Disclosing sustainability: methodological note

SUSTAINABILITY PERFORMANCE: LEGISLATIVE DECREE NO. 254/2016, REGULATION 852/2020 AND GRI STANDARD

Acea has published a Group Sustainability Report since 1999, the year in which the Parent Company was listed on the Stock Exchange. Since then, the sustainability report complies with the annual publication frequency, is prepared according to international Guidelines¹ and is subject to third-party verification. Since the 2017 edition, the Sustainability Report has also complied with Legislative Decree no. 254/2016², which transposed EU Directive 95/2014 into Italian law. Under the Decree, companies that meet the conditions set out in article 2 are required to publish their sustainability performance in a non-financial statement – individual or consolidated – which contains information: “(…) to an extent necessary for ensuring an understanding of the company’s activity, its performance, results and the impact it produces, relating to environmental, social and employee matters, respect for human rights, anti-corruption and bribery matters, which are relevant given the activities and characteristics of the enterprise (…)”³.
It is also worth noting the entry into force of Regulation 852/2020⁴, which "establishes the criteria for determining whether an economic activity can be considered environmentally sustainable"⁵. The Regulation - also known as “EU Taxonomy” - states that companies subject to the requirement to publish information of a non-financial nature include in the Consolidated Non-Financial Statement information on the activities carried out associated with “eco-sustainable activities” and on quantitative performance indicators economic (KPI) - in particular, the turnover, CapEx and OpEx shares - attributable to them⁶. Application of the Regulation is gradual and starts, in the initial phase, from 1 January 2022.
This Sustainability Report, for the financial year 2021 has been prepared in accordance with the GRI Standards⁷: Comprehensive option and is therefore called Acea Group’s 2021 Sustainability Report (Consolidated Non-Financial Statement pursuant to Legislative Decree no. 254/2016, prepared in accordance with GRI Standards), taking the form of an autonomous document, as permitted by the aforementioned Legislative Decree⁸.
The Consolidated Non-Financial Statement also includes the disclosure required from the first year of application of Regulation 852/20209 and Delegated Regulations 2021/2178 and 2021/2139; it will therefore be applied to the same set of companies included in the NFS scope, considered significant and adequately representative of the Group pursuant to Legislative Decree no. 254/2016 (see the paragraph on Materiality, GRI Standard and scope of the report below). The findings that emerged, as well as the description of the methodological definition process, are reported in the chapter The information required by the European Taxonomy.
The Sustainability Report, enclosing a Summary Note, following its approval by the Board of Directors, is available to the supervisory body and submitted for limited assurance by the independent auditor, with which Acea has no joint interests or other connections and appointed in order to assess the compliance thereof with Legislative Decree no. 254/2016 and its consistency with the implemented reporting standards10 the limited assurance does not concern the information and data relating to the EU Taxonomy or the requests of art. 8 of EU Regulation 2020/852 (see Opinion Letter of the independent auditor).
The document is disseminated through publication on the institutional website at the same time as the Consolidated Financial Statements and distributed during the Shareholders’ Meeting.

MATERIALITY, GRI STANDARDS AND REPORT SCOPE

In 2020, Acea, driven by the disruptive change in context caused by the Covid-19 health emergency, deemed it appropriate to verify the validity of the “material” economic and governance, social and environmental issues, connected to the company’s business, carrying out an ad hoc in-depth analysis with the direct involvement of stakeholders.

In summary, this in-depth analysis included:

• Covid-19 context analysis, carried out on around 35 documents (at international, European, government, sustainability and sector level) representative of both the evidence linked to the emergency phase and the guidelines for recovery, in order to identify the current and prospective trends;
• the “reinterpretation” of the “material” issues on the basis of the evidence highlighted by the Covid-19 context analysis, which placed emphasis on specific elements of 12 out of the 19 “material” issues¹¹;
• the involvement of the interested parties (external and internal)¹², through a digital multi-stakeholder focus group, in the final phase of which the Chairperson of the Company took part, aimed at gathering the stakeholders’ thoughts on the pandemic and learning their expectations of the role that Acea could play in the recovery of the territory it operates in;
• the direct involvement of Group managers, through a virtual meeting with 25 company managers. After illustrating the main results of the multi-stakeholder consultation, the managers assessed the most strategic aspects of the “new normal” for recovery, including in consideration of the cases raised by stakeholder involvement.

