Report in Accordance with GRI Standards

Report in Accordance with GRI Standards


In this Report in Accordance with GRI Standards, the management approaches and selected GRI disclosures relating to the material topics as presented in the Sustainability Report are explained in more detail.




Materials Compliance

Materials compliance is compliance with any laws, regulations and specifications that restrict or even prohibit the use of various substances and/or materials in products, including, for instance, environment-related legislation, international law, religiously motivated specifications, and specifications by companies. For Comet as a manufacturer of industrial products, an indispensable requirement for doing business worldwide is compliance with regulations relevant to the environment and to market access – such as Registration, Evaluation, Authorization and Restriction of Chemicals (REACH), Restriction of Hazardous Substances (RoHS), and the Toxic Substances Control Act (TSCA) – as well as with legislation driven by international law and ethics, including conflict minerals legislation, the Dodd-Frank Act and Regulation (EU) 2017/821. In 2022, for example, in connection with REACH and its Substances of Very High Concern (SVHC), we classified all our safety data sheets in SAP. This resulted in the elimination or replacement of ten of the identified 13 substances on the SVHC list from our products.

We are committed to providing our customers with the highest-quality supply chain that meets all established product performance standards and expectations. Our purchasing department maintains these high standards by continuously evaluating the performance of our established suppliers.

Comet’s Supplier Code of Conduct (Supplier CoC) is based on the Code of Conduct of the Responsible Business Alliance (RBA) and sets out the basic requirements for our suppliers and external service providers regarding their responsibility toward their stakeholders and the environment. We reserve the right to amend the requirements of our Supplier CoC to reflect changes in our compliance policies.

In addition to supplier self-declaration in the form of the signed Supplier CoC, we work with third-party supply chain specialist Assent Compliance Inc. The Assent platform collects the data required to comply with REACH, RoHS, conflict minerals rules and the TSCA. This solution provides assurance that our suppliers are compliant with all relevant laws and regulations. Suppliers who do not submit data to Assent are contacted directly by us and requested to provide the necessary documentation. When appropriate, we work together with our suppliers to identify actions to achieve improvement. However, we reserve the right to terminate the business relationship with the supplier (subject to applicable laws) if the supplier fails to comply with the code, and we reserve the right to take legal action against the supplier.

As part of its due diligence measures in the reporting year, Comet identified minor deviations from best practices with regard to conflict minerals regulations at a small number of suppliers. This was brought to the attention of the suppliers and the situation continues to be closely monitored.

The responsibilities for the processes are mapped in the Comet Group management system. Essentially, the specifications for materials compliance are made at the Group level by the Vice President of Global Operational Excellence (VP GOE), who reports directly to the CEO. The VP GOE defines the compliance regulations together with the Group legal experts. The responsibility for implementation in the regions rests with the divisions, and accountability for it lies with the respective country general managers. Materials compliance activities are coordinated worldwide within the Quality & Excellence Board.

Environmental Management System and Compliance

The principle of sustainability is an integral part of Comet’s corporate culture. We strive to offer our customers high-quality products and services while avoiding environmental risks and producing in ways that conserve resources. The principles of this approach are set out in the Comet Group’s Quality, Environmental and Safety Policy, with supplementary information in the Code of Conduct.

While all our production and research and development sites are certified to ISO 9001:2015, only Comet Yxlon (the IXS division) in Hamburg has designed and implemented an environmental management system in accordance with ISO 14001:2015. Smaller entities that perform only sales and marketing activities are not certified. To ensure compliance with environmental regulations, however, internal audits, customer and certification audits, benchmarking and best-practice applications are conducted at regular intervals at all production sites.

Comet plans to achieve one single Group-wide ISO 9001 certification by the end of 2023. The Group-wide certification of ISO 14001 will then be added during 2024. As most of Comet’s major sites will be due for recertification in 2023, that year will represent a natural opportunity to unify the quality management systems and achieve single certification.

The Vice President of Global Operational Excellence (VP GOE) is responsible for the performance of the Comet quality management system, including the process framework and architecture. The VP GOE drives the definition, implementation, and improvement of Group-wide processes in close cooperation with the divisions. Among other responsibilities, the VP GOE sets minimum standards for non-financial KPIs and ensures certification and compliance with ISO standards. In this function, support comes from various boards and councils, such as the Operations Council and the Quality & Excellence Board, which includes the Q&E heads of the divisions. Accountability for environmental compliance rests with the respective country general manager, while responsibility for it lies with the division country manager. In the year under review, the Comet Group did not face any ongoing or completed legal proceedings for non-compliance with environmental laws or regulations. Likewise, no fines for environmental infractions were imposed on the company.

Energy Management and Carbon Emissions

All steps of the Comet value chain involve energy consumption and associated greenhouse gas emissions. Electricity consumption dominates in the production and use phases of the products. Energy consumption and emissions in the upstream chain are also significant, especially in the production and transport of raw materials and semi-finished products.

In the reporting year 2022, Comet refined its environmental data collection process. This allows us to report consolidated Group-wide environmental KPIs for our production (Scope 1 and 2) for the year under review.

Comet has developed a climate roadmap to meet short-, medium- and long-term CO2 emission reduction targets and to progress toward the net-zero emission ambition by 2050. Measures to reduce emissions in line with these targets were implemented. Further steps were taken to increase the energy efficiency of our Group-wide production and to enhance the share of green electricity in our energy mix. In a dedicated working group, we will start in 2023 to identify a set of measures to further refine the Group’s approach to energy management and emission reduction.

In 2022, Comet’s Board of Directors approved the formation of a sustainability organization. This is set out in the Sustainability Policy approved at the end of December and is described in detail in the Sustainability Report in the section “Governance and organization”.




Environmental metrics 1


Energy consumption total






Electricity total



Of which renewable



Heating total



Heating oil



Natural gas



District heating



Fuels total















Greenhouse gas emissions total 2

tCO 2 e





Greenhouse gas emissions total



Scope 1 total

tCO 2 e



tCO 2 e



tCO 2 e


Scope 2 total

tCO 2 e


Electricity 3

tCO 2 e


District heating

tCO 2 e





Resource efficiency metrics


Waste total 4






Water consumption 5

m 3


1 Scope covers all of Comet’s companies and locations.

2 Calculations in accordance with the WRI/WBCSD Greenhouse Gas Protocol guidelines. Scope 1: GHG emissions from own sources, e.g., fuels. Scope 2: GHG emissions stemming from the production of electricity and district heating. Sources for emission factors: Defra & IEA.

3 With the exception of Flamatt and Hamburg, greenhouse gas emissions associated with the production of electricity were accounted for in accordance with the "location-based approach" under the Greenhouse Gas Protocol Scope 2 standard. No emissions stem from electricity consumption in Flamatt and Hamburg, as the sites run entirely on renewable electricity. Considering only the location-based approach, electricity consumption across all sites would be responsible for 4,354 tCO2e emissions in 2022.

4 Does not include Comet Electronics Co. Ltd., Comet Solutions Taiwan Ltd., Object Research Systems (ORS) Inc., and Yxlon X-Ray Equipment Trading Co. Ltd.

5 Does not include Object Research Systems (ORS) Inc.