021. 
 
RResponsibility of the Directors for the Sustainability Report 
 
The Directors of AFV Acciaierie Beltrame S.p.A. are responsible for the preparation of the Sustainability 
Report in accordance with the “Global Reporting Initiative Sustainability Reporting Standards” 
established by GRI – Global Reporting Initiative (“GRI Standards”), as stated in the paragraph 
“Methodological note” of the Sustainability Report.  
 
The Directors are also responsible, for such internal control as they determine is necessary to enable the 
preparation of the Sustainability Report that is free from material misstatement, whether due to fraud or 
error. 
 
The Directors are also responsible for the definition of the Group’s objectives in relation to the 
sustainability performance, for the identification of the stakeholders and the significant aspects to 
report. 
  
Auditor’s Independence and quality control 
 
We have complied with the independence and other ethical requirements of the Code of Ethics for 
Professional Accountants issued by the International Ethics Standards Board for Accountants, which is 
founded on fundamental principles of integrity, objectivity, professional competence and due care, 
confidentiality and professional behaviour.  
 
Our auditing firm applies International Standard on Quality Control 1 (ISQC Italia 1) and, accordingly, 
maintains a comprehensive system of quality control including documented policies and procedures 
regarding compliance with ethical requirements, professional standards and applicable legal and 
regulatory requirements. 
  
 
  
2 
Auditor’s responsibility 
 
Our responsibility is to express our conclusion based on the procedures performed about the compliance 
of the Sustainability Report with the GRI Standards. We conducted our work in accordance with the 
criteria established in the “International Standard on Assurance Engagements ISAE 3000 (Revised) – 
Assurance Engagements Other than Audits or Reviews of Historical Financial Information” (hereinafter 
“ISAE 3000 Revised”), issued by the International Auditing and Assurance Standards Board (IAASB) for 
limited assurance engagements. The standard requires that we plan and perform the engagement to 
obtain limited assurance whether the Sustainability Report is free from material misstatement. 
 
Therefore, the procedures performed in a limited assurance engagement are less than those performed 
in a reasonable assurance engagement in accordance with ISAE 3000 Revised, and, therefore, do not 
enable us to obtain assurance that we would become aware of all significant matters and events that 
might be identified in a reasonable assurance engagement. 
 
The procedures performed on the Sustainability Report are based on our professional judgement and 
included inquiries, primarily with Company personnel responsible for the preparation of information 
included in the Sustainability Report, analysis of documents, recalculations and other procedures aimed 
to obtain evidence as appropriate. 
 
Specifically we carried out the following procedures: 
 
1. analysis of the process relating to the definition of material aspects disclosed in the Sustainability 
Report, with reference to the methods used for the identification and prioritization of material 
aspects for stakeholders and to the internal validation of the process results; 
2. comparison between the economic and financial data and information included in the paragraph “7.3 
Economic sustainability parameters” of the Sustainability Report with those included in the Group’s 
Financial Statements; 
3. understanding of the processes underlying the origination, recording and management of qualitative 
and quantitative material information included in the Sustainability Report.  
 
In particular, we carried out interviews and discussions with the management of AFV Acciaierie Beltrame 
S.p.A. and we carried out limited documentary verifications, in order to gather information about the 
processes and procedures, which support the collection, aggregation, elaboration and transmittal of 
non-financial data and information to the department responsible for the preparation of the 
Sustainability Report.

142
3 
In addition, for material information, taking into consideration the Group’s activities and characteristics: 
 
• at group level: 
 
a) with regards to qualitative information included in the Sustainability Report, we carried out 
interviews and gathered supporting documentation in order to verify its consistency with the 
available evidence; 
b) with regards to quantitative information, we carried out both analytical procedures and limited 
verifications in order to ensure, on a sample basis, the correct aggregation of data; 
 
• for AFV Acciaierie Beltrame S.p.A., which we selected based on the activity carried out, the 
contribution to the performance indicators at the consolidated level and its location, we carried out 
site visits, during which we have met the management and have gathered supporting documentation 
on a sample basis with reference to the correct application of procedures and calculation methods 
used for the indicators. 
 
CConclusion 
 
Based on the work performed, nothing has come to our attention that causes us to believe that the 
Sustainability Report of the AFV Acciaierie Beltrame Group as of December 31, 2021 is not prepared, in 
all material aspects, in accordance with the GRI Standards as stated in the paragraph “Methodological 
note” of the Sustainability Report. 
 
OOther matters 
 
The data for the year ended December 31, 2019 presented for comparative purposes in the 
Sustainability Report have not been subject to a limited or to a reasonable assurance engagement.  
 
 
DELOITTE & TOUCHE S.p.A. 
 
Signed by 
CCristiano Nacchi 
Partner 
 
 
Padova, Italy  
June 29, 2022 
 
143
2021 Sustainability Report
AFV Acciaierie Beltrame S.p.A.
Registered office: Viale della Scienza, 81
36100 Vicenza - Italy
Companies Register of Vicenza and VAT number 13017310155 
R.E.A. Vicenza nr. 292852
Code Identification CEE IT 13017310155
Cap. Soc. € 113.190.480,00 I.V.
info.it@beltrame-group.com 
www.gruppobeltrame.com
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AFV Beltrame Group
Photos
Photographic archive AFV Beltrame Group 
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Vicenza, July 2022