Policies related to own workforce S1-1

Norðurál emphasizes professional human resource management guided by the company’s role, vision and values. Norðurál’s human resources policy aims to create an accident-free and desirable workplace where safety, equality and the well-being of employees are paramount.

Equality and human rights 

Norðurál conducts its activities and business with respect for human rights. Norðurál emphasizes the equal right of staff to career advancement, remuneration, and rights, irrespective of their sex, sexual orientation, religion, or origin. Norðurál aims for continuous improvements and complies with laws and other stipulations on human rights and equality.

Human rights and equality goals:

• Prevention of bullying, harassment, and other forms of violence
• Promotion of gender equality
• Equal pay for comparable jobs

Safety and Health Policy 

Norðurál prioritizes safety and health. All employees are aware of the importance of safety protocols and conduct in the workplace, and respect at all times the principle that no job should be done under unsafe circumstances. Active participation by employees in accident prevention and in making improvements is emphasized. Norðurál adheres to all laws and regulations concerning safety and health.

Processes for engaging with own workers and workers’ representatives about impacts S1-2

Norðurál emphasizes a positive and constructive working environment where the well-being and satisfaction of employees is the guiding principle. Emphasis is placed on diverse communication channels where employees and managers can convey suggestions, messages or ideas.

Workplace analysis 

A workplace analysis has generally been carried out every two or three years, and the last analysis was made in November 2023. The main results were that the average employee engagement was 3.71, but in the last survey from 2022, the average employee engagement was 3.62. Employee satisfaction with Norðurál as a workplace also rose from 3.54 in 2022 to 3.64 in 2023.
In 2025, so-called pulse measurements will be introduced where job satisfaction is measured more often throughout the year so that work on improvements will be more targeted.

Employee interviews 

Employee interviews are held annually, where employees have the opportunity to speak with their superiors in a formal manner. Employee interviews include discussions about employee performance, working environment, communication and well-being.

Termination interviews 

Employees who resign on their own initiative are invited to have a termination interview with a human resources specialist. In such an interview, the reasons for termination are reviewed, among other things, so that opportunities for improvement can be identified.

Feedback system 

Employees can send suggestions about human resources issues through Norðurál’s feedback system. The safety, environment and improvement division is responsible for the feedback system, following up on feedback and ensuring that feedback reaches the right parties within the company.

Microsoft Teams 

All Norðurál employees have access to the communication program Teams. Channels are defined on Teams, both by subject and by employee groups. There is also a general channel where news, announcements and messages are published. Employees have the option to write comments on news, announcements and messages. Teams also allows employees and managers to compose and send messages and/or make calls.

Norðurljós (Northern Lights) 

Norðurljós is the name of the company’s intranet. The intranet offers various information such as a quality manual, safety rules, requests and orders, computer help, educational materials, the canteen menu, access to a suggestion website and a project website, job vacancies and much more.

Processes to remediate negative impacts and channels for own workers to raise concerns S1-3

Norðurál emphasizes the safety and well-being of employees, not least psychosocial safety, as risk factors in the work environment related to organization, management and communication are identified. Norðurál has issued and updated a contingency plan on how to respond to bullying, sexual and gender-based harassment, and other forms of violence. Such conduct in the workplace is not tolerated and appropriate action is therefore taken in these cases, and external experts may be consulted to ensure impartiality.

Education and prevention are important in this area. Educational sessions have been held and emphasis is placed on employees taking an online course that can be found on Learn Cove, Norðurál’s educational system.

Employees are encouraged to report any incidents or suspicions of inappropriate conduct to their supervisor or to contact the human resources manager or human resources specialists directly.

Last year, no formal reports of bullying, sexual harassment, gender-based harassment or violence were received.

 

Taking action on material impacts on own workforce, and approaches to mitigating material risks and pursuing material opportunities related to own workforce, and effectiveness of those actions S1-4

Norðurál places great emphasis on creating a safe, equality-oriented and constructive working environment, in line with the company’s policy and values. Norðurál regularly identifies key human resource risks, such as the loss of key personnel, knowledge of safety regulations, lack of skills or the risk of social exclusion.

