Health and safety along the supply chain: awareness raising and audits

The Group is extremely attentive to occupational safety, which it also applies across the supply chain. In particular, Acea has tasked organisational structures, in the parent company and the operating companies, with activities aimed at monitoring and more effectively controlling how suppliers manage safety.

The Site Safety Unit in Acea Elabori, is the Group structure of ref- erence, for the management of the safety of works and services contracted out by Group companies (mainly Acea Ato 2, Acea Ato 5, Areti and Acea Ambiente⁹⁷), ensuring compliance with the high- est standards and with regulations⁹⁸. To this end:

• Support and assistance to the Works Manager and general Safety Coordination;
• Coordination of safety in the design phase and during execution at specific sites;
• Safety inspections for works and services that do not require coordination during execution;
• Services ancillary to safety inspection

Site safety inspections are mainly related to the main works that are the subject of maintenance contracts for networks and services in the water and electricity sectors, but also concern minor contracts⁹⁹.

Activities are distinguished into works requiring Safety Coordination during the Execution phase (Coordinators appointed as need- ed by the Works Director) and works with random safety inspections.

To facilitate the operation of the organisational structure, inspec- tion activities are managed with computerised systems that issue work orders to the security inspectors to check ratings that exceed a certain threshold. The system also provides support for technical and professional suitability checks and the engagement of a Safety Coordinator at the execution or design stage, where required.

For the interventions carried out during the year the following peo- ple were involved:

• 21 Safety coordinators in the execution and design phase, as- signed to specific worksites as needed;
• 19 Safety inspectors, who assessed and verified the safety standard through random inspections;
• 5 Planners, who followed the planning and dispatching of the safety inspections to the sites of the contractors;
• 10 Technical Support resources, who managed the technical and professional audits of the companies engaged in the contracts.

In particular, in 2021, the Site Safety Unit:

• carried out the activities in support of the technical and profes- sional audits of 812 companies (45% of contractors and 55% of subcontractors and operated equipment rentals¹⁰⁰), about 32% more than in 2020 (617 companies);
• activated Safety Coordination in the Execution phase for 492 tasks and carried out Safety Coordination in the Design phase for 54 tasks;
• conducted 15,444 on-site safety¹⁰¹ inspections (+3.6% com- pared to 14,904 inspections in 2020).

During the audit of the staff of contractor and subcontractor com- panies, the Site Safety Unit also ascertains that the Employer has provided basic health and safety training and, where applicable, specific training.

After the occupational health and safety audits conducted during inspections by the Site Safety Unit inspections, a total of a total of 1,023 non-conformities¹⁰² (of which 677 were of minor impor- tance, 251 of medium importance and 95 were of major impor- tance), confirming, despite the constant increase in inspection vis- its, the considerably decreasing trend recorded over the last three years¹⁰³ both in the absolute number of non-conformities detected and, above all, in the number of non-conformities in the "major" category.

The Acea Elabori Site Safety Unit and all Group Companies that independently manage site audits, either in whole or in part, also contribute to protecting the safety of contractors working on the construction sites, by meeting the employers of the companies before the start of work to inform them of the standards adopt- ed. In fact, all contractors are informed by the relevant Units in charge of managing the contract, the Works Management and the relevant Safety Coordinators for the Execution of the Works (the latter where provided for by current legislation), through the DUVRI (Single Risk Assessment Document, to be attached to the contract), the SCP (Safety and Coordination Plan) or specific co- ordination meetings.

As an example, AdF which conducts its own inspections, during 2021 took steps to carry out coordination meetings with the con- tracting companies given the prolonged health emergency situa- tion caused by Covid-19, reiterating the correct procedures to be implemented, also in view of the repeated updates to the relevant legislation and the need to keep site procedures and documents constantly in line with national and regional regulations.

In Acea, moreover, the Training Camp is a space dedicated to the training and education of staff on occupational health and safety. It is used for both internal training (see also Staff section) and for training of contractors in relation to specific activities (such as, for example, climbing/descending medium and low voltage power line poles, access to underground confined spaces, etc.), depending on the contracts awarded during the year.

In 2021, due to the continuation and development of the health emergency, the activities of the Coronavirus Prevention Commit- tee set up in 2020 by the Parent Company, from the very early stages of the Covid-19 emergency, constantly coordinates with Group companies and with contractors (see also Staff - Health and safety at work). In particular, contractors have been trained to comply with the "Shared protocol for the regulation of measures for the prevention and containment of the spread of the Covid-19 virus in workplaces"¹⁰⁴ which requires the adoption of technical, or- ganisational and procedural measures (safety measures to prevent contagion), defined on the basis of a precautionary approach, for the management of health emergencies both in the workplace and with regard to the procurement of goods and supplies, extending also to the site owners and all subcontractors and sub-suppliers present; an operational instruction containing the Covid-19 Pre- vention Guidelines was provided to contractors.

The Companies that carried out site inspections during the year, above and beyond the work of the Site Safety Unit, took the Parent Company’s guidelines into consideration. In particular, Acea Ato 2increased the activities assigned to the Supervision and Inspection Unit, and1,118 inspections were conducted during the year. In ad- dition, in June and July 2021, the Company dedicated two days to conducting unannounced field surveillance activities on safety and environmental issues, respectively, and has decided to repeat both initiatives periodically. Acea Ato 5 also stepped up its audit activities and carried out 270 inspections through its Internal Security Team (Risk & Compliance and Security Unit), to audit suppliers on occupational health and safety, environmental issues and the quality of the work carried out, as well as compliance with prevention procedures for the dissemination of Covid-19, including possession of Green Certification (also known as the “Green Pass”) by the workers. The findings of the inspection visits were shared with the companies concerned, to raise their awareness on the issues detected by the inspection.

