Guidance needed for classifying metrics from Cleveland Cliffs

[MichaelTiemannOSC]

Cleveland Cliffs has become a vertically integrated steelmaker. If you read their SEC disclosure (https://www.sec.gov/ix?doc=/Archives/edgar/data/0000764065/000076406522000037/clf-20211231.htm#) and look at the tag us-gaap:ScheduleOfSegmentReportingInformationBySegmentTextBlock you will see that they consider their one reportable segment to be "Steelmaking", which covers everything from mining to refining to fabrication to finished goods.

How should revenues, emissions, and intensities be collected and reported to make data comparable with steel companies that don't do their own mining? Or which refine but do not fabricate?

On page 58 of their report they say "Intensity value is inclusive of emissions across Cleveland-Cliffs vertically integrated footprint including mining, pelletizing, cokemaking, steel production, and downstream steel and specialty products facilities". The report: https://d1io3yog0oux5.cloudfront.net/clevelandcliffs/files/docs/20210716/ClevelandCliffs_Sustainability+Report+2020+FINAL.pdf

[ttschmucker]

Hi @MichaelTiemannOSC ,

I´m now back from vacation. @LeylaJavadova and me, we will have a look at this topic and give feedback.

Best
Tu

[DavWinkel]

The SEC data is very interesting. After discussing this topic with some experts we believe that it is - at least in the current stage - too much work to integrate another methodology (segment-based) on how to subdivide companies. So far everything is based on corporate entities (identified by LEIs), which carries the assumption that every corporate (sub-)entity only is active in a single segment of business.
In the case that we encounter a conglomerate which is a single corporate entity, without any subsidiary structure, we propose a fallback solution by mapping the entire company to the most conservative business segment, i.e., to that segment of the company which has the highest level of emissions.
We acknowledge that this is not an optimal solution and in the future, we should work on also incorporating segment data, such as provided by the SEC disclosure.