Key emphases:

• Recruitment and diversity: Norðurál follows professional recruitment processes to ensure the employment of qualified personnel, regardless of gender, origin, religion or sexual orientation.
• On-the-job training & the Norðurál School of Heavy Industry: Annual mapping of employee training needs ensures targeted on-the-job training. Norðurál has operated its School of Heavy Industry since 2012, which increases skills, understanding of production processes and job satisfaction.
• Safety and occupational health: Safety regulations are strict and enforced for all employees in the area. Diverse safety education and follow-up of incidents and projects is an integral part of daily work.
• Equality and rights: Norðurál guarantees equal rights to career advancement, pay and opportunities, without discrimination.
• Team spirit and job satisfaction: The company emphasizes fostering team spirit and ownership, which leads to low employee turnover (average length of service of about 7.7 years) and a strong workplace culture.
• Employees’ Association (STNA): The employees’ association strengthens culture, solidarity through events, education and social activities that enhance well-being and relationships within the company.

 

Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities S1-5

Norðurál places great emphasis on safety and occupational health safety so that accidents and incidents can be prevented. The company’s safety management system is based on the philosophy of continuous improvement and is certified by ISO standards. Risk management and incident investigations are part of Norðurál’s key management system processes reviewed in internal audits.

To ensure the safety of staff, contractors, and visitors to the site, all those who work on and visit Norðurál’s premises must familiarize themselves with the safety rules. The rules apply to everyone who enters Norðurál’s premises. We work under the slogan “All for one!” which refers to the fact that safety is a collaborative project of all of us who work at Norðurál. We look after each other and help one another to address all tasks sensibly and safely.

Organizing and managing occupational health and safety at Norðurál

Norðurál operates a systematic health and safety management system with an emphasis on prevention, improvement and active participation of employees. The Safety, Health and Environment Committee (SHE), led by Norðurál’s managing director, consists of the executive board, safety representatives and shop stewards. The committee promotes improvements and sets goals in accordance with Act No. 46/1980.

The main tasks of the SHE committee and related professional councils are:

• Risk assessment and education on safety and health.
• Monitoring of equipment and facilities.
• Registration and analysis of accidents, incidents and health incidents.
• Monitoring of bullying, wellbeing and the use of personal protective equipment.
• Consulting on policy and work processes.

Norðurál operates according to standard operating procedures based on a risk analysis. All work is risk-screened before implementation and employees discuss safety issues at the beginning of the shift in daily whiteboard meetings. Contractors receive training and an introduction to safety rules before they start working for the company.

“Safe behavior” is a safety culture project based on employee participation. It involves analyzing the work environment and procedures with an emphasis on safe execution. Goals are set and we celebrate when safe habits are achieved. In 2024, participation in the project was over 97%.

All safety and environmental incidents are registered in Norðurál’s reporting system and processed through actions and incident analysis. Registrations also include deviations in the quality system and responses to customer and supplier feedback.

Norðurál emphasizes continuous review and improvement in safety and health matters through active dialogue, metrics and training of employees at all levels.

Safety training and safety culture in the workplace

Safety training is a cornerstone of Norðurál’s risk management. All employees attend an induction course upon hiring and training in safe procedures according to risk assessments. In 2024, special emphasis was placed on training in lock-tag-verify procedures, working at height, access to confined spaces and response training. Managers and foremen also received special training on safety culture and risk management.

Safety was at the forefront during the annual “inset days”. The importance of personal responsibility was discussed and employees participated in a workshop where they answered the question “Why do you put safety first?”

The Golden rules for safety were introduced in 2024. The rules are based on standard procedures and describe behavior that contributes to an accident-free workplace. Employees are encouraged to stop work if conditions are unsafe and look for ways to ensure safe procedures.

Norðurál has followed the “Safe Behavior” methodology since 2011. The goal is to promote safety awareness and establish safe working practices. Performance is measured and we celebrate when goals are achieved. In 2024, 97% participation in the project was achieved.

A safety culture survey was conducted in 2024 with approximately 80% employee participation. Results showed improved knowledge of goals, increased visibility of safety values, and stronger participation in prevention. The survey was previously conducted in 2017 and the current results show measurable progress in developing a safety culture.

Ongoing projects include strengthening shared responsibility, improving safety training and increasing positive feedback. Safety is a shared responsibility and the key to making Norðurál’s vision of an accident-free workplace a reality.

 

Characteristics of the undertaking’s employees S1-6

At the end of 2024, a total of 675 people worked at Norðurál.

