Bluebell Capital Partners - Response to Solvay Board Open Letter Regarding Soda Ash Operations in Rosignano

LONDON, Feb. 17, 2022 (GLOBE NEWSWIRE) -- With reference to the open letter issued by the Board of Directors of Solvay S.A. (“Solvay”) (Euronext Brussels: SOLB.BR), regarding its soda ash operations in Rosignano (the “Solvay Open Letter”), dated 10^th February, 2022, we would like to clarify the following:

We confirm that Bluebell Capital Partners owns 1 (one) share of Solvay, to qualify itself as a shareholder. This qualifying holding is part of a not-for-profit initiative (“One Share ESG Campaign”), where, without any material economic interest, we deploy our expertise as a financial activist investor, to support environmental organizations, local communities, and policy makers. The sole objective is to address on a pro bono basis, significant environmental or social issues, as part of our broader ESG commitment.

In the 21^st century, conservation, and the use of sustainable practices, to limit organisations’ negative impact on both freshwater and marine resources, is universally considered to be one of the key pillars of the climate agenda. This is underlined by the adoption of the 2030 Agenda for Sustainable Development Goals, by the Member States of the United Nations. The 2025 target to “prevent and significantly reduce marine pollution of all kinds, in particular from land-based activities, including marine debris” (SDG 14.1) is particularly prominent.

It is unfortunate that Solvay - which defines itself as “a science company with ESG at its core”¹ - does not seem ready to support this principle (SDG 14.1) at its soda-ash factory in Rosignano (Italy), where every year, the company discharges on to the coast, and subsequently into the Mediterranean Sea, hundreds of thousands of tons of suspended solids, containing nickel, cadmium, chrome, arsenic, and mercury. This data point is entirely, as per the company’s own declaration, where it stated that in the three-year period from 2018 to 2020, Solvay dumped 688,000 tons of suspended solids, containing 88,7 tons of heavy metals².

The disposal of Solvay’s by-products from its soda manufacturing process in Rosignano, has created an open landfill, with the captivating (and misleading) appearance of an idyllic Caribbean beach (the so called ‘White Beaches’ of Rosignano).

Contrary to what Solvay stated in its Solvay Open Letter, Bluebell Capital Partners are only interested in a science and fact-based discussion, and we have made available to Solvay all the supporting documentation³ that we have reviewed and complied. We have also considered, in great detail, the answers provided by Solvay to the questions raised by Bluebell Capital Partners, at its May 2021 AGM. We find it deeply disappointing that Solvay has subsequently refused (on the 11^th June, 2021)⁴ to provide clarification to the inconsistencies and omissions which we highlighted to the company, following our due diligence on the information provided to us shareholders, at the AGM⁵.

We have also reviewed the presentation “Solvay’s Soda Ash Production in Rosignano (January 2022)”⁶ (the “Solvay Presentation”), referenced in the Solvay Open Letter. We found it to be inconclusive, entirely irrelevant, and hence utterly misleading.

Solvay Presentation states that, according to Italian monitoring agency ARPAT⁷ in Rosignano, the “quality of bathing is Excellent”. We consider this statement to be misleading, as it fails to specify that ARPAT’s assessment is based “only [on] 2 microbiological parameters (Escherichia coli and Intestinal Enterococci” (ARPAT) “without taking into account any ecological aspect, neither chemical, nor organoleptic (i.e. perceptible through the senses, such as smell, color, etc.), nor aesthetic or landscape, referring to the water, beaches or seabed” (ARPAT). This statement alone confirms that ARPAT’s assessment does not support any tangible conclusion that the substances discharged by Solvay into the sea, do not negatively affect the quality of bathing, as had been clearly implied, by the statement included in the Solvay Presentation. Indeed, we can only conclude that it is entirely misleading, at best, but ultimately could be considered to be deceptive.

Solvay Presentation states that the “ecological and chemical status at Rosignano [is] in line with the Tuscan Coast”, referring to a second report issued by Italian monitoring agency ARPAT⁸. On the premise that Solvay’s environmental impact in Rosignano would not be diminished by the existence of similar environmental issues in other areas, Solvay failed to specify that ARPAT classified the chemical status of the water body in Rosignano as ‘NO GOOD’⁹. ARPAT report went further to make extensive reference to the excessive presence of mercury, arsenic and hexachlorobenzene (HCB) in the water body at Rosignano.

Furthermore, Solvay has publicly repeated that heavy metals (including mercury¹⁰), contained in the suspended solids discharged into the sea in Rosignano, “remain imprisoned in the solid state of the limestone and cannot be absorbed by living organisms, including people and fish” and “cannot be absorbed by living organisms, including people and fish”¹¹. Solvay’s Presentation failed to state that the above mentioned ARPAT report, explicitly named in the presentation, concluded that “analyses to determine the presence of mercury in fish indicated bioaccumulation of this metal along the entire coast, with exceedances of the environmental standard in all water bodies except the Serchio Coast" (ARPAT), i.e. one can safely assume that Rosignano is within that area of study.

