Environmental, Social and Governance (ESG) risks

For each risk category in the Group’s risk map, environmental, social and governance (ESG) impacts are assessed and the risks affected by the Covid-19 emergency are analysed, resulting in a comprehensive, detailed and integrated risk register that also considers ESG impacts on the mapped risk categories. For each risk category, the operational, contractual and insurance mitigation measures implemented, in progress and to be implemented to reduce the risk level are identified.

By way of example but not limited to, the main risk categories with social impacts are: supply chain, technological innovation, infrastructure and facilities; those with environmental impacts are: legislative and regulatory changes, natural and accidental events, climate change; those with governance impacts are information systems, third-party unlawful acts and process adequacy. This last aspect is fundamental to guarantee the resilience of the business even in the face of unforeseen events, ensuring the continuity of critical processes. Precisely for this reason, the Board of Directors, with the opinion of the CRSC, approved in 2021 the Crisis Management Procedure as part of the Group’s Business Continuity Management (BCM) Project, which formalised and implemented a BCM model with the provision of organisational and technological safeguards to ensure the continuity of processes, as well as a proactive and structured response to emergency or crisis events.

The analysis of ESG impacts is the basis for the risk matrix below.

The assessment of ESG impacts shows a correlation between the priority topics defined in the materiality analysis process and the risks/opportunities, also with specific reference to the provisions of Legislative Decree 254/2016 (art. 3 paragraph 1 point c).

All priority topics are linked to one or more risks identified in the enterprise risk management model, as shown in the table below.

