Employment and Social Affairs

Employment in the natural resources sector

The extractive industry provides industrial jobs in a variety of different occupations and activities. At the end of 2022 (2023), around 59,000 people (58,000 people)¹ were employed in the extractive industry. This corresponds to around 0.17% (0.17%) of all employees in Germany subject to social security contributions. At around 65% (65%), most employees worked in the quarrying and other mining sector, followed by the provision of services for mining and quarrying at around 15% (15%).

Compared to the reporting period 2016 (1st D-EITI report), the number of employees in the sector fell by around 12,300 in 2022 (13,300 in 2023), mainly due to the phasing out of the hard coal mining by the end of 2018.

Each direct job in the extractive industry is associated with additional jobs in upstream and downstream economic sectors.²

The role of legislation

The German economic system is characterised by the interplay of free market activities and state social policy. At the same time, there is a strong social partnership, especially in the extractive sector, by means of which existing differences of interest between employers and employees can be compensated.

In principle, the German legislature regulates a uniform (minimum) level of protection for employees (e.g. working hours, holidays, protection against dismissal, protection laws for young people, pregnant women or the severely disabled, safety and health at work, etc.).³ Above this level of protection, the social partners are free to regulate working conditions independently for the company or the respective sector within the framework of their collective bargaining autonomy guaranteed by Article 9(3) of the German Basic Law.

Statutory social security provides protection against life risks such as unemployment, illness, dependency, accident and occupational disease as well as old-age security. In particular, employees are insured under the social security scheme; self-employed persons are partially covered by this scheme. Social insurance funds are mainly raised through contributions from insured persons and employers. An exception is the statutory accident insurance, which is financed exclusively by the employer. Some branches of social security are additionally financed by taxes. The social security institutions are corporations with legal capacity under public law with self-government. Self-government is generally exercised by the insured persons and the employers.

The role and cooperation of the social partners

Co-Determination

One of the main pillars of the social market economy in Germany is co-determination, i.e. the right of employees and their stakeholders to participate in company or entrepreneurial decisions. The scope and form of participation differ according to company size, legal form and industry.

Company co-determination goes furthest in mining and in the iron and steel producing industry (co-determination in the coal, iron and steel industry: (MontanMitbestG (~Act on Co-determination in the Coal, Iron and Steel Industry),⁴ MontanMitbestGErgG (~ Supplementary Co-determination Act)⁵): Here, the supervisory boards are made up of an equal number of shareholder and employee representatives. In addition, a labour director is appointed, who is responsible for personnel and social affairs as an equal member of the management. According to the MontanMitbestG, his/her appointment is subject to the approval of the majority of employee representatives in the supervisory board.

For other companies, which are managed in the legal form of a corporation or a cooperative, the equal representation of employees and shareholders in the supervisory bodies according to the Co-Determination Act (MitbestG) also applies in case of more than 2,000 employees. However, there are two significant differences compared to the co-determination in the coal, iron and steel industry.

If there is a tie in votes, the Chairman of the Supervisory Board, who is generally attributable to the shareholders, has the casting vote. This dual voting right of the Chairman of the Supervisory Board effectively overrides the formal parity between employees and employers. In addition, the labour director can in principle also be appointed against the votes of the employee representatives on the supervisory board. To companies with 500 to 2,000 employees, the one third participation of employee representatives on the supervisory board (DrittelbG⁶) applies.

Company co-determination is governed by the Works Constitution Act. In every company in Germany with at least five employees, employees have the right to elect a works council. As representative of all employees, the works council represents the interests of the employees vis-à-vis the employer. It has different rights of participation, especially in social, personnel and economic matters. Works agreements are a key instrument in the work of the works council. Similar to collective agreements, they are legally binding agreements between the employer and the works council and regulate the employment relationship of the employees. Frequent topics are regulations on working hours, occupational health and safety, health promotion, data protection or further training, which are tailored to the conditions prevailing in the company. However, the works council must also be involved in the introduction of new technical equipment and work processes or the drawing up of social plans in the event of planned operational changes.