At the end of the activities, the results were returned with a report to the stakeholders and managers involved, shared with the Group’s top management and explained to the members of the Ethics and Sustainability and Control and Risk Committees in joint session with the members of the Board of Statutory Auditors.
The in-depth analysis confirmed the validity of the previously defined materiality matrix, which therefore represents the reference up to the next round of analysis, and the “prioritisation” (of low, medium and high importance) of the 19 “material” issues of an economic, social and environmental governance, while also being consistent with the strategic sustainability planning of the Group. In particular, 16 topics are located in the high significance area (score 68-100) and 3 in the medium significance area (score 33-67) (see Chart no. 1).
Ahead of the new round of analysis scheduled for 2022, Acea, in 2021, carried out a project aimed at defining and sharing with the Group companies an evolution of the materiality analysis process. In particular, an intragroup working group was set up, which retraced the procedures and objectives of each phase of the process, reconsidered the functions and methods of use of the support tools and shared the expected changes in context around the issue, especially in light of the new GRI “Universal Standards” published in October 2021. The project, through an inclusive approach, intended to lay the groundwork for enhancing the process’s ability to intercept and represent the Group’s relevant topics, identifying, in a coordinated and more consistent manner, the specific needs of the Operating Companies and their stakeholders.

Chart no. 1 – Relevant topics for the company and its stakeholders: Acea materiality matrix – 2021

Besides being a strategic reference, the “Acea Materiality Matrix” is necessary to identify which aspects to include in greater or lesser detail depending on the results of prioritisation and to select the indicators required by the adopted standards.

To prepare the Sustainability Report in accordance with the GRI Standards: Comprehensive option, it is necessary to illustrate performance according to:

• “Universal Standards”, which include the reporting principles (GRI 101: Reporting principles) and the 56 general standards (GRI 102: General information);
• the “Specific Standards” referring to the economic, environmental and social dimension (GRI 200: Economic, GRI 300: Environmental, GRI 400: Social) considered to be material (“material topics”) and related indicators selected from among the 34 topics envisaged in the specific standards;
• the management approach (GRI 103: Management approach) for each of the specific topics considered material.

In order to select GRI Material Topic-Specific Standards, consideration is given to13 their correlation with Acea’s Materiality Matrix and the meaning thereof conferred by international standards, in some cases tracing them back to the corporate context and, in others, establishing their non-applicability¹⁴.
Following the assessments described above, 26 Specific Standards¹⁵ were identified out of a total of 34, as consistent with Acea material topics of high significance (see Table no. 1). Furthermore, among all the indicators envisaged in the Specific Standards considered as “material”, only 3 were considered not applicable and excluded from the analysis¹⁶.
Only one Acea material topic of high significance is not correlated to the Specific Standards, this being the Consolidation of elements of sustainability in corporate governance, which however, is fully consistent with the general standards dedicated to aspects of governance (GRI 102: General information).
Lastly, also regarding Acea material topics of medium significance present in the report on a less descriptive basis, consistencies were found, albeit not highlighted in the table, with both the material specific Standards and the standards of the General information.

Table no. 1 – Consistency with GRI Material Topic-Specific Standards and Acea material topics of high significance

NB: the economic, environmental, and social GRI Topic-Specific Standards shown in the table are only those deemed material. When indicators are placed in brackets next to a GRI topic this means that only the indicators shown in the table apply, or, where not specified, all the indicators related to the topic apply (also see the GRI Content Index). For “Acea material topics” as identified in the table by a number, reference should be made to the figure showing the materiality matrix (Chart no. 1).

The principle of materiality or significance is also applied to the definition of the “report scope”, as envisaged both by the GRI Standards and by Legislative Decree no. 254/2016. The latter, indeed, under art. 4, states: “To an extent necessary for ensuring an understanding of the group’s business, its performance, results and the impact it produces, the consolidated declaration includes data about the parent company, its fully consolidated subsidiary companies and covers the topics pursuant to article 3, paragraph 1”.