Priority topics (reference to the Group risk map)	Risk factors / Opportunities	Management methods
Solid and transparent governance for sustainable growth Ethics, fight against corruption and compliance (E2, E3, F4, F5)	RISK FACTORS Failure to achieve the targets set out in the Business Plan and consequent negative impacts (operational, economic and reputational) Commission of offences related to Legislative Decree 231/2001 Non-compliance with tax regulations Company’s administrative responsibility for violation of rules and regulations Criminal liability of management for violation of regulations Violation of the Code of Ethics conduct criteria Violation of confidentiality or abuse of privileged information Negative operational, economic and reputational impact deriving from conduct contrary to company ethics, rules and regulations	Pianificazione e monitoraggio dei target di Piano Industriale Comitati endoconsiliari Sistema di ERM Modello organizzativo 231 Codice Etico Codice di Corporate Governance Piano di Internal Audit Organismi di Vigilanza Formazione dei dipendenti su Modello 231 e Codice Etico Procedure: Whistleblowing, Internal dealing, Gestione delle informazioni rilevanti e privilegiate, Gestione interna e comunicazione all’esterno di informazioni rilevanti e/o informazioni privilegiate Politica per la gestione del dialogo con la generalità degli Azionisti e degli Investitori Sistema sanzionatorio
Effective and transparent dialogue and communication with stakeholders (A6, E1, E2, F4, F5)	RISK FACTORS Ineffective communication to stakeholders Disruption of relations with Public Bodies with subsequent negative reputational impact Errors/omissions in the contents of a product/service communication campaign Disputes with Public Bodies Commission of offences against the Public Administration Ineffective communication towards employees Violation of the Code of Ethics conduct criteria OPPORTUNITIES Brand promotion	Structured communication plans on strategies, objectives, facilities and services Code of Ethics Organisational model 231 Organisational and managerial oversight Local Committees Employee training on Code of Ethics Procedures: Management of Media Relations, Whistleblowing, Internal management and external communication of relevant information and/or privileged information Policy for the management of dialogue with all Shareholders and Investors Sanctioning system
Sustainable management of the supply chain (A4, F4, G1, G7)	RISK FACTORS Qualification in the Register of a supplier not complying with the Group’s quality/ sustainability standards Occupational accidents and work-related illness of employees of third-party companies Non-compliance with worker health and safety regulations by suppliers, including in relation to pandemic events Violation of the Code of Ethics conduct criteria and current regulations by supplier Supplier behaviours that disregard the values of diversity and inclusion Supplier behaviours that do not comply with the Group’s environmental regulations and policies	Code of Ethics Questionnaire for supplier qualification Score for qualification in the Supplier’s Register Monitoring of potentially sensitive contracts concerning environmental protection and health and safety at work Supply chain monitoring on workers’ rights Supply chain monitoring on human rights Contracts that enhance the work of disadvantaged personnel Contractual clauses with suppliers on Code of Ethics and social criteria
Decarbonization and reduction of emissions (C3, E2, G1, G2, G3, A4)	RISK FACTORS Failure to achieve the targets set out in the Business Plan and consequent negative impacts (operational, economic and reputational) also on accessibility to sustainable finance instruments Negative impacts on environment, health and safety with consequent negative reputational and economic impacts Unintentional exceeding of emission thresholds provided for by environmental authorisations or regulations Loss of environmental certifications Tightening of emission constraints and need for adaptation of processes/plants Errors/omissions in the design/permit/ implementation activities with subsequent impairment of plant operating continuity OPPORTUNITIES Opportunità di business legate alla transizione energetica e ambientale	Planning and monitoring of Business Plan targets and sustainable finance instruments ERM system (Operational Risk Policy and Climate Change Risk Policy) Certified Management System (risk assessment, containment measures and third-party audits) Organisational model 231 Procedures: Environmental analysis, Management of emissions from waste-toenergy plants and thermoelectric power stations, Management of emergencies aimed at returning within certain timescales to the established emission thresholds, Management and maintenance of vehicle fleets Adoption of best available technologies Continuous emission monitoring systems and real-time connection with control bodies Periodic audits by control bodies Improvement plans and related investments Environmental authorisations Medium- and/or long-term objectives for management
Circular economy: management, sorted waste collection and reuse of waste (C3, E2, F1, F4, G3, G6, A4)	RISK FACTORS Failure to achieve the targets set out in the Business Plan and consequent negative impacts (operational, economic and reputational) also on accessibility to sustainable finance instruments Impacts inconsistent with circular economy directives or negative environmental, health and safety impacts with consequent negative reputational and economic impacts Loss of environmental authorisations Incorrect handling of waste by employees or suppliers OPPORTUNITIES Favourable regulatory framework Growth opportunities in the domestic market Increased consumer awareness	Planning and monitoring of Business Plan targets and sustainable finance instruments ERM system (Operational Risk Policy andClimate Change Risk Policy) Certified Management System (risk assessment, containment measures and third-party audits) Adoption of best available technologies Organisational model 231 Procedures: Environmental analysis, special waste management Environmental authorisations Requirements in the specifications regarding the tracing of waste and timely checks Qualification and monitoring of suppliers Audit of the most significant and potentially sensitive contracts concerning environmental protection Medium- and/or long-term objectives for management
