Alpha Metallurgical Resources, Inc. (AMR) — ESG & Values Scores

Environment story

Alpha Metallurgical operates a pure metallurgical coal extraction business with significant scope 3 emissions from end-use combustion of coal by customers. The company has disclosed no net-zero target year, no scope 1/2/3 quantified emissions data, and no physical decarbonization infrastructure investments. The 10-K explicitly acknowledges that coal is subject to increasing climate regulation and demand reduction. No renewable energy percentage disclosed. Major environmental liabilities of $227.4M accrued for reclamation. Substantial regulatory and litigation risk from clean air, clean water, and endangered species act compliance. The business model is fundamentally dependent on continued coal demand, which regulatory disclosure indicates is expected to decline due to climate policy and power plant retirements.

Criticisms on file

Fundamental business model exposure: Company produces metallurgical and thermal coal for combustion by customers (steel, coke, utilities). 10-K risk disclosure states coal demand is expected to decline due to climate regulation, renewable energy adoption, coal plant retirements, and global climate initiatives (Paris Agreement, Glasgow Climate Pact, COP28 fossil fuel transition language). No mitigation strategy disclosed.
Source: AMR 10-K Item 1A Risk Factors - Global Climate Change section and throughout Environmental and Regulatory Matters discussion.
Regulatory & litigation risk from Clean Air Act (MATS, CSAPR, Good Neighbor Plan, ozone NAAQS, PM2.5 standards, regional haze) and potential EPA GHG regulations. 10-K acknowledges these rules reduce coal demand and power plant utilization, and litigation over EPA rules remains active.
Source: AMR 10-K Environmental and Regulatory Matters - Clean Air Act subsection.
Clean Water Act compliance risk: Company must obtain NPDES permits, Section 404 dredge/fill permits, and comply with effluent guidelines. 10-K notes COE nationwide permits expire March 15, 2026 and new permitting may be required. Sackett v. EPA (May 2023) narrowed CWA jurisdiction; ongoing rulemaking by EPA/COE on waters definition (proposed Nov 2025).
Source: AMR 10-K Environmental and Regulatory Matters - Clean Water Act and Dredge and Fill Permits subsections.
Endangered Species Act: Guyandotte River Crayfish and Big Sandy River Crayfish critical habitat designated by FWS on March 15, 2022, covering ~717 stream kilometers in KY, VA, WV. FWS issued guidance in July 2020 requiring protection measures (100-foot vegetative buffers, stream-crossing restrictions) for coal mines in designated habitat. Potential for permitting delays and operational constraints.
Source: AMR 10-K Environmental and Regulatory Matters - Endangered Species Act subsection.
Surface Mining Control and Reclamation Act (SMCRA) compliance and permit-blocking risk: 10-K notes unabated violations can delay, refuse, or revoke mining permits. Company states no material violations to date, but notes complexity and litigation by environmental groups over permitting.
Source: AMR 10-K Environmental and Regulatory Matters - Mining Permits and SMCRA subsections.
No carbon offset or net-zero disclosure: Company makes no public statements on carbon offsets, carbon capture, or net-zero commitments. 10-K contains no discussion of climate transition strategy.
Source: AMR 10-K—absence of disclosure in Item 8 (Financial Statements & Notes) and entire 10-K document.

Disclosed initiatives

Mine Safety & Environmental Compliance Procedures

Company states it has procedures to enable compliance with federal, state, and local environmental and safety laws. Behavior-based safety process and Safe Production process implemented.

Operational risk mitigation only; does not reduce scope 1, 2, or 3 emissions.
No Mountaintop Removal

Company discloses it does not use mountaintop removal mining and has no plans to do so.

Limits local habitat disruption compared to some peers; does not reduce carbon footprint.
Reclamation & Bonding

$227.4M accrued for reclamation liabilities; $170M in surety bonds posted as of Dec 31, 2025.

Environmental remediation obligation; does not offset scope 3 combustion emissions.

Social story

Alpha Metallurgical maintains approximately 3,960 full-time employees (74% hourly), with 97% non-union workforce. Approximately 3% represented by UMWA under wage agreements expiring July 31, 2028 and February 28, 2026. Company reports good labor relations and no recent strikes or NLRB actions disclosed. Safety performance (NFDL rate) reported as 38% better than U.S. industry average in 2025. Long tenure workforce (36% with ≥10 years service, 27% with ≥15 years) indicates low turnover in operations. Employee compensation includes competitive base pay, safety/environmental performance bonuses, comprehensive benefits, EAP, and apprentice miner training. No diversity metrics (gender, race/ethnicity) disclosed in 10-K. CEO-to-median-worker pay ratio not disclosed. Supply chain ethics (e.g., equipment suppliers, coal third-party purchases) not audited in filing.

Criticisms on file

No diversity metrics disclosed: 10-K contains no breakdown of workforce gender, race/ethnicity, or leadership diversity percentages. No DEI program or supplier diversity initiatives mentioned.
Source: AMR 10-K Human Capital Resources section—absence of diversity data.
CEO-to-median-worker pay ratio not disclosed: 10-K does not provide executive compensation details or pay equity metrics required to assess pay ratio.
Source: AMR 10-K—absence of executive compensation disclosure in Item 7-10 sections.
Supply chain labor & ethics not audited: 10-K acknowledges reliance on third-party suppliers (equipment, parts, explosives, fuel) and third-party coal purchases for resale, but provides no supply chain audits, human rights due diligence, or conflict minerals policies.
Source: AMR 10-K Item 7 MD&A - Procurement section and Marketing/Sales section.