Collective bargaining coverage

Freedom of association and the right to collective bargaining are guaranteed in Germany by Article 9 of the Basic Law. Collective agreements are concluded by one or more employers or employers’ associations with one or more trade unions. They are binding only on their members (collective bargaining coverage). However, it is common practice for employers bound by collective agreements to allow employees who are not unionised to participate in what has been agreed by collective agreement by referring to the relevant collective agreements in individual contracts. In addition, many companies that are not bound by collective agreements are guided by existing collective agreements. In 2022, 32% of the companies in the extractive sector⁷ were bound by collective agreements; 25% within the framework of a regional collective agreement and 7% with a company collective agreement. The collective agreements apply to 62% of employees in the sector, with 25% subject to the terms of a regional collective agreement and 37% subject to those of a company collective agreement.⁸

Training

The demanding activities in the extractive industry require well-trained specialist personnel. Approximately 74% (74%) of employees have a recognised vocational qualification⁹, and another 11% (12%) have an academic degree¹⁰ in, for example, engineering.

Vocational training in Germany is essentially carried out via the dual vocational training system, in which training takes place in parallel at two learning locations. The trainee concludes a training contract with the company and learns the necessary practical vocational skills and competencies in the workplace. The second pillar of the system is the vocational school, which teaches general and specialist theoretical knowledge. The duration of training depends on the respective profession and varies between two and three and a half years. During this time, the trainee receives a training allowance from the company. After successful completion of the training, you are qualified to work directly as a qualified specialist.

The sector provides training in a number of different professions. These include, for example, mechatronics technicians, electronics technicians, industrial and process mechanics, reprocessing mechanics, miners and machine operators, mining technologists and industrial clerks. At the reporting date¹¹, 1,998 (1,992) of the employees in the extractive industry were trainees, which corresponds to a training rate of 3.4% (3.3%). The training rate in the sector was therefore below the German average of 4.5% (4.5%). Looking at individual sectors, the picture for the extractive industries is relatively differentiated. For example, the training rates in the mining and quarrying industry fluctuate (from 0.8% (0.5%) to 4.9% (4.4%) (2022 (2023)) because the importance of training occupations varies and the proportion of semi-skilled workers varies accordingly.

Earnings level

Gainful employment plays a central role in both social and individual terms.

Work is undisputedly seen as the main source of livelihood, and earnings are the most important component of personal income for employees. The average gross monthly earnings of full-time employees in the sector amounted to EUR 4,682 per month in 2023, with an additional EUR 687 per month in special payments.¹² This means that average monthly earnings in the extractive sector are a good 8.8% higher than the average in the manufacturing and service sectors.¹³ Due to the income tax to be deducted and the proportionate social security contributions to be paid, employees’ individually disposable net wages are significantly lower than their gross wages.¹⁴

The average paid weekly working time was 40.5 hours, which was relatively high compared to the manufacturing industry as a whole, at 38.7 hours.¹⁵

In Germany, equality between women and men is protected by constitutional law. A key component of this is the requirement of equal pay for women and men for equal work and work of equal value. This means that gender-specific income differences in particular must be further reduced. This is also the aim of the Act on the Promotion of Pay Transparency between Women and Men (Pay Transparency Act (Entgelttransparenzgesetz (EntgTranspG))). Among other things, it includes an individual right to information for employees, reporting obligations for large companies and the requirement for large private employers to carry out company audit procedures to review pay structures.

The planned further development of the Pay Transparency Act will also take into account the EU Pay Transparency Directive, which entered into force in June 2023. The directive must be transposed into national law by June 2026. In 2023, the average gross monthly earnings of 5,636 euros of women in the extractive industry were 5.5% higher than the average gross monthly earnings of male employees (5,340 euros).¹⁶

Diversity and equal opportunities

The different life experiences and work horizons of employees make a significant contribution to the economic success of companies. By consciously promoting diversity, companies can tap into an important success and competitive factor that has a positive impact on both companies and their workforces.

Diversity can be measured using a range of quantitative indicators, such as the proportion of women among all employees and managers, the proportion of foreign employees or the age structure of the workforce.

At the end of 2022 (2023), the proportion of women among those employed in the sector subject to social security contributions was 13.7% (13.7%). Foreign nationals accounted for 6.7% (6.9%) of the total workforce.¹⁷

The proportion of female supervisory board members in the mining industry is very low at 15.4% (fiscal year 2021). Of the management board members of these companies, only 10.8% are women. In order to further increase the proportion of women in the workforce and in management positions, there is also a great need for action compared to other sectors. It should be noted that the employment structure is traditionally characterised by male-dominated technical training occupations and degree courses.¹⁸

At 61.4% (60.6%), the 25 to under 55 age group made up by far the largest proportion of the workforce, followed by the 55 to under 65 age group at 30.1% (29.8%). 7.4% (7.5%) of the employees were younger than 25 years and 1.3% (1.5%) of the employees were older than 65.

