integrated management manual

Integrated

Management Manual

Revision 5.0 – April 2019

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INTEGRATED MANAGEMENT MANUAL (IMM)

Chapter 0 – Contents

1 Basic information .......................................................................................................... 5

2 Declaration of intention and company policy ............................................................. 6

3 Company portrait .......................................................................................................... 9

3.1 The company DILLINGER ............................................................................................. 9

3.2 Social Responsibility, Sustainability and environment ................................................. 13

3.3 History of DILLINGER ................................................................................................. 17

3.4 Organization of the Dillinger Group ............................................................................. 18

4 Context of the organization ........................................................................................ 19

4.1 Understanding of the organization and its context ...................................................... 19

4.2 Understanding the needs and expectations of interested parties ................................ 19

4.3 Determining the scope of the quality management system ......................................... 19

4.4 Integrated management system and its processes ..................................................... 19

5 Leadership ................................................................................................................... 21

5.1 Leadership and commitment ....................................................................................... 21

5.1.1 General 21 5.1.2 Customer focus 21

5.2 Policy ........................................................................................................................... 21

5.2.1 Establishing the Quality Policy 21

5.2.2 Communicating the Quality Policy 21

5.3 Organizational roles, responsibilities and authorities ................................................... 21

5.4 Consultation and participation of workers .................................................................... 24

6 Planning ....................................................................................................................... 25

6.1 Actions to address risks and opportunities .................................................................. 25

6.2 Quality objectives and planning to achieve them ........................................................ 27

6.3 Planning of changes .................................................................................................... 27

7 Support ......................................................................................................................... 28

7.1 Resources ................................................................................................................... 28

7.1.1 General 28

7.1.2 People 28

7.1.3 Infrastructure 28 7.1.4 Environment for the operation of processes 29 7.1.5 Monitoring and measuring resources 29

7.1.6 Organizational knowledge 30

7.2 Competence ................................................................................................................ 31

7.3 Awareness .................................................................................................................. 33

7.4 Communication ........................................................................................................... 33

7.5 Documented information ............................................................................................. 35

7.5.1 General 35 7.5.2 Compiling and updating 35

7.5.3 Control of documented information 36

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INTEGRATED MANAGEMENT MANUAL (IMM) Chapter 0 – Contents

8 Operation ..................................................................................................................... 37

8.1 Operational planning and control................................................................................. 37

8.2 Requirements for products and services ..................................................................... 38

8.2.1 Customer communication 38 8.2.2 Determining of requirements for products and services 39 8.2.3 Review of the requirements for products and services 39

8.2.4 Changes to requirements for products and services 39

8.3 Design and development of products and services ..................................................... 43

8.3.1 General 43

8.3.2 Design and development planning 45 8.3.3 Design and development inputs 45 8.3.4 Design and development controls 45 8.3.5 Design and development outputs 46

8.3.6 Design and development changes 46

8.4 Control of externally provided processes, products and services ................................ 47

8.4.1 General 47 8.4.2 Type and extent of control 48

8.4.3 Information for external providers 49

8.5 Production and service provision................................................................................. 50

8.5.1 Control of production and service provision 50

8.5.2 Identification and traceability 65

8.5.3 Property belonging to customers or external providers 67 8.5.4 Preservation 67 8.5.5 Post-delivery activities 68

8.5.6 Control of changes 68

8.6 Release of products and services ............................................................................... 68

8.7 Control of nonconforming outputs ............................................................................... 71

8.8 Aspects of occupational safety, health and environmental protection, of energy efficiency and safety of facilities .................................................................................. 72

8.8.1 Assessment of working conditions (risk and stress factors) 72

8.8.2 Placing orders with externals 75

8.8.3 Environmental aspects 75

8.8.4 Organization for emergencies and prevention of danger 78 8.8.5 Improvement of the energy related performance, including energy efficiency,

energy use and energy consumption 78 8.8.6 Binding commitments and the review of their compliance 79

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Chapter 0 – Contents

9 Performance evaluation .............................................................................................. 80

9.1 Monitoring, measurement, analysis and evaluation..................................................... 80

9.1.1 General 80 9.1.2 Customer satisfaction 81 9.1.3 Analysis and evaluation 82

9.2 Internal audit ............................................................................................................... 82

9.3 Management review .................................................................................................... 83

9.3.1 General 83 9.3.2 Management review input 83

9.3.3 Management review output 83

10 Improvement ................................................................................................................ 84

10.1 General ................................................................................................................ 84

10.2 Nonconformity and corrective action .................................................................... 84

10.3 Continual improvement ........................................................................................ 85

Revision 02 5


Chapter 1 – General information

1 Basic information

The present Integrated Management Manual outlines the fundamental building-blocks of the Integrated Management System (IMS) as well as the basic organizational structure, such as duties and responsibilities.

Scope of applicability extends over:

AG der Dillinger Hüttenwerke (incl. Heavy Fabrication Division)

Roheisengesellschaft Saar mbH (ROGESA)

Zentralkokerei Saar GmbH (ZKS)

Dillinger France

Steelwind Nordenham

Steel Service Centers, marketing companies, shipping companies and other companies of the Dillinger Hütte Group.

Furthermore, this Integrated Management Manual applies to Stahl-Holding-Saar (SHS) and to the SHS companies (SHS-Logistics and SHS-Services, SHS-Infrastructure), as far as they give instructions to, and provide services for, the Dillinger Hütte Group.

The processes, programmes, functions and committees described in this Integrated Management Manual partly relate to the situation at the Dillingen location. Especially in the areas of occupational health and safety as well as environmental protection and energy management, the subsidiaries have in position adjusted and harmonized regulations defined on site in own documents.

The foundations of the IMM are based on the current norms ISO 9001 (quality management), ISO 14001 (environmental protection), ISO 45001 (occupational health and safety), ISO 50001 (energy management) and safety management according to 12. BlmSchV, Appendix 3 (Federal Immission Control Act) (StörfallV - Ordinance on Industrial Incidents) – valid for the hazardous incident plants ZKS and ROGESA.

All employees are required to observe and apply this IMM. It is subject to regular evaluation by the Board of Management.

The present Integrated Management Manual (IMM) is Revision 5.0. It replaces the IMM Rev 4.0 of 2017 (IMH-D450-0001).

This Revision 5.0 takes into consideration the changes to the Norm ISO 45001:2018.

The content structure of this Integrated Management Manual (IMM) is orientated around the High Level Structure of the ISO Directive for Management System Standards and here, in particular, ISO 9001:2015. Occupational safety, health and environmental protection aspects, energy-efficiency and plant safety are summarised in Chapter 8.8.

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Chapter 2 – Declaration of intention and company policy

2 Declaration of intention and company policy

As Europe’s leader in heavy plate production, DILLINGER competes world-wide with its products and services, and persistently strives towards enduring company success. The company policy is accessible to all employees at all times on the intranet in the form of a vision and guidelines in their latest version. The company policy is regularly reviewed and changed if need arises.

DILLINGER,

Europe's leading heavy plate producer, is committed to achieving top-class performance in steel together with its customers.

On the solid foundation of our employees' skills and commitment, we continue to increase our strong performance on each site, in order to manufacture top-quality and economically

competitive products, while maintaining the necessary balance with our environment and safety.

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Our guidelines

We are the heavy plate partner No. 1

We are the reliable and long-term partner for our customers worldwide. We exist on our services for the customers.

Partnership with customers and suppliers is based on mutual trust and reliability regarding the quality and compliance with commitments (in particular delivery reliability, properties and image of our products).

We are persistently and systematically working to keep and further develop this position through innovation.

We make the steel

We concentrate on our core business of steel and heavy plate. We are a competent partner for our customers in this area.

We deliver a broad product range of premium quality heavy plate. The cost-effectiveness of our products and services for our customers always stand in the foreground.

With innovations, solutions in steel and service features, our customers are in the position to realize premium quality achievements in steel.

We work with safety-awareness

We have committed ourselves to ensuring that all who work together with our company can safely complete their tasks while also staying healthy.

We strive for zero work accidents during all operations. To this end, safety holds precedence over all other company goals.

Cleanliness and good order are just as important for a safe workplace as well as for a high product quality and the good impression we want to leave on our customers.

We generate profits

Profits are the prerequisite for innovation, investment, further development of the company, and the security of our jobs.

Shareholders are entitled to appropriate dividends.

Our economic success is strongly secured through optimal customer orientation, qualified and hard-working personnel, reliable top-quality facilities and entrepreneurial actions. Together we take care to secure and continuously improve these factors.

We are constantly increasing our productivity and reducing our costs. This makes it possible for us to operate our facilities at full capacity, and helps us to offer our customers’ products at fair prices.

We rely on competent and dedicated employees

The creativity and motivation of our employees are decisive factors in our success. They are challenged and supported by competent and model management.

We are constantly working on devising a corporate structure and configurations to enable our employees to not only develop themselves, but to also play a part in the overall improvement process.

Board members, management, personnel and the Supervisory Board work together cooperatively and with full trust, and cultivate a company culture of co-determination.

Training and qualification are supported by the company, just as these are expected from each and every employee through his own learning process.

Active junior staff development and individual human resources development allow for a constant advancement of the company and the employees.

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We operate pro-actively and entrepreneurially

Quick and flexible decisions and a far-sighted and enduring orientation make for optimized processes. Shortened paths make way for the easy implementation of decisions. This goes for the entire company as well as for each and every individual area.

The core business is secured by optimized and cost-conscious internal customer-supplier relationships which are marked by a mutual concept of service.

We work in a continuous process of improvement in all of our activities and recognize this as a major component of a modern management system. In this context we monitor our performance with suitable key-figures.

We support our employees

The high commitment of our employees to their jobs is accompanied by the company’s social duty to create the best work conditions and the fairest payment conditions possible.

A modern social policy aids employees in particular circumstances.

A transparent communication policy and an open internal dialog allow for mutual trust and credibility.

We maintain and promote the health of our employees. Employees with impaired abilities and aging employees are offered career perspectives when needed.

We are securing a sustainable environment

Through sustainable development we are securing our location for future generations.

We apply all of our experience, technical knowledge and creativity in order to protect resources and to avoid burdening humans and the environment.

We belong to the region

We are a company with a very long tradition and our location in Dillingen has grown roots over the generations.

We are proud of this tradition and we are committed to our region and at the same time to our other locations in Europe and worldwide. We respect the cultures of these other locations.

We are a strong group

Our creativity in heavy plate production in Dillingen and Dunkirk is complemented and supported by further business activities. This includes for example the Heavy Fabrication Division, and the Foundry, the trading and steel service companies, as well as sales agencies, transport and sales or our insurance company.

We consciously rely on the internationality of our group and our employees. The cultural diversity of our employees is a factor in our success on the market and in the collaboration of companies. We utilize these synergies and the potential for an exchange of experience within the group.

Over and above these general guiding principles, specific guidelines for quality, safety, health, environmental, energy and safety management are also defined. In this context, corporate management obliges itself and the Company to :

Adherence to not less than the legal and official requirements, with the aim of performing better than these requirements.

Continuous improvement of the Integrated Management System.

The elimination of hazards and minimisation of SHE risks.

Consultation with and involvement of employees and their representatives within the scope of the Employees' Codetermination in the Mining, Iron and Steel Industries Act (Montanmitbestimmungsgesetz).

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Chapter 3 – Company portrait

3 Company portrait

3.1 The company DILLINGER

DILLINGER was founded in 1685 by the entrepreneur Marquis de Lenoncourt and has since developed into Europe’s leading producer of top-quality heavy plate. With more than 5.600 employees at the main locations in Dillingen (Germany), which the affiliated companies Zentralkokerei Saar (ZKS) and Roheisengesellschaft Saar (ROGESA) also call home, and in Dunkirk (France), up to 2.3 million tons of heavy plate and the resulting products are manufactured each year.

ZKS, one of Europe’s most important and modern coking plants, and ROGESA, are companies without employees and transfer the operation of the facilities to the joint stock company of Dillinger Hüttenwerke.

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Custom-made heavy plate products

Non-alloy structural steels

Normalised fine-grained structural steels

Thermomecanically rolled fine-grained steels

High-strength quenched & tempered fine-grained steels

High-temperature steels

Cryogenic steels

Weathering-resistant steels

Case-hardening & quenching & tempering steels

Security steels

Tool & mould steels

Wear-resistante steels

Sour-gas-resistante steels

Offshore steels

Linepipe steels

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Applications

Structural steel

Hydropower Engineering

Pressure Vessels & Boilers

Earthmoving Machinery & Mining

Mechanical Engineering

Offshore Oil & Gas

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Large Diameter Pipes

Shipbuilding in. Refrigerated Transport

Plastics and Concrete Moulds

Wind Energy

Protection

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3.2 Social Responsibility, Sustainability and environment

Social Responsibility

CSR Certification

In 2018, DILLINGER received an award for its CSR activities.

The Company was audited for this purpose by an internationally active rating agency. The result achieved puts DILLINGER among the top 30 % of the best performers in the business category "Manufacture of basic iron and steel".

Social Corporate Policy

In addition to good retirement provisions for its employees, DILLINGER's responsible corporate policy has also traditionally always included a broad range of social provisions and in-company social advisory services. Two children's day centres initiated and supported by DILLINGER are available to employees to facilitate the harmonisation of family and working life.

For its commitment in this field, DILLINGER has received the "Family-friendly company" mark of quality issued by the "Working and Living in the Saarland" service centre.

Our employees

Our employees – key to success Motivation, creativity, team work and a healthy communication in the enterprise guarantee the long-term quality of our products. We persistently work on creating the culture and the structure of our enterprise in such a way that our employees can fully develop their capabilities and can fully commit to our continuous process of improvement. Board of Directors, executives, workforce and works council work in a cooperative way and support a culture of co-determination. Only through the untiring commitment and the high quality of all our employees is the long-term success of our enterprise secured.

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In order to cope with demographic change and thus with the shortage of skilled labour, DILLINGER is continuously investing in training and the promotion of young talent. The Company has long maintained cooperation with universities in order to promote future academically qualified staff. The competence of our employees is assured by means of an extensive range of internal and external provisions for further training.

Health and Safety

Safe and healthy working is top priority at DILLINGER. The DILLINGER Occupational Health & Safety Management System has been certified since 2004, and thus demonstrably meets the internationally acknowledged requirements.

Health protection – at DILLINGER this means not only conforming to the minimum standards, but instead going well beyond them. All working procedures and individual activities which occur within the Company are systematically analysed for their potential hazards and physical/mental burdens. The results are incorporated, inter alia, into our preventative programmes and training courses. We put our trust in numerous safety programmes and initiatives, in order to promote safety awareness and to minimise hazards and physical/mental burdens.

