We are committed to delivering the highest-quality environmental management in our operations, and to ensuring compliance with all environmental regulations.  Our commitment to the environment is outlined in our Corporate Environmental Policy. All Harsco employees are expected to understand, promote, and assist in the implementation of this policy.

Through our environmental program, we continually assess and seek to minimize the environmental impact of our facilities and products, for the benefit of our customers, employees, neighbors and communities. Our commitment extends beyond expected compliance with environmental laws; it includes the incorporation of sound environmental practices into our business decision-making processes.  Our environmental commitment also extends to the work we do. Minimizing the environmental impact, recycling, and repurposing waste and industrial co-products is a core focus of our business.

Harsco’s environmental policy and global environmental compliance is overseen by our Vice-President of Sustainability and Environmental Solutions, a member of Harsco’s Executive Leadership Team, and a direct report to our Chief Executive Officer and Chairman of the Board.

Harsco’s environmental program is executed by the Company’s 150+ member Environmental, Heath, and Safety (EHS) team, and supported by other Company functions and external consultants. The EHS team is responsible for implementing Harsco’s environmental policy and ensuring environmental compliance at Harsco sites. To support implementation, the EHS team utilizes an environmental management system to manage regulatory compliance, internally report environmental incidents across the Company’s operations, and manage corrective actions to address incidents. In addition, fifty-seven of our facilities around the globe are ISO 14001 certified, the leading environmental management standard in the industry. Key environmental issues monitored and managed by the EHS team include climate change and GHG emissions, energy use and management, air quality and management, waste and hazardous materials management, and water and wastewater management. 

Evaluation of environmental risks and opportunities are evaluated on a quarterly basis through Harsco’s enterprise risk management process and are reported to the Board of Directors’ Audit Committee at the Company’s quarterly board meetings. Oversight for ESG issues is provided by the Governance Committee of our Board of Directors.  Environmental concerns are integrated into the Company’s decision-making processes, including the evaluation of new investments and mergers and acquisitions.  We also perform audits of our operations’ environmental compliance and performance through our Internal Audit team and our Harsco Way Assessments, which target a review of every Harsco facility every two to three years.

Our vision to be a global leader of environmental solutions.  In recent years, we have moved to formalize our focus on environmental solutions and to reconfigure our portfolio through acquisitions and divestitures to transform into a global, market leading, single-thesis environmental solutions platform. In 2019, we took two giant and simultaneous steps forward in that process. We announced a rebrand of our Metals & Minerals division into Harsco Environmental. The second major step was our acquisition of Clean Earth, one of the largest independent specialty waste companies in the United States. In April 2020, we made another strategic investment, acquiring Stericycle’s Environmental Solutions business, increasing our geographic scale and reach while enabling us to create a leading national hazardous waste management platform. In 2020, 82 percent of Harsco’s total revenue was derived from our environmental services businesses, compared to just 60 percent three years ago. In 2019 and 2020, Harsco’s industry classification was changed to waste management or environmental services by leading industry classification standards including the Global Industry Classification Standard and Industry Classification Benchmark.

Our treatment, recycling and repurposing of industrial waste and byproducts help accelerate the circular economy, preserve natural resources and reduce carbon emissions. For example, our Environmental division’s core business is focused on helping our steel and aluminum customers manage their environmental challenges and meet their environmental goals. Harsco Environmental’s solutions currently help our customers:

• Increase the recycled content in steel and aluminum production
• Reduce or eliminate material sent to landfill
• Reduce carbon emissions from the production process
• Reduce dust emissions, improve air quality, and use less water

We estimate the recycling activities and value-added products of Harsco’s Environmental division in 2020 contributed to the avoidance of over 5.8 million metric tons of carbon emissions. This benefit can be passed-on to our customers and helps contribute to a lower-carbon, circular economy.

We strive to improve our environmental footprint through operational efficiency and continuous improvement efforts.  In 2020, we set our first enterprise energy and carbon emissions reduction goal to reduce the energy and carbon intensity of our operations 15% by 2025 (2019 baseline).  In addition, our divisions set sustainability and environmental goals relevant for their businesses. The Environmental team in North America has implemented GPS tracking on large mobile equipment to reduce idling time and improve the efficiencies of material movements at our sites.  In 2020, this asset management tool was implemented across more than 300 vehicles at 18 sites, reducing diesel fuel use by over 230,000 gallons and saving over $1 million in operating expenses.  At our Ijmuiden site in Amsterdam, we have committed to a 15 percent greenhouse gas reduction target.  Our Clean Earth division has set a number of sustainability goals as part of their 2016-18 sustainability plan. 