Equal opportunities in Germany are promoted by the General Equal Treatment Act (AGG). It prohibits discrimination in employment on grounds of race or ethnic origin, sex, religion or belief, disability, age or sexual identity.

Climate policy and structural change

The Federal Government has committed itself to implementing the climate targets and the Paris Climate Protection Agreement.¹⁹ In order to support this objective, in addition to ending the production of hard coal in 2018, hard coal and lignite-fired power generation in Germany will also be phased out by 2038 at the latest. With the political change in 1990, there was considerable intervention in lignite mining in eastern Germany, and in the early 1990s there was a drastic reduction in the number of people employed in the lignite mining areas in eastern Germany.²⁰ In order to make the decision to phase out coal and the associated structural change socially just, the German government set up the Commission on “Growth, Structural Change and Employment”²¹, which drew up proposals for shaping the structural change in Germany based on energy and climate policy. The aim of the commission was to make recommendations for the preservation and creation of new, good jobs secured by collective agreements in the affected regions, for the secure and affordable supply of electricity and heat at all times and for the preservation and further development of the coal-mining areas into regions that remain attractive and worth living in.

Climate policy requirements, security of energy supply and competitiveness were the subject of the Commission’s comprehensive dialogue. This social agreement on the use of coal was confirmed by the Bundestag and Bundesrat in July 2020 and resulted in the adoption of the Act to Reduce and End Coal-Fired Power Generation and to the amendment of other laws (Coal Phase-out Act) and the Coal Regions Investment Act (InvKG) (see below). The main component of the Coal Phase-out Act is the Act to Reduce and End Coal-Fired Power Generation (Act to Reduce and End Coal-Fired Power Generation – KVBG). With the adoption of these

laws, a social compromise was reached. Coal mining and coal-fired power generation are mostly located in structurally weaker regions, where they account for a significant share of industrial value creation. An industrial job has indirect and induced employments in various sectors, depending on the region.²²

The extraction of lignite in open-cast mines has an impact on the economic, ecological and social structure of the communities directly affected and the communities on the edge of the open-cast mines in the mining areas. The polluter pays principle applies to the influence and use of infrastructure and property. Compensation, relocation and resettlement must be arranged and paid by the mining companies. Since German lignite mining began in the early 1920s, 120,000 people have been relocated.²³

Villages are still affected by the resettlement. The owners of the affected areas are compensated by the companies for the resettlement. The same applies to municipal property. Municipal facilities will be rebuilt in agreement with the affected municipalities. Rare cases of compensation for expropriation under mining law²⁴ are stipulated by law (Art. 14(3) GG in conjunction with Section 84 et seq. German Federal Mining Act (BBergG)).

In the event of an agreement under private law, the parties concerned are directly responsible for determining the amount of compensation payments; only in the rare case of a necessary expropriation/assignment of land is this determined by the authorities following a valuation by an expert. It is subject to judicial review. The agreement on the lignite phase-out path has an influence on the expansion and adaptation of open-cast mines. New buildings planned in terms of infrastructure may not be necessary.

Based on the Coal Regions Investment Act (InvKG), which entered into force on 14 August 2020^25, the lignite coalfields²⁶ are supported with 40 billion euros, so that the mining areas can continue to exist as successful economic regions and the lost employment is compensated for (see also Effects of the energy transition). The Federal Government has also made a legal commitment to create 5,000 new jobs in federal authorities and other federal institutions in the coal regions by 2028. Even structurally weak hard coal-fired power plant locations receive funding under the Coal Regions Investment Act. Up to €1 billion is planned for this by 2038. The former lignite mining areas of Helmstedt and Altenburger Land will also each receive 90 million euros.

As part of the Coal Regions Investment Act, the “STARK” ²⁷ funding programme aims to continue to support the economically, ecologically and socially sustainable transformation of coal regions with the aim of turning them into internationally visible model regions for greenhouse gas-neutral, resource-efficient and sustainable development (see also Effects of the energy transition). On the one hand, this is achieved by investing in people and their commitment (networking, education, knowledge transfer, public services, understanding of the future and innovation). On the other hand, it requires business investment in transformation technologies (such as wind, PV, H2, batteries and CCSU).

