Procurement Policies

The Purchasing and Logistics Department of the Parent Company defines policies and guidelines and manages, as a service, the procurement of goods, services and works required by the Departments of the Holding Company and the main Group Companies. To perform its duties, it values the technical skills of the buyers, handles the requests of “internal customers” (Functions/ Companies in the Group) and develops a transparent relationship with suppliers.
In 2022, the Purchasing and Logistics Department also oversaw the flow of materials, logistics and warehouses of the Group, managing the operations of the central depot and most of the territorial depots of Areti and Acea Ato 2, at the service of the operational personnel dispatched to the territory. It also supplied materials for scheduled and urgent works, interacting with most of the companies contracted by the two largest operating companies. At the logistics centre of Santa Palomba, verification of water meters and activities at the low-voltage laboratory of Areti (Engineering and Testing Unit) were carried out. From November 2022, with a view to flow optimisation, all activities carried out by the logistics centre of Santa Palomba were taken over directly by the operating companies.

DEALINGS WITH SUPPLIERS AND PROCUREMENT MANAGEMENT

The Acea Code of Ethics, updated at the end of 2022, recalls the reference principles¹⁰⁷ that should guide relations between Acea, as a contracting authority, and its suppliers (contractors and subcontractors), “on the basis of the principle of mutual benefit and cooperation that underlies such relations”:

• equal opportunities for each supplier;
• conduct based on mutual loyalty, transparency and collaboration;
• compliance with rules and procedures, including verification processes to identify potential risks to reputation and/or corruption;
• protection, by the supplier or sub-supplier, of the human rights of their employees (decent working conditions, protection of health and safety) and safeguarding of the environment (protection of ecosystems and biodiversity, rational use of natural resources, minimisation of waste, energy saving, etc.), respect for privacy, and guarantee of the quality of goods, services, and performance.

Suppliers issue a declaration of acceptance and commitment to comply with the provisions contained in the Code of Ethics, which constitutes an element of the contractual relationship. Any violation of the principles and criteria of conduct envisaged by the Code of Ethics, revealed by audits, will authorise Acea to take appropriate measures.

With a specific focus on topics of social importance along the supply chain, for many years now, Acea has shared a Water Contracts Protocol with the trade unions involved in the water contracts and contractors, which concerns aspects such as employment protection (fair application of the social clause on the subject of contract changes), combating irregular forms of work or work that does not comply with the applied national collective bargaining agreements, health and safety at work and compliance with contractual regulations.

Acea mainly uses tenders¹⁰⁸ to select suppliers, adopting criteria of transparency: in 2022, 60% of procurement, managed at a centralised level¹⁰⁹, was awarded through a tender procedure.
For centrally-managed Group companies, the Purchases and Logistics Function has published on the website¹¹⁰, in the “Supplier” Area, the documentation relating to purchases regulated by the Public Procurement Code¹¹¹. Operators who are interested in participating in tenders can freely access the portal of the Qualification Systems and the portal for participation in online calls for tenders. The web portal is based on the same operational procedure as traditional tenders: it checks the adequacy of the supporting document, acknowledges possession of the eligibility requirements, discloses the bids and displays the ranking. The companies operating in the water segment, which manage their own procurement process, also carry out tenders electronically, while Deco does not use tenders, rather it follows a procedure that involves the qualification of suppliers, market surveys accompanied by several offers from qualified suppliers on the company’s vendor list and the issue of purchase orders.

The Administration, Finance and Control Function monitors supplier payment times: in 2022, for the companies in the scope¹¹², the average payment delay was 34.4 days¹¹³ (a slight increase compared to the 27.3 days recorded in 2021); the same figure, weighted in light of the amounts, falls to 26 days¹¹⁴. This was the case for 34% of the value of payments made in the year (compared to 26% in 2021), while the percentage of amounts paid on time was 66% (74% in 2021).

SUSTAINABILITY CRITERIA IN TENDERS

In 2022, for the Group Companies under analysis, over 7,830 orders/contracts were processed, for a total of more than 3,780 suppliers involved (please see the Order Analysis below).
Within the centralised management of tenders, which covers around 82% of the total value of procurement within the 2022 scope of consolidation, amounting to 3,115 orders/contracts managed and 1,664 suppliers involved, as a requirement for participation, for 100% of tenders for the award of works contracts and for numerous contracts for the purchase of goods and services, Acea requires UNI EN ISO 9001 quality management system and the UNI EN ISO 45001:2018 occupational health and safety certifications. Furthermore, for the 149 product categories subject to tender and relating to the purchase of goods, services or works, evaluation criteria of the technical offer based on the following systems are included during the tender process, when applicable: UNI EN ISO 14001 – UNI CEI EN ISO 50001 – UNI ISO 37001 – FSC Chain of Custody.
These requirements were added to potentially eligible calls for tenders, awarded on the basis of the most economically advantageous offer. In 2022, 98% of the 112 potentially eligible contracts concluded¹¹⁶ were awarded on the basis of sustainability criteria. Specifically, for some tenders for water, electrical and civil engineering works awarded with the method indicated, rewarding criteria were also included regarding the use of ecological vehicles, additional training of workers in the area of safety, and the possession of certifications (where not already participation requirements) in the following areas: environment, health/safety, energy efficiency, the use of environmentally sustainable materials and anti-corruption. Finally, the technical specifications for procurement by Group Companies include sustainability criteria concerning materials, such as recycling, re-usage and the repairability index.

Acea will include, where relevant, the normative references to the Minimum Environmental Criteria (CAM) adopted by Decree of the Ministry for the Environment, Land and Sea Binding parameters or bonuses in tender documents¹¹⁷. In particular, the reference to CAMS was applied in tenders related to the rental services for generators, ordinary and extraordinary maintenance contracts for lifting systems, the purchase of computers and printer cartridges, in addition to categories such as paper, office furnishings, public lighting – supply and design of LED lighting fixtures – work clothes, cleaning of buildings, maintenance of green areas and vehicles.

107 The Acea Code of Ethics, approved by the Board of Directors in its latest version updated in November 2022, dedicates specific space, and numerous other references in the text, to Relations with Suppliers. The Code is shared on the company’s intranet and is available online at www.gruppo.acea.it, in the Governance section. Particular attention is paid to social safeguards in higher-risk contexts: “In supply contracts with suppliers from at-risk countries, defined as such by recognised organizations, contractual clauses have been introduced that involve compliance of the supplier with specific social obligations (e.g. measures that guarantee employees respect