We are also exploring opportunities to increase the usage of renewable energy across our business.  In 2020, our total enterprise energy use was 4.4 million gigajoules (GJ) with 97% (4.29 million GJ) of this energy derived from non-renewable sources and 3% (154,600 GJ) sourced from renewable sources.  All our renewable energy usage is associated with electricity use sourced from the grid. In 2020, we estimate that approximately 26% of our enterprise electricity use was derived from renewable sources.  We are evaluating opportunities to increase the sourcing of electricity from renewable generation sources and opportunities to increase the electrification of our mobile assets.

Our community and civic engagement efforts reflect our commitment to building strong, sustainable communities. Every day, in every corner of the globe, Harsco employees offer their time and talents to our neighbors and neighborhoods. From charity hikes for cancer research, to helping rebuild the Houston area after the devastation of Hurricane Harvey, our colleagues volunteer thousands of hours to help create positive outcomes for the communities in which we live and work.

Harsco’s diverse, global work force is a source of pride, and Inclusion is one of our Core Values. We value our differences and welcome the unique contributions, perspectives, and ideas of every employee. Wherever we do business, we work together in a spirit of collaboration, respect, and inclusion, and know that many perspectives can produce the best solutions.

Harsco is an equal opportunity employer; our policies, including the equal opportunity and affirmative action policy, prohibit unlawful discrimination. Harsco’s Code of Conduct includes our policy against harassment in all forms. Harsco does not tolerate harassment, whether sexual or non-sexual in nature, and whether committed by a Harsco employee or someone with whom we do business. Harsco's 2021 EEO-1 Report is available here.

Our human capital strategy is led in partnership between Harsco’s Chief Human Resources Officer and leaders within our divisions.  Harsco employs a matrix organization structure, assigning clear ownership of specific responsibilities around human capital strategy and workforce management across the business.

Employee Care is one of our Core Values.  We provide our employees with market-leading financial, health and wellness, and career development benefits.  Specific benefits vary worldwide and are based on regional needs, but some common features of our benefit program, available to all employees globally, include recognition, opportunity, involvement and reward.

The Company has established a comprehensive development framework, including training, implemented globally for all employees.  Our leadership programs are built around our Core Values.  

We conduct a global engagement survey of all employees on an annual basis. The survey results are cascaded through the organization with voluntary employee team struck to address items at the local level.

Consistent with our Values, Harsco believes every human being has the right to safe, healthy working conditions, and to be treated with dignity and respect.  Our Human Rights policy, is guided by the U.N. Guiding Principles for Business and Human Rights, and outlines our human rights commitments. We expect our agents, contractors, consultants, distributors, suppliers and vendors (collectively "Business Partners") to share our commitment to human rights. As part of our procurement process, all business partners are required to acknowledge Harsco’s Business Partner Code of Conduct. In compliance with the UK Modern Slavery Act of 2015, we have provided our statement outlining our actions to ensure that slavery and human trafficking are not taking place in our business or global supply chains.  All employees receive training on our human rights policy through our required Code of Conduct training.     

It is the policy of Harsco Corporation and its subsidiaries or affiliated entities (collectively, “Harsco”) to conduct business in compliance with laws that require publicly-traded companies to disclose their use of “conflict minerals” originating in the Democratic Republic of the Congo (“DRC”) or an adjoining country. Conflict minerals include columbite-tantalite (coltan), cassiterite (tin), wolframite (tungsten), and gold, (collectively, “3T&G”) and any of their derivatives. We encourage our suppliers to adopt similar policies and management systems with respect to conflict minerals and to drive those efforts throughout their supply chain to ensure that the specified metals are being sourced only from (1) mines and smelters outside the DRC or an adjoining country; or (2) mines and smelters within the DRC or an adjoining country which have been certified by an independent third party as “conflict free.” Harsco has engaged Crowe LLP, an international accounting and consulting firm, to assist with our conflict minerals due diligence. You can email questions to Harsco.ConflictMinerals@crowe.com. More information about the conflict minerals ruling is available at https://www.crowe.com/conflict-minerals.”

Harsco Corporation - Form SD and Conflict Minerals Report 2020

Our goal is to provide our customers with products of the highest quality.  Nearly all of our major manufacturing facilities globally are ISO 9001 certified.  For example, with Harsco Rail’s “Quality At The Source” strategy, every employee assumes responsibility for the performance, consistency, safety and value of our products.  Customer focus is the backbone of Harsco Rail’s ISO 9001 certified integrated management system.  On this basis, all processes are regularly monitored, and process effectiveness and efficiency are continuously improved. This enables us to offer our customers first class products and services that meet and exceed our customer expectations.