Energy efficiency, renewable sources and district heating (B1, C1, C3, F1, G3)	RISK FACTORS Failure to achieve the targets set out in the Business Plan and consequent negative impacts (operational, economic and reputational) also on accessibility to sustainable finance instruments Impacts inconsistent with directives and guidelines on energy efficiency and production from renewable sources, resulting in negative economic and reputational effects Shortage of water resources affecting hydropower generation Reduction in demand for district heating caused by the rise in average temperatures Extreme natural phenomena that may cause impacts on assets or the district heating network Changes in the legislative/regulatory framework regarding incentives for energy efficiency measures OPPORTUNITIES Growth opportunities in the energy efficiency sector Evaluation of possible external growth lines in the renewables sector Extensibility of district heating systems in new geographical areas	Planning and monitoring of Business Plan targets and sustainable finance instruments ERM system (Operational Risk Policy and Climate Change Risk Policy) Certified Management System (risk assessment, containment measures and third-party audits) Procedures: Environmental analysis Temperature monitoring Adoption of state-of-the-art technologies Maintenance plans, including predictive plans Use of materials and components less subject to climate change Medium- and/or long-term objectives for management
Innovation, smart city and sustainable mobility (F, A7)	RISK FACTORS Failure to achieve the targets set out in the Business Plan and consequent negative impacts (operational, economic and reputational) also on accessibility to sustainable finance instruments Delay in technological change OPPORTUNITIES Acceleration of digital transformation Business opportunities related to energy and environmental transition and technological evolution Participation in local systems to build resilient cities	Planning and monitoring of Business Plan targets and sustainable finance instruments Group innovation plan and related investments
Protection of biodiversity (C1, C3, E2, G1, G3)	RISK FACTORS Natural/accidental event affecting minimum vital water flow mechanisms according to regulations Possible gaps in monitoring the biodiversity impact of plants, activities or services Accidental spills impacting biodiversity	Business Plan ERM system Certified Management System (risk assessment, containment measures and third-party audits) Biodiversity Policy Procedures: Environmental analysis Mapping of the Group’s plants and networks for biodiversity impacts assessment (to be completed) Plant equipment and monitoring systems to minimize possible impacts on biodiversity Emergency plans Collaboration with local protection agencies, institutions and associations
Economic development and value for local areas (F, A, B)	RISK FACTORS Failure to achieve the targets set out in the Business Plan and consequent negative impacts (operational, economic and reputational) Reduction in value distributed to stakeholders Negative ratings or downgrading in ratings Loss of growth opportunities in business sectors Ineffective performance communication Failure to achieve quality of service OPPORTUNITIES Business opportunities related to energy and environmental transition and technological and digital evolution Access to sustainable finance instruments	Planning and monitoring of Business Plan targets and sustainable finance instruments ERM system (Financial Risk Policy, Credit Risk Policy) Structured financial management for return on investment Structured traditional investor relationship system and ESG Adoption of sustainable finance instruments Transparent performance communications Medium- and/or long-term objectives for management
Development of local communities Sustainability education (A6, A7, F1, F4)	RISK FACTORS Disruption of relations with the representative subjects of the local areas with subsequent negative reputational impact Negative perception by the community related to the presence of Group’s plants or managed activities Lack of perception of the Group’s investments for the development/ modernisation of regional infrastructures OPPORTUNITIES PNRR Policy and legislative framework increasingly oriented towards sustainable development Participation in national and international networks for sustainable development	Piano industriale e relativi investimenti per le infrastrutture territoriali Piani strutturati di comunicazione su strategie, obiettivi, impianti e servizi Comitati Territoriali Programma educativo Eduiren Programmi di sensibilizzazione alla sostenibilità Attività di monitoraggio e di definizione di azioni correttive in caso di reclami/lamentele Procedure: Gestione delle sponsorizzazioni, Gestione delle media relations Impianti aperti alle visite
Efficient, reliable and safe management of processes and infrastructures (G1, G2, G3, G4, G5, G7, G8, E3, F4)	RISK FACTORS Failure to achieve the targets set out in the Business Plan and consequent negative impacts (operational, economic and reputational) also on accessibility to sustainable finance instruments Malfunctions or business interruption of plants, networks and services Emergency or crisis events that may result in the interruption of business processes Damage to third-parties (persons and/or property) attributable to activities carried out by the Group Accidental spills impacting on soil or water Noise pollution related to the Group’s activities Odour emissions into the atmosphere Generation of electromagnetic fields Cyber risk or inadequacy of the ICT system Non-compliance in the processing of personal data Legal proceedings brought by consumers Impairment of continuity and quality of service	Planning and monitoring of Business Plan targets and sustainable finance instruments ERM system (Operational Risk Policy, Climate Change Risk Policy and Cyber Risk Policy) Business Continuity Management (BCM) model: organisational and technological safeguards for the continuity of business processes Service and plant monitoring tools, remotely controlled systems for the safety of networks and plants Certified Management System (risk assessment, containment measures and third-party audits) Adoption of best available technologies Environmental authorisations Business continuity plan Emergency management planning Annual customer satisfaction surveys and identification of improvement actions Insurance plans 27001 certification Personal data processing management system