Since our initial involvement in September 2020, Bluebell Capital Partners’ concerns regarding Solvay’s activity in Rosignano have attracted the attention of policymakers in the European¹², Italian Regional^13,14 and national^15,16,17 Parliaments, investors and non-profit environmental organizations¹⁸, the Representative of the United Nations Special Rapporteur on the Implications for Human Rights of the Environmentally Sound Management and Disposal of Hazardous Substances and Wastes¹⁹, the Chair of the Italian Parliamentary Commission for Investigation on Illegal Activities Connected with the Waste Cycle and on Environmental Offenses²⁰, the rating agency MSCI (which downgraded Solvay’s ESG rating in March 2021, referring to the “backlash against waste discharge from its soda ash plant in Rosignano”), members of the local community, leading domestic and international media organisations and millions of active members of social media platforms expressing their anathema at this utterly irresponsible environmental activity²¹.

In the best interest of genuine progress on this urgent issue, we seek a constructive interaction, to find the best solution for all stakeholders involved. Once again, we urge Solvay to make available, in addition to the documents referenced in the addendum to the Solvay Open Letter, a list we deemed to be highly incomplete and insufficient to reach a fully informed conclusion, the independent scientific research data to disprove that: (i) suspended solids discharged by Solvay into the sea accumulate to create a localised build up (the ‘White Beaches’); (ii) heavy metals contained in grains, with a size of few microns, are absorbed by a living organism; (iii) coastal erosion is caused, or influenced, by Solvay’s drainage of water from the Cecina and Five Rivers and by the construction of the San Luce dam; (iv) Solvay’s intake of seawater is used predominantly for cooling water; and (v) elevated mortality levels are observed in chronicle-degenerative disease (or in other diseases) in the municipality of Rosigano, on a relative basis to the nearby less industrialised municipality of Cecina, and there is a cause-effect relationship between excess mortality and local environmental releases.

With reference to the 20^th January, 2022 renewal of the environmental authorization (IPPC) granted to Solvay’s operations in Rosignano, by the Italian current Minister for the Ecological Transition, this does not validate Solvay’s environmental practices. These questions which Bluebell Capital Partners raised in 2020-2021, were directly acknowledged in the press release issued by the Ministry for the Ecological Transition on the 1^st February, 2022: “the issues touched upon by the new environmental authorization (IPPC) granted in 2022 are unrelated to the broader and more complex issue of environmental damage and reclamation at Rosignano. On these, however, the Ministry is continuing to work. For example, all reports received between 2020²² and 2021²³ have been forwarded to the ministerial structures in charge, which immediately requested the Italian Institute for Environmental Protection and Research (ISPRA) for further verifications and proposals for intervention. These were received in December 2021 and are the subject of a discussion between the Ministry and Solvay” (Ministry of Ecological Transition, 1^st February 2022, translation)²⁴.

Anecdotally, the current Italian Minister for the Ecological Transition, who renewed the twelve year authorization five years in advance of its natural expiration date, thereby extending Solvay’s environmental authorization by an additional seven years, despite (by its own admission) outstanding “further verifications” on the “wider and more complex” environmental issues at Rosignano. We are curious about the accelerated environmental approval extension.

The Italian Minister in his former role as a senior manager of the defence company Leonardo Spa, on the 2^nd February, 2021 (i.e. eleven days prior to his appointment as Minister) announced a joint-venture between Leonardo Spa and Solvay^25,26. To our knowledge, the current Minister of Ecological Transition, appointed in February 2021, did not resign from Leonardo Spa, but instead took a leave of absence. Because of the potential conflict of interest, and in light of the well-known unresolved environmental issues of Solvay’s operations in Rosignano, the new authorization granted by the Minister in January 2022, has attracted extensive media coverage and additional scrutiny by several members of the Italian Regional²⁷ and National ^28,29,30 Parliaments.

As influential fashion-magazine Vogue wrote, in its iconic September 2021 issue: “the beach of Rosignano-Solvay becomes the symbol for an urgent conversation on the ever so relevant relationship between people and the environment”³¹.

Solvay cannot escape from having this “urgent conversation” with its stakeholder by simply uploading an ‘Open Letter’. Rather, we would prefer to see finally it promote an open and constructive conversation to address this environmental controversy.