Broken down by:

• Gender (male 530, female 145, other 0)
• Positions / roles: Grundartangi 645 Norðurál EHF 30
• Employment types: Permanent 590, substitute job 82, temporary 3

Employee turnover was 11.43%, average age and average tenure 7.5 years.

Norðurál partially employ purchased services and contractors for limited projects, including maintenance, technical solutions and cleaning. Contractors follow the same safety rules as other employees and receive the same training.

Residence of Norðurál Employees

• Akranes 57%
• The capital area 32%
• Borgarfjörður 5%
• Hvalfjarðarsveit municipality 4%
• Elsewhere in Iceland 2%

 

Characteristics of non-employee workers in the undertaking’s own workforce S1-7

Numerous contractors work for Norðurál at any given time, whether in specialist positions or as production operators. Contractors work in close collaboration with Norðurál employees and managers. Contractors working within Norðurál are hired on the basis of expertise or specialization in the relevant field. They are subject to the same rules and requirements as other Norðurál employees when it comes to competence, knowledge and compliance with safety rules. All contractors regularly attend safety courses.

Contractors are subject to the same safety rules and education as other employees:

• They receive training and an introduction to safety rules before they start working for the company.
• They must follow Norðurál’s rules on occupational health and safety, the use of personal protective equipment and participation in feedback systems.
• Coordinated processes ensure that contractors’ procedures and equipment are comparable to regular employees.

 

Collective bargaining coverage and social dialogue S1-8

The majority of Norðurál employees, around 470 people, are employed as production or maintenance workers under a collective agreement. Managers, middle managers, specialists, and some office workers have employment contracts that are not linked to a collective agreement. The notice period for permanent staff is one week during the trial period, one to three months during the first year of employment, and at least three months after that. Under the collective agreement, employees leave the employ of the company in the month when they turn 67 years old. Five employees retired due to age in 2024. The company offers those nearing retirement age a course addressing a variety of issues to be considered at such a juncture.

A large majority of Norðurál’s workforce belongs to the trade unions VLFA, FIT, RAFIS, StéttVest, and VR. A collective agreement between Norðurál and the unions was signed in April 2025 and will remain in effect until year-end 2029.

 

Diversity metrics S1-9

Diversity and equality are key factors in creating a positive and constructive workplace culture. Equality goals are the guiding principle in all recruitment, as every recruitment is aimed at hiring the right person for the job while considering the underrepresented gender. This provides opportunities to recruit more women as production operators and tradespeople, as well as engineers and technicians in middle management.

As in the previous year, Norðurál received an Equality Scale from the Association of Women Business Leaders in Iceland (FKA) in 2024. The recognition is given to those companies that have taken action to equalize the share of women in senior management and have managed to equalize the proportion of the sexes at the top of management. The goal is for the ratio between men and women in the executive management of Icelandic companies to be at least 40/60 by 2027. Three out of seven members of Norðurál’s Executive Team are women.

Norðurál has a certified equal pay system in accordance with the equal pay standard ÍST 85:2012 and has also received a Gold Certificate in PWC’s equal pay audit for five years in a row, or since the equal pay audit was first carried out.

In 2024, BSI conducted a maintenance audit of the equal pay system, which confirmed that the equal pay system is designed to achieve the objectives of the company’s equal pay policy.

The unexplained gender pay gap at Norðurál in 2024 was 1.1% and the coefficient of determination was 95%.

 

Adequate wages S1-10

Please see more under S1-8.

 

Social protection S1-11

Norðurál always adheres to the applicable collective agreements that the company has made with the relevant unions. The collective agreement guarantees the rights and obligations of employees, such as wages, sick leave, holiday entitlement, termination provisions, maternity leave, accident-related rights and retirement due to age.

The rights of those outside the unions are guaranteed in an employment contract, which specifically addresses sick leave, vacation rights, maternity leave, accident-related rights, insurance, provisions for pension funds, food and health benefits.

All Norðurál employees have access to the public social security system in accordance with Icelandic law and collective agreements. This includes, among other things, the right to health care, unemployment benefits, disability benefits, maternity leave and pension fund payments.

Therefore, 100% of Norðurál employees are insured by social security and no employee is excluded from such rights.

