Item 3 on the agenda: Approval of the actions of the Executive Board for the 2024 financial year
The Association of Ethical Shareholders Germany proposes that formal approval of the actions of the members of the Executive Board be denied.
Reason:
The Executive Board continues to fail to adequately fulfil its human rights and environmental due diligence obligations.
Export and commercialisation of pesticides that are harmful to health and banned in the EU
Alzchem is one of the companies that continues to export pesticides that are classified as carcinogenic, mutagenic or toxic to reproduction and have therefore not been authorised in the EU for a long time. According to Public Eye, large quantities of these hazardous substances are sold annually to countries in the Global South – regions where health and environmental protection standards are often lower and the workers concerned often have little or no access to protective equipment or healthcare.
This practice not only contradicts ethical principles, but also international guidelines such as the UN Guiding Principles on Business and Human Rights (UNGPs), which attribute a responsibility to companies to respect human rights in their supply chain. Alzchem is explicitly committed to the UNGPs. According to Article 13b of the UNGPs, human rights due diligence requires companies to endeavour to prevent or mitigate adverse human rights impacts that are directly linked to their products or services through their business relationships, even if they have not directly contributed to these impacts.
The EU itself is currently working on a ban on the export of pesticides that are banned within its borders. Irrespective of ethical considerations, Alzchem should change its risky business model in this respect, also in its own economic interest.
Health-threatening and irresponsible use of Dormex
A particularly worrying example is the export of the Alzchem product Dormex. The active ingredient is cyanamide, the use of which was banned in the EU in 2008 due to extremely high health risks (carcinogenic, toxic to reproduction). Dormex appears to be used on a large scale in South Africa, among other countries. Farmers and civil society organisations from South Africa report on applications without sufficient training, a lack of protective equipment and, as a consequence, health damage, which are clear violations of health and safety regulations to prevent health hazards and occupational accidents. This has recently become clear in the South African People’s Tribunal on AgroToxins (SAPToA) at the end of March 2025: https://agrotoxinstribunalsa.co.za/
Not enough information is provided in the annual report about these risks and consequences of using the products manufactured by Alchem. Full transparency towards shareholders and the public about regulatory, human rights and environmental risks in the product portfolio is needed, especially in the business with high-risk active ingredients.
Violation of human rights and environmental due diligence obligations
It is completely unclear whether and how Alzchem fulfils its own promises with regard to human rights, as formulated in the Alzchem Group AG Declaration of Principles on Respect for Human Rights, in reality. For example, Alzchem states that it organises training courses. However, according to our information, there is insufficient evidence that these training programmes are comprehensive, regular and effective.
The continued export of Dormex to countries with weak protection structures fundamentally contradicts this responsibility. It is correct to point out that local employers such as large farms are responsible for occupational health and safety – but this does not release Alzchem from its own human rights duty of care to ensure the safe use of its own products, particularly in a preventative manner. With products as harmful as Dormex, it is not possible to rule out health and environmental hazards even if the highest safety measures are observed. This is why its use is banned in the EU.
We are therefore unable to exonerate the Management Board. It is not comprehensible whether and how Alzchem checks and discloses how, when and with whom training courses on the safe use of Dormex are conducted in export countries. There is no binding action plan, not even a non-binding phase-out plan, on how Alzchem will ensure that no more products are exported that are banned in the EU due to health or environmental risks. A gradual switch to less hazardous alternatives, especially for export markets, does not seem to be the intention at all.