We see physical and social well-being as a holistic task. Prevention programmes serve to prevent occupational illnesses, and to promote general health care and the avoidance of infectious diseases (inoculations and travel-medicine advice).

Ethics

DILLINGER is committed to adherence to the law and to corporate values in the context of voluntary obligation.

DILLINGER has also declared its commitment to the SHS Group Code of Ethics. This contains all the fundamental principles and provisions aimed at assuring conformant conduct on the part of the Company's legal representatives and employees and also of third-parties. It derives from the internal codes and principles of our group and is also orientated around national and international standards.

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Environment and Sustainability

According to its corporate vision and its environmental guidelines, DILLINGER is persistently committed within the whole enterprise to sustainable economic activity and production, which preserve environment and resources.

Environment

Large-scale investments in ultra-modern technologies help in reducing burdens on the environment and in continuously improving energy-efficiency. To the greatest extent possible, all environmental effects are determined, evaluated and reduced at regular intervals. In addition, programmes for the minimisation of air pollutants, noise, waste-water and solid waste, and for the conservation of all resources, are initiated and continuously implemented and expanded. DILLINGER practises a frank and open information policy.

We operate by way of pre-emption an Accident and Emergency Management system which is closely coordinated with the authorities and assures high-speed reaction.

DILLINGER's Environmental Management System has been certified in conformity to ISO 14001 since 2004. The Company was additionally certified in accordance with ISO 50001 in 2012.

Sustainability – a forward-looking concept

Today, sustainability demands from enterprises equal weighing of economic, social and ecological objectives and their perception as an interlinked system. This is why we attach great importance to respecting the principle of sustainability and acting accordingly within the area of the three corporate objectives – economy, welfare and ecology.

Continuous investment in Research & Development, and also our own Innovation Management System, enable us to make innovative products cost-effectively and energy-efficiently, while conserving resources to the greatest extent possible.

The future belongs to renewable energy sources. Ever scarcer fossil sources of energy, combined with growing environmental awareness, are accelerating the expansion of the obtainment of energy from regenerative sources. The high-performance material steel makes all this possible.

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Recycling – steel has unlimited reusability

At the end of a long life cycle steel becomes scrap - and thus it becomes an important raw material for the production of new steel. Purposeful recycling enables unlimited re-usability. In Germany, almost half of the steel is produced from scrap. Recycling of ca. 20 million tons of steel scrap, this equals eight Eifel Towers per day, saves the mining of 1.5 tons of iron ore and 0.65 tons of coal per ton of scrap.

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3.3 History of DILLINGER

1685

1804

1809

1835

1948

1961

1981

1985

1991

1992

1998

2010

2014

2014

2016

2017

Established by Marquis de Lenoncour by the order of Ludwig XIV.

First rolled plate in Dillingen

First joint stock company in Germany

The "Dillinger Blechlehre" (plate gage)

Dillinger Hütte is co-founder of SOLLAC

First continuous slab casting facility of the world goes into operation

Establishment of ROGESA and ZKS

A 5.5 m quarto high-stand line is put into operation

Establishment of Europipe, in cooperation with Mannesmann and GTS Industries

Integration of the heavy plate rolling mill at GTS Industries

First continuous slab casting facility in the world with 400 mm slab thickness and soft-reduction

Extension of the vertical bending machine to a slab thickness of 450 mm.

Opening of Steelwind Nordenham

GTS Industries changes its name to Dillinger France

Commissioning of the new CC6 vertical continuous-caster with the casting of a 500 mm thick slab.

The world's thickest continuous-cast slab – thickness 600 mm – is produced on the new CC6 machine.

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3.4 Organization of the Dillinger Group

In terms of a common Integrated Management System (IMS) and the group certification of DILLINGER, the following basic principles apply:

Organization based on the following structure

Cross-company sharing of responsibility for all concerned organizational units by the board members of Dillinger Hütte

A common IM-Manual (IMM)

A common IM-representative (IMS-coordinator of DILLINGER), supported by local IM-responsibles (IMB) if needed

DILLINGER company structure

The above structure shows the most important shareholdings of DILLINGER. Our heavy plates are used all over the world in a wide variety of projects. That is why DILLINGER, with its specialized processing centers and sales agencies, is positioned worldwide.

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Chapter 4 – Context of the organization

4 Context of the organization

4.1 Understanding of the organization and its context

4.2 Understanding the needs and expectations of interested parties

4.3 Determining the scope of the quality management system

In a continuous process, internal and external topics which are of importance for the enterprise as well as the requirements and expectations of interested parties are analysed, assessed and pursued.

4.4 Integrated management system and its processes

DILLINGER runs an Integrated Management System (IMS), in which the quality management, environmental protection management and occupational health and safety and the energy and safety management are joined together. It regulates the strategic responsibility and the operational practices in these fields of work across all operative plants within the company.

The IMS also fulfils, in part or in whole, the requirements of other various international and national standards and regulations.

DILLINGER products and production processes are also approved and/or certified by numerous national and international certification- and classification societies..

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Chapter 4 – Context of the organization

Process orientation

The process structure and the resulting process variations in an iron and steel plant such as DILLINGER are considerable.

Due to their value creation, the core processes are of central importance. They are strengthened through support processes. Control and further development are carried out through the management processes.

The DILLINGER process landscape

For all processes, there are explanatory and detailed process descriptions.

The process structures of the subsidaries are adapted to the respective situations and defined on site.

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Chapter 5 – Leadership

5 Leadership

5.1 Leadership and commitment

5.1.1 General

The Board of Management takes full responsibility for the effectiveness of the Integrated Management System. It defines the corporate policy and ensures that the requirements of IMS are integrated into the business processes. The requirements of customers, authorities and laws, and the requirements of IMS are conveyed to the whole enterprise. Additionally, it defines superordinate objectives, which are broken down in the facilities to the local conditions, and it performs regular management assessments. Thus, it is ensured that the IMS meets its intended results. Moreover, its tasks also include ensuring the availability of the required resources and allocating authorities, responsibilities and competencies. 5.1.2 Customer focus

DILLINGER’s success depends on the immediate recognition of the needs and expectations of the customers. Special attention is paid to customer requirements with regard to technology and deadlines. It is our utmost priority to sustain and intensify the satisfaction of our customers with our products as well as to satisfy the customer needs with regard to consultations and information. 5.2 Policy

5.2.1 Establishing the Quality Policy

5.2.2 Communicating the Quality Policy

The Board of Management determines the main features of quality, occupational health and environmental protection policies, energy as well as facility safety, in the "policy statement”.

The management thus ensures that this policy

presents the (core) competence and organization of the company,

offers, with customer satisfaction, employee orientation, economic efficiency, as well as occupational health and safety and environmental protection as well as energy efficiency, a framework for defining and reviewing goals,

is reasonable in reference to the manner and extent of occupational health and safety risks, as well as the environmental effects and energy aspects of their activities, products and services,

is obliged to the realization and continual improvement of the IM systems,

is regularly inspected/reviewed for effectiveness,

is communicated and understood in the company.

5.3 Organizational roles, responsibilities and authorities

The Board has full responsibility for the Integrated Management System. The representative of the Board for quality, environment, safety and energy management ís the Chief Technical Officer. The representative for the work and health protection management ís the Labour Director. For the fulfilment of its duties, the Board transfers certain tasks and responsibilities to certain executives. Its full responsibility and duty for supervision remains unaffected by this.

The close functional cooperation between DH and DF is layed down in procedures. This guarantees harmonized work processes and a unified order management.

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Overview organization chart of DILLINGER

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Management officers

In accordance with the certifications valid at the respective locations, the management representatives are appointed at each location within the group. The Dillinger IMS coordinator is responsible for the central coordination of the IMS.

Quality Management officer and Integrated Management officer

Introduction, implementation and monitoring of the Integrated Management System (IMS) lie within the responsibility of the IMS. In overall questions of the IMS, s/he acts independently of all other departments, and s/he represents the executive management against all organizational units, certification and approval bodies, authorities as well as customers.

With regard to function, s/he reports directly to the Chief Technical Officer. S/he has to ensure independence, authority and responsibility so that the requirements of this IM Manual are met. For this, s/he carries out regular internal audits in all areas of the enterprise. In this, s/he is supported by an internal auditor pool. Within the framework of the management review, s/he reports to the Board about the performance and possibilities for improvement of the IMS. Thus, it is ensured that the integrity of the IMS is maintained even in the course of changes.

Main safety engineer

The main safety engineer is responsible for the occupational safety department. S/he reports to the labor director.

S/he accomplishes all tasks that are derived from the occupational safety law. Thereby, the company management consults in all questions of occupational safety and all accident prevention.

S/he is responsible for planning the occupational safety management and in coordination with the IMS , s/he is responsible for reviewing the effectiveness of the system and optimizing it.

Environment officer

The company environment officer is the manager of the environmental protection and technology department (UST). With regard to function, s/he reports directly to the Chief Technical Officer and reports to him/her regularly about the environmental performance.

S/he is responsible for all relevant specialist activities and measures for the implementation of official constraints, as well as the application of all applicable legal requirements inside the field of environmental management.

Energy manager

The energy manager is appointed by the executive management. He is responsible for all professional aspects of the energy management. The energy manager’s respective tasks are described in detail in the IMS-module "Energy Management at the Dillinger Hütte location".

Company doctor

The company doctor ís the head of the "Health Services" department. With regard to function, s/he reports directly to the Labor Director.

S/he accomplishes all tasks that are derived from the occupational safety law. On the basis of this, s/he consults the company management in all questions concerning preventive health.

Furthermore, particularly for personnel with managerial, executive, and auditing activity, the respective authorities and responsibilities with respect to essential requirements of the IMS are regulated and known. Thus, it is ensured that the IMS meets its intended results.

Internal organizational regulations define the tasks and functions of the areas and the respective sub-units with interfaces. This is implemented through the display of the organizational structure including the corresponding organization charts, name assignments, substitute regulation and information on appointed experts.

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The respective legally required representatives or "Appointed Persons" are appointed at all locations of the group.

Among these are:

Industrial Incidents officer

Immissions protection officer

Water pollution control officer

Waste management officer

Dangerous goods officer

Hazardous materials officer

Occupational safety specialist

Radiation protection officer

Fire Department

Company security officers

Works council

5.4 Consultation and participation of workers

DILLINGER, as a steelmaking group, is subject to codetermination in the mining and steel industries and thus to the Employees' Codetermination in the Mining, Iron and Steel Industries Act (MontanMitbestG).

This assures the workers' representatives on the Supervisory Board of significant influence on important business processes and on the appointment of the Executive Officer, Human Resources.

The interest of our employees are, in addition, represented by unions, workers' councils and other forms of worker representation.

In the field of occupational health and safety, the employees and/or their representatives are genuinely involved in and/or consulted on company processes. The following can be mentioned by way of example:

Health & Safety Steering Committee

Hazard assessment at the workplace

Specialist officer system

Departmental safety programmes and safety dialogues

Cross-audits and plant visits

Auditing

Company suggestion scheme

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Chapter 6 – Planning

6 Planning

Company management establishes that the planning (conception) of the IM system follows a manner in which

all applicable laws, body of regulations, standards, etc., are acknowledged and upheld.

the requirements of customers, interested parties and of norms can be realized. For this, the essential, required processes concerning objective, implementation, interactions, control, measurements, monitoring must be determined.

the goals are reached/can be reached. The Board ensures sure that all necessary resources (personnel, infrastructure) are available.

For this purpose, suitable planning instruments (steering commissions and committees) integrated into the process of the enterprise are employed, which deal with the following topics:

Quality

Health and occupational safety

Integrated Management System 6.1 Actions to address risks and opportunities

The risk management process of DILLINGER and the essential subsidiaries are embedded into the SHS Group’s risk management system. The SHS risk management system consists of central and decentralized elements. The SHS risk management system (SHS-ZRM) takes over central risk management tasks for the enterprises of the Saarland steel industry. In this, it functions as service provider for Aktien-Gesellschaft der Dillinger Hüttenwerke and thus complements the decentralized operative risk management in the areas, operations and subsidiaries. Moreover, in terms of a Group Risk Management, SHS-ZRM is also responsible for the creation and implementation of the risk management framework conditions within the Group of the enterprise.

In all essential special departments and subsidiaries risk coordinators have been appointed. These are the first contact persons for SHS-ZRM, and they liaise and support with SHS-ZRM in all activities of their departments and subsidiaries. Furthermore, the risk coordinators are responsible for the periodic risk inventory as well as the correct and complete report of risks, within the time stipulated, of their departments and, respectively, their subsidiary. To achieve this, risk coordinators and SHS-ZRM cooperate on a partnership basis.

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Structure and objectives of the risk management

DILLINGER’s risk management system (RMS) covers the entirety of actions safeguarding the systematic handling of risks, and focusses on the following objectives:

Risk transparency: The risk management has the objective of identifying and revealing at the earliest possible moment the essential risks connected with the operational activities. For this purpose, a systematic and unified analysis and assessment method is implemented.

Risk manageability: A further objective of the risk management is to prevent, to reduce or to transfer the risks identified through risk controlling instruments either already implemented or to be newly introduced. Risk transfer is conducted by the central service provider SHS Versicherungskontor GmbH, which is responsible for the configuration of an adequate scope of insurance protection.

Risk communication: The Board is informed about the current risk situation in a regular and incident-related way. Additionally, essential questions of the risk management are discussed with the Supervisory Board.

The RSM consists of three components: Framework & Organization, Risk Management Process, and Monitoring.

SHS-ZRM is responsible for the component "Framework and Organization". The framework conditions such as deadlines and risk assessments are defined and adjusted by SHS-ZRM. The risk management is based on recognized framework and standard works such as COSO Enterprise Risk Management – Integrated Framework (2004) and ISO 31000:2009 Risk Management.

The component "Risk Management Process" (RMP) comprises the parts "risk inventory", "ad-hoc notifications" and "reporting". Risk inventories are self assessments of the departments/operations/subsidiaries and are obligatory for them. These are carried out in three steps – risk identification, definition of the controlling actions and risk assessment. On top of this, in 2016, the ad-hoc notifications were introduced. They are part of the RMS and make it possible at any time to display a current overview of the risk situation. The periodic performance of the risk inventories and the incident-related ad-hoc notifications ensure that the risk situation is up to date and complete.

"Monitoring" of the RMS is carried out in a process-integrated as well as process-independent manner. Process-integrated monitoring is carried out through the periodic review of the risk inventories and the ad-hoc notifications. The risk inventories are documented and safely stored against any alterations. Also, the process description is documented and verifiable through regulations and instructions for completion. The RMS is monitored internally and externally in a process-independent way. Internally, this is carried out by Internal Review. An external examination is carried out by the chartered accountants within the process of the annual audit.