 

Persons with disabilities S1-12

Norðurál respects the rights of people with disabilities and therefore refers to the company’s equality and human rights policy as well as laws that apply to the issue. Generally, there is no discrimination on the basis of disability when hiring within the company, but special consideration must be given to the working environment and whether it is possible to accommodate a disabled person.

 

Training and skills development metrics S1-13

Norðurál places great emphasis on the education and training of employees. The employees of Norðurál have various opportunities to educate themselves further and develop their careers. The need for training and career developments is assessed every year in accordance with the ambition and competence of the individual and the needs of the company. Promising employees are encouraged to seek further development and training.

Training schedule 

Our training schedule is made for three years at a time and sets guidelines for the education and training that employees receive. Production employees annually review guidelines for regular work procedures. In addition to regular training, Norðurál’s policies on quality standards, the environment, health and safety, human rights, and equality are visibly displayed throughout Norðurál’s facilities and through the company’s communication channels.

Human resources and training system 

Norðurál uses Kjarni, a human resources and payroll system. The system offers a wide range of possibilities for keeping track of information and data related to employee education, training and certifications, and work has been done on its utilization and development. During the year, emphasis was placed on the implementation of electronic educational materials and the production of educational materials on safety issues and increased access to various types of electronic education. Norðurál uses the Learncove teaching system to disseminate electronic education, which is useful for dissemination and follow-up on progress.

Total training hours: 11,730:

• 477 hours of induction training
• 585 hours in regular safety courses
• 1,050 hours in management training – safety management
• 3,390 hours of team training (“inset days”)
• 6,229 hours of additional types of training

Reception and training of new employees

New hires at Norðurál receive induction training focused on safety matters and environmental concerns. They are also given an overview of the company’s policies and production procedures before beginning intensive training specific to their position. In 2024, employees received an average of 19.5 hours of training. New employees attend courses and receive specific training in accordance with their roles. Examples include safety courses that are mandatory for certain groups, such as “Lock-tag-verify”, fall protection courses and courses on working in confined spaces. Contractors are provided with a general safety presentation each year and courses as needed.

Inset days 

In the spring, annual “inset days” were organized for all employees with various types of education and workshops. Department and group issues were addressed with discussions on the most important issues. Material from the safety, environment and improvements department (ÖUU) was also covered, including a review of Norðurál’s policies and objectives, the effectiveness of the feedback system, the contingency plan, risk assessments, use of PPE, road safety and chemical issues. The environmental impact of production was also covered, along with waste classification and waste management. There was also a workshop on team building.

Safety training

Great emphasis is placed on all types of safety training, whether it is safety in the workplace, psychosocial safety or information security. Safety issues are an absolute priority, as the emphasis is on creating a safe working environment in all respects.

The primary focus of safety training in 2024 was behavior-based safety, response team training and leadership training for shift and team supervisors. There was also training in the use of portable fire extinguishers for all staff in the autumn.

Management training 

This year, management training was primarily focused on managing safety issues. Aspects such as risk management, incident investigations, on-site inspections and safety culture were reviewed. Shift managers, team leaders and department heads in production participate in management training. Production specialists also participate in some of this training.

Norðurál places great emphasis on the education and training of employees. The employees of Norðurál have various opportunities to educate themselves further and develop their careers. The need for training and career developments is assessed every year in accordance with the ambition and competence of the individual and the needs of the company. Promising employees are encouraged to seek further development and training.

 

Health and safety metrics S1-14

Norðurál makes employee safety and health a priority in all operations. The company measures and evaluates its health and safety performance using the following key performance indicators, which are in line with the requirements of the ESRS and the ISO 45001 standard:

KPIs:

Safety and health objectives:

• Accident-free workplace – no one is injured while working
• Employee health – all employees undergo annual health checks
• Employee participation in prevention – 90% of employees receive annual safety training

 

Work-life balance metrics S1-15

Norðurál aspires to be a family-friendly workplace where there is a balance between work and private life.

It is generally expected that employees carry out tasks at their location. Employees are accommodated where appropriate and have the option to work remotely when circumstances and tasks allow. This is implemented in each area individually in consultation with the immediate superior.

Job satisfaction increased from 3.54 in 2022 to 3.64 in 2023. It was not measured in 2024.

In 2025, so-called pulse measurements will be introduced where job satisfaction is measured more often throughout the year so that work on improvements will be more targeted.