In order to cushion the social consequences of the coal phase-out, the German government has also introduced an adaptation payment (APG) for older employees aged 58 and over in line with the recommendations of the Commission on “Structural Change, Growth and Employment”. The aim is to make it easier for these workers to retire earlier by granting an APG for a maximum of five years. Details of the APG under the Act to Reduce and End Coal-Fired Power Generation (KVBG) were regulated in separate APG guidelines by the former BMWi in agreement with BMAS and BMF dated 3 September 2020.

Corporate responsibility

German companies are closely integrated into global supply and value chains. As a result, the companies have a special responsibility, not only nationally but also internationally, to consider the conditions under which natural resources are extracted, and to combine economic success with social justice and ecological compatibility. This applies especially in the area of international mining, which can be associated with high human rights and social and environmental risks. Legislators, the German government and companies are addressing these challenges on several levels.

Internationally, the UN Guiding Principles on Business and Human Rights (2011) and the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct, which were last revised in 2023, provide an internationally recognised cross-sector framework for human rights due diligence and responsible business conduct. Although not legally binding, the principles and recommendations for companies laid down there correspond to the expectations of the Federal Government.

The Federal Government’s National Action Plan (NAP) to implement the UN Guiding Principles on Business and Human Rights contains a broad catalogue of measures to protect human rights. At the same time, the German government has enshrined the responsibility of German companies to respect human rights for the first time in the action plan. The NAP is currently being revised and the work is to be completed this year.

On 11 June 2021, the Supply Chain Due Diligence Act(LkSG) was adopted by the German Bundestag. The LkSG is closely aligned with the requirements of the NAP and the core elements of corporate due diligence enshrined therein. The LkSG is intended to improve the protection of human rights and certain environmental concerns in supply chains. Since 2023, the Act has applied to companies with a registered office or branch office in Germany and from 3,000 employees, and since 2024 to companies with 1,000 employees or more in Germany. In February 2022, the European Commission also presented a proposal for an EU directive on corporate due diligence regarding sustainability (Corporate Sustainability Due Diligence Directive, CSDDD). The Council of the European Union adopted the CSDDD on 24 May 2024. The Directive entered into force on 25 July 2024.³⁰

The so-called Conflict Minerals Regulation (EU) 2017/821 introduced mandatory due diligence requirements for EU importers of tin, tantalum, tungsten, their ores and gold (3TG) for the first time from certain thresholds in conflict-affected and high-risk areas. The aim of the ordinance is to curb the financing of armed conflicts through the proceeds from the sale of the minerals mentioned. The ordinance lays down numerous due diligence obligations that importers of 3TG have to comply with since 1 January 2021.

The national implementing law ²⁹,which entered into force on 7 May 2020, ensures the effective application of the Conflict Minerals Ordinance in Germany.

A directive on CSR reporting has been in place at EU level since 2014, which aims to increase transparency with regard to the environmental and social aspects of companies (Directive 2014/95/EU, Non-Financial Reporting Directive). Since the 2017 financial year, large companies of public interest in Germany with more than 500 employees have been reporting on their concepts for respecting human rights, among other things. In January

2023, the so-called Corporate Sustainability Reporting Directive came into force.³⁰ This Directive will gradually extend the group of companies obliged to report on sustainability to all large or capital market-oriented companies, starting with financial years beginning after 31 December 2023. Furthermore, binding EU reporting standards and mandatory auditing of the information to be reported are provided for the first time. Implementation into German law is to be completed by the end of 2024.

In addition to mandatory regulations, there are voluntary standards for environmental management systems, such as the globally applied ISO 14001 environmental management system standard or the more ambitious European environmental management system “Eco-Management and Audit Scheme” (EMAS), which promote sustainable business practices.³¹

Initiatives for greater sustainability are also increasingly being launched at industry level. For example, the Mining, Chemical and Energy Industrial Trade Union and the Construction, Agriculture and Environment Industrial Trade Union drew up a joint declaration on the sustainable use of natural resources in 2004 together with the Bundesverband (Federal Association) Baustoffe – Steine und Erden e.V. and the German Nature and Biodiversity Conservation Union (NABU).³² In addition to the most environmentally friendly natural resources extraction and the strengthening of biodiversity and resource efficiency, the high importance of employee training is also addressed. Employees and employers are also working together to achieve greater sustainability in the industrial processing of natural resources. For example, the social partners (trade unions and associations) in the German cement industry founded the “Cement connects sustainably” initiative back in 2002. In addition to nature and environmental protection measures, key issues include safeguarding domestic production, the economic interests of companies and the social interests of employees. The main aim of the sustainability initiative is to promote dialogue between politics and society as well as trade unions and employers.³³

 

Employment under the mandatory social security scheme by economic sector

Source: Federal Employment Agency (2022), reporting date 31 December 2021

* For reasons of data protection and statistical confidentiality, numerical values of 1 or 2 and data from which such numerical values can be mathematically deduced are made anonymous.