The efficiency of the RMS of Aktien-Gesellschaft der Dillinger Hüttenwerke is ensured through the structure and the objectives of the RSM.

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6.2 Quality objectives and planning to achieve them

Ganzheitliche Planung und Steuerung (GPS - Comprehensive Planning and Control) and annual development plan (JEP - Jahresentwicklungsplan): Global goals and the measures needed to achieve goals are the manner in which the Ganzheitliche Planung und Steuerung (GPS – Comprehensive Planning and Control) system is determined and followed. GPS’s goal, with the company vision as orientation and in consideration of the company principles, is to systematically strengthen the continuous improvement process and to anchor it into the DILLINGER structures. With GPS the company will be steered step by step in the direction of the vision. In annual planning, the year’s key topics are determined and put into an annual development plan (JEP): The JEP is a plan with key topics that DILLINGER desires to significantly develop further throughout the year. Goals are agreed upon in the various topics. In order to secure success, a plan of measures is determined. The effectiveness of these measures is regularly monitored with suitable performance figures. Furthermore, each employee is informed yearly by his supervisor about the annual development plan. 6.3 Planning of changes

Any changes to the IM system are carried out in a planned way, in the course of which in particular the integrity, the availability of resources as well as all responsibilities and competencies are taken into account.

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Chapter 7 – Support

7 Support

7.1 Resources

7.1.1 General

Provision of resources

The executive management provides the necessary resources for the realization of the IM System’s determined goals, functions and measures,. Notable particulars are:

continuous and focused investigations about customer requirements and satisfaction

market, customer, and product-oriented sales and divisional structure

the necessary organization of the company (incl. definition of authority, responsibility and tasks)

licenses, approvals, qualifications (of products, processes, facilities)

measures and projects for the improvement of environmental protection and occupational health and safety and improvement of the safety of facilities

measures for the enhancement of efficiency concerning the specific energy consumption for the manufacturing of individual products, intermediate products and by-products.

the necessary manufacturing and testing equipment

purchasing of necessary equipment, products, instruments, etc.

internal and external communication

a "system” of work groups, reports, data collection and analysis

internal and external audits

corrective and preventive measures 7.1.2 People

Skilled employees are a necessary condition for the success of our enterprise. The foundation for this is created by consistent qualification of all employees and executives. The requirements for the individual persons are defined in job charts or job specifications as well as in relevant regulations.

The individual qualification is documented in the personnel files and in the concerned areas. With this as a base, any specific needs or requirements (targets) and the facts (actuality) are aligned. 7.1.3 Infrastructure

The requirements for the infrastructure are defined by the object of the company

Of notable mention are:

manufacturing facilities and installations

media supply (electricity, water, gases)

transport and logistic system, e.g.: railway, trucks, cranes, roller passes, etc.

hard- and software

internet, intranet, telephones, fax, employee newspapers, posters

buildings, warehouses, open areas

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7.1.4 Environment for the operation of processes

The process environment is understood as a combination between people and environment-related conditions.

The required measures, in particular for the realization and maintaining of compliant product characteristics, are for example:

approved, authorized and released products, processes, facilities, equipment

ergonomic, clean and hygienic working conditions

purpose-appropriated rooms and storage spaces

measures for human, machine and product protection, for example:

- protection from fire, water, weather: emergency preparedness

- maintenance of transport and warehouse installations for products, raw materials, etc.

- water cycle management, recycling of materials

- appropriate lighting

- energy-efficent facilities

Regular monitoring occurs through, for example:

authorities such as professional trade associations, insurances

internally through inspection (reviewing, on-site inspections), servicing and maintenance 7.1.5 Monitoring and measuring resources

All necessary monitoring and measuring devices are chosen for their specific usage (acceptance criteria) and are regularly tested according to the stated instructions.

With respect to testing equipment, marking, identity, adequate measurement accuracy (usage and acceptance criteria), handling, protection and storage (ambient conditions) and protection from misadjustment are guaranteed at any time.

The controlling regulations conform to the official requirements and/or internal agreements that arise from conforming to official regulations and in dependence of the frequency of use.

Regulations govern the procedures and the cycle of calibration and, if applicable, the official testing of individual measuring and testing equipment, as well as the equipment labeling and responsibilities.

Calibration of measurement and testing installations is carried out according to the valid regulations and under application of national and international standards. Thus, the metrological traceability is ensured.

Those responsible for measuring and testing equipment conduct records of the results from internal and/or official calibrations.

Measuring and testing equipment on which a deficiency has been determined are excluded from further use and only reinstated for use when they have returned to an orderly condition and tested once again. Products with measurement results from the time before the misalignment was determined undergo a specific retesting.

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7.1.6 Organizational knowledge

The knowledge of an enterprise is the foundation for a successful existence in the market. Due to DILLINGER’s long business activity, the knowledge required so as to be able to carry out the processes and to ensure the conformity of the products is available. For the transfer of this knowledge, traditional instruction and further training measures as well as modern measures concerning knowledge transfer from one employee to another are applied. The latter as well as the permanent documentation of the knowledge of the enterprise in data bases, regulations and reports serves the purpose of preserving knowledge. For the design of DILLINGER’s products, the focus lies paradigmatically on the already existent (implicit and explicit) knowledge, which is generated from internal and external sources of knowledge. This knowledge flows in particular into quality planning, quality control and quality optimization.

Internal sources of knowledge

A documentation system supports the steel designers by providing knowledge on technical research gained from projects, on comparable customer requirements and on values concerning design, processes and results. This knowledge is used by the product managers for forecasting of production variants and for estimation of probability ("frequency") of failure and by the technologists for definition of process parameters. New knowledge gained from projects is collated, and categorised in so-called "lessons learned", action then assigned and the action checked for its effectiveness. This thus supports the process of continuous improvement.

External sources of knowledge

For decades, experts have been representing the enterprise in technical and standards committees of VDEh (Steel Institute) and further panels as well as on the European level. In these panels, also an overall exchange of experience is supported, and the technical interests of the enterprise are incorporated into the techological framework conditions/norms. As a matter of course, the regularly attended expert conferences serve the technical exchange of knowledge and the formation of networks for the creation of new alliances with research institutions and partner enterprises. Also the joint development of products together with customers (e.g. with pipe manufacturers or with engineering firms) serves the gain of knowledge for our plates.

Transfer of knowledge

Against the background of the demographic development and the necessary flexibility of the enterprise, many employees have been qualified for the supervision of the knowledge transfer in personnel succession situations. The documentation of operational processes also serves the more focused working-in of employees.

Supervision of knowledge transfer

In a structured interview the experiences and the knowledge of the knowledge provider are transferred to the knowledge receiver as job maps and implementation plans are compiled. Also the implementation of the knowledge transfer is discussed through defined milestones.

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7.2 Competence

The basic principle is that employees are chosen and put into their position according to their professional training, experiences and professional competence.

Training

Dozens of young people are trained as skilled workers every year in DILLINGER's training facilities.

Not only basic general occupational knowledge, but also special industry-specific information, often tailored precisely to the Company, is imparted in this context.

The Company has also long maintained cooperation with universities in order to assure academically trained future personnel.

Training Courses

The basic steps are:

determination of needed skills

determination of the delta "nominal/actual”

determination of needed training

training planning/qualification measures

completion of training course

documentation of training measures

evaluation of effectiveness

In the plant operations, job profiles are created and the resulting requirements are compared to the qualification of the employee.

With a detected need for training courses, training will be planned, organized and completed with the involvement of the further training department and the relevant departments. The training courses are documented and evaluated.

The evaluation of the effectiveness of training measures is divided into three areas:

Regulated areas: On-the-job training and training courses are completed through testing and evaluations (e.g. professional job training, training courses for NDT or welding qualifications)

Internal training courses (A+W – Further Training Department): Comprehension test at the end of the training course (oral discussion/comprehension question about course or short written test)

Observations by the supervisor: About 3 months after attending an internal or external further training, the participant will receive a form concerning the verification of the efficiency, which s/he will complete together with her/his supervisor. Through this it becomes apparent if the undertaken training/qualification measures have met the desired effectiveness. If this is not the case, a need for further training is determined and planned.

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Special qualifications

Should certain activities demand specific personnel qualifications, then these activities will only be carried out by people with the necessary qualifications.

Example: Materials testing, non-destructive testing, welding, crane operation, fork lifting, as well as the functions of legally appointed officers as a part of the occupational work and safety and environmental protection as well as facility safety and energy management.

The requirements for the officers’ qualifications are legally regulated, as are the duties for further training. The officiers comply with these duties through the participation on known, external further training events.

Instruction

Instructions are important tools in the prevention of accidents and emergencies. Attendance in instruction sessions is recorded.

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7.3 Awareness

Through regular information of the employees via various channels and media, it is ensured that they are familiar with the policy and objectives of the enterprise and that they are aware of their contribution to the improvement of the IMS.

Programs for continual improvement promote the idea of quality and demand active cooperation in the improvement of performance.

For the improvement of the awarenes of occupational safety, of environmental protection and energy efficiency, specials tools and programmes are implemented. Among these programmes are for example dialogues with employees and regular instructions (toolbox meetings). 7.4 Communication

Internal communication

The inclusion of all company employees through regular information and communication is an important component of the management system. Herein included is the exchange of information between managers, employees, work groups and specialist departments.

The following instruments are used for internal communication:

information for executives and employees

meetings/assemblies with the Board, works council members, specialist departments, etc.

through annual report, employee newspapers, intranet, posters or billboards, newsletters

sectional and general meetings, presentations, etc.

meetings within and across areas and sections, presentations etc.

trainings, qualifications, consultations

internal handing-over of external information (for example information about legal changes)

in the spirit of continual improvement, employees are called upon to communicate their ideas

feedback talks (4-eyes talk between superior and employee)

Software systems for the exchange of documents and lists of actions to be taken. External communication

The Communication Department is exclusively responsible for communications with the public (press etc.).

Technical and scientific publications need prior approval of the Board of Directors.

The Sales Department is the primary contact for customers. In the case of further consulting (pre- or after-sales) or technical discussions, in particular the areas of Marketing, Research and Development and Technical Services are available.

Concerning questions relating to approvals and certifications, the Quality Management Representative is responsible for the communication with the certification and approval bodies. S/he ís the contact person for all external audits (e.g. customers) relating to the IMS.

Irrespective of the contacts of other sections, the facility operators of AG der Dillinger Hüttenwerke, ZKS and ROGESA, the employees of the Occupational Safety Department, the works doctor, the environmental officer, the energy manager and the incident officer are in contact with the relevant ministries and authorities.

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Information relevant to the SHE management system is communicated from the Health & Safety department to external bodies.

This includes, for example:

The Personnel and Social Report

The Health & Safety section in the Annual Report

Accident reports (accidents during work or travel) to the "Wood & Metal" professional association and the Saarland Bureau for the Environment and Occupational Safety (LUA)

Notification of occupational illnesses and, in case of serious accidents, description and details of the accident, to the Saarland Bureau for the Environment and Occupational Safety (LUA)

Annual works fire-brigade statistics (deployment figures) to the Ministry of the Interior

Communication with authorities and the neighborhood in the event of emergencies and disturbances with effects on the people living nearby is regulated in the works alarm and hazard prevention plan (BAGAP).

Complaints from thre neighborhood are handled by the department for environmental protection in agreement with the central legal office (ZRA).

DILLINGER does not communicate environmental aspects and energy-related performance at regular intervals. Neighbours and interested parties are notified in case of special situations concerning pollution and other nuisances. Requested and necessary information is nonetheless supplied to the authorities.

Regular environmental and energy communication/reporting to the authorities:

Reports to the German Environment Agency:

- Emissions burdens in the Pollutant Release and Transfer Register (PRTR)

- Facilities subject to mandatory emissions trading (German Emissions Trading Authority [DEHst])

Reporting to the Saarland Bureau for the Environment and Occupational Safety (LUA)

- Emissions-measurement report for all continuously monitored sources

- Solvent balance for the corrosion-protection system

- Report in acc. with the 13th Prevention of Pollution Ordinance for blast-furnace-gas-fired power plants

- Report in acc. with Article 31 of the Federal Prevention of Pollution Act

- "Full-scope" emissions declaration

- Safety report in acc. with Article 9 of the Industrial Accidents Ordinance

Energy-management reporting

- Applications to the Federal Office for Economic Affairs and Export Control (BAfA) for concessions under the Renewable Energy Sources Act

- Statistical evaluations to the State Central Services Department

- Energy-monitoring reports to the Federal Network Agency

- Electricity/natural gas balance to the electricity and natural gas network operators (and/or transmission-grid operators)

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7.5 Documented information

7.5.1 General

The documented information required by the norm and necessary for the effectiveness of the IMS is compiled, updated and controlled. Documented information of the IMS is compiled and controlled in the electronic Document Management Systems (DMS). Customer and order-related documented information, such as customer enquiry, offer, specifications are administrated by the Sales Department in software solutions intended for this purpose (such as CRM, AKIS). 7.5.2 Compiling and updating

During compiling and updating of documented information in the DMS, these are adequately marked. Marking includes, among others, title, date, author, document number. Alterations to the documents are traceable.

For compiling, centrally provided templates are used. Each document is tested and approved prior to distribution.

The subdivison of the system documentation is displayed in the figure on the right.

In the case of customer or order-related document information, it is ensured by the Sales Department that the current documents are provided and marked correspondingly (supplement number in the customer order).

In the case of customer orders with special measures, a list of the documents concerned is, if need be, compiled in addition to the order documents. Other documents than the IMS regulations

Further documents are, for example: norms, laws and regulations, internal specifications, safety reports according to the ordinance on industrial incidents, rules and regulations of BG (German Employers' Liability Insurance Association).

Maintenance and control of such documents is the duty of the areas involved. Independent of the kind and amount of the measures of control, the principle applies that only valid documents shall be used.

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7.5.3 Control of documented information

The control of the IMS documents such as handbooks, instructions for processes, work, audits, and operation is carried out with the support of electronic Document Management Systems (DMS). Through this kind of control a consistent and monitored distribution including the confirmation of reception is ensured.

Filing, storage and maintenance

Documented information which constitutes proof concerning the fulfillment of requirements as well as the effective mode of operation of the IM system is archived. The scope of archiving should be suitable to:

prove the quality and the general obligation to exercise diligence for possible product liability cases

prove the compliance with requirements as well as other regulations

prove the compliance with contractual obligations

enforce own warranty/guarantee claims

reflect the running maintenance of capital goods and buildings

show and prove the requirements and effectiveness of the Integrated Management System for the achievement of the targets of quality, environment, occupational health and safety, energy and safety objectives.

The areas charged with their compilation or processing are generally responsible for archiving. Duration, medium, location and responsibility of archiving are defined.