 

Remuneration metrics (pay gap and total remuneration) S1-16

Norðurál has had a certified equal pay management system in accordance with the Icelandic equal pay standard ÍST 85:2012. In 2024, BSI conducted a maintenance audit of the equal pay system, which confirmed that the equal pay system is designed to achieve the objectives of the company’s equal pay policy. Norðurál’s goal is that there is no unexplained gender pay gap between the sexes. In 2024, it was found to be 1.1% in favor of men.

In 2024, two market salary analyses were conducted, one by PWC and the other by Intellecta. These analyses showed that Norðurál pays fair and competitive salaries.

 

Incidents, complaints and severe human rights impacts S1-17

According to Norðurál’s human rights and equality policy, the company emphasizes equal rights for employees regardless of gender, sexual orientation, religion, origin or other aspects related to human rights and equality. Norðurál aims for continuous improvements and complies with laws and other stipulations on human rights and equality.

Norðurál has zero tolerance towards bullying, gender-based and sexual harassment, and violence. Employees are encouraged to report all incidents or suspicions of bullying, sexual and gender-based harassment and/or other violence to their immediate supervisor or HR.

In 2024, no formal reports of bullying, sexual harassment, gender-based harassment or violence were received.

 

Policies related to value chain workers S2-1

Norðurál works systematically to ensure that the company’s value chain is based on responsible working practices. In doing so, Norðurál seeks to ensure that the conditions for employees, suppliers, service providers and contractors, are fair and just.

In addition to the procurement policy, Norðurál and its parent company Century Aluminum have set out a Code of Ethics for Suppliers and Business Partners:

• Ethical and social responsibility: Suppliers and business partners must adhere to terms that stipulate respect for human rights, prohibition of forced labor and child slavery, equality and acceptable working conditions.
• Statutory and collective bargaining requirements: All business partners are required to comply with applicable laws and regulations and fulfil the main requirements of Century Aluminum’s code of ethics.
• Integration of contractors into the safety and quality system: All contractors working on Norðurál’s site receive training and access to the company’s safety regulations. They are subject to the same occupational health and safety procedures as Norðurál’s employees.
• Work on supplier risk analysis: Norðurál has implemented a procedure to assess risks in the supply chain, especially in areas where the legal framework and monitoring are weaker.
• Criteria and implementation: Work is underway to implement objectives in supply chain management in accordance with the criteria of the Aluminium Stewardship Initiative (ASI) and international sustainability standards.

 

Processes for engaging with value chain workers about impacts S2-2

Norðurál demands from suppliers to respect human rights and the rights of employees in the supply chain through a purchasing policy and a code of conduct for suppliers, which include clear expectations regarding:

• Occupational Safety and Security
• Equality and non-discrimination
• Right to form unions
• Prohibition of forced labor

Evaluation of suppliers and impacts in the value chain is carried out through supplier assessments and site visits to suppliers. Norðurál and Century Aluminum are, among other things, collaborating with EcoVadis, an international assessment company specializing in sustainability, labor rights and ethics in value chains. Eco Vadis collects and evaluates information from suppliers and others in accordance with international standards.

 

Processes to respond to negative impacts on employees in the value chain S2-3

Norðurál has set itself the goal of ensuring that parties in the value chain respect human rights, occupational health and safety, collective agreements and statutory rights of employees. The company emphasizes building cooperation with suppliers and service providers on core values of social responsibility, equality and safety.

Goal:

• All key suppliers and service providers meet Norðurál’s basic requirements for ethics and social responsibility.
• Work is underway to increase transparency in the value chain through clear requirements and certifications.
• We are working systematically to reduce the risk of human rights violations, workplace accidents or inequality in the supply chain.

Measures:

• In 2024, we began working with EcoVadis with the aim of assessing the sustainability of suppliers.
• Formal supplier terms have been implemented with requirements to comply with laws and collective agreements.
• Suppliers who are directly involved in Norðurál’s production process are assessed – e.g. for raw materials, contractors and services.
• Special assessment processes are used for suppliers in countries where the legal framework and trade unions are weaker.

 

Taking action on material impacts on value chain workers, and approaches to managing material risks and pursuing material opportunities related to value chain workers, and effectiveness of those action S2-4

Norðurál assesses all suppliers according to a specific process. Business with suppliers who are deemed not to meet requirements is temporarily suspended or terminated.

Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities S2-5

The Procurement Policy and the Code of Conduct for Suppliers stipulate that provisions on human rights are met.

 

Policies related to affected communities S3-1

Norðurál places great emphasis on ensuring that the company’s operations are in harmony with the local community and contribute to long-term positive impacts. The core of Norðurál’s corporate social responsibility is to create value in a sustainable and responsible manner, taking into account the environment, economy and society.

Norðurál works systematically to analyze and understand the impact of its operations on society and actively collaborates with its main stakeholders. Emphasis is placed on recognizing common interests and finding opportunities for improvement and positive impact.

In 2024, a stakeholder analysis and a dual materiality analysis were carried out in collaboration with the consulting firm Langbrók. The analysis was part of the sustainability strategy and approach for Norðurál’s sustainability report.

The stakeholder analysis was carried out in co-operation with Norðurál’s managing director and steering committee and involved prioritizing stakeholders based on importance, risks and opportunities in the operations.

The double materiality assessment involved conversations and interviews with customers, suppliers, municipalities and the parent company, Century Aluminum. The following were assessed:

• The impact of the company’s operations on society and the environment.
• The impact of sustainability factors on the company’s operations.

The results provide a basis for targeted prioritization and disclosure of sustainability issues and support ongoing communication and responsibility towards society.

Creating long-term value in a sustainable and responsible manner, for the long term and with a positive impact on society, is at the heart of Norðurál’s corporate social responsibility.

Norðurál has partnered with the following organizations and associations:

• (ASI) Aluminium Stewardship Initiative
• Álklasinn – Aluminum Industry Cluster Initiative
• European Aluminum
• Festa – Icelandic Center for Corporate Social Responsibility
• Grænvangur – Green by Iceland
• Samál – Association of Icelandic Aluminum Producers
• Samtök atvinnulífsins – Confederation of Icelandic Employers
• Samtök iðnaðarins – Federation of Icelandic Industries

The company has developed a clear vision and practices of social responsibility and active participation in our local communities’ environmental issues. Norðurál strives to strengthen trust, transparency and active communication with stakeholders and build long-term partnerships with the local community in Grundartangi and Hvalfjörður municipality. The progress of individual community projects is reviewed regularly and is part of the company’s sustainability indicators.

Strategic focuses include:

• Active participation in community projects and support for sports, culture and youth activities.
• Support for scientific and innovative projects, especially related to energy and the environment.
• Open dialogue and consultation with municipalities, regulatory agencies and residents, for example with regular public meetings.
• A clear response plan to social challenges, such as in relation to environmental issues or changes in operating conditions.

Community support and participation

Norðurál sees it as part of its social responsibility to support diverse and constructive activities in the local community. The goal is to have a positive and lasting impact on the community around the operations through direct support, active participation and collaboration with stakeholders. When selecting projects, emphasis is placed on supporting social infrastructure that benefits children and young people.

Norðurál sponsors a number of community projects, with more than ISK 20 million being provided for such projects in 2024. The company is a proud sponsor of the ÍA football club in Akranes and the Valur football club in Reykjavík. When awarding grants, emphasis is placed on ensuring that they are reflected in the work of young players. Additional sponsorship agreements have been made with Fablab and Leynir Golf Club in Akranes.

Smaller grants include these recipients: Mæðrastyrksnefnd Akraness (the Akranes Mothers’ Aid Society), Björgunarfélags Akraness (the Akranes SAR team), Fjölbrautaskóli Vesturlands (the Comprehensive College of West Iceland), Skógræktarfélags Ísland (the Icelandic Forestry Association), Íþróttasamband fatlaðra (Sports Association for the Disabled, Hinsegin dagar (Gay Pride), Bestu deildarinnar (Soccer club), Efnafræðifélag Íslands (Icelandic Chemistry Society), Samhjálp (Shelter for People on the fringes of society), Krabbameinsfélagsins Framfarar (Framför Cancer Society), Blindrafélagið (Icelandic Association of the Visually Impaired), Kvenréttindafélags Íslands (The Icelandic Women’s Rights Association) and Nemendafélaga Grundaskóla og Brekkubæjarskóla (elementary schools Grindaskóli and Brekkubæjarskóli Student Associations) and various student associations in both upper secondary schools and universities.