Service quality and customer orientation (G1, G6, E2, E3, F4, A4)	RISK FACTORS Loss of customers Errors in service charges and credit management Reduction in customer satisfaction levels Delays/defaults by suppliers in the execution of outsourced activities Commercial practices inconsistent with the existing legal/regulatory framework Non-compliance with customer protection protocols and regulations Failure or improper management of customer relations Disputes with customers, Consumer Associations/Class action suits Loss of ISO 9001 certification and the subsequent inability to participate in tenders Ineffectiveness of business strategy OPPORTUNITIES Market share development	Business Plan and related investments for service quality Code of Ethics ARERA Code of Business Conduct Certified Management System (risk assessment, containment measures and thirdparty audits) ERM system Multi-channel CRM and caring initiatives Specific agreements with consumer organisations and constant monitoring or relations Protocols and regulations concerning customer protection via specific processesmand procedures Annual customer satisfaction surveys and identification of improvement actions Monitoring activities and definition of corrective actions in case of claims/ complaints Service charters and service specifications Joint conciliation Medium- and/or long-term objectives for management
Employment, development of human resources and welfare (E3, G4, F4)	RISK FACTORS Failure to achieve Business Plan targets Loss of key skills/inadequate job profiles Loss of talent Slowdown/interruption of operations and/ or impairment of service quality level due to lack of personnel Outsourcing policies not adequately managed Labour disputes Sanctions and fines for non-compliance with labour laws Lack of attention to employees’ well-being Poor work-life balance OPPORTUNITIES Improvement of the internal climate Favourable legislative framework for better corporate welfare	Planning and monitoring of Business Plan targets Code of Ethics Certified Management System (risk assessment, containment measures and thirdparty audits) Talent acquisition initiatives Compensation & benefits policies Corporate retention and welfare programmes Monitoring of labour law developments and specific audits on regulatory compliance Procedures: Personnel recruitment and selection; Training and education Guidelines: Definition of key resources; Management by objectives; Economic and professional development Internal communication Career planning and merit enhancement systems Welfare plan Medium- and/or long-term objectives for management
Industrial relations (G4, F4, A6)	RISK FACTORS Disruption of relations with trade unions and the subsequent negative operational and reputational impact Slowdown/interruption of operations due to workers’ strikes (e.g. on the occasion of renewal of the collective agreement, business transformation, organizational changes, etc.)	Management of industrial relations articulated on 3 levels: Group, corporate, local areas Studies for the renewal of the reference National Collective Labour Agreements and participation in their work at national level
Diversity and inclusion (G4, F4)	RISK FACTORS Failure to meet Business Plan targets Collective/individual policies/behaviours that disregard the values of diversity and inclusion Advertising content perceived as discriminatory	Planning and monitoring of Business Plan targets Code of Ethics Diversity management programmes and initiatives “Futuro D“ Project Hiring of disadvantaged personnel Medium- and/or long-term objectives for management
Occupational health and safety (G7, F4, E2, E3)	RISK FACTORS Occupational accidents and work-related illness of employees Epidemic events affecting workers’ health Civil and/or criminal liability of persons covered by Legislative Decree 81/08 Loss of ISO 18001 certification and the subsequent loss of the INAIL award Non-compliance with health and safety standards Negative operational, economic and reputational impact related to the failure to protect the health and safety of workers OPPORTUNITIES Technological innovations that make operations safer	Planning and monitoring of Business Plan targets Code of Ethics Prevention and protection service Specific personnel training ERM system Certified Management System (risk assessment, containment measures and third-party audits) Procedures: Management of occupational health and safety aspects; PPE management; Management of accidents and injuries; Protection of the health and safety of pregnant workers, those who have recently given birth and those who are breastfeeding Emergency management planning Health monitoring plans Insurance plans Organisational model 231 and information flows to the Health and Safety Supervisory Bodies “Near miss” analysis and subsequent actions Medium- and/or long-term objectives for management
Protection of human rights (G4, F4, E3)	RISK FACTORS Violation of conduct criteria of the Code of Ethics and current regulations by employees Discriminatory actions against customers and employees Violation of the rights of people with disabilities Violation of the rights of employees and contractors in the supply chain Negative operational, economic and reputational impacts of human rights violations	Code of Ethics System for reporting to the Supervisory Bodies National Collective Labour Agreements Service charters Removal of architectural barriers in Group buildings Accessibility of services for people with disabilities