Each direct job in the extractive industry is linked to further jobs in upstream and downstream economic sectors.²

 

¹ Federal Employment Agency (2024): Employees by economic sector (WZ 2008) – Germany, West/East and Federal States (quarterly figures) – December 2023. URL: https://statistik.arbeitsagentur.de/Statistikdaten/Detail/202312/iiia6/beschaeftigung-sozbe-wz-heft/wz-heft-d-0-202312-xlsx.xlsx?__blob=publicationFile&v=1 (accessed 23 August 2024).

² See example DIW Econ (2022): Economic importance of the building materials and quarrying industry, including indirect and induced effects. A study by DIW Econ on behalf of the Bundesverband Baustoffe – Steine und Erden e.V., URL: https://www.bv-miro.org/wp-content/uploads/bbs-DIW-Studie-Volkswirtschaftliche-Bedeutung.pdf (accessed 12 July 2024)

³ Further information on statutory provisions and social security contributions: Federal Ministry of Labour and Social Affairs (BMAS) (2023): Social protection at a glance. URL: https://www.bmas.de/SharedDocs/Downloads/DE/Publikationen/a721-soziale-sicherung-im-ueberblick.pdf?__blob=publicationFile&v=6 (accessed 22 October 2024).

⁴  One-Third Participation Act (DrittelbG). URL: https://www.gesetze-im-internet.de/drittelbg/BJNR097410004.html (accessed 12 July 2024).

⁵ Act on Co-determination in the Coal, Iron and Steel Industry (MontanMitbestG). URL: https://www.gesetze-im-internet.de/montanmitbestg/MontanMitbestG.pdf (accessed 12 July 2024).

⁶ Supplementary Co-determination Act (MontanMitbestGErgG). URL: https://www.gesetze-im-internet.de/montanmitbestgergg/MontanMitbestGErgG.pdf (accessed 12 July 2024).

⁷ Federal Employment Agency (2024): Employees by economic sector (WZ 2008). Section B.

⁸ Federal Statistical Office (2022): Collective earnings, collective bargaining coverage. URL: https://www.destatis.de/DE/Themen/Arbeit/Verdienste/Tarifverdienste-Tarifbindung/_inhalt.html#sprg262570 (accessed 12 July 2024).

⁹ “recognised vocational qualification” is the sum of “with recognised vocational training” and “master craftsman/technician/equivalent technical college qualification”

¹⁰ “academic degree” is the sum of “Bachelor”, “Diploma/Magister/Master/State Examination” and “Doctorate”

¹¹ Federal Employment Agency (2024): Employees by economic sector (WZ 2008), reference date 31 December 2023.

¹² Destatis (2024): Average working hours and gross earnings of full-time employees in 2023 – the data are provided by Destatis on request.

¹³ Ibid.

¹⁴ In an international comparison, the tax ratio, which includes social security contributions as well as taxes, was 39.3% in Germany in 2022. See: Federal Ministry of Finance (BMF) (2024): The most important taxes in international comparison in 2023. URL: https://www.bundesfinanzministerium.de/Content/DE/Downloads/Broschueren_Bestellservice/steuern-im-internationalen-vergleich-2023.pdf?__blob=publicationFile&v=5 (accessed 31 October 2024).

¹⁵ Ibid.

¹⁶ The proportion of men employed is significantly higher among “skilled workers” in “mining” than the proportion of women. In contrast, the higher proportion of “specialists and experts” are employed women. Women are more likely to be represented in the administration (possibly higher positions) in this sector. For this reason, the structure of employees in higher paid employment affects the average results of gross earnings “as a whole”. A breakdown of average gross monthly earnings by job level can be found in the D-EITI report portal.

¹⁷ Federal Employment Agency (2024): Employees by economic sector (WZ 2008), reference date 31 December 2023.

¹⁸ Federal Government (2023): Eighth annual information from the Federal Government on the development of the proportion of women at management levels and on boards in the private and public sectors. URL: https://www.bmfsfj.de/bmfsfj/service/publikationen/… (accessed 14 August 2024).

¹⁹ Paris Climate Protection Agreement. URL: https://www.bmuv.de/fileadmin/Daten_BMU/Download_PDF/Klimaschutz/paris_abkommen_bf.pdf (Accessed 12 July 2024).