The qualitative and quantitative criteria necessary to identify the companies that ensure an understanding of the Group’s business, performance, results and the impact it produces have been revisited and updated, verifying their adequacy. Qualitative criteria highlight the significance of the role carried out by the companies for the Group’s qualifying business (namely, companies carrying out a relevant and current role in the main businesses, or due to the services they provide, and in implementation of the industrial and sustainability plans) and territoriality (namely, the operations in the geographic area in which almost all of the turnover is generated, the majority of the stakeholders are located and a large part of the managed assets are located). Quantitative criteria concern, for all companies included according to the qualitative criteria, correspondence to a minimum value over 90% of the entire scope of consolidation with reference to specific economic data (turnover, CapEx and OpEx) and socio-economic data¹⁷ (customers and CO2 emissions). In-depth analyses were also carried out on the water business, given its increasing strategic and environmental importance, verifying the sector’s coverage on relevant data (drinking water supplied, waste water treated, waste processed), noting, again in this case, minimum coverage values of 89%.

Compared to the companies included in the scope of consolidation of the Parent Company in 2021 (see Table no. 2) the analysis led to a proposal of scope, initially shared with Top Management, the Board of Statutory Auditors and the relevant board committees. After further verification of the data, the scope was defined and, having heard the opinion of the Head of the Legal and Corporate Affairs Department and the CFO, was shared with the Chief Executive Officer and the Chairperson and finally explained to the Ethics and Sustainability and Control and Risk Committees, in the presence of the supervisory body.

In light of the factors set out above, the scope for the Acea Consolidated Non-Financial Statement (NFS) 2021, starting with that of the NFS 2020 whose Companies are all reconfirmed, allows new Companies to enter the Environment sector: Bio Ecologia Srl, merged by incorporation into Acea Ambiente in 2021, Berg SpA, both operating in the chemical/physical and biological treatment of liquid waste, and Demap Srl operating in the recovery, selection and recycling of plastic packaging and plastic/metal from municipal separate collection; as well as other PV Companies¹⁸:  Acea Solar, Fergas Solar, JB Solar Srl, M2D Srl, PSL Srl, Solarplant Srl, Acea Green Srl, Acea Renewable Srl¹⁹, see Table no. 3.

Companies included in the Parent Company’s full consolidation area (2021)

Table no. 3 – Scope of the Acea Group Consolidated Non-Financial Statement for 2021 (pursuant to Legislative Decree no. 254/2016 and the GRI Standards)

In May 2021, the company Bio Ecologia Srl was merged by incorporation into Acea Ambiente.
NOTE: for Berg, Demap and for companies with PV plants, mainly environmental data will be reported.

The scope of the Acea Group’s 2021 Sustainability Report, albeit wider, guarantees continuity and comparability with the year before, as well as coverage of the companies that ensure full understanding of the Group’s activities and most significant sustainability performance.
Lastly, in compliance with the principle of completeness required under GRI Standards, the 2021 Sustainability Report includes qualitative and quantitative information regarding corporate and environmental matters of certain companies that are not included within the scope of the Consolidated Non-Financial Statement. Specifically, this concerns foreign activities and the following companies operating in the water area: Acque, Publiacqua and Umbra Acque, which were included in some Group data and described in a dedicated chapter (Water companies data sheets and overseas activities), giving clear evidence of their individual contribution.