Norðurál actively collaborates with various organizations and stakeholders, including:

• Aluminium Stewardship Initiative (ASI), which confirms Norðurál’s commitment to responsible and transparent aluminum production.
• Álklasinn (The Icelandic Aluminum Cluster) and European Aluminum, to strengthen competitiveness and sustainability in European aluminum production.
• Festa Icelandic Center for Corporate Social Responsibility and Grænvangur (Green by Iceland), in favor of responsible business practices and our goals for carbon neutrality and green transition.
• Samál (The Association of Icelandic Aluminum Producers), the Confederation of Icelandic Employers the Confederation of Icelandic Industries, in relation to advocacy, strategy planning and the development of the Icelandic economy.

 

Interests and views of stakeholders ESRS 2 SBM-2

A double materiality assessment was carried out by Norðurál in 2025 in accordance with ESRS standards and as part of the company’s preparation for sustainability reporting under CSRD. The analysis included both financial impacts (outside-in) and the impact of the operations on society and the environment (inside-out). The aim was to identify risks and opportunities related to sustainability and prioritize the major factors that are relevant to Norðurál’s operations and society. The analysis was based on internal assessments and conversations with key stakeholders, including key managers and staff, local government representatives, regulators, suppliers, and customers.

The results of the analysis support:

• The selection of content in the company’s annual and sustainability report.
• Norðurál’s long-term sustainability strategy.
• Prioritization of actions related to social responsibility, environmental and climate issues.

They confirm the importance of sustainability in the value chain, responsible procurement and clear information provision to customers, ensuring long-term competitiveness and trust.

Stakeholders emphasize:

• Total carbon footprint (Scope 1, 2, and 3), positive effects of green aluminum for end users, innovation and sustainability.
• Responsibility in the value chain and information provision to customers.
• Origin of raw materials and responsible supply chain management.
• Quality of data, traceability of origin and certifications.
• Impact of production on image and market expectations.

 

Material impacts, risks and opportunities ESRS 2 SBM-3

Norðurál places great emphasis on analyzing and understanding both the actual and potential impacts of its operations on the local community. Mapping the attitudes of key stakeholders in the local community and societal expectations is the basis for a targeted sustainability policy and disclosure.

A Double Materiality Assessment conducted in 2025 showed:

• The company’s impact on the community, particularly in the Hvalfjörður region and surrounding areas.
• The impact of societal factors on Norðurál’s operations, including reputation, licensing, energy security and access to labor.

Impact:

• Norðurál’s operations have a positive economic impact on the local community through jobs, service purchases and community projects.
• Collaboration with scientific and educational institutions promotes innovation and knowledge development.
• Norðurál produces aluminum with a low carbon footprint that supports energy transition and the circular economy and improves energy efficiency and recycling properties in the final product.
• The main negative impacts are related to potential environmental impact that can affect public trust and licensing.

Risks:

• Reputational risk.
• Disruptions to operations due to lack of consensus or delays in licensing.
• Technical and operational difficulties in meeting customer requirements.
• Risks related to security of supply and market fluctuations.

Opportunities:

• Stronger collaboration with the community and stakeholders that reinforces trust and operational security.
• Increased innovation in collaboration with scientific and educational institutions.
• Positive economic impact on the region through jobs and service purchases.
• Growing demand for products with a certified carbon footprint (e.g. Natur-Al™).
• Deeper business relationships and long-term contracts with customers who prefer aluminum produced in a responsible and sustainable manner.
• Increased competitiveness of Norðurál as a producer of environmentally friendly Icelandic aluminum.

 

Processes for engaging with affected communities about impacts S3-2

Many aspects of our methods of work are the result of discussions and cooperation with stakeholders. Our communication with them is based on a commitment to transparent and honest interactions, and this is an important part of the company’s continued success.

Cooperation and procedures, including the frequency of cooperation, depend on the stakeholders and their nature. Communications take place according to a communications plan, and cooperation and construction projects are recorded in Norðurál’s management systems. Our suppliers and contractors must comply with Norðurál’s safety and environmental standards and code of ethics. We appreciate feedback from stakeholders and strive to respond to all queries.