Safety is of paramount importance in everything we do. Our vision to eliminate workplace injuries and illnesses is embedded in our Employee Care value and drives a sustainable safety culture designed to protect our employees, customers, work environment, and communities. Our commitment to workplace health and safety is grounded in our belief that all workplace injuries and illnesses are preventable. All Harsco employees and contractors are responsible for their own safety, and that of their colleagues and others in the workplace. Our Health & Safety policy applies across all Harsco divisions, subsidiaries, third party businesses, contractors, and visitors.  The Company’s safety policies and operational controls are overseen by a cross-functional Safety Committee composed of senior leaders from every division.  The Committee reports to Harsco’s Chairman and Chief Executive Officer.

Across cultures, time zones and organizational lines, our values are the link that connects us all. As the cornerstone of our shared Harsco culture, our values – Integrity, Passion for Winning, Employee Care, Satisfy the Customer, Inclusion, Respect – reflect our overarching direction and purpose as a business.  See our Core Values for more information.

Excellence in corporate governance is fundamental to how we manage and operate Harsco. See the Corporate Governance section of our website to learn more about our governance principles, including Board composition and structure, Board Committees, and Compensation.  Additional corporate governance information can be found in our latest proxy statement found on our Investor Relations site.

Harsco has a dedicated Global Compliance & Ethics program that reinforces our uncompromising commitment to doing business the right way.   Harsco’s values are memorialized in our Code of Conduct, which is available in over 20 languages on our public website.   The Code of Conduct applies to all Harsco operations, including subsidiaries. Its principles are further memorialized in our  Business Partner Code of Conduct, which applies to all third parties that do business with Harsco.  All employees and contractors are required to complete Code of Conduct training upon joining Harsco; this training is frequently reinforced in other ongoing Compliance trainings and communications.  Further, Harsco’s Internal Control Framework – available in 15 languages – applies to all employees and is provided to new employees.   

Harsco’s global compliance program is led at the executive level by our Chief Compliance Officer and is overseen ultimately by the Audit Committee of our Board of Directors.  Harsco’s Vice President of Global Compliance executes and drives compliance initiatives, such as ongoing trainings, communications, and investigations of misconduct, consistent with the expectations of the U.S. Department of Justice.  Harsco’s global compliance program works closely with our corporate partners in Human Resources, Internal Audit, and Finance to specifically tailor initiatives to the various risks inherent in Harsco’s businesses, to test relevant policies and controls, and to ensure appropriate risk mitigation regarding Harsco’s third-party business partners.   

Ownership of compliance and ethics by the business is an important principle in Harsco’s global compliance program.  For example, “Compliance Councils” within each business, composed of cross-functional leaders, discuss “A-Z” compliance issues, such as seeking continuous improvement for targeted trainings and communications, and ensuring that misconduct is prevented, detected, and swiftly remediated.   

Further, Harsco’s global compliance program monitors – via a third-party vendor – our Integrity Line, which is a mechanism to anonymously and confidentially report misconduct, 365 days a year, 24 hours a day, and in multiple languages.   Retaliation in any form against good-faith reports of misconduct is not tolerated.  In addition to addressing reports of misconduct, Harsco’s global compliance program takes an active role in identifying control or policy gaps for purposes of root cause analysis.  

Harsco also has a robust anti-bribery/anti-corruption policy, consistent with the requirements of the U.S. Foreign Corrupt Practices Act and the UK Bribery Act.    The policy includes stringent requirements for interactions with government officials, such as pre-approvals and detailed expense documentation, is reinforced via frequent trainings and communications, and prohibits facilitation payments.  The policy is also reflected in Harsco’s due diligence program that screens potential business partners and other third parties that seek to do business with Harsco.   Further still, Harsco’s written agreements include numerous anti-bribery/anti-corruption provisions that Harsco actively monitors for compliance and enforcement.   

We encourage our employees to volunteer contributions of time, talent and money to support causes that are important to them. This includes political candidates and campaigns. Our policies related to political activities, formalized in our Code of Conduct, prohibit Harsco employees from using Harsco funds, assets, resources, time or the Harsco name to support political activities.  All lobbying activities on behalf of Harsco must first be approved by the Harsco General Counsel.

Management of Harsco’s global suppliers and supply chains is critical to support Harsco’s operations around the world.  Supply chain management is led by the Vice President of Procurement in our Harsco Environmental division, the Vice President of Global Integrated Supply Chain in our Rail division, and the Director of Operations in our Industrial division.  These roles are responsible for oversight of Harsco’s procurement and supplier relationships.

Harsco’s Code of Conduct and Business Partner Code of Conduct applies to all Harsco suppliers and third parties that do business with Harsco, setting our expectations that these organizations share our commitment to human rights, compliance with labor laws, implementing sound environmental, health and safety practices, and ethical business practices.  Our suppliers are required to acknowledge Harsco’s codes of conduct as part of the contracting and procurement process.