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 Unit¹²² in Acea Elabori, is the Group structure of reference, 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 Ambiente¹²³), ensuring compliance with the highest standards and with regulations¹²⁴. 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 contracts¹²⁵.
All supported by the use of computer systems, the activities are distinguished into works requiring Safety Coordination during the execution phase (Coordinators appointed as needed by the Works Director) or during the design phase and works with random or on-demand safety inspections.
For the interventions carried out during the year the following people were involved:

• 21 Safety coordinators in the execution and design phase, assigned to specific worksites as needed;
• 18 Safety inspectors, who assessed and verified the safety standard through random inspections;
• 4 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 2022, the Site Safety Unit:

• carried out the activities in support of the technical and professional audits of 1,045 companies (45% of contractors and 55% of subcontractors and operated equipment rentals¹²⁶), about 29% more than in 2021 (812 companies);
• activated Safety Coordination in the Execution phase for 411 tasks and carried out Safety Coordination in the Design phase for 73 tasks;
• carried out 14,724 on-site safety¹²⁷ inspections.

During the audit of the staff of contractor and subcontractor companies, the Site Safety Unit also ascertains that the Employer has provided basic health and safety training and, where applicable, specific training.
The occupational health and safety audits conducted during the inspections in 2022 made it possible to detect a total of 1,686 non-conformities¹²⁸ (of which 1,178 of minor importance, 380 of medium importance and 139 of major importance), confirming the trend detected in the last three-year period of a clear prevalence of the weighting as a percentage of minor non-conformities (70% in 2022) and the constant decrease in the weighting as a percentage of major non-conformities (8% in 2022) of the total non-conformities found¹²⁹.

The Acea Elabori Site Safety Unit and all Group Companies that independently manage site audits¹³⁰, 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 and informing them of the standards adopted. 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 coordination meetings.
As an example, AdF, which conducts its own inspections, took steps to carry out coordination meetings with the contracting companies on the correct procedures to be followed in terms of health and safety, and carried out 2 training/coaching courses aimed at contractor staff, for a total of 40 hours of training on the correct use of systems for the recovery in emergencies for staff operating in the workplace, through the preparation of specific anchor lines for each type of plant.

Acea Elabori, due to the construction activities that it carries out as a contractor, has adopted an innovative control model that provides for interaction between a specifically established role (the High Vigilance Monitoring Officer (REMAV)), the Delegated Executives, the Employer and the Safety Officers, with the support of a dedicated app (Vigilanza 4.0), developed in collaboration with La Sapienza University in Rome. The REMAV performs monitoring for the verification of compliance with prevention and protection measures on site, using checklists that consider general behaviour, safe work instructions, and requirements of conformity of the work environments and sites. The outcomes of the inspections, which are tracked and sent via the app to the delegated executives and the employers, make it possible to assess the overall safety level and, where necessary, to identify improvement prevention and protection measures for workers and to intervene to ensure their implementation. In 2022, 10 high vigilance monitoring sessions were carried out, during which no critical issues were found.

In Acea, moreover, the Training Camp is still operational. The space, dedicated to the training and education of staff on occupational health and safety and technical/specialist subjects, is used for both internal training (see also chapter Staff) and to explain certain working methods to contractor staff; training and coaching are related to specific activities such as, for example, climbing/ descending medium and low voltage power line poles, access to underground confined spaces, and, above all, securing the plants during works, which represents the activity with the greatest consequences on safety.
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"¹³¹ which requires the adoption of technical, organisational 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 Prevention 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 2 increased the activities assigned to the Supervision and Inspection Unit, and 2,467 inspections were conducted during the year (1,118 in 2021) at contractors, with no serious critical issues detected. Acea Ato 5 also stepped up its audit activities and carried out 544 inspections (270 in 2021) through its Internal Security Team (Risk & Compliance and Security Unit), to audit suppliers on occupational health and safety, environmental issues and quality of the work carried out. The findings of the inspection visits were shared with the companies concerned, to suitably raise their awareness of the issues detected by the inspection, including through specific meetings.
This also applies to non-centrally managed companies: Through its Technical Management Systems Unit, in 2022 AdF increased the audits to verify safety conditions and compliance with the Covid-19 regulations, performing 503 audits (223 in 2021) and detecting 28 deviations concerning lack of documentation, but no cases of procedural problems and/or lack of PPE; Gori conducted 2,953 on-site health and safety audits and Gesesa carried out 31 inspections at contractors’ sites to check compliance with safety regulations and to identify and resolve anomalies.