The responsible departments must take care that records are appropriately stored and protected from loss or damage, as well as ensure that they stay readable and retrievable during the entire length of archiving. When working with electronic archiving it is necessary to archive the data in an appropriate form (e.g. picture data or PDF) or systems (e.g. SAP, CRM). It is acceptable only if no other external requirements are in existence.

The securing of data preservation is the task of the IT department, which prevents data loss through redundant systems and regular data securing.

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Chapter 8 – Operation

8 Operation

8.1 Operational planning and control

The planning of product realization is oriented towards the predefined goals and specifications, meaning:

the delivery conditions for products and their characteristics

manufacturing processes and methods deployed for this purpose

required installations, resources (incl. personnel), etc.

necessary procedures for verification, validation, release and approval

specific examinations, records, documentations

Normally, guidelines and measures towards realization of customer orders, in their sequence, form a "quality plan”. This plan incorporates the basis of:

requirements

designs

flow charts in production units or "day programs - Tagesprogramme” (TP)

quality testing

testing and measuring procedures and equipment

All quality plan data are saved in data banks and are selectively called up on the individual operation sites. Additionally, all essential determinations are visible in the following documents:

in the manufacturing of heavy plate and semi-finished products: the commercial order (KA), the technical order (TA), the production schedule (FP)

in the area of processing: the production and testing sequence (FPP)

In internal orders, all order-specific details and determinations are defined, for example:

requirements on product characteristics (physical, chemical, geometrical) surface quality and internal quality

manufacturing and testing processes

required verification, supervision and release measures

time limits, quantities, logistics

identification, documentation

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8.2 Requirements for products and services

8.2.1 Customer communication

Communication with customers consists of many means of communication and processes.

Means of communication, e.g.:

Plant brochures, delivery program, segment or product brochures, material data sheets, specifications

Trade fair exhibits, customer days, speeches at congresses; articles in trade journals

Internet: order tracking by special information pages

Company tours

Specific communication in individual processes, e.g.:

Visits at/by customers

Inquiries, offers, order processing and confirmation,

Clarification of details concerning requirements and processes, approval of documents submitted (bid clarification meetings, pre-production meetings, pre-inspection meetings)

Audits by customers

(Joint) projects and developments; future strategies

Market analysis, product observation, customer satisfaction analysis

Technical consultations

Technical consulting work is primarily carried out by internal special departments Marketing Department supported by for example Research and Development, the Quality Department or the production facilities.

In the case of objections or claims, the Technical Service is in charge.

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8.2.2 Determining of requirements for products and services

8.2.3 Review of the requirements for products and services

8.2.4 Changes to requirements for products and services

Identification and assessment of higher-ranking market requirements to the product or the service is carried out according to the following chart:

Sales Department

The representation of DILLINGER at its customers is carried out by Sales.

The Sales Department is also responsible for the handling of enquiries and offers, the forwarding of orders into the internal IT system and the order confirmation for the customers as well as for the commercial order processing.

The steering, testing and approval of contracts goes through the sales department or the marketing company. In this way, it is essentially cleared up whether or not goods, delivery dates, amounts and transport can be carried through to completion in agreement with the customer.

To establish the details, the sales department consults all responsible departments.

The requirements (incl. verbal agreements) are recorded in writing and entered into the order dossier, customer files, CRM, or IT System by the authorized people. In this way the guidelines and results can be checked. Order dossiers or order data and customer files are also the basis for order confirmation as well as for the internal operations release concerning order implementation.

The following diagram shows the basic steps of inquiry, offer and order processing.

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Determination and assessment of the product requirements

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Inquiry and offer processing

Incoming requests are recorded by the sales department in the CRM, and the technical part (e.g. in the area of heavy plate by the technical offer department), if needed, is cleared up by the responsible departments within the company. On the basis of the technical statements, the sales department or marketing companies work out an offer under the specifications of price and deadline.

Where the product enquired for is not within DILLINGER's technical capabilities, no technical quotation is submitted.

Purchase order processing

Orders

The incoming orders are automatically given an order number. The assignment between order number and customer order is always clear and consistent.

Commercial order processing

In the sales sections all orders undergo checking directly after their arrival. Checking is done on the order elements (goods, standards, specifications, etc.), commercial framework conditions, deadlines, prices, credit rating, transport, completeness of the order documents and the agreement with the possible offer.

For heavy plate and semi-finished products:

the implementation of customer orders into the "commercial order” is carried out according to the rules of the commercial order processing (governed by specific regulations)

when the order contract has been checked, it is released only after the feasibility of the delivery dates has also been checked.

In the area of the Heavy Fabrication Division, the order dossier goes to internal work preparation.

Technical order processing

When discrepancies arise between order and offer, which affect the technical feasibility or lead to significantly higher costs, then a clarification with the concerned departments will follow.

With technical order processing, the technical details of construction will be checked and determined on the basis of commercial order processing, as well as on possible customer specifications, and then added to the already existing record of the order. The added data can affect additional customer requirements as well as the internal design and examination specifications.

Standards office

For the support of the enquiry and order handling, the norms and regulations necessary for the heavy plate supplies are analyzed and interpreted by the standards office. The result of these activities is made available for further processing in the form of standardized Word documents ("Information about norms) and computer files (Master files).

Examination, release, order confirmation

With heavy plate and semi-finished products, an automatic plausibility check of the technical order data is carried out once the order has been entered into the IT system.

Depending on the type of the discontinuity, the computer blocks any further processing, and requests correction or written confirmation. With the help of a control printout a manual check of correctness and completeness of the data is carried out. When all indications and deviations are successfully cleared up the technical part of the order is released.

On the basis of the technical order and the facility availability, a time-scale is calculated and synchronized with the date agreed on. If the date cannot be maintained, clarification with the

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commercial department ensues. If there is no blocking-notice by the commercial department, release for production is given.

After commercial and technical contract-checking and release have been carried out, the order confirmation is sent to the customer as a finalization and documentation of the contract-checking.

Changes and additions to the order

Significant changes to the order are recorded through identifiable changes to the commercial order.

The acceptance or rejection of the changes is dependent on the content of the changes and the processing-status of the order.

Creation of the manufacturing documents

For production, the specifications from the customer order as well as the design and test requirements are implemented within the framework of the work preparation. In the course of this, standardized processes are defined for standard products, and both rolling mills use the same metallurgic design.

From this, production documents for the production plants are compiled; among these are:

the technical order

lump-sum offsets (calculation of starting material usage), ordering of hot metal and heats

In the Heavy Fabrication Division

heat treatment plans

order unit lists, manufacturing and testing sequence plans (FPP), work plans, manufacturing drawings and sketches, geometric calculations, etc.

Project coordination

The project coordinator coordinates and optimizes the internal processes and activities within large-scale projects, from the inquiry down to the delivery of the plates. Apart from the Sales Department s/he is the first contact for the customer for technical questions. Her/His main tasks are, among others:

Central monitoring of company-wide large-scale projects

Definition of the project team in agreement with the necessary departments

Coordination of the project activities, project communication and alignment of the respective areas

Coordination and monitoring of the project activities including documentation

Review of project documents (e.g. MPS – Manufacture Procedure Specification, ITP – Inspection and Test Plan)

Organization and facilitation of internal meetings for decision-making during critical phases within a project

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8.3 Design and development of products and services

8.3.1 General

Design means the activities necessary for the design of the product and/or their manufacturing processes. These activities are under the control of "Design Control”.

Externally initiated design

There are 2 different situations for externally initiated design:

The customer orders with known requirements and within a determined range of dimension, of which a design already exists and is saved in the data banks (standard design). The known data are taken over into the technical order (variant I).

The customer orders with new requirements or new dimensions, of which no new design as yet exists. In this case, it is checked at the time of the order whether the standard design for the requested steel quality can be used or if a modification is needed. This is already determined at this point in time if needed.

During the order processing the design results are either taken over from the request or determined in detail at this point in time and taken over into the technical order (variant II).

This procedure is mostly standardized, controlled by regulations, as a simplified design plan.

Internally initiated design

The design process is internally initiated when the basis for a design is not available and a new one must be developed (variant III):

Requests or order-related designs or development activities

Research projects not immediately order-related

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Overview: Development/design controlling (schematic)

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8.3.2 Design and development planning

Organization, planning and controlling emerge from the schema "development/design controlling”. The highest authority in the approval and release of design projects and their results is the executive management (Board of Directors, or the PWE committee ((product further development)). The quality assurance management or F+E-GB (R & D/Products) are generally responsible for the control of design projects. They plan in cooperation with other concerned departments, e.g. marketing, manufacturing, production planning:

Goal, means, time frame, feasibility studies

Responsibilities, authorizations, other persons concerned/interfaces

Planned phases (including, if needed, assessment, verification, validation)

Documentation (e.g. procedural regulations, material data sheet, design definition, report)

8.3.3 Design and development inputs

The guidelines take into consideration, for example:

Material properties (chemical composition, mechanical and technological properties, processing at customer, etc.), as a target from customer specifications

Dimensions

Inner and outer product property, tolerances

Facilities and process for manufacturing

Testing procedures, scope of testing

Licenses, regulations, bodies of rules and regulations, laws, patents, etc., to be observed

Quantity, deadline, costs

The targets are determined, compiled and documented, if needed, with the cooperation of all the concerned departments. 8.3.4 Design and development controls

Activities and procedures of development can include:

Comparison with proven design (basis: evaluation of reference orders)

Use of models (neuronal networks)

Trials in the laboratory or plant

Initial sample/prototype (if needed through testing with a processor or user)

Production of a sample

Product managers (PV)

The steel grades supplied by DH are divided into several groups. For each group, a product manager is appointed responsible. S/he will be supported by the so-called product teams, which are composed of specialists from various areas. The activities of the product managers act in particular according to the objectives for the optimization of products and processes:

Further development of existing products/Development of new products

Optimizing of product and process standards

Support of inquiries and orders

Development and support of models

General quality development

Inclusion of all products into the quality regulations of all areas involved in cooperation with the production plants and their technological departments (PQ, steel plant, slab yard, rolling mill, inspection department)

Cooperation in Marketing Divisions

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Special experts

For specific questions concerning feasibility, special experts from various operations (steel plant, rolling mill, research development and design, inspection department, chemical lab etc.) are available. 8.3.5 Design and development outputs

With respect to the development inputs, it is monitored and assessed in the respective development phases whether

the necessary results and documents are available

each guideline for the product can be realized

the processes can be managed adequately and risks can be quantified

the tests fulfil their purpose in relation to the guidelines

tools, organization, logistics, and IT, as far as required, are available

quantities, deadlines and costs can be realized

results can harmonize with calculations/expectations and/or proven designs.

Date, scope and conditions for the verification and assessment of the development results are planned and set by those responsible for the development project.

Verification and reviews are carried out and documented, where necessary or required, by other people than those involved in the development output. After successful verification and assessment the development is released for manufacturing. Only after proven acceptability with respect to customer specifications, the determined application, or intended use of the product, can the concept be raised into a standard.

The development result is approved prior to release and made available and documented in an adequate way, such as in the form of regulations, procedures, specifications, reports or data.

Forms of release and documentation of the development/design result Design and development results may be released and documented as follows:

Validated design and development results raised to the standard are saved in a central computer. (Variant I)

Before the implementation of customer orders into manufacturing, the verified design result is released and documented, in general into the technical order. (Variant II, III)

In the case of development activities, the results are generally released and documented as research reports. These can serve as a contribution to know-how or as a design basis. (Variant III)

8.3.6 Design and development changes

In the case of changes in the development, these are identified and documented, and the concerned development activities (e.g. assessment, verifications, validation) are once again defined or newly defined before their approval.

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8.4 Control of externally provided processes, products and services

8.4.1 General

The process of purchasing generally follows this diagram.

In the case of semifinished products and heavy plate production as well as further processing there is, as a rule, no external procurement of pre-material. The production of hot metal, steel and slabs is carried out in the Dillingen plant, the production of plates in own rolling mills. In absolute exceptions (such as a slab shortage) slabs can be purchased from other producers. In this case, it is ensured that apart from the quality requirements also the necessary certifications of the producer are available.

Supplies of quality-relevant products and external services are only provided by qualified suppliers. To ensure evidence that the requirements for the suppliers are fully met, a supplier assessment for quality-relevant and other major products and services is carried out. Criteria of occupational safety, of energy efficiency and of environmental protection beside the quality criteria are firmly grounded in the purchasing policies.

The purchasing activities for AG der Dillinger Hüttenwerke and Saarstahl AG are carried out by SHS-Services. The Purchasing Department of ROGESA is responsible for the raw material purchasing in the area of the blast furnace (ROGESA) and ZKS. Over and above this, the subsidiaries have their own departments for specific purchasing at their locations.

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8.4.2 Type and extent of control

The quality-relevant products and services used for manufacturing products and the accompanying documents undergo a receiving inspection:

The manufacturing or processing operations are responsible for internal deliveries, according to the respective agreements of those concerned

External deliveries undergo a receiving inspection regarding the order:

Depending on the product, for example, by:

- the areas responsible for receiving and/or storage; the consuming operations

- the chemical laboratories

These products are used only after their release, even in the unscheduled situation of an urgent manufacturing job.

In the case of non-conformities operations are carried out as described in chapter 8.7.

Supplier rating

A supplier rating is carried out as an initial rating, and as a repeat rating of an already qualified supplier. The following aspects are, for example, of particular interest to the rating:

Quality of the products or services

Recognized management system (certified, audited, proven)

Commercial order processing

Flexibility

Delivery reliability

Pricing

Qualification of the executive or performing personnel

Especially in the area of services, such topics as occupational safety, environment and energy are taken into account for assessment.

For quality-relevant and other major products an initial sample testing and a trial shipment of a smaller scale is carried out on principle prior to the first order.

The results and changes of the supplier assessment are documented and are taken into account for purchasing. This in particular includes the possible blocking of suppliers and products.

Supplier audits are carried out as needed on a national or international level in conjunction with the relevant individual departments.

Procedures for construction projects

The planning responsibility belongs to the construction builder or the project manager. For planning, s/he is required to incorporate in time the necessary specialist departments, such as occupational safety, health service, environmental protection and technology, the incident officer and the energy manager. Moreover, s/he is bound to comply with the legal and governmental regulations as well as those of the Employers’ Liability Insurance Association, such as the appointment of suitable coordinators or the compilation of a safety and health protection plan.

Purchasing of hazardous materials

The purchasing of hazardous materials is done exclusively over the warehouse administration and carried out by SHS-Services. This procedure ensures that the hazardous materials are controlled and have access to Dillinger by only one defined way. In cases of new purchases the procedural regulations for purchasing hazardous materials through the purchasing department apply.