Disclosed initiatives

Apprentice Miner Training Program

In-house six-month program providing robust safety and mining training; participants obtain required miner's certification. Addresses industry-wide shortage of skilled miners.

Workforce development and safety capacity building.
Employee Safety Leadership & Training

Behavior-based safety process, situational awareness training, incident response plans, mine rescue teams. Awards for safety and mine rescue performance.

Safety rate reported 38-45% better than U.S. industry average in 2025-2024.
Comprehensive Benefits & Compensation

Competitive fixed base pay, safety/environmental/production bonus programs, paid time-off, medical/dental/vision, disability/life insurance, 401(k) with employer match, EAP (mental health, addiction, legal, childcare, eldercare services), long-term incentive programs with equity/cash grants.

Talent retention and employee welfare.
Supervisory & Certification Training

Opportunities for EMT, mechanical engineering technology, foreman, supervisory, and electrical certifications.

Career advancement and skills development.

Governance story

Board independence percentage, share structure (single vs. dual-class), and detailed lobbying expenditures not disclosed in 10-K filing. Company does not mention supermajority founder voting or takeover defenses. No antitrust, consumer-safety, or financial-fraud proceedings disclosed; no SEC consent decrees mentioned. However, extensive regulatory litigation risk disclosed (EPA, COE, FWS, state regulators) over environmental/climate rules and permit validity, which is material governance exposure. No shareholder proposals or proxy contests disclosed in provided documents. Governance audit limited by absence of board composition, executive compensation, and lobbying detail in 10-K; proxy statement (Def 14A) would be required for complete assessment.

Criticisms on file

Substantial regulatory and litigation exposure: 10-K describes active and proposed litigation/rulemaking by EPA (MATS, CSAPR, Good Neighbor Plan, GHG Power Plant Rule, Supplemental ELG Rule), COE (CWA jurisdiction, nationwide permits), FWS (Endangered Species Act), and state regulators. Multiple rules have been stayed, challenged, or are under reconsideration. Company's coal business is directly exposed to outcome of this litigation and rulemaking.
Source: AMR 10-K Environmental and Regulatory Matters—comprehensive regulatory risk disclosure throughout.
Permit-blocking risk under SMCRA: 10-K notes that unabated permit violations or violations by related entities (officers, directors, significant stockholders, 10-50% owners) can result in permit revocation and denial of new permits/modifications. No disclosure of whether company or related parties have unabated violations.
Source: AMR 10-K Environmental and Regulatory Matters - SMCRA subsection.
CWA permitting uncertainty: Nationwide permits (NWPs 5, 21, 49, 50) expired March 14, 2026; new NWPs reissued January 8, 2026 and effective March 15, 2026 (expiring March 15, 2031). Sackett v. EPA (May 2023) and subsequent EPA/COE rulemaking (August 2023 conforming rule, November 2025 proposed rule) create ongoing jurisdictional and permitting uncertainty.
Source: AMR 10-K Environmental and Regulatory Matters - Clean Water Act - Dredge and Fill Permits subsection.
Board composition and voting structure not disclosed: 10-K does not provide board size, independence metrics, committee composition, executive compensation, or voting structure (single vs. dual-class shares). Proxy statement required for governance assessment.
Source: AMR 10-K—absence of Governance section detail; Item 10 (Directors, Executive Officers) not provided in source documents.
Lobbying expenditures not disclosed: 10-K does not report annual lobbying spend or specify policy positions on climate, environmental deregulation, or consumer protection. 10-K does acknowledge that climate regulation is expected to reduce coal demand, but does not disclose company's advocacy on this issue.
Source: AMR 10-K—absence of lobbying disclosure.
No antitrust or SEC enforcement proceedings disclosed: 10-K states company is 'party to legal proceedings from time to time...in the ordinary course of business' involving 'contract disputes, personal injury claims, property damage claims, environmental and safety issues, securities-related matters and employment matters' but does not itemize any major proceedings or settlements.
Source: AMR 10-K Legal Proceedings section and Note 20 (not provided in full).

Disclosed initiatives

Compliance Procedures & Monitoring

Company states it has procedures in place designed to enable compliance with federal, state, and local environmental and safety laws. However, acknowledges that due to complexity and interpretation, complete compliance cannot be guaranteed and violations are likely to occur.

Risk mitigation framework; does not prevent regulatory violations.
Legal & Regulatory Engagement

Company actively manages permitting, litigation, and regulatory dialogue with federal and state agencies (OSM, EPA, COE, FWS, state regulators). Acknowledges ongoing litigation over EPA rules.

Maintains operational permits and participates in regulatory process.
Code of Business Ethics & Employee Policies

Employee handbook covers anti-harassment, workplace violence, code of business ethics, drug/alcohol, safety, vehicle policies.

Internal control framework.

These are Missionomics' own editorial scores — directional signals built from disclosed facts under a published method, not certifications or definitive ratings of Alpha Metallurgical Resources, Inc.. Coverage and confidence vary by data point, and figures can lag real-world changes. Read the full Methodology for sourcing, scoring, and correction details — or open Alpha Metallurgical Resources, Inc. in the app for interactive charts and portfolio building.

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