To improve oversight of health and safety along the value chain and to make such topic a distinctive trait of the Group, the Investor Relations & Sustainability Department and the Occupational Safety Unit of the Parent Company, in synergy with the parent company Units and the operating companies handling relations with suppliers in various capacities, launched in 2020 and subsequently implemented a project entitled “Sustainability and safety, a virtuous pair”. The project aims to actively involve contractors working with Acea, urging them to conduct training sessions and in particular, improve the process of collecting and reporting accident data. For this purpose, an event was organised in 2022 to raise awareness about safety in the workplace among the Group’s main suppliers (see info box).

In line with the previous two-year period, in 2022 the operating companies of the Group identified 411 suppliers of the main works and services active during the year and asked them to complete the data collection survey on access occurring during the year on Acea contracts. The questionnaire received a response from 225 contractors, or 55% of the panel selected. An analysis of the survey data found that there were a total of 28 accidents in 2022 involving contractor staff employed on Acea contracts (around 400 people), divided in 24 occupational accidents (of which 21 with minor injuries) and 4 non-occupational accidents (all with minor injuries). Additionally, there were no fatal accidents during the year, nor were there any occupational diseases involving contractor staff. The main causes of accidents are due to stumbling, bumping, slipping, cuts, crushing, and road accidents. The frequency index¹³² of total accidents, measured by the survey, is 3.23 and the severity index is 0.14.
With a view to continuous improvement, period analyses were conducted to define additional actions to be taken in order to standardise the process and successfully involve an increasing number of Group suppliers.

INVOLVEMENT OF SUPPLIERS ALSO IN OTHER SENSITIVE ISSUES

Some Group companies carry out activities for engagement and awareness of suppliers with respect to 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 2022, Areti involved suppliers on the use of the new licence portal – training 9 contractor operators – and continued training on “Hammer Meter Readers - Time Meters Received”, involving 15 contractor operators, for a total of 20 hours of training. The initiatives were held on the Teams platform, with contributions from 5 internal teachers.
Every year, Deco engages with 5 suppliers on aspects envisaged by the standard SA 8000, using a dedicated questionnaire, which also includes supplier perception of the management of those same aspects by Deco, with the aim of gradually raising their awareness of social responsibility aspects, associated in particular with the protection of workers’ rights.
Finally, every year, Acea Energia monitors the quality of the sales service provided by the door-to-door and/or telemarketing agencies 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 particular, in 2022 Acea Energia carried out a training programme for a total of 401 hours, of which 212 hours were delivered to 336 door-to-door sellers, for a total of 34 days, and 189 hours delivered to 91 telemarketing agency workers (front end, back office and supervisors).

122 In December 2022, the Site Safety Unit was renamed the Safety Unit.
123 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.
124 Legislative Decree no. 81/08 “Consolidated Act on Safety”, as amended.
125 Such as electrical or electromechanical maintenance work carried out on plants, meter changes, road repairs, video-inspections and sewerage pumping, etc.
126 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.
127 The number includes visits for all types of contracts, both main ones and “minor ones”.
128 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.
129 In 2020, over 14,904 inspections, 1,457 non-conformities were recorded (of which 962, or 66%, of minor importance; 337 of medium importance, and 158, or 11%, of major importance). In 2021, over 15,444 inspections, 1,023 non-conformities were recorded (of which 677, or 66%, of minor importance; 251 of medium importance, and 95, or 9%, of major importance).
130 Note that the company Deco, included in the NFS scope since 2022, had no site activities in the year in question.
131 The Shared Protocol regulating measures to combat and contain the spread of the Covid-19 virus in work places 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.
132 The frequency index of accidents is calculated using the following formula: [(number of accidents/total hours worked in the period) x 1,000,000] with accident meaning a work-related incident that prevents the employee of the contractor from returning to work during the day on which the accident occurred and/or on the following day/work shift scheduled.