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8.4.3 Information for external providers

Purchasing from external suppliers is generally carried out under the following processes or instructions:

Need determination, provision requests, inquiry, supplier instructions, order/request, delivery, examination, modalities in the case of changes or, respectively, non-conformity, documentation.

As a part of the order, the following, among others, are defined:

order number, supplier

instructions for the product, such as delivery standard, specification, quantity, identity, (safety) data sheet

where reasonable: procedures, processes, equipment

internal delivery address (user, warehouse)

date of delivery

checking and release

where appropriate: qualification of personnel (e.g. at partner companies)

required occupational safety criteria or specifications or environmental regulations

The services- and material-specific content of the orders placed by the purchasing department to suppliers must be identical with those detailed in the requisition notification.

The order documents are secured in the purchasing departments, and the supplier documents (e.g. shipping notes, bill of delivery) in the offices responsible for the respective incoming goods.

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8.5 Production and service provision

8.5.1 Control of production and service provision

DILLINGER is an integrated mill, which covers the complete production chain, from the production of coke and hot metal to steel and plate production. In this way, all decisive factors can be controlled, optimized and perfectly adjusted. In this context, technologies from Industry 4.0 are used in more and more areas so as to organize the processes more efficiently, flexibly and faster.

At DILLINGER, all processes and competencies are concentrated in one location. Here, employees from the blast furnaces, the steel plant, the rolling mill work closely together with metallurgists, IT-experts and logistics specialists. Together with our customers, we thus develop convincing solutions for the challenges of the future.

Production planning and -control

Production planning and control includes specification and coordination of order-completion scheduling and capacity planning, and also control of production in the rolling-mill and steelmaking plant production sectors.

Specifically, this means with respect to

The scheduling:

Scheduling of orders through allocation to DH or DF under consideration of deadlines, capacities, costs and delivery possibilities (feasibility in both plants)

Capacity-shortage management for the DH / DF production plants

Agreement of medium-term quantity planning (quarterly planning) with sales planning

Continuous inclusion of the production situation by means of regular Target/Actual assessments

Handling of order changes

Planning, co-ordination and adjustment of the slab supply of DF

The slab supply:

Determination of the slab weights, pre-material input calculation and optimal combination of the plates in the slabs for mother plates

Determination of the analyses, of the customer orders to be planned within one melt according to grades, norms and plate thicknesses

Compilation of sequences from the planned melts

Slab release on the basis of warehouse allocation/after casting

Warehouse management of unallocated slabs at the Dillingen and Dunkirk warehouses

Needs notification and use of bought-in material

The production control of the steel plant:

Drafting of the daily production plan

Regular coordination on deadlines and restrictions with the planning department and slab supply

Monitoring: On-time casting

Heat monitoring for adherence to analysis specifications, inc. release, embargoing or additional sampling/analysis

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Production control in the rolling mill:

Controlling the time schedules and the flame-cutting program of the slab preparation shop

Compilation of the rolling program with the objective of a high throughput under consideration of quality assurance

Determination of the input into the bogie hearth furnaces and pusher

Medium-term planning of rolling campaigns

Determination of the bunker input for optimal utilization of the hot stacking capacities

Determination of the input requirements of the bogie hearth furnaces

Time schedule supervision and production monitoring for control of production in due time

Co-ordination of tests and sample rollings

Coupon and sample requirements in special testing jobs

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Production chain of DILLINGER

Diagram: Production chain of DILLINGER Coking plant

Zentralkokerei Saar GmbH (ZKS) is a joint subsidiary of Aktien-Gesellschaft der Dillinger Hüttenwerke, Dillingen, and Saarstahl AG, Völklingen, with each directly or indirectly holding 50% of the company’s shares. ZKS operates with two coke batteries in continuous operation, whose total capacity is up to approx. 1.2 million tons of coke per year. Aside from the coke, which is produced exclusively for use in the blast furnaces of the affiliated company, ROGESA Roheisengesellschaft Saar GmbH (also a joint subsidiary of Aktien-Gesellschaft der Dillinger Hüttenwerke and Saarstahl AG), the production program also includes resulting by-products such as raw tar, crude benzene and pure sulfur.

Production facilities:

Batteries: 2 (Battery 1 with 40 ovens, Battery 2 with 50 coke ovens)

Process: Saarberg compression process

Chamber height: 6.25 m

Chamber volume: 44 m³

Products: Blast furnace coke, coking gas, tar, naphta, sulfur

Capacity: ca. 1.2 mio. t total coke/annum

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Blast furnace

ROGESA Roheisengesellschaft Saar mbH, Dillingen, is a joint subsidiary of Aktien-Gesellschaft der Dillinger Hüttenwerke, Dillingen, and Saarstahl AG, Völklingen, with each directly or indirectly holding 50% of the company’s shares.

"Hot metal" is produced in the blast furnaces from iron ore, coke, coal and additives. Upstream of the blast furnaces are two sinter plants.

The blast-furnace process is being continuously optimized to achieve higher efficiencies and quality, by means, for example, of extremely high coal-injection rates. Sustainability is also of great importance, however, and by-product gases are converted to electrical energy in a blast-furnace gas power plant located at Dillingen.

The production of hot metal also yields a by-product: slag, which is used as an ecologically safe building material in highway construction, or in the cement industry, in the form of ground granulated blast-furnace slag (GGBFS).


No. of blast furnaces: 3 (of which one as back-up)

Diameter: 12 m, 11.2 m, 8.5 m

Products: Hot metal, lump slag, slag sand for the building industry

Capacity: 4.6 mio. t hot metal/annum for Dillinger Hütte and Saarstahl AG

Approx. 1.2 mio. t slag granulation plant

*Blast furnace 3 Blast furnace 4 Blast furnace 5

Year constructed 1965 1974 1985 Hearth diameter 8.5 m 11.2 m 12.0 Usable volume 1,280 m3 2,360 m3 2,893 m3 Nominal capacity 2,000 t/d 6,100 t/d 7,000 t/d *on standby

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Steel plant

Hot metal is refined with the addition of recycled scrap to make crude steel using the basic oxygen process in two 190 t converters in the LD steelmaking plant. This process converts the high-carbon iron to low-carbon steel. An important operation in the steelmaking plant's process takes the form of so-called secondary metallurgical treatments, such as vacuum treatment of the liquid steel, for example. VD vacuum degassing installations make it possible to adjust extremely low residual contents of detrimental impurity elements – such as sulfur, for instance – in the steel and to match alloying to the downstream rolling process. The capacity of the vacuum installations is dimensioned to permit treatment of the entire production quantity for the achievement of ultra-high cleanness in these steels.

The steelmaking plant's main products are continuous-cast slabs, which are cast in formats of up to 600 x 2,200 mm - a world record! Both the vertical bending and the vertical process are used in Dillinger's steelmaking plant. These processes achieve much superior cleanness throughout the entire cross-section of the slab than other continuous-casting systems. Other products of the steelmaking plant include conventionally cast ingots of up to 60 tons gross weight, and steel castings.

The figure below schematically represents the production route described above:

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Hot-metal desulfurization system with deslagging stand

Two basic oxygen converters, each 190 t, with Ar/N2 bottom bubbling

Secondary metallurgy:

- Ladle-bottom bubbling (1 to 3 bubbling bricks)

- Lance bubbling

- Vacuum treatment/ladle degassing

Three continuous casters

Ingot casting (up to 60 t ingot weight)

Continuous casters

- Number: 4

- Type: Twin-strand vertical-bending caster

- Slab thicknesses: up to 600 mm

- Slab widths: up to 2200 mm Inspection and test during the steel plant process

Cl.

No. Manufacturing Step Process/Product Characteristics

1 Order processing Technical order

2 Desulfurization of hot metal Chemical composition, Temperature

3 Steel making Chemical composition, Temperature

4 Secondary metallurgy Chemical Composition, Temperature

5 Radioactive control Radioactivity

6 Continuous casting Temperature, Casting speed

7 Analysis check Chemical composition

8 Hydrogen control Hydrogen content, Time, Temperature

9 Cutting to length Slab dimension

10 Mother slab visual inspection; Test scarfing Surface condition, Free of visible detrimental defects

11 Slab identity/Traceability Slab number, Heat number

12 Despatch Slab/Heat Number

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Heavy-plate rolling mills

Dillinger's heavy-plate rolling mills, located at Dillingen and Dunkirk (Dillinger France), are among the most powerful in the world. They are used to transform slabs and ingots into heavy plates with lengths of up to 40 m, widths of above 5 m and thicknesses of up to 500 mm. The steelmaking plant, rolling mill and Product Development departments co-operate closely to produce tailor-made heavy plates: chemical composition, rolling process and heat-treatment parameters are optimally matched to the steel's specified requirement profile.

For rolling, two four-high reversing stands are used. The unusually large roll-body lengths permit the production of exceptionally wide plates and high item weights. Extremely high reduction ratios can be achieved even when rolling very thick plates, thanks to the enormous rolling force applied.

Production in the rolling mills is largely automated and computer-based. The process parameters (passing schedule with temperature, thickness reduction, cooling schedule etc.) are determined beforehand on the basis of mathematical models and transferred into the operation-data processor.

The production of heavy plates in all required delivery states is possible when these plants' cooling lines and heat-treatment furnaces plus a quenching-and-tempering system are included.

Prior to shipping, every plate that leaves our mills is submitted to an inspection in accordance with the customer's specifications. Non-destructive testing, such as surface inspection, geometrical and dimensional checks, and ultrasonic inspection, is performed on the plate itself during the flow of production. Specimens are taken and examined using the most diverse range of test procedures in the acceptance-inspection laboratory in order to check mechanical and technological properties, such as yield strength, tensile strength, hardness, Charpy V-notch toughness, etc. For shipping, large loading and transport capacities (truck, rail or inland water vessel) are available.

Production facilities

Rolling mill Dillingen Rolling mill Dünkirchen

3 slab pusher + 3 bogie hearth furnaces

5.5 m Quarto: roughing stand

4.8 m Quarto: finishing stand

Dimensions of heavy plates:

- 6 - 450 mm thickness - up to 5,200 mm width

MULPIC-cooling section (ACC, direct quenching)

Flame cutting and shear line

Automatic ultrasonic testing machine

Heat treatment furnaces

Water quenching facility

Shot blasting and priming facilities

Treatment methods: TM, normalizing rolled, normalized, tempered, water quenched

3 slab pusher furnaces

4.3 m Quarto: roughing stand

5.0 m Quarto: finishing stand

Dimensions of heavy plates:

- 6 - 200 mm thickness - up to 4,700 mm width

ACC-cooling section

Flame cutting and shear line

Automatic ultrasonic testing machine

Heat treatment furnaces

Shot blasting and priming facility

Treatment methods:

TM, normalizing rolled, normalized, tempered

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The figure below schematically represents the production route for the Dillingen location as described above:

Measurement equipment in the mother plate production process

During the production of the mother plate a large number of parameters are measured within the various production steps, such as length, width, thickness, levelness, contour and internal properties.

For the calibration of the thickness measurement equipment, reference units are built in, which are inserted in regular intervals into the measurement gap.

Furthermore, for cyclical testing of the measurement equipment, reference test units are passed through and measured.

Temperature Measurement

The temperature measurement facilities, which are installed, for example,

in the production facilities

in the heat treatment furnaces

are inspected and maintained on the basis of defined time schedules.

The following measurement methods are applied in this context:

Temperature measurement with thermocouples

Temperature measurement with resistance thermometers

Temperature measurement with pyrometers

For this measurement procedure, company standards relating to national standards are in place, which are tested against national and international temperature standards. Against these company standards all temperature measurements are tested and the results are systematically archived.

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Quality monitoring during heating and heat treatment

Quality monitoring in the rolling mill furnaces of DH is carried out in several steps:

The measurement equipment in the furnace is subject to continuous quality assurance and is regularly reviewed.

Comprehensive tests with prepared test plates and slabs heated in the furnaces under production conditions are carried out in regular intervals. The temperatures measured are used for quality monitoring, for the compilation of requirements and for the parametrization of mathematical models. These tests are also carried out after alterations in a furnace.

Through continuous monitoring of the mechanical-technical properties of the heat-treated products, the reproducibility of the thermal process steps is confirmed and assured.

Inspection and Test during the rolling process

Manufacturing step Process-, product

characteristics

1 Order processing Technical order

2 Incoming inspection

CC-slabs

Identity, weight of slab

3 Re-heating of slabs Heating rate,

temperature, time

4 Plate rolling Temperature, thickness,

width, time

5 Accelerated cooling Temperature

6 Hot levelling Flatness

7 Hot marking Identity

8 Hydrogen effusion Identity, temperature,

time, stack height

9 Visual inspection Surface condition

10 Dimensional checks Nominal dimensions and

tolerances

11 Sketching and Stamping

plate and test coupon

Identity,

correspondence of

plate/test-coupon,

order/plate/heat number

12 Marking Order/plate/ heat number,

grade, dimensions

13 Sensitivity check UT Detection of artificial

defects on test plate

14 Ultrasonic inspection Inspection, soundness of

plate

Manufacturing step Process-, product

characteristic

15 Ultrasonic inspection Re-Inspection

16 Heat treatment

Temperature, time, holding

time

17 Plate cutting Condition of equipment,

dimensions, edge scrap

18 Sampling Agreement of identity and

position

19 Grinding (if applied) Identity, surface condition,

plate thickness

20 MPI (magnetic particle

inspection)

No cracks or crack-like

defects, surface condition

21 Testing of mechanical

properties Test results

22 Test of product analysis Product analysis

23 Final inspection

Surface condition

dimensions, shape,

marking and supplemental

requirements acc. to

specification

24 Dispatch Released plates

25 Certification Inspection documents

Tolerances of dimension and form and surface properties of the heavy plates

DILLINGER’s plates are produced according to international norms and technical delivery conditions. Depending on the customers’ specifications higher requirements can be supplied.

Surface treatment

For heat treatment of the plates, automatic shot blasting facilities and shop primer facilities are available so as to temporarily protect the plates from corrosion.

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Maintenance at DILLINGER

The Maintenance Department ensures the sustainable availability and functionality of the facilities for production, transport, communication, and testing, as well as the facilities for energy and media supply.