Priority topics (reference to the Group risk map)

Risk factors / Opportunities

Management methods

Solid and transparent governance for sustainable growth

Ethics, fight against corruption and compliance

(E2, E3, F4, F5)

RISK FACTORS

Failure to achieve the targets set out in the Business Plan and consequent negative impacts (operational, economic and reputational)
Commission of offences related to Legislative Decree 231/2001
Non-compliance with tax regulations
Company’s administrative responsibility for violation of rules and regulations
Criminal liability of management for violation of regulations
Violation of the Code of Ethics conduct criteria
Violation of confidentiality or abuse of privileged information
Negative operational, economic and reputational impact deriving from conduct contrary to company ethics, rules and regulations

Pianificazione e monitoraggio dei target di Piano Industriale
Comitati endoconsiliari
Sistema di ERM
Modello organizzativo 231
Codice Etico
Codice di Corporate Governance
Piano di Internal Audit
Organismi di Vigilanza
Formazione dei dipendenti su Modello 231 e Codice Etico
Procedure: Whistleblowing, Internal dealing, Gestione delle informazioni rilevanti e privilegiate, Gestione interna e comunicazione all’esterno di informazioni rilevanti e/o informazioni privilegiate
Politica per la gestione del dialogo con la generalità degli Azionisti e degli Investitori
Sistema sanzionatorio

Effective and transparent dialogue and communication with stakeholders

(A6, E1, E2, F4, F5)

RISK FACTORS

Ineffective communication to stakeholders
Disruption of relations with Public Bodies with subsequent negative reputational impact
Errors/omissions in the contents of a product/service communication campaign
Disputes with Public Bodies
Commission of offences against the Public Administration
Ineffective communication towards employees
Violation of the Code of Ethics conduct criteria

OPPORTUNITIES

Brand promotion

Structured communication plans on strategies, objectives, facilities and services
Code of Ethics
Organisational model 231
Organisational and managerial oversight
Local Committees
Employee training on Code of Ethics
Procedures: Management of Media Relations, Whistleblowing, Internal management and external communication of relevant information and/or privileged information
Policy for the management of dialogue with all Shareholders and Investors
Sanctioning system

Sustainable management of the supply chain

(A4, F4, G1, G7)

RISK FACTORS

Qualification in the Register of a supplier not complying with the Group’s quality/ sustainability standards
Occupational accidents and work-related illness of employees of third-party companies
Non-compliance with worker health and safety regulations by suppliers, including in relation to pandemic events
Violation of the Code of Ethics conduct criteria and current regulations by supplier
Supplier behaviours that disregard the values of diversity and inclusion
Supplier behaviours that do not comply with the Group’s environmental regulations and policies

Code of Ethics
Questionnaire for supplier qualification
Score for qualification in the Supplier’s Register
Monitoring of potentially sensitive contracts concerning environmental protection and health and safety at work
Supply chain monitoring on workers’ rights
Supply chain monitoring on human rights
Contracts that enhance the work of disadvantaged personnel
Contractual clauses with suppliers on Code of Ethics and social criteria

Decarbonization and reduction of emissions

(C3, E2, G1, G2, G3, A4)

RISK FACTORS

Failure to achieve the targets set out in the Business Plan and consequent negative impacts (operational, economic and reputational) also on accessibility to sustainable finance instruments
Negative impacts on environment, health and safety with consequent negative reputational and economic impacts
Unintentional exceeding of emission thresholds provided for by environmental authorisations or regulations
Loss of environmental certifications
Tightening of emission constraints and need for adaptation of processes/plants
Errors/omissions in the design/permit/ implementation activities with subsequent impairment of plant operating continuity