¹https://www.solvay.com/sites/g/files/srpend221/files/2020-10/ESG%20webinar%20Slides.pdf
² Solvay, Q&A AGM 2021 https://www.solvay.com/sites/g/files/srpend221/files/2021-05/2021.05.11%20-%20AGM%20-%20Q%26A%20%28May%2025%2C%202021%29.pdf
³https://www.dropbox.com/sh/9v78t7qaim50i2s/AAADQ-CZApx-C9EpGXhoAlQwa?dl=0
⁴ https://www.dropbox.com/s/lbztzui0a1xcelj/%20Solvay%27s%20Letter%20to%20Bluebell%20Capital%20Partners%20%2811%20June%202021%29%20.pdf?dl=0
⁵https://www.dropbox.com/s/r951l2q2i118i9q/%20Bluebell%20Capital%20Partners%20Letter%20to%20Solvay%20%20%284%20June%202021%29.pdf?dl=0
⁶https://www.solvay.com/sites/g/files/srpend221/files/2022-01/Solvay%20Rosignano%20presentation.pdf
⁷ http://www.arpat.toscana.it/documentazione/catalogo-pubblicazioni-arpat/rapporti-balneazione/il-controllo-delle-acque-di-balneazione-stagione-2020
⁸ http://www.arpat.toscana.it/datiemappe/dati/stato-chimico-ed-ecologico-delle-acque-marino-costiere-della-toscana and then: http://www.arpat.toscana.it/documentazione/catalogo-pubblicazioni-arpat/monitoraggio-delle-acque-marino-costiere-in-toscana-anno-2020
⁹ based on a dual system classification: GOOD or NO GOOD
¹⁰ Source: Solvay, Q&A AGM 2021 https://www.solvay.com/sites/g/files/srpend221/files/2021-05/2021.05.11%20-%20AGM%20-%20Q%26A%20%28May%2025%2C%202021%29.pdf
¹¹ Source: Solvay, Q&A AGM 2021 https://www.solvay.com/sites/g/files/srpend221/files/2021-05/2021.05.11%20-%20AGM%20-%20Q%26A%20%28May%2025%2C%202021%29.pdf
¹²https://www.europarl.europa.eu/doceo/document/E-9-2021-000611_IT.pdf
¹³http://www.consiglio.regione.toscana.it/upload/crt/interrogazioni/11/MOZ0221.pdf
¹⁴http://www.consiglio.regione.toscana.it/upload/crt/interrogazioni/11/IS0439.pdf
¹⁵https://www.senato.it/japp/bgt/showdoc/showText?tipodoc=Sindisp&leg=18&id=1188847
¹⁶https://aic.camera.it/aic/scheda.html?numero=4/08095&ramo=CAMERA&leg=18
¹⁷https://aic.camera.it/aic/scheda.html?numero=4/09957&ramo=CAMERA&leg=18
¹⁸https://collaborate.unpri.org/group/8626/stream or https://docs.google.com/forms/d/e/1FAIpQLScUy2NoUF-ofL0Yvv21S4wBnmtyTtogk4nMXxzKG94tadqV1w/viewform
¹⁹https://www.ohchr.org/EN/NewsEvents/Pages/DisplayNews.aspx?NewsID=27957&LangID=E
²⁰ Solvay, Q&A AGM 2021 https://www.solvay.com/sites/g/files/srpend221/files/2021-05/2021.05.11%20-%20AGM%20-%20Q%26A%20%28May%2025%2C%202021%29.pdf
²¹ https://www.tiktok.com/@ciaosasha/video/6985158797295701254?is_copy_url=0&is_from_webapp=v1&sender_device=pc&sender_web_id=6981796188971894277
²² https://www.dropbox.com/s/sicdbcn0sli0lfi/Letter%20from%20the%20Italian%20Ministrry%20of%20Environment%20%2813%20October%202020%29%20.pdf?dl=0
²³ https://www.dropbox.com/s/zir5jnzdcrnfdj1/Letter%20from%20the%20Italian%20Ministtry%20of%20Environment%20%20%2815%20July%202021%29.pdf?dl=0
²⁴https://www.mite.gov.it/comunicati/comunicato-aia-2022-solvay
²⁵https://www.leonardo.com/en/press-release-detail/-/detail//02-02-2021-leonardo-e-solvay-nasce-il-laboratorio-di-ricerca-congiunto-sui-materiali-compositi-termoplastici
²⁶https://www.solvay.com/en/press-release/solvay-and-leonardo-launch-joint-research-lab-for-thermoplastic-composites
²⁷https://www.consiglio.regione.toscana.it/upload/crt/interrogazioni/11/IS0680.pdf
²⁸https://www.senato.it/japp/bgt/showdoc/showText?tipodoc=Sindisp&leg=18&id=1331619
²⁹https://www.senato.it/japp/bgt/showdoc/showText?tipodoc=Sindisp&leg=18&id=1332043
³⁰https://aic.camera.it/aic/scheda.html?numero=4/11348&ramo=CAMERA&leg=18
³¹https://www.vogue.it/news/article/update-from-vogue-italia-september-cover

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