Maintenance is carried out in a controlled way by the special sections:

by the production-relevant maintenance department directly at the production facilities

by the Central Energies and Media Department directly at the energy facilities and media networks

by the company’s central maintenance all across the plant

by the central workshops (maintenance, repair and manufacturing of building components (DH)

by the partner companies

Maintenance activities concern:

preventive maintenance with inspection, servicing and/or condition-related repair

technical modernization

technical analyses with weak points examination and removal

restoring of functions following failures/disturbances (also with safety and environment-relevant conditions)

servicing of manufacturing equipment

storing and provisioning as well as purchasing and processing of the spare and reserve parts

qualification of personnel

participation in conception and optimization of the manufacturing facilities

support of appointed partner companies

Through regular maintenance of the environment-, energy- and safety-relevant plant units (safety devices; exhaust air filter; heat exchangers etc.), the risk of adverse effects on the environment, of energy losses, accidents and damage to health through the occurrence of defects is minimized. Among the preventive maintenance measures are the periodic expert inspections which are, for example, carried out on pressure vessels or VawS facilities (VawS: Regulations on facilities handling substances dangerous to water), the risk assessment of the facilities, the examination of the facilities with state-of-the-art diagnostic procedures (for example vibration measurements of the bearings).

Central Workshops and Warehouse Administration (DH)

The Central Workshops function as the works-wide, stationary maintenance and repair, as well as the provision of operational media for the production facilities.

The core compentencies of the Central Workshops are:

immediate elimination of production disruptions

repair/new manufacture of strategic spare and reserve parts (up to 100 t)

supply of the means of production to the production areas

maintenance of utility vehicles and rail vehicles (according to ECM regulations)

production steps on DILLINGER products

Further task-related certifications of the Central Workshops are for example according to: DIN 18800-7(E), DIN EN 15085-2, AD2000 HP0, EN ISO 3834-2, ECM approval according to EU Regulation no. 445/2011

The core competencies of the Warehouse Administration are:

storage and inventory management of auxiliary and operation materials as well as spare and reserve parts

making refractory materials available for all production operations

full service as needed for the steel plant with respect to refractory material

hazardous substances management

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New construction

The new construction of facilities at DILLINGER is centrally controlled by the new construction departments. Project handling comprises the steps of project organization, rough planning of concepts, execution planning and project management of new construction projects.

This initially contains the compilation of specification sheets, the definition of the spare and reserve parts and their complete procurement process (tender/selection/ordering).

Purchasing is carried out in cooperation with the departments of operational safety, environmental protection/technology, and the energy managers, with the aim of acquiring safe, environment-protecting and energy-efficient facilities and facility components.

The approval process with the authorities is realized in cooperation with the Environmental Protection and Technology Department.

For project management, the New Construction Department takes over planning engineering, building site monitoring, construction site management and construction monitoring.

Further tasks are the commissioning and final inspection of the facilities as well as the warranty management.

The complete new construction process is documented and archived. Heavy Fabrication Division

The Heavy Fabrication Division (WV), located in Dillingen, is an integrated steel processing and service operation with two core activities in the operational areas of WV-heavy plate (focuses: forming technology, welding technology) and WV-foundry.

The task of the business unit is the independent marketing, sales and manufacturing of high-quality processed plates, plate cuttings, cold/hot-formed components, welded components as well as foundry products from steel casting and cast iron. Mainly products from DILLINGER are used in these processes.

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The services of Heavy Fabrication can be used by the customers in manifold ways, for example if their own possibilities for further processing have reached a limit. Thus, this allows the complementation and enlargement of their own production range.

Furthermore, Heavy Fabrication also contributes with its products and services to the supply of the operations and subsidiaries of the group (among others, new manufacture or repair of construction units/components, own demand for spare/reserve parts) or through support of their activities (among others, trimming, levelling and heat treatment of heavy plate).

Heavy Fabrication is subdivided into the areas sales, work preparation, production planning and control, production operations, maintenance and the area of central functions (IT, controlling, management systems). Heavy Fabrication - Sales is responsible for the commercial processes of the business unit (among others, sales/turnover responsibility, offer/order processing), and it represents the Heavy Fabrication Division at its customers. Work Preparation and Production Planning and Production Controlling (among others, technical offer/order processing, product/process/quality development, order planning/scheduling, time management) are responsible for the techical, time-related and quantitative process requirements, as well as procedure audits and approvals.

The manufacturing of the intermediate and final products, of the tool and fixture construction and, respectively, forms construction, as well as the development, introduction and mastering of new production processes in the area of forming technology, welding technology and foundry technology is the task of the respective Heavy Fabrication production units.

The preparation & components construction operations, presses

Dimensionally accurate machining of heavy plate through thermal cutting

Welding seam preparation (thermal cutting, milling, turning)

Plates with welding seam preparation (edge preparation) can also be bent on radius, with smallest tolerances

Hot and cold forming – depending on product, dimension and purpose of use – of thick-walled and large-dimension plates into shells and shell sections, single or multi-part vessel heads, edge-milled and pressed parts

Welding of components (e.g. shell sections, steel pouring ladles)

Tool design and construction; FEM analyses/forming simulation; tool design and tool construction; fixtures construction

Mechanical processing

Heat treatment: normalising, annealing, tempering

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Foundry operation

Manufacturing of cast iron and cast steel products: e.g. slag pots, ingot molds, bottom pouring plates, pouring funnels and dies for tools

Form filling, form finishing, casting, preparation of rough cast components: stripping, removal of feeding and gating system, cleaning, heat treatment, finishing and construction welding

Final inspection (among others dimension, NDT tests), documentation of the test results and release of the Heavy Fabrication Division products are carried out by the ABN-Fabrication Control Department, or, respectively, third party inspection, if agreed upon.

The Heavy Fabrication Division core processes are supported by the further processing areas:

IT and systems development (WV-ERP system)

Controlling and management systems

Maintenance and service

Overview: Processes of the Heavy Fabrication Division

The Heavy Fabrication Division is certified in all areas according to ISO 9001, ISO 14001, OHSAS 18001, ISO 50001; in the area of Heavy Fabrication Division - Heavy Plate additionally according to ASME Section I, VIII-1, VIII-2, AD2000 (HP0), TRD201, ISO 3834-2, EN 1090-2 (EXC4), Manufacturer License of Special Equipment for Boiler & Pressure Vessel PRC.

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Subsidiaries of DILLINGER

Steelwind Nordenham (SWN)

The manufacturing concept of SWN is based on the complete production of foundations for offshore wind generators consisting of monopiles and transition pieces, including all necessary onshore works and services such as coating or assembly of the secondary steel components or technical installations.

Products

Mega Monopiles consist of a foundation pile which is rammed, drilled or vibrated deep into the seabed and extends up above sea level, and transition pieces mounted on the foundation pile.

Steelwind Nordenham manufactures Mega Monopiles which can be used in water depths of up to 45 m with unit weights of up to 1,500 t, lengths of up to 120 m and diameters of up to 10 m with wall thicknesses of up to 150 mm.

Moreover, transition pieces of up to 300 t, fully equipped, coated and ready for installation, conical shell sections and piling pipes can be manufactured.

Industry-section related certifications at SWN are for example ISO 3834-2 or EN 1090-2:2008+A1:2011.

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Jebens

Jebens specializes on flame-cut steel parts, cut-to-size plates and ready-to-install welded components for demanding requirements in the heavy machine and facility construction sector. Products and services

Flame-cut parts and cut-to-size plates with unit weights of up to 55 t – with the support of a mobile crane, of up to 70 t. Moreover, ready-to-install welded components with unit weights of up to 160 t can be manufactured. With the works-owned annealing furnace, for example, components of up to 160 t can be job-annealed. Additionally, Jebens operates a plate warehouse for trading heavy plates with unit weights of up to 55 t.

Ancofer Stahlhandel

As a steel trader, Ancofer supplies a comprehensive range of heavy plates, flame cut parts and hollow structural sections, backed up by extensive heavy fabrication. Products and services

Ancofer Stahlhandel supplies heavy plates ex warehouse with unit weights of up to 50 t.

Additionally, flame-cut parts of up to 600 mm thickness can be manufactured via CNC-controlled flame-cutting machines and a plasma facility. With respect to length and width, flame-cut parts of a width of up to 9 meters and a length of 30 meters can be manufactured. DILLINGER Middle East

DILLINGER Middle East supplies heavy plates ex warehouse and is responsible for sales in the Middle East. Saar-Rhein-Transportgesellschaft und Trans-Saar

The focus of the transport companies Saar-Rhein and Trans-Saar is the transport of heavy plate and raw materials by using rail and truck as well as inland waterway vessels and sea-going ships.

http://www.ancofer.de/en/the-ancofer-range/heavy-plate/

http://www.ancofer.de/en/the-ancofer-range/flame-cut-components/

http://www.ancofer.de/en/the-ancofer-range/hollow-sections/

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8.5.2 Identification and traceability

The products and their documents and data can be identified and allocated throughout the entire order-process (manufacturing, storage, transport) and all the way back to their origins.

Identity and traceability of the products are ensured through physical markings on the products or through appropriate replacement measures with accompanying papers or computer programmes.

Particularly when the markings on the products are themselves momentarily inaccessible or lost, specific replacement measures, such as furnace charging plans, written records, transfer to other surfaces, ensure that the right product is provided with the proper markings again before further processing.

Possible marking-types are, according to specification: (hard) stamping, dye stamping, labels.

Specific employees are defined and qualified for stamping and re-stamping.

The following schema shows the sequences of each processing step and the associated markings, identity securing and traceability.

Identification and traceability

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Plate marking

DILLINGER heavy plates are regularly marked with a marking by steel stamp – pointed, low stress – and/or paint marking. Other types of marking are possible on agreement.

Steel stamping consists of the following information:

Steel grade, melt number, mother plate and individual plate number, rolling direction, manufacturer’s mark, as well as the mark of the final reception officer, and other data agreed on.

The standard paint marking contains the mother plate and individual plate number, the works order and position number, as well as the order dimensions with plate width, length and thickness.

An additional marking specified by the customer can be attached to the upper surface of the plate.

Paint bar code markings can be agreed on for the paint marking of the plate edge.

Example for a plate marking Material tracing

Material tracing is ensured through a works-programmed software (Platerouter). Platerouter is based on a Local Positioning Radar (LPR)-system. Each crane in the rolling mill and the slab preparation yard is equipped with LPR. Each plate movement is confirmed with statement of place and time. In the production plan each required process step is defined by the systems technology. Concluded process steps are systematically confirmed.

Through the combined application of the production plan and the Platerouter, it is possible to determine the position of each slab and each plate at any time (see figure below).

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Combination: Trace and Manufacturing Schedule

8.5.3 Property belonging to customers or external providers

The case that the customer’s placed products become part of the consignment only occurs as an exception, for example, as a part of job work or foundry products.

The following regulations are applied:

Customer property (including intellectual) is generally handled with the same care as DILLINGER property, in particular with respect to: inspection of incoming goods, identification/marking, handling, storage and conservation as well as delivery of customer-provided products.

Further measures, such as quality-tests and certificates, are carried out according to

agreements. Loss, damage or impairment of customer property are documented in the process,

and a solution will be worked out together with the costumer. 8.5.4 Preservation

From each of the operations/mills, the products are transported, handled and stored according to the applicable and relevant regulations from the beginning of manufacturing all the way to shipment, so that any impairment in the condition can be avoided.

Before usage or processing, the product’s condition is assessed in order to find and eliminate any possible errors to products or parts.

The means to the identification of the temporarily stored products is their individual marking.

The loading of products onto rail wagons, trucks or ships is carried out according to internal regulations or those of the transport company.

After completion of the final inspection the product is released, without this release no product can be loaded for shipping.

The product’s quality and identification documents are provided to the customer as part of the transport, by mail or through electronic communication.

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8.5.5 Post-delivery activities

For technical questions or claims, the customer receives in-depth consultation by the Technical Service, if needed also through diverse special departments. 8.5.6 Control of changes

Process changes in production are verified and validated as a matter of principle, so that conformity with the requirements is ensured. 8.6 Release of products and services

In the case of heavy plate, certain quality examinations are allocated to qualified and responsible test personnel of the inspection department or of the production operations. The monitoring of the processes of the "company self-inspection” as well as the final release is carried out by the "Inspection Department", which is independent of the production operations.

Certain examination steps or monitoring measures may be carried out, depending on an agreement at the time of ordering, in the presence of the orderer or of his representative ("third party inspection").

If a product does not meet the requirements the examining department identifies and documents the deviations.

Inspection department

The Inspection Department is accredited according to EN ISO/IEC 17025.

The tasks of the inspection department are:

ABN (Inspection Department) order processing

Sample shop (sample taking, simulating sample heat treatment)

Test house (sample testing for mechanical-technological material testing)

Metallography (metallographic examinations, corrosion-chemical material testing)

Third-party inspector control and compiling of certificates

Test technology – DT (such as measurement uncertainty calculations)

ABN-IT-systems

Quality-testing in the rolling mill/NDT (e.g. surface inspection, dimension examination, incl. sample taking)

Ultra-sonic testing in production (automatic and manual)

NDT (Non-destructive test technology) (such as compiling of testing specifications)

Slab monitoring

Production monitoring

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The activities, testing facilities and testing equipment, the procedures for conducting examinations and measurements and the procedures for monitoring and calibration of the testing facilities and testing equipment are described in the QM-Manual of the testing laboratories of the Inspection Department.

The tests and examinations preferably applied are:

destructive:

Tensile and Charpy impact tests

Hardness tests

Bending tests

Drop weight tear tests

Weld bead bend tests

Corrosion tests (HIC, SSC)

Examinations of welding seams

Makroscopic and microscopic methods in metallography

non-destructive:

Ultrasonic testing

Magnetic particle testing

Eddy current testing

Dye penetrant test

Hardness test on the product

Visual surface inspection

Examination of dimensions

Measurement of residual magnetism

X-ray examination

Spectrometer

The Inspection Department participates in comparative studies (round robin tests), organized nationally and internationally, e.g. by professional associations.

Moreover, final inspection (Fabrication Control Group) is responsible for non-destructive testing within the framework of maintenance at the Dillingen location.

Non-destructive testing of plates within the production process

DILLINGER steels are always tested against compliance with the parameters laid down in the respective norms, standards, materials sheets and customer specifications. For this test, among others, non-destructive testing is performed within the production flow. The inspection of the surface properties and form and dimension is carried out according to the conditions of valid international norms as long as no other conditions were agreed on.

Ultrasonic testing

The inspection of the interior properties of the plates (absence of unacceptable material discontinuities and inclusions) is carried out through ultrasound. Ultrasonic tests (US) within the production flow are carried out by an automatic ultrasonic heavy plate testing facility or through multi-channel mobile test devices (5 to 8 channels).

If specified in the order, US-testing can be carried out according to national, European and international standards, as well as according to other norms and customer specifications after prior agreement.

All classes for surface area and edge zone as well as all class combinations are possible. The scope of testing as defined by the norm is applied as a standard procedure.

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The testing personnel is qualified and certified both for automatic and manual testing, and certified according to Level 2 DIN EN ISO 9712 and, if applicable, according to SNT-TC-1A.