OPPORTUNITIES

Opportunità di business legate alla transizione energetica e ambientale

Planning and monitoring of Business Plan targets and sustainable finance instruments
ERM system (Operational Risk Policy and Climate Change Risk Policy)
Certified Management System (risk assessment, containment measures and third-party audits)
Organisational model 231
Procedures: Environmental analysis, Management of emissions from waste-toenergy plants and thermoelectric power stations, Management of emergencies aimed at returning within certain timescales to the established emission thresholds, Management and maintenance of vehicle fleets
Adoption of best available technologies
Continuous emission monitoring systems and real-time connection with control bodies
Periodic audits by control bodies
Improvement plans and related investments
Environmental authorisations
Medium- and/or long-term objectives for management

Circular economy: management, sorted waste collection and reuse of waste

(C3, E2, F1, F4, G3, G6, A4)

RISK FACTORS

Failure to achieve the targets set out in the Business Plan and consequent negative impacts (operational, economic and reputational) also on accessibility to sustainable finance instruments
Impacts inconsistent with circular economy directives or negative environmental, health and safety impacts with consequent negative reputational and economic impacts
Loss of environmental authorisations
Incorrect handling of waste by employees or suppliers

OPPORTUNITIES

Favourable regulatory framework
Growth opportunities in the domestic market
Increased consumer awareness

Planning and monitoring of Business Plan targets and sustainable finance instruments
ERM system (Operational Risk Policy andClimate Change Risk Policy)
Certified Management System (risk assessment, containment measures and third-party audits)
Adoption of best available technologies
Organisational model 231
Procedures: Environmental analysis, special waste management
Environmental authorisations
Requirements in the specifications regarding the tracing of waste and timely checks
Qualification and monitoring of suppliers
Audit of the most significant and potentially sensitive contracts concerning environmental protection
Medium- and/or long-term objectives for management

Energy efficiency, renewable sources and district heating

(B1, C1, C3, F1, G3)

RISK FACTORS

Failure to achieve the targets set out in the Business Plan and consequent negative impacts (operational, economic and reputational) also on accessibility to sustainable finance instruments
Impacts inconsistent with directives and guidelines on energy efficiency and production from renewable sources, resulting in negative economic and reputational effects
Shortage of water resources affecting hydropower generation
Reduction in demand for district heating caused by the rise in average temperatures
Extreme natural phenomena that may cause impacts on assets or the district heating network
Changes in the legislative/regulatory framework regarding incentives for energy efficiency measures

OPPORTUNITIES

Growth opportunities in the energy efficiency sector
Evaluation of possible external growth lines in the renewables sector
Extensibility of district heating systems in new geographical areas

Planning and monitoring of Business Plan targets and sustainable finance instruments
ERM system (Operational Risk Policy and Climate Change Risk Policy)
Certified Management System (risk assessment, containment measures and third-party audits)
Procedures: Environmental analysis
Temperature monitoring
Adoption of state-of-the-art technologies
Maintenance plans, including predictive plans
Use of materials and components less subject to climate change
Medium- and/or long-term objectives for management

Innovation, smart city and sustainable mobility

(F, A7)

RISK FACTORS

Failure to achieve the targets set out in the Business Plan and consequent negative impacts (operational, economic and reputational) also on accessibility to sustainable finance instruments
Delay in technological change

OPPORTUNITIES

Acceleration of digital transformation
Business opportunities related to energy and environmental transition and technological evolution
Participation in local systems to build resilient cities

Planning and monitoring of Business Plan targets and sustainable finance instruments
Group innovation plan and related investments

Protection of biodiversity

(C1, C3, E2, G1, G3)

RISK FACTORS

Natural/accidental event affecting minimum vital water flow mechanisms according to regulations
Possible gaps in monitoring the biodiversity impact of plants, activities or services
Accidental spills impacting biodiversity

Business Plan
ERM system
Certified Management System (risk assessment, containment measures and third-party audits)
Biodiversity Policy
Procedures: Environmental analysis
Mapping of the Group’s plants and networks for biodiversity impacts assessment (to be completed)
Plant equipment and monitoring systems to
minimize possible impacts on biodiversity
Emergency plans
Collaboration with local protection agencies, institutions and associations

Economic development and value for local areas

(F, A, B)