DOCUMENT STRUCTURE AND DISSEMINATION

The 2021 Sustainability Report, in line with previous years, is divided into three main sections: Corporate identity – which also integrates the information required by Regulation 852/2020 – Relations with the stakeholders and Relations with the environment, supplemented by the Environmental Budget. The latter comprises about 500 items and parameters monitored which quantify the physical flows generated by the activities: the products, factors used (resources), outbound outputs (rejects and emissions) and some performance indicators. References to the main economic-financial data and corporate governance are consistent with those given in the Consolidated Report and the Corporate Governance Report and which may derive from the latter.
The published data and information are provided by the Industrial Areas, Companies and responsible Functions (data owner), they are processed – and possibly reclassified in compliance with the reference Standards – by the internal workgroup which draws up the document and then submitted it once again to the Areas/ Companies/ Functions responsible for final validation, formalized by the issuing of a specific certificate.
Downstream of the audit activities by the appointed independent auditor, the report is distributed by means of storage on SDIR 1Info, publication on the institutional website – www.gruppo.acea.it – and the company intranet, as well as the other formats provided under Legislative Decree no. 254/2016 and the implementing Consob Regulation (implemented by Resolution no. 20267 of 19 January 2018). It is also distributed together with the consolidated financial statements to the shareholders during the annual Shareholders’ Meeting upon closure of the financial year.

For further information about the Sustainability Report and its contents, it is possible to write to the following email address: RSI@aceaspa.it.