Furthermore, several qualified and certified UT Level 3 testers according to DIN EN ISO 9712 and, if applicable, according to SNT-TC-1A, are available as test supervisors.

US heavy plate testing unit for plate thicknesses of up to 55 mm in

the shearing line

Manual US testing for plate thicknesses

of up to 400 mm

Chemical analyses and chemical-physical examinations at the Dillingen location

The chemical laboratories of Dillinger Hütte are qualified according to EN ISO/IEC 17025.

The activities of the testing lab are:

sample taking and sample processing from the essential plant-specific materials

anorganic-chemical analysis of steel, hot metal, coke as well as production materials, raw materials and by-products of the steel, hot metal and coke production.

anorganic, organic-chemical analysis of waters, waste waters, soils, sludges, dusts, gases and air

chemical-physical determination as well as chemical analysis of lubrication materials

anorganc, organic-chemical contract analysis

contradictory anorganic-chemical analysis from purchasing contracts

Activities in the case of additional qualification as a certification lab

Production and certification of anorganic reference material for internal and external use. The activities, testing facilities and testing media, the processes for carrying out inspections and measurements and the processes for monitoring and calibration of the testing facilities and testing media are defined in the QM-Manual of the chemical laboratories.

The generally applied measurement tools are:

Optical emission spectrometry (OES) after spark excitation

Ex-ray fluorescence spectrometry (RFA)

Atomic absorption spectrometry (AAS), UV/VIS-spectral photometry, infrared spectrometry (IR)

Inductively coupled plasma with optical emission spectrometry (ICP-OES), with quadrupole mass spectrometry (ICP-QMS), with sector field mass spectrometry (ICP-SFMS)

Combustion process with infrared detection, with coulometric detection

Hot extraction process with thermal conductivity detection

Ion chromatography (IC), gas chromatography (GC), high performance liquid chromatography (HPLC), flow injection analyses (FIA), gas chromatography with mass spectrometric detection (GC-MS), viscosimetry

The labs participate in comparative studies (round-robin tests), organized nationally and internationally, e.g. by professional associations.

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Release for dispatch

The Inspection Departments shall examine the conformity of the quality characteristics of the products (plates, construction components) to the agreed specifications.

In the case of indubitable conformity of the quality characteristics to the order requirements, the release of the products for dispatch is granted. In the case of heavy plate the final release is granted after feedback of all individual specific release steps.

Release will become evident:

in the case of heavy plate: through the release code in the IT-system and, externally, through the test stamp of the Inspection Department on the plate.

in the Heavy Fabrication Division: through the release mark of Fabrication Control on the plate construction-component, or, respectively, of the component-related documentation of the finished casting components.

In the case of agreed third party inspection, the Inspection Department at first carries out the agreed inspections and/or examinations in co-operation with the "third-party inspector"; then, release is granted through the "third-party inspector" and finally through DILLINGER.

Released and dispatched products (heavy plate, construction components, forms) are registered in order documents (IT, dossier). The Inspection Department issues statements and inspection test certificates and brings the relevant inspection documents together into a dossier. 8.7 Control of nonconforming outputs

The production of the products in its complete process from order to shipping is subject to a planned succession of quality tests. Like the production steps, they are defined in production documents specific to the order (e.g. in the Technical Order [TA] Fabrication Plan.

All official quality tests are based on norms, process procedures, inspection procedures, work procedures or IT programs.

Standard controls and holding points are integrated into the production plan so that production can be continued only after the nominal values as defined through the regulated tests have been reached. The performance and the result of the quality tests are documented. The respective status of production and tests is continuously updated in the production plan. Thus, it is traceable at any time ("order tracing").

A large part of the non-conformities (e.g. products, processes) and their possible errors are differentiated by "error keys/codes” according to error-type; specific further measures are often attached to this standardization.

In the manufacturing of slabs and plates, errors are registered and documented by the IT system, and in the Heavy Fabrication Division by the ”error report"

If necessary and feasible, non-conformities (e.g. errors in products) are particularly labelled, blocked or separated. Non-conforming results are documented with respect to type, actions, releases and the responsible unit. If a process/product is identified as deficient, counter-actions will be taken so as to remove the deficiency.

Plates showing non-conformities are marked with a blocking note in the production plan. The planned, subsequent production steps cannot be carried out anymore. For example, the system cannot print out delivery papers for blocked plates.

If removal of the deficiency is possible, additional testing steps are automatically inserted for reworking. If necessary, permissions for release are required from a relevant office and/or the customer (concession request, special releases).

The objective of all the activities mentioned is that non-conforming products, processes or facilities are not used unintentionally, delivered, or operate further.

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8.8 Aspects of occupational safety, health and environmental protection, of energy efficiency and safety of facilities

8.8.1 Assessment of working conditions (risk and stress factors)

Occupational Risk Assessment

The employer is bound by various laws, ordinances and regulations (e.g. ArbSchG, BetrSichV, GefStoffV, DGUV V1 - Safety and Health at Work Act, Industrial Safety Regulation, Ordinance on Hazardous Substances, Regulation on Safety at Work) to assess the working conditions in its enterprise from the perspective of occupational safety and to take the required safety measures. The most important tool for the implementation of the obligation is the risk assessment (GBU).

In this context, occupational risk assessment at DILLINGER also includes, inter alia:

Hazards and risks for the environment, the product and the facilities

Relevant historical incidents

Hazardous substances

Psychological factors

The risk assessment at DILLINGER takes additional risks under consideration, such as hazards or, respectively, risks for the environment, the product and the facilities.

The result of the risk assessment is documented in the Integrated Management Information System (IMIS).

For this, process descriptions of the operational, value-adding processes serve as the basis, so that the respective risks can be directly allocated to the processes and can there be described.

Necessary actions are allocated to the responsible persons by name.

In the IMIS module "Conclusion Management", the processing status of the actions is continuously updated and regularly reported to the responsible person via Outlook notification.

Additionally, the actions resulting from the risk assessment are subjected to implementation and efficiency monitoring and are conclusively verified through internal audits.

In this respect the procedure is as follows:

1. Determination of the risk (with all known protective actions)

2. Documentation of known, concluded, efficient actions

3. In the case of too high a risk: Determination of new, additional actions

4. Monitoring of implementation and efficiency of the new, additional actions

5. New assessment of the risk

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Specification of action takes place at DILLINGER in accordance with the following graduated hierarchy of measures:

Occupational Risk Assessment – Hazardous Substances

Assessment of hazards arising from hazardous substances is performed separately in SAP. The so-called "Simplified Procedure" is used as an initial step in the case of hazardous substances which do not meet the criteria for classification as carcinogenic, mutagenic, reprotoxic (CMR) or toxic. In this case, the hazard assessment is conducted using a nine-point check-list.

The hazard assessment is completed once all the criteria on the check-list have been fulfilled. An expanded risk assessment, as is standard for CMR and toxic substances, must be performed if even only one criterion on the check-list is not met.

The operating procedure, containing explanatory details on the hazards and the safety measures derived, is generated at the end of each risk-assessment process.

Where the occupational risk assessment indicates that replacement with a less hazardous substance is possible, this replacement is implemented.

The occupational risk assessment of hazardous substances produced on site is always conducted on the basis of the expanded procedure in SAP, due to the large quantities involved and the in many cases relatively high hazard potentials. The critical hazard potentials of the individual substances/mixtures acting with one another are taken into account and prioritised in this context.

Potential Emergency Situations (Near-miss Situations)

Potential emergency situations are registered in an Intranet-based central registration module and are documented and correspondingly evaluated in SAP. Where necessary, the potential hazard is included in the occupational risk assessment and corresponding measures are initiated.

2. Technical safety measures (spatial separation at the source)

4. Use of personal protection equipment (spatial separation on the human body)

3. Organisational measures (spatial/chronological separation of factor and human)

1. Avoidance/elimination/reduction of hazard sources;

Modification of the properties of the source

5. Behaviour-related measures

Rea

ch

of th

e a

ctio

n

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Non-Routine Activities

Non-routine work, i.e., work which can be planned in advance only with difficulty, if at all, and which is performed for the first time or only rarely, can be included in the operational hazard assessment described above only partially or not at all. For this reason, it is analysed for potential hazards in the context of a "Short risk assessment" performed immediately prior to the start of the work. If necessary, the occupational risk assessment is modified.

Explosion Safety

A hazard assessment in acc. with Article 6 of the Hazardous Substances Regulations must be performed if there is a possibility of the occurrence of an explosible atmosphere in or around gas holders, gas-fired systems and equipment, storage facilities for gases, etc., for example. The result of this risk assessment is the drafting of explosion-safety documents in which the hazards and the necessary provisions are described.

On the basis of the risk assessments and the results of the measurements for hazardous substances, the operations report those employees to the health service who must regularly be examined. They are advised by the works doctor in this matter.

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8.8.2 Placing orders with externals

Next to the economic aspects, the upholding of occupational health and safety protective regulations must also be taken into account when placing orders to external providers. An extensive outside-company management system, which regulates dealings with outside companies, and also their obligations with respect to industrial safety and health protection, exists for this purpose.

Regular supplier evaluations are performed in all cases.

On behalf of the external provider, the first indications of risks that could occur during the execution of the order are made known. The first indications for possible dangers must be further specified over time when needed.

The complete risk assessment is made up of 3 components:

The general binding and facility-specific part

The contract or situation-specific part

The work and trade-specific part

In the case of placing an order with an external provider, all employees of the external provider receive an initial instruction session (general safety video followed by a test to ensure comprehension). The initial training session must be repeated annually. In the course of this, information about the occupational protection policy and regulations is provided.

People who work under contract and whose activities may be the source of significant risk are well trained in the pre-determined safety procedures before their work begins ("building-site instruction - Baustelleneinweisung"). They are informed about goal-setting, the pre-determined operational procedures and the specific dangers of the operations. In addition, they are sensitized to the possible consequences of a deviation.

The adherence to the occupational protection regulations is assessed and documented at the completion of an order, through the operation in which the service was provided.

Regular inspections of the worksites by DILLINGER are performed, inter alia, for this purpose.

External providers will also have to keep to the DILLINGER environmental guidelines relevant for them. These describe for example the handling of substances hazardous to water, or waste disposal.

DILLINGER requires all partner companies to prove that their employees involved have the necessary abilities and trainings. 8.8.3 Environmental aspects

The assessment of the environmental aspects of the company which have a significant impact on the environment is important for the formulation of an applicable environmental policy. Environmental goals are derived from the environmental aspects and serve to minimize environmental impacts of business activities. These goals are also in harmony with the company’s environmental policy.

Safety for human beings and the environment

Avoidance of environmental pollution and the conservation of resources

Manufacture-integrated environmental protection

Promotion of environmental responsibility

Open information policy

Environmental protection management

Changed operating conditions or changes in legal regulations can change the relevance of the individual aspects. Due to this, the assessment of the environmental aspects is a regulated process with a constant focus on the current situation. Assessing the environmental aspects and environmental impacts of each activity follows a uniform and defined system. Inasmuch, all operations follow plant-specific procedures.

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Environmental aspects in product realization

The environment cannot be impacted by the company’s activities over and above the unavoidable. This is why environmental protection measures are an important part of the manufacturing processes and should be preferred over taking action after the fact.

Defined environmental aspects as a part of product realization are:

Emissions into the atmosphere, noise emissions, tremors, smells, dusts, etc.

Discharge and drainage into waters (sanitary and manufacturing waste water)

Recycling, reuse, transfer and disposal of solid and other waste, in particular of hazardous waste (if applicable, environmentally-friendly storage of iron works-related residue on the dump)

Use and pollution of land

Use of natural resources (e.g. water) and raw materials, including energy consumption.

Internal and external operational transport

Risks from environmental impacts that may occur during incidents, accidents and potential emergency situations

Risks that may develop through contact with hazardous goods during shipping from the mill grounds as well as their reception onto the mill grounds

Administrative and planning decisions

From the environmental aspects mentioned above, impacts on the environment can result, such as: Resource consumption

Air pollution, odor nuisance

Burdening of surface waters through direct discharge

Ground water pollution

Land consumption

In order to reduce the impact on the environment, it is necessary to constantly further develop the manufacturing processes concerning environmental protection. Measures that need to be implemented for the improvement of environmental protection, amongst others, are the following:

Application of resource-conserving manufacturing procedures for the optimization of raw materials use and for the optimization of working material use

Minimization of pollutant emissions from the manufacturing processes through the technical optimization of existing installations, as well as through the selection of manufacturing procedures with low pollutant output in the planning of new installations

Reduction of the amount of manufacturing-water waste through, for example, the construction of closed water-circulation systems

Introduction of manufacturing procedures that avoid waste and in which it is possible to utilize the waste created (construction of an internal materials circulation system: ideally = a closed circulation system)

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Facilities requiring approval/approval management

As a part of the new or renovation measures for facilities there are constraints on specific facilities, as determined by legislation, such as according to the BlmSchG (Federal Immission Control Act) acc. to 12. BImSchV (Federal Immission Control Ordinance), acc. to the Energy Management Act and acc. to the Energy Conservation Act (EnEV). The contracting entity/project manager must ensure that all approval regulations concerned (notification according to sec. 15 or the approval request according to sec. 4 or sec. 16 BlmSchG, safety technical statements, inspections and fulfilment of the requirements of EnEV) are processed in time prior to the start of construction.

In the area of approval management, the environment protection and technology department (UST) works closely together with the new construction department (NB) and the central legal department (Zentrale Rechtstabteilung). Approval requests for facilities requiring approval according to the BImSchG, both in the case of new facilities and change approvals, are processed together by UST and NB. UST is also involved in the processing of building projects that are subject to the LBO (state building regulations), as well as any planning relevant to the environment (e.g. VAwS facilities, use of green areas).

Dangerous goods shipment

All dangerous goods transport on public streets and railways is regulated by the Goods Transport Act (GGBefG) and given a concrete form by the ordinance on the national and international carriage of dangerous goods by road, rail and waterways (GGVSEB) in connection with the agreement for International Carriage of Dangerous Goods by Road (ADR and RID).

Handling of waste

All waste that occurs on the mill grounds is compiled for central documentation by the UST department. This is required for the legally prescribed creation of proof of disposal, waste reports, waste register, waste statistics and proof of disposal books.

The filling of containers and all internal operation-waste transports are under the responsibility of the discharging operations (waste producers).

Handling and storage of water-polluting materials

The handling of water-polluting materials (storage, handling, bottling, filling, using) is carried out according to the applicable regulations of the Water Resource Act (WHG) and the ordinance of handling water pollutants (VAwS), and their administrative regulation and technical rules.

Handling and storage of hazardous materials

The hazardous materials ordinance requires that all users investigate all hazardous materials in their work areas and determine dangers for employees, so that countermeasures can be introduced when needed. Apart from this, the possibility for less use of hazardous materials must be investigated, in order to reach an optimization of health protection for the employees.