This also applies to non-centrally managed companies: Through its Technical Management Systems Unit, AdF conducted 223 audits to verify safety conditions and compliance with the Covid-19 reg- ulations, detecting 7 deviations concerning lack of documentation and no cases of procedural problems and/or lack of PPE; GORI conducted 2,600 on site health and safety audits and Gesesa car- ried out 24 inspections at contractors' sites to check compliance with safety regulations and to identify and resolve anomalies.

The Parent Company’s Occupational Safety Unit in turn organised 9 meetings with technical directors and supervisors of contractors under contract with Acea SpA, during which it stressed the impor- tance of accident prevention.

In 2020, the Investor Relations & Sustainability Department and the Occupational Safety Unit of the Parent Company, in syner- gy with the parent company Units and the operating companies handling relations with suppliers in various capacities launched a project titled “Sustainability and safety, a virtuous pair”, which was further developed in 2021. The project aims to actively involve con- tractors working with Acea, urging them to conduct training ses- sions and in particular, improve the process of collecting and re- porting accident data. Numerous meetings were held to this end during the year with the RSPPs of the Group companies, who are key players in the process of collecting data from contractors, in order to optimise the process, reach as many companies as possible and analyse increasingly complete data.

After the pilot survey carried out in 2020, to which 81 companies responded, in 2021 all the Companies asked the companies that provided the main services during the year to complete question- naires on the subject of safety in order to ascertain the level of in- ternal control each company has and what accidents have occurred. 225 contractors responded to the survey.

Analysis of the data showed that total of 31 accidents occurred in 2021, broken down into occupational and non-occupational acci- dents. Of these, 25 professional accidents occurred in the year to contractor personnel working on Acea jobs, of which 7 for work-related travel and almost all (21) involving only minor personal injuries.

There were 6 non-occupational accidents, 5 of which involved minor injuries.

The main causes of accidents are due to stumbling, bumping, slip- ping and road accidents. The frequency index of total accidents is 12.44 and the severity index is 0.38. There were no fatal accidents. Lastly, no cases of occupational diseases were recorded for con- tractors’ staff during the year.

With a view to continuous improvement, analyses are under way to identify the actions to be taken in order to standardise the process and involve as many of the Group's suppliers as possible.

INVOLVEMENT OF SUPPLIERS IN OTHER SENSITIVE ISSUES

Some Group companies carry out activities from involvement and awareness of suppliers with respect to other aspects mainly concerning technological developments implemented in operating processes and Group guidelines, to ensure constant alignment and adequate training of partners working on behalf of the Company. In 2021, Areti involved suppliers on the topics of 'mass replacement of 2G measuring units' and 'commercial quality and 2G metering’ providing 40 operators from the contracting companies with a to- tal of 560 hours of training divided into 5 training sessions. In addition, 8 contractor operators in the field of "Hammer meter readers - time meters received 8 hours of training. The initiatives were carried out with the help of the supplier and 8 internal teachers, in full compliance with the anti-Covid-19 provisions for inperson training. The training venues were the Magliana training room and the “Cabin of the Future”, a real electrical cabin specially set up for technical-operational training featuring some equipment and interactive panels.

Finally, every year Acea Energia monitors the quality of the sales service provided by the door-to-door and/or telemarketing agen- cies in the “domestic” and “micro-business” segments of the deregulated market, and in accordance with the Agency Mandate, it trains those who work in the name and on the behalf of Acea so that they can convey adequate information to customers (please also see the chapter on Customers). In 2021, Acea Energia notably carried out a training programme, providing 927 hours of training in total, of which 427 hours were delivered to 551 door-to-door sell- ers, for a total of 63 days, and 500 hours delivered to teleselling agency workers.

97 For Acea Ambiente, Acea Elabori's Construction Site Safety Unit has mainly carried out Safety Coordination during execution (CSE) activities on a smaller number of sites.
98 Legislative Decree no. 81/08 “Consolidated Act on Safety”, as amended.
99 Such as electrical or electromechanical maintenance work carried out on plants, meter changes, road repairs, video-inspections and sewerage pumping, etc.
100 Operated equipment rental is a contract that involves the rental of work equipment and the performance of a specialized operator, essential for the operation/use of the equipment itself.
101 The number includes visits for all types of contracts, both main ones and “minor ones”.
102 For the main contracts, as envisaged in the contract documentation, the results of audits are recorded according to four categories: compliant or non-applicable, minor (generally corrected on the spot), medium and major infractions. The non-conformities are associated with corrective actions and penalties applied by the contracting company on
the basis of the provisions of the tender documentation, and, serious infractions may lead to the suspension of works.
103 In 2019, after approximately 12,400 inspections, 1,741 non-conformities were recorded (1,141 minor, 367 medium and 233 major) and in 2020, after 14,904 inspections, 1,457
non-conformities were recorded (962 minor, 337 medium and 158 major).
104The Shared Protocol regulating measures to combat and contain the spread of the Covid-19 virus in workplaces was signed on 14 March 2020 by the trade unions and employers' organisations in agreement with the Government. It was further supplemented on 24 April 2020 and updated with the Protocol of 6 April 2021, for the duration of the emergency.