Agenda Item 3: Approval of the actions of the Management Board for the 2025 financial year
The Association of Ethical Shareholders Germany requests that approval of the actions of the members of the Management Board be refused.
Rationale:
The Management Board continues to fall short of its human rights and environmental due diligence obligations. In particular, the continued marketing of the product Dormex, containing the active substance cyanamide—which is classified as probably carcinogenic and toxic to reproduction—poses significant and well-documented health risks, especially for agricultural workers.
Double standards without an exit strategy
Alzchem continues to pursue a business model based on the marketing of substances banned in the EU in other regions of the world, particularly in countries with insufficient regulatory frameworks and weak labour and environmental protection standards.
There is still no clear plan to phase out the export of highly hazardous pesticides, no transparent strategy for developing safer alternatives, and no adequate reporting on human rights risks or on the implementation of the company’s own human rights due diligence obligations.
Downplaying scientifically established health risks
Alzchem’s claim that Dormex can be used safely when applied “properly” contradicts the state of scientific knowledge. The active substance cyanamide lost its approval in the EU in 2008 following documented poisoning incidents. This decision was based on the clear conclusion by European authorities that the substance poses significant health risks to users.
Of particular concern is that even when personal protective equipment is used, the acceptable operator exposure level (AOEL) is exceeded by more than 60 times. Third parties are also affected: exposure limits are exceeded many times over for bystanders and residents—even inside their homes. Scientific literature documents severe acute poisoning cases, including extensive skin damage, sensitisation effects, and cases of multiple organ failure. There is also evidence of long-term health impacts, particularly on the thyroid, as well as reproductive toxicity. These findings clearly show that the risks cannot be controlled through “proper use.”
Systemic failure of occupational safety in practice
Alzchem argues that training and the provision of protective equipment ensure safe use. However, reports from application regions clearly contradict this claim.
Concrete cases—such as those reported from South Africa—demonstrate a lack or complete absence of adequate personal protective equipment, insufficient or non-existent training, and serious health damage among farm workers.
Even where protective equipment is theoretically provided, it remains entirely unclear whether it can be effective given the extremely high exposure levels. Available scientific evidence suggests that even optimal protective equipment does not provide sufficient protection. This fundamentally calls into question Alzchem’s entire safety concept.
Improper shifting of responsibility
Alzchem’s argument that local partners and employers are responsible for occupational safety does not absolve the company of its own responsibility. Under the UN Guiding Principles on Business and Human Rights—to which Alzchem explicitly commits—companies have an independent responsibility to identify, prevent, and mitigate human rights risks throughout their entire value chain.
This responsibility cannot be delegated, particularly in the case of a product whose risks are demonstrably not adequately controllable.
Insufficient transparency and lack of evidence
Alzchem fails to provide key evidence of how it fulfills its human rights due diligence obligations. In particular, the following are missing: detailed information on export volumes of cyanamide and Dormex in recent years, concrete and verifiable information on the type and effectiveness of the protective equipment used, independent studies or tests demonstrating actual protective performance, reliable data on the distribution and use of protective equipment on the ground.
Misleading justification based on alleged lack of alternatives
The claim that Dormex is “indispensable” for agricultural production is not convincing. Practical examples demonstrate that cultivation is possible without Dormex, for instance through adapted crop varieties or alternative methods.
Its use primarily serves economic interests such as yield maximisation and production stability in industrial agriculture—not a genuine necessity for ensuring global food security.
