In Acea operates a system for receiving and managing reports (called “Whistleblowing”), which can be activated by both employees and external parties, relating to any non-compliance with the law, internal rules and the Code of Ethics and the Human Rights Policy, as well as issues related to the Internal Control SystemCorporate Information, the Company's Administrative Liability (Legislative Decree n. 231/01), fraud and conflicts of interest. This procedure ensures the highest degree of confidentiality and privacy in the processing of communications received, to protect the reporting person, the reported person and the persons involved.

What can be reported

The scope of alleged violation reports that can be submitted through the reporting system adopted by Acea and the Group companies is wider than that set forth by Legislative Decree 24 of 10 March 2023 (Implementation of Directive (EU) 2019/1937 of the European Parliament and of the Council, dated 23 October 2019, on the protection of persons who report breaches of Union law and laying down provisions concerning the protection of persons reporting breaches of national regulations) being extended, apart from the violations referred to in the said decree, also to alleged violations of the Code of Ethics, the Human Rights Policy and the body of internal regulations adopted by the various Companies.

In accordance with the provisions set forth by Legislative Decree 24/2023, through the system adopted, it is possible to report behaviour, acts or omissions that harm the public interest or the integrity of Acea and the Group’s subsidiaries, comprising:

  • administrative, accounting, civil or criminal offences;
  • significant unlawful conduct pursuant to Legislative Decree 231/2001, or violations of the organisation and management models envisaged therein;
  • offences falling within the scope of European Union or national acts (as indicated in Annex 1 to Legislative Decree 24/2023, to which reference is made for further details) relating to the following sectors: public procurement; financial services, products and markets and prevention of money laundering and terrorist financing; product safety and compliance; transport safety; environmental conservation; radiation protection and nuclear safety; safety of food and feed and animal health and welfare; public health; consumer protection; safeguarding of privacy and protection of personal data and security of network and information systems;
  • acts or omissions adversely affecting the financial interests of the Union;
  • acts or omissions concerning the internal market;
  • acts or behaviours thwarting the object or purpose of the provisions contained in Union acts.

Reporting channels

Reporting channels available to the whistleblower:

  • internal company channel (communicate Whistleblowing);
  • external channel (ANAC - the National Anti-Corruption Authority, the independent administrative authority whose institutional mission is to prevent corruption in all areas of administrative activity);
  • public disclosure (through the press, electronic means or means of dissemination capable of reaching a large number of people);
  • complaint to the judicial or accounting authority.

Conditions for reporting

Choice of reporting channel

As a matter of priority, whistleblowers are encouraged to use the internal channel adopted by Acea and the Group companies and, only when certain conditions, explicitly set out below, are met, may they make an external report or public disclosure.

Safeguards of the whistleblower

The safeguards set out below, as set forth by Legislative Decree 24/2023, apply both to the reporting party and to the following subjects:

  • the facilitator (natural person who assists the whistleblower in the reporting process and operates within the same work environment);
  • people in the same work environment as the reporting person, the complainant or the person who has made a public disclosure and who are linked to them by a stable emotional or family relationship up to the fourth degree;
  • work colleagues of the reporting person or of whosoever has submitted a complaint or made a public disclosure, insofar as they are employed in the same work environment as the reporting person and have a current ongoing relationship with such person;
  • institutions owned by the reporting person or where the said persons are employed, as well as institutions operating in the same workplace as the above mentioned persons.

Relevant reports received during the year

  2021 2022 
Relevant reports received during the year divided according to the case being reported: 14 24
Supplies 7 6
Sales   4
Human resources 4 2
HSE 2 7
Other (protection of assets, company regulations, etc.) 1 5
Relevant reports dealt with during the year divided according to investigation outcome: 14 24
Unfounded 6 14
Dismissed1 7 2
Well-founded 1 7
Suspended2   1

The investigation on all reports received in 2022 relating to Acea SpA and its subsidiaries in Italy and abroad was completed.

1 Reports are classified as dismissed based on the reported facts: they cannot be qualified as detailed / verifiable since, in the light of the results of any preliminary checks carried out, there is no possibility of starting the subsequent assessment phase.

2 Investigation suspended pursuant to the Whistleblowing procedure.

Notice for Acea Group customers

Any reports referring to cases of a technical/commercial nature (for example, commercial services, contract management, claims. invoicing, meter readings, transfers, lack of water or power, breakdown reports, etc.) must be sent to the competent structures of the various Group Companies through MyAcea, the reserved area dedicated to Acea Group customers, and/or via the contacts listed in the section Contacts and Assistance.


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