RISK FACTORS

Failure to achieve the targets set out in the Business Plan and consequent negative impacts (operational, economic and reputational)
Reduction in value distributed to stakeholders
Negative ratings or downgrading in ratings
Loss of growth opportunities in business sectors
Ineffective performance communication
Failure to achieve quality of service

OPPORTUNITIES

Business opportunities related to energy and environmental transition and technological and digital evolution
Access to sustainable finance instruments

Planning and monitoring of Business Plan targets and sustainable finance instruments
ERM system (Financial Risk Policy, Credit Risk Policy)
Structured financial management for return on investment
Structured traditional investor relationship system and ESG
Adoption of sustainable finance instruments
Transparent performance communications
Medium- and/or long-term objectives for management

Development of local communities Sustainability education

(A6, A7, F1, F4)

RISK FACTORS

Disruption of relations with the representative subjects of the local areas with subsequent negative reputational impact
Negative perception by the community related to the presence of Group’s plants or managed activities
Lack of perception of the Group’s investments for the development/ modernisation of regional infrastructures

OPPORTUNITIES

PNRR
Policy and legislative framework increasingly oriented towards sustainable development
Participation in national and international networks for sustainable development

Piano industriale e relativi investimenti per le infrastrutture territoriali
Piani strutturati di comunicazione su strategie, obiettivi, impianti e servizi
Comitati Territoriali
Programma educativo Eduiren
Programmi di sensibilizzazione alla sostenibilità
Attività di monitoraggio e di definizione di azioni correttive in caso di reclami/lamentele
Procedure: Gestione delle sponsorizzazioni, Gestione delle media relations
Impianti aperti alle visite

Efficient, reliable and safe management of processes and infrastructures

(G1, G2, G3, G4, G5, G7, G8, E3, F4)

RISK FACTORS

Failure to achieve the targets set out in the Business Plan and consequent negative impacts (operational, economic and reputational) also on accessibility to sustainable finance instruments
Malfunctions or business interruption of plants, networks and services
Emergency or crisis events that may result in the interruption of business processes
Damage to third-parties (persons and/or property) attributable to activities carried out by the Group
Accidental spills impacting on soil or water
Noise pollution related to the Group’s activities
Odour emissions into the atmosphere
Generation of electromagnetic fields
Cyber risk or inadequacy of the ICT system
Non-compliance in the processing of personal data
Legal proceedings brought by consumers
Impairment of continuity and quality of service

Planning and monitoring of Business Plan targets and sustainable finance instruments
ERM system (Operational Risk Policy, Climate Change Risk Policy and Cyber Risk Policy)
Business Continuity Management (BCM) model: organisational and technological safeguards for the continuity of business processes
Service and plant monitoring tools, remotely controlled systems for the safety of networks and plants
Certified Management System (risk assessment, containment measures and third-party audits)
Adoption of best available technologies
Environmental authorisations
Business continuity plan
Emergency management planning
Annual customer satisfaction surveys and identification of improvement actions
Insurance plans
27001 certification
Personal data processing management system

Service quality and customer orientation

(G1, G6, E2, E3, F4, A4)

RISK FACTORS

Loss of customers
Errors in service charges and credit management
Reduction in customer satisfaction levels
Delays/defaults by suppliers in the execution of outsourced activities
Commercial practices inconsistent with the existing legal/regulatory framework
Non-compliance with customer protection protocols and regulations
Failure or improper management of customer relations
Disputes with customers, Consumer Associations/Class action suits
Loss of ISO 9001 certification and the subsequent inability to participate in tenders
Ineffectiveness of business strategy

OPPORTUNITIES

Market share development

Business Plan and related investments for service quality
Code of Ethics
ARERA Code of Business Conduct
Certified Management System (risk assessment, containment measures and thirdparty audits)
ERM system
Multi-channel CRM and caring initiatives
Specific agreements with consumer organisations and constant monitoring or relations
Protocols and regulations concerning customer protection via specific processesmand procedures
Annual customer satisfaction surveys and identification of improvement actions
Monitoring activities and definition of corrective actions in case of claims/ complaints
Service charters and service specifications
Joint conciliation
Medium- and/or long-term objectives for management

