The Code of Ethics includes the principles and rules of conduct recognised by Acea as having a positive ethical value, to which all company practices must be referred, with a view to safeguarding Acea’s correctness and transparency, reliability and reputation. The corporate bodies, management, employees, external collaborators and any and all other parties associated with the Acea Group are required to observe these principles, each according to their respective functions, powers and responsibilities. The document also defines the procedures for enforcing and monitoring the Code of Ethics.

In order to be effective, the Code of Ethics is updated on a regular basis, so as to bring it into line with the rules and regulations and reflect any changes in corporate culture and the Group’s organisation. In 2021, Acea’s Ethics Officer together with the Ethics and Sustainability Committee initiated a review of the Code of Ethics. The new edition of the document was approved by the Board of Directors on 9 November 2022, to replace the 2018 version.

In addition to reflecting the regulatory and organisational trend, the revision is designed to make the Code of Ethics more straightforward and applicable, and to allow a broader dissemination of Acea’s principles and values among all the companies and people belonging to the Group. The main interventions concern the integration of benchmark principles and standards associated with projects that are strategic for the Group, with particular regard to sustainability and, specifically, the enhancement of principles associated with ESG issues as:

  • the protection of human rights in all operational situations, including the supply chain;
  • explicit reference to matters concerning the inclusion and involvement of Acea’s people and organisational wellbeing;
  • commitment to the preservation of biodiversity;
  • the importance of dialogue and engagement with stakeholders;
  • the necessity to interact with suppliers who are mindful of sustainability issues.

Acea is committed to disseminating the Code of Ethics and promoting awareness of its contents. Compliance with the Code is, in fact, of fundamental importance for the pursuance of growth and sustainability objectives, business reliability, the safeguarding of the company’s reputation and the contribution that Acea intends to make to the social and environmental context of its operations.

With this in mind, in 2020 we established the Ethics Officer, a collective body whose purpose is not only to manage the reporting system but also to oversee compliance with the values of transparency, legality, fairness and ethical integrity in dealings with all stakeholders. The Ethics Officer supports the company structures appointed to draw up the Code of Ethics, and the Ethics and Sustainability Committee, in monitoring the Code’s adequacy and implementation. The Ethics Officer can propose the adoption and amendment of guidelines and operating procedures, if any, with a view to reducing the risk of Code violations, and can make suggestions to the Committee regarding possible Code of Ethics updates.

Acea, also through the Ethics and Sustainability Committee, monitors observance of the Code and puts in place suitable prevention and control tools and procedures aimed at ensuring transparency of the measures and practices adopted, intervening with ongoing improvement actions where necessary.

The Code of Ethics is the cornerstone of the internal control and risk management system, an integral part of the 231 Organisation and Management Model, the Corruption Prevention Management System and the other systems adopted by Acea and by the Group’s subsidiaries for the prevention of non-compliance.

Our Human Rights Policy

The Human Rights Policy, approved in December 2023, reaffirms and focuses the commitment undertaken by Acea towards the protection of people's fundamental rights, already expressed in the Code of Ethics, and represents the specific reference to promote full respect for human rights in the activities managed by the Group. Our Policy is based on the most important international documents on the matter, such as those of the UN, OECD, ILO and the Global Compact, as well as on the internal regulatory requirements already in force at Acea, including those focused on equality, diversity and inclusion, anti-corruption, fair competition, protection of privacy, and evaluation of supplier performance.

The Human Rights Policy identifies two relevant macro-areas, in which a total of 20 principles are set out:

  • Work – this area relates to the internal dimension of the company, focusing on the protection of workers' fundamental rights, including basic principles such as the refusal of forced labor, the guarantee of adequate working conditions and wages, as well as the freedom of association and collective bargaining. Additionally, more advanced issues of the matter are considered, such as the enhancement of skills, employee well-being, and diversity and inclusion policies.
  • Community, Society and Environment – this area focuses on the external dimension of the company, enhancing the positive impact that the safeguard of human rights generates on people and the area, from the access to adequate services to the health and safety of customers, including consumer protection, privacy, fair competition, and environmental protection.

The Policy applies both in Italy and to Group companies operating abroad. The recipients are the members of the Governance and Control Bodies of Acea SpA and the other Group companies, the managers, employees, collaborators and suppliers linked to the Group by contractual relationships, in the context of the activities carried out and within the limits of their respective responsibility.

In order to ensure the effective implementation of the Policy, in addition to the adequate dissemination of the document among internal and external stakeholders, the Group will implement a specific risk assessment process, use dedicated monitoring tools and set up a reporting channel dedicated to potential violations (whistleblowing).

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