 

Processes to remediate negative impacts and channels for affected communities to raise concerns S3-3

See S3-2.

 

Taking action on material impacts on affected communities, and approaches to managing material risks and pursuing material opportunities related to affected communities, and effectiveness of those actions S3-4

• Norðurál operates according to detailed, certified production processes. In addition, Norðurál has a certified environmental and safety management system.
• Detailed disclosure of operations and impacts to the local community and other stakeholders.

 

Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities S3-5

• Norðurál’s certified management systems have inherent processes for continuous improvement.
• Detailed disclosure of operations and impacts to the local community and other stakeholders.

 

Consumers and end-users S4

Norðurál sells aluminum to customers in European markets, mainly in the automotive and construction industries. The company’s decisions on production, traceability and sustainability impact consumers and stakeholders down the value chain.

Description of the processes to identify and assess material impacts, risks and opportunities ESRS 2 IRO-1

Please see GOV-2 under Stjórnarhættir

Policies related to consumers and end-users S4-1

Norðurál emphasizes long-term cooperation with customers based on transparency, trust and mutual benefit. The company’s policy is to offer a responsible and traceable product that meets the strictest quality requirements and contributes to our customers’ sustainability goals.

Key points in Norðurál’s customer policy:

• Low-carbon aluminum with certification: Norðurál produces certified aluminum with only about 4 tons of CO₂ equivalents per ton of aluminum. This is among the lowest carbon footprints in the world and enables customers to achieve their own climate goals.
• Disclosure and traceability: Norðurál provides clear information about the origin of raw materials, energy efficiency and carbon footprint. The product is traceable from raw materials to delivery and information is accessible to customers.
• Quality assurance and product warranty: Norðurál operates according to a certified quality system (ISO 9001) and defines product warranty according to agreements and recognized procedures.
• Collaboration on innovation: Norðurál actively participates in collaborative projects with customers aimed at developing sustainable solutions, a circular economy and environmentally friendly product development.
• ASI certification: Norðurál is the first aluminum producer in Iceland to receive certification from the Aluminum Stewardship Initiative (ASI), thus ensuring responsible business practices and sustainable production according to international standards.

 

Processes for engaging with consumers and end-users about impacts S4-2

Norðurál maintains regular and effective communication with customers. Customers can access information about the production process from the Annual and Sustainability Report, Life Cycle Analysis, Environmental Product Declarations (EPDs), audits and general visits.

Processes to remediate negative impacts and channels for consumers and end-users to raise concerns S4-3

There have been no incidents at Norðurál in recent years related to:

• Violations of customer data privacy or data loss.
• Data leakage from Norðurál or the group’s systems.
• Norðurál works in accordance with Century Aluminum’s data protection rules and uses secure systems for all business communications.

 

Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities S4-4, S4-5

Norðurál has set measurable goals and priorities with the aim to minimize negative impacts and maximize positive impacts on its customers. The goals are part of the company’s sustainability policy and its management system goals. They are based on transparency, responsibility and collaboration with customers.

Main goals and priorities:

• Satisfied customers: The company regularly monitors customer satisfaction and strives to provide reliable service and high-quality products.
• Low carbon footprint of products: Norðurál’s goal is to keep the carbon footprint of aluminum below 4 tons of CO₂ equivalent per ton produced, which is about a quarter of the global average. This makes the company’s products an environmentally friendly option for customers who want to reduce their own emissions.
• Innovation and development: Norðurál emphasizes innovation and the development of processes with sustainability as a guiding principle to meet increasing demands for environmental responsibility and traceability in the value chain.
• Transparency and disclosure: The company ensures detailed and regular disclosure of information about the product’s origin, carbon footprint, and the production process in accordance with international standards and customer needs. This includes certification according to the Aluminum Stewardship Initiative (ASI).

Actions to achieve goals:

• Collaboration with customers on the development of low-carbon products and circular solutions.
• Production certification according to the Aluminum Stewardship Initiative (ASI).
• Use of recognized traceability processes and data collection for environmental information.
• Informed service and response to suggestions or complaints.

Risk and opportunity management:

• Norðurál regularly performs a sensitivity analysis of the financial impact of changes in raw material markets, energy prices and environmental requirements (cf. IRO-1).
• The goals are part of an integrated sustainability strategy and managed in collaboration with the business department and the sustainability implementation team.