DILLINGER runs a hazardous materials register according to the hazardous materials ordinance. The care and revision of the hazardous materials register is carried out by the warehouse administration department, and is appropriately changed when legal changes or needs arise. In addition, up-to-date safety data sheets are available.

Employees who work with hazardous materials are given oral instructions before taking on their work, and annually thereafter. The content and date of this instruction are documented in writing.

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8.8.4 Organization for emergencies and prevention of danger

Emergency organization and measures are regulated by DILLINGER central emergency organization, which unites all emergency measures in an organized fashion. A safety management system has been introduced at ZKS and ROGESA, as required by StörfallV (Major Accidents Ordinance).

A central part of the central emergency organization is the alarm and response regulation of DILLINGER task force, the alarm and prevention of danger plan (sec. 10 StörfallV), the safety report according to sec. 9 StörfallV, the emergency evacuation plan, company fire department, company security and health service, complemented by the operational regulations and special additional regulations (e.g. crisis team, standby, emergency ZKS, qualified fire protection organization, etc). The necessary task force and rescue measures are initiated by the company’s safety control center, which is continuously on stand-by, in accordance with the alarm and response regulation. Thereafter, the responsible internal and external areas are informed according to the given information and notification plans.

In the case of events or incidents of major emergencies, a crisis team is created. The crisis team is the on-site administrative support of the task force leader, and is authorized to issue instructions to the task force.

As a part of the organization for emergencies, regular trials are carried out.

Especially in the company areas of ZKS and ROGESA, which are subject to StörfallV, regular inspections are carried out by industrial incidents officers, as well as other operational departments (e.g. company fire department, qualified fire protection officer, occupational safety, environmental protection, etc.), for the investigation of possible danger.

Requirements to prevent accidents

In the operations run according to their intended purpose measures are taken to prevent fires and explosions in the operation areas, as well as attacks by unauthorized individuals on safety-relevant parts. Above that, through regular and documented maintenance of safety-technical relevant facility components and their equipment with reliable warning, alarm and security amenities, a high level of safety is ensured. Necessary safety-technical precautions are met in order to prevent operating errors. Employees are regularly trained in the implemented operating instructions and procedural regulations in order to prevent operating errors. 8.8.5 Improvement of the energy related performance, including energy efficiency, energy

use and energy consumption

DILLINGER carries out a systematic energy planning process. The energy planning includes a review of the activities of the organization which influence the energy-related performance. It is in agreement with the energy policy and leads to activities for the continuous improvement of the energy-related performance.

This serves the purpose of minimizing greenhouse gas emissions, other effects on the environment, as well as energy costs which result from the operational activities.

The keynote is as follows:

"We want to continuously improve the energy efficiency and the energetic efficiency rate of our systems and processes so as to reduce our specific energy consumption and to sustainably preserve the resources".

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Factors of influence on the energy-related performance in product realization

Determined energy influence factors in the framework of product realization are:

amount of the product

type of the product

operational hours

process cycle/planning

technological aspects

maintenance (intervals)

internal loads

weather conditions

user behaviour

qualification of the personnel

The influence factors are reviewed in a continuous process so as to avoid waste of energy. The continuous monitoring of the energy-related performance through consumption measurement and suitable key figures is thus an essential part of the production process.

Actions implemented for the improvement of the energy-related performance are the following among others:

the optimal, plant-wide distribution and utilization of the internally generated energies for minimizing the energy demands from external sources

enhancement of the transparency of energy flows and energy

reduction of the specific energy consumptions of the facilities

optimal efficiency rates in steam generation and distribution and, connected with that, the review of the increase of the heat recovery potentials

8.8.6 Binding commitments and the review of their compliance

Compliance with legal and other commitments is regularly reviewed and documented within the framework of the management reviews.

Information about changes of requirements is communicated through intensive contact with authorities and the Trade Association, through publications and through an external data bank (service provision) which is continuously updated, and internally, through various committees, such as ASA. Additionally, the Trade Association DVD (collection of regulations) is distributed annually to the executives.

Changes to the requirements are taken into account as fast as possible.

Meeting the requirements, legal and other, is of the highest priority while carrying out any activity.

The Environmental Protection/Technology Department (UST), in co-operation with the Central Legal Department (ZRA), compiles, processes and registers the legal requirements and other regulations concerning environmental protection. UST systematically compiles the environmental regulations relevant to the enterprise. Fundamental environment-relevant regulations are also available at ZRA. UST assesses the fulfilment of the obligations relating to the environment in regular intervals.

The departments of Occupational Safety (AS), Health Services (GD) and SHS-S-Energy and Media meet these tasks concerning occupational safety and health protection and, respectively, energy management.

Own norms offices in the areas of quality and new construction ensure that norms and specifications are always available in their latest valid form.

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Chapter 9 – Performance evaluation

9 Performance evaluation

9.1 Monitoring, measurement, analysis and evaluation

9.1.1 General

DILLINGER has an extended system of measurement, monitoring and analysis procedures with subsequent assessment and determination of actions. As an example, the following can be mentioned:

Implementation, testing and control of the relevant processes through

- clear instructions, approvals, requirements, etc.

- systematic collection of data and analysis of processes and products

- company internal and third-party control

product testing through company acceptance tests, as well as through external test and inspection bodies

risk analysis and risk assessment

feedback of customers and authorities


certifications, licenses, supplier assessments

committees and work groups concerned with the analysis and improvement of processes

qualification/validation of processes, products, machines/facilities, personnel

measurements and analyses in the areas of occupational safety, health and environmental protection as well as energy management

Measurement of occupational health and safety, environmental protection, plant safety and energy

Measurements and calibrations of equipment are carried out according to applicable rules and with regard to national and international standards. Responsibility for testing is taken up by external experts, as well as in-house special departments, or a combination of external and internal qualified personnel.

In order to provide protection for the employees, the compliance with legal and professional trade association regulations must be ensured by the area of occupational health and safety. The environmental protection area must comply with the restrictions in operations relevant to the environment. Therefore, systematic monitoring is utilized. Through this monitoring the fulfilment of internal guidelines is being assessed, such as the implementation of goals in occupational health and safety as well as environmental protection.

The following measurements are carried out:

quality of air (emissions, immissions, pollution)

noise (emissions, immissions, pollution)

energy consumption (e.g. electric power, throughput, temperatures, pressures ...)

waste water quality (pollution, chemical and biological parameters), ground water

investigation of specific accidents, illness, injuries, dangers, risks

control of hazardous materials and critical situations

organization of work areas/environment (e.g. noise, stress)

minimization of accidents (accident prevention)

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Components of the monitoring are:

testing of manufacturing equipment:

If necessary for facilities and equipment, all requirements of data acquisition and tracking of equipment test-periods, as well as documentation and identification, are met at company level by the responsible operations

Certain safety- and environment-related facilities are regularly reviewed by skilled employees or experts

Regular monitoring according to BlmSchG/inspection according to StörfallV

Regular visits by executives and special departments

Inspections serve the purpose of proactively recognizing and removing any existing dangers and/or deficiencies, with regard to occupational health and safety, environmental protection, fire prevention and hazardous materials, and, if necessary, to implement any relevant actions.

Data observation/key-figure monitoring

Occupational safety:

With regard to the "reporting, recording, examination and documentation of accidents", a procedure exists with which all accidents are collected on the basis of data banks.

The Safety and Health Department is responsible for the statistical recording of accidents. All operation managers are obliged to participate in this as a part of their responsibilities. The publication of these figures is carried out in the safety report.

All incidents (accidents, entries in the First Aid book) are registered and processed in SAP by GD/AS. AS will centrally initiate an accident investigation (accident-investigation procedure in acc. with the "Systematic Accident Investigation" standard: Ishikawa/"5 Whys" method), depending on the severity/potential of the incident.

Environmental protection:

The monitoring of consumption data serves as a control to determine whether the facilities are in operational compliance, and as a monitoring of the effectiveness of realized environmental actions.

Energy and water consumption data are collected on a monthly basis. Testing occurs quarterly. The implementation of raw, auxiliary and operation materials is compiled and reviewed once a year.

Energy management:

The energy consumptions are measured through continuous measurement systems directly at the relevant consumers, recorded in data banks, and systematically evaluated by the department SHS-S-Energy and Media, and will be balanced in the monthly and yearly reports. Key figures serve the tracing of the energy consumptions. 9.1.2 Customer satisfaction

The perception and satisfaction of the customers is subject to a continuous qualitative and quantitative observation.

In these activities the sales and section organization is of central importance: through collecting, analyzing and assessing the market, customer, process and manufacturing-specific information. These are, if applicable, transferred as a measure into the individually defined organization unit.

A significant part here is the customer satisfaction analysis generally carried out over 4 years with the help of external institutes.

In regular procedures (e.g. section meetings, working groups) the results of their effectiveness are tested and communicated.

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9.1.3 Analysis and evaluation

Inside the company, data is investigated, collected and analyzed in various ways.

The use of statistics serves the demand to be able to determine, analyze, ensure and further develop the quality of processes and products. Quality criteria for relevant processing and testing steps are continuously determined and statistically assessed.

The results of these evaluations are used for improvement as a part of research and development, quality planning and assurance, as well as process development.

A regularly meeting quality circle consisting of product, process and facilities responsibles from steel production and rolling mill facilities, final inspection, research and development, the quality office and process planning describes the current non-qualities. In particular, discontinuities, the reasons thereof, customer claims and objections as well as trends are presented in detail. The causes are discussed and documented for all parties involved.

So as to take away lessons, the Quality Steering Committee concerns itself with the deviations presented and decides on suitable actions for planning, design and process flow.

A variety of statistics and reports serve as information and assessment of the Integrated Management System by the Board of Directors.

9.2 Internal audit

For the determination of the application, efficiency and maintenance of the IM systems, internal audits are carried out in various areas according to the illustration below.

The internal audits are carried out periodically at all certified locations of the Dillinger Group. The IMS coordinator is responsible for the programme of internal audits at the Dillingen location and, carried out centrally, for the internal audits at the subsidiaries. Furthermore, the larger subsidiaries carry out additional internal audits at their own locations..

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The performing of internal audits and the necessary qualifications of the auditors are defined as "documented procedures”. The criteria of the performing of the audit and the auditors’ qualifications conform to the respective guideline of the standards. The auditors do not carry responsibilities in the audited department, and cannot audit their own work. It is intended that the audit team be made up of employees from different areas.

The auditors are regularly trained and further qualified. 9.3 Management review

9.3.1 General

The Board of Directors of DILLINGER carries out a regular (generally in the yearly cycle) review of the Integrated Management System (IMS).

The review serves to determine the continuous suitability, appropriateness and effectiveness of the IMS, to accomplish the set goals and guidelines of the policy, and to ensure compliance of the IMS with the basic standard regulations. The review shows the possibilities for improvement and any need for changes in the IM System.

Regular management review is carried out in all certified enterprises of the DILLINGER group. The review is made available to the IMS coordinator. 9.3.2 Management review input

Review input is the regular and necessary information concerning the IMS coordinator and other officers up to the executive management.

A summary report is created by the IMS coordinator concerning quality, environmental protection and occupational health and safety, safety and energy management in co-operation with the responsible departments.

The report incorporates all the input concerning the management review required by the norms. The review of the Integrated Management System is always carried out in written form and is archived by the IMS coordinator. 9.3.3 Management review output

All of the data for the review are analyzed and any possible conclusions, suggestions, measures and decisions from it are then deduced.

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Chapter 10 – Improvement

10 Improvement

10.1 General

At DILLINGER, there are various approaches to continuously improve the process of the enterprise and the efficiency of the IM System. For example:

definition of specific elements of the company policy and choice of appropriate goals

use of data analysis for the assessment and improvement of processes, products and production facilities

carrying out of comprehensive innovation projects with all areas participating

carrying out of internal and external audits and the resulting measures; with practically all "IMS-relevant" company areas

realization of specific, effective corrective measures through the removal of known or possible weak points

Inclusion of the employees in the framework of special programs for continuous improvement 10.2 Nonconformity and corrective action

Procedures are in place for the determination of non-conformities to ensure the continuing efficiency of the Management System. Non-conformities are for example realized through:

quality tests

analysis of quality key figuresdetermination of customer satisfaction

complaints of customers


operational disturbances, accidents or emergencies

deviations of analysis results in environmental protection

inspections in the operational areas

hints from employees about deficiencies or suggestions for improvement

assessment and evaluation of the energy balances

Non-conformities are analyzed, assessed and corrected as far as possible. In the course of this, the causes of these existing non-conformities are determined. From this, corrective actions are derived so as to prevent the recurrence of non-conformities. The potential opportunites arising from the results gained are analyzed, and enter into the future way of proceeding.

Corrective and preventive measures are listed in area-specific overviews, and then assigned to those responsible, and deadlines are set. The execution of measures is tracked by the responsible area, and the results are documented. A measure is seen as successfully completed only when the implementation is tested with regard to effectiveness.

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Complaints

Customers complaints are received by Sales and controlled and documented through the CRM system (module CCM; Customer Complaints Management).

Each customer complaint receives an unambiguous identity.

Commercial complaints are cleared up by Sales. If it is a technical complaint, Sales passes on the complaint to the Technical Service (TDI) for technical clarification of the matter.

If needed, Sales or TDI consult the respective responsible units (such as Transport Department, rolling mill, Inspection Department ...).

For each technical complaint a final statement is made which is passed on to the customer by Sales.

As a final step, an analysis and assessment is carried out for each technical complaint.

If necessary, corrective actions are developed, implemented and reviewed for their efficiency.

Periodically, an assessment of the technical complaints is presented in the Quality Circle (QZ) and the Quality Steering Committee (LAQ).

10.3 Continual improvement

DILLINGER must maintain its position in the strongly competitive world market in the future. Dis-advantages of location compared to competitors must be offset by continuous further development and improvement. In order to come closer to achieving this goal, the locations execute ongoing programs, as well as significant regular projects and initiatives, which altogether serve as continuous and sustainable improvement.

Committees and programs for continual improvement.

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Lean and Shop-floor Management

DILLINGER's Lean and Shop-floor Management System serves to assure holistic structural and process optimisation, and thus supports the continuous improvement process.

In this context, the Shop-floor Management System aims at the optimisation of management functions. "Lean" applies to the entire value chain.

The common aims of Lean and Shop-floor Management are: Reduction of waste

Quicker delivery via shortening of cycle times

Reduction of processing costs

Improvement of competitiveness via increased customer satisfaction

"Lean" is a cultural transformation which starts in the head and is guided by a clear and uniformly comprehended mission statement.

integrated management manual

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