Employment, development of human resources and welfare

(E3, G4, F4)

RISK FACTORS

Failure to achieve Business Plan targets
Loss of key skills/inadequate job profiles
Loss of talent
Slowdown/interruption of operations and/ or impairment of service quality level due to lack of personnel
Outsourcing policies not adequately managed
Labour disputes
Sanctions and fines for non-compliance with labour laws
Lack of attention to employees’ well-being
Poor work-life balance

OPPORTUNITIES

Improvement of the internal climate
Favourable legislative framework for better corporate welfare

Planning and monitoring of Business Plan targets
Code of Ethics
Certified Management System (risk assessment, containment measures and thirdparty audits)
Talent acquisition initiatives
Compensation & benefits policies
Corporate retention and welfare programmes
Monitoring of labour law developments and specific audits on regulatory compliance
Procedures: Personnel recruitment and selection; Training and education
Guidelines: Definition of key resources; Management by objectives; Economic and professional development
Internal communication
Career planning and merit enhancement systems
Welfare plan
Medium- and/or long-term objectives for management

Industrial relations

(G4, F4, A6)

RISK FACTORS

Disruption of relations with trade unions and the subsequent negative operational and reputational impact
Slowdown/interruption of operations due to workers’ strikes (e.g. on the occasion of renewal of the collective agreement, business transformation, organizational changes, etc.)

Management of industrial relations articulated on 3 levels: Group, corporate, local areas
Studies for the renewal of the reference National Collective Labour Agreements and participation in their work at national level

Diversity and inclusion

(G4, F4)

RISK FACTORS

Failure to meet Business Plan targets
Collective/individual policies/behaviours that disregard the values of diversity and inclusion
Advertising content perceived as discriminatory

Planning and monitoring of Business Plan targets
Code of Ethics
Diversity management programmes and initiatives
“Futuro D“ Project
Hiring of disadvantaged personnel
Medium- and/or long-term objectives for management

Occupational health and safety

(G7, F4, E2, E3)

RISK FACTORS

Occupational accidents and work-related illness of employees
Epidemic events affecting workers’ health
Civil and/or criminal liability of persons covered by Legislative Decree 81/08
Loss of ISO 18001 certification and the subsequent loss of the INAIL award
Non-compliance with health and safety standards
Negative operational, economic and reputational impact related to the failure to protect the health and safety of workers

OPPORTUNITIES

Technological innovations that make operations safer

Planning and monitoring of Business Plan targets
Code of Ethics
Prevention and protection service
Specific personnel training
ERM system
Certified Management System (risk assessment, containment measures and third-party audits)
Procedures: Management of occupational health and safety aspects; PPE management; Management of accidents and injuries; Protection of the health and safety of pregnant workers, those who have recently given birth and those who are breastfeeding
Emergency management planning
Health monitoring plans
Insurance plans
Organisational model 231 and information flows to the Health and Safety Supervisory Bodies
“Near miss” analysis and subsequent actions
Medium- and/or long-term objectives for management

Protection of human rights

(G4, F4, E3)

RISK FACTORS

Violation of conduct criteria of the Code of Ethics and current regulations by employees
Discriminatory actions against customers and employees
Violation of the rights of people with disabilities
Violation of the rights of employees and contractors in the supply chain
Negative operational, economic and reputational impacts of human rights violations

Code of Ethics
System for reporting to the Supervisory Bodies
National Collective Labour Agreements
Service charters
Removal of architectural barriers in Group buildings
Accessibility of services for people with disabilities

The Group Risk Management Department, which reports to the Deputy Chairperson, is responsible, among other things, for the audit of the ERM integrated management system of the Group, in terms of methodological approach, definition of policies and monitoring of the system and, in collaboration with the Chief Executive Officer, for taking out and managing insurance policies with the support of the Procurement, Logistics and Services and Legal Affairs Departments. A periodic assessment process is also in place about adverse events in the various sectors and across all Group’s operational areas in order to describe in detail their causes and implement the most suitable methods for preventing and/or limiting the impacts of the events.