²⁰ Hauke Hermann, Katja Schumacher, Hannah Förster (Öko-Institut Berlin) on behalf of the German Federal Environment Agency (2018): Employment development in the lignite industry. URL: https://www.umweltbundesamt.de/sites/default/files/medien/3521/publikationen/2018-07-25_climate-change_18-2018_beschaeftigte-braunkohleindustrie.pdf p. 13 (accessed 4 January 2024).

²¹ Federal Ministry for Economic Affairs and Energy (2019): Final report of the Commission on Growth, Structural Change and Employment. URL: https://www.bmwk.de/Redaktion/DE/Publikationen/Wirtschaft/abschlussbericht-kommission-wachstum-strukturwandel-und-beschaeftigung.html (accessed 4 January 2024).

²² See example DIW Econ (2022): Economic importance of the building materials and quarrying industry, including indirect and induced effects. A study by DIW Econ on behalf of the Bundesverband Baustoffe – Steine und Erden e.V., URL: https://www.baustoffindustrie.de/fileadmin/user_upload/bbs/Dateien/Studie_Volkswirtschaftliche_Bedeutung.pdf (accessed 4 January 2024)“

²³ Federal Ministry for Economic Affairs and Energy (2019): Final report of the Commission on Growth, Structural Change and Employment. URL: https://www.bmwk.de/Redaktion/DE/Publikationen/Wirtschaft/abschlussbericht-kommission-wachstum-strukturwandel-und-beschaeftigung.html (accessed 4 January 2024).

²⁴ In that regard, the Basic Law (Article 14(3)) states: “Expropriation shall only be permissible for the public good. It may only be ordered by or pursuant to a law that determines the nature and extent of compensation. Such compensation shall be determined by establishing an equitable balance between the public interest and the interests of those affected. In case of dispute concerning the amount of compensation, recourse may be had to the ordinary courts

²⁵ Structural Strengthening Act for Coal Regions (2020). URL: https://www.bgbl.de/xaver/bgbl/start.xav?startbk=Bundesanzeiger_BGBl&jumpTo=bgbl120s1795.%20pdf#__bgbl____1741958588879 (accessed 4 January 2024)

²⁶ Lausitz coalfield (federal states: Brandenburg/Saxony), central German coalfield (Saxony/Saxony-Anhalt/Thuringia), Rhenish coalfield (North Rhine-Westphalia), Helmstedt coalfield (Lower Saxony).

²⁷ STARK is an abbreviation of the German for “Strengthening the transformation momentum and new beginnings in the regions and at the coal-fired power plant sites”

²⁸ See https://www.csr-in-deutschland.de/DE/Wirtschaft-Menschenrechte/Europa/Lieferketten-Gesetzesinitiative-in-der-EU/lieferketten-gesetzesinitiative-der-eu.html (accessed 12 August 2024).

²⁹ Act implementing Regulation (EU) 2017/821 of the European Parliament and of the Council of 17 May 2017 laying down supply chain due diligence obligations for Union importers of tin, tantalum, tungsten, their ores and gold originating from conflict-affected and high-risk areas (Mineral Raw Materials Due Diligence Act – MinRohSorgG) (accessed 19 July 2023).

³⁰ Directive (EU) 2022/2464 of the European Parliament and of the Council of 14 December 2022 amending Regulation (EU) No 537/2014 and Directives 2004/109/EC, 2006/43/EC and 2013/34/EU as regards sustainability reporting by companies (OJ L 322 dated 16 December 2022, p. 15

³¹ German Federal Environment Agency (UBA) (2024): Environment and energy management. URL https://www.umweltbundesamt.de/themen/wirtschaft-konsum/wirtschaft-umwelt/umwelt-energiemanagement#wozu-dient-ein-umwelt-und-energiemanagement)“ (accessed 26 August 2024).

³² Naturschutzbund Deutschland e. V., Bundesverband Baustoffe – Steine und Erden e.V., Mining, Chemical and Energy Industrial Trade Union and Construction – Agriculture – Environment Industrial Trade Union (2004): Joint declaration on the use of natural resources in Germany. URL: https://www.biodiversitaet-sichern.de/resources/artenschutz/gemeinsame-erkl%C3%A4rung-rohstoffnutzung-in-Deutschland (accessed 12 July 2024).

³³ See https://www.zement-verbindet-nachhaltig.de/