Irene Mercadante

SUSTAINABILITY PLANNING & REPORTING UNIT

Stefano Raffaello Songini

INVESTOR RELATIONS & SUSTAINABILITY DEPARTMENT

¹After also following other guidance, Acea opted for compliance with the guidelines issued by the Global Reporting Initiative (GRI), applying them starting with the 2002 Sustainability Report with the highest level of “compliance” possible and following its progressive development.
²Article 1, paragraph 1073 of the 2019 Budget Law introduced an amendment to Legislative Decree no. 254/2016, art. 3, paragraph 1, letter c, also prescribing the illustration of the methods for managing the main risks.
³Legislative Decree no. 254/2016 as amended, in particular articles 2, 3, paragraphs 1, 4.
⁴As part of the Action Plan on Sustainable Finance adopted in March 2018 by the European Commission to steer the capital market towards a more sustainable development model, in June 2020, Regulation 852/2020 was approved “relating to the establishment of a framework that favours sustainable investments", which entered into force on 12 July 2020.
⁵Article 1 of the Regulation - Object and scope of application - states: "This regulation establishes the criteria for determining whether an economic activity can be considered environmentally sustainable, in order to identify the degree of environmental sustainability of an investment". The economic activities that the Regulation identifies are considered for their substantial contribution to achieving 6 environmental objectives: climate change mitigation; adaptation to climate change; sustainable use and protection of water and marine resources; transition to the circular economy, also with reference to waste reduction and recycling; pollution prevention and control; protection of biodiversity and the health of eco-systems. The Regulation has currently governed, through the adoption of Delegated Acts, the 2 objectives on climate change. Activities that potentially contribute to achieving the environmental objectives are defined as “eligible” for the taxonomy; on the other hand, only the activities that meet the technical screening criteria indicated by the Regulations are defined as “aligned” with the taxonomy, making a substantial contribution towards achieving the objectives.
⁶Regulation 852/2020, art. 8, paragraphs 1 and 2, reads: “Any company subject to the requirement to publish information of a non-financial nature (...) includes (...) in the consolidated statement of a non-financial nature, information on how and to what extent the company's activities are associated with economic activities considered environmentally sustainable pursuant to articles 3 and 9 of this regulation ". (…) “In particular, non-financial companies communicate the following: a) the share of their turnover deriving from products or services associated with economic activities considered environmentally sustainable pursuant to articles 3 and 9; and b) the share of their capital grants and the share of operating expenditure relating to assets or processes associated with economic activities considered environmentally sustainable pursuant to articles 3 and 9". In July 2021, the Commission adopted the delegated act on article 8 of the Regulation "intended to specify the content, methodology and presentation of information that must be communicated by companies" (Disclosure Delegated Act).
⁷In 2016, when the previous version of the Guidelines (GRI-G4) were superseded and further developed, the Global Reporting Initiative (GRI) published the GRI Standards - Consolidated set of GRI Sustainability reporting standards 2016. Since then, GRI has, every year, also issued updates to individual standards, without having to re-edit the entire set, of which it indicates the mandatory adoption deadlines for reporting. The Italian translation of the GRI Standards (Raccolta consolidata dei GRI Sustainability Reporting Standards 2019) is available on the website www.globalreporting.org,while the English version is already in the 2021 edition, with the latest revisions introduced. 8 Legislative Decree no. 254/2016, art. 4 and art. 5, paragraph 3 b.
⁸Legislative Decree no. 254/2016, art. 4 and art. 5, paragraph 3 b.
⁹Article 10 of the Disclosure Delegated Act also governs the entry into force of the Regulation: “From 1 January 2022 until 31 December 2022, non-financial companies should only report the share of economic activities eligible for the taxonomy and not eligible for the taxonomy within their turnover, their capital grants and their total operating expenditure and the qualitative information referred to in section 1.2. of Annex I relevant to the information in question". The information regarding the activities effectively “aligned with the taxonomy” is, however, postponed until 1 January 2023.
¹⁰Legislative Decree no. 254/2016, under art. 3, paragraph 10, provides that: “The subject entitled to perform the statutory audit of the Sustainability Report (…) or another subject entitled to carry out the statutory audit as specifically designated” issues “a certification concerning the compliance of the provided information with the requirements under this legislative decree and the principles, methods and procedures provided under paragraph 3”. Namely principles and methodologies: “provided by the reporting standard used as reference (…)”.
¹¹In particular, the in-depth study of the changes in the context of the health crisis focused on aspects that contribute to the more articulated definition of the following 12 material topics: Occupational health and safety; sustainability and circularity along the supply chain; strategic approach to stakeholder relations and the community; customer focus; involvement of the territory and development of skills; protection of territory and biodiversity; decarbonisation and adaptation to climate change; consolidation of sustainability elements in corporate governance; company well-being, diversity and inclusion; integrated risk management; responsible finance, and innovation as a transversal element.
¹²Through the multi-stakeholder focus group, carried out remotely, and some one-to-one interviews, a total of 48 people were involved, including subjects already engaged in the previous round of materiality analysis, to give continuity to the comparison, and others particularly significant for the purposes of in-depth analysis (organisations of social importance, trade unions etc.), representing 11 stakeholder categories.
¹³It is important to consider that both the specific GRI Standards – each of which includes a description of the management method and a number of indicators – and Acea material topics both refer to contents that are far more complex and detailed than their brief name may suggest which, given their level of detail, cannot be presented at this time. See the GRI Standards on the website www.globalreporting.org.
¹⁴By way of example and not limited to, this has led to the exclusion of the Specific Standards related to Market Presence and Human Rights which, according to the meaning given to them by the GRI, are more pertinent to multinational enterprises and not suited to the reality of the Group’s most significant operations.
¹⁵In 2020, with the obligation to apply it to the 2021 financial year, the specific GRI 306 standard “Waste 2020” was updated, which will be reported by superseding the previous version (“Effluents and Waste 2016”).
¹⁶See the GRI Content Index.
¹⁷The verification of coverage on the socio-environmental data of the Group and of the sector was carried out on data from 31/12/2020, the most up-to-date available at the time of defining the scope.

¹⁸It should be noted that at the end of December 2021, Acea Produzione signed an agreement with Equitix aimed at the sale of a majority stake in the newco that will manage the photovoltaic assets.

¹⁹In light of the applied criteria, the following companies are outside of the scope of the 2021 Consolidated Non-Financial Statement: Iseco, Deco, AS Recycling, Ecologica Sangro, Meg, Ferrocart, Cavallari, Cesap Vendita Gas, Umbria Energy, Acea Energy Management, Agile Academy, Acea Dominicana, Aguas de San Pedro, Acea International, Acea Peru, Consorcio Acea-Acea Dominicana, Consorcio Servicios Sur, Consorcio Agua Azul, Consorcio Acea, Consorcio Acea Lima Norte, Acque Blu Arno Basso, Acque Blu Fiorentine, Acea Molise, Ombrone, Sarnese Vesuviano, Umbriadue Servizi Idrici, Adistribuzionegas, Servizi Idrici Integrati, Notaresco Gas, Acea Liquidation and Litigation, SIMAM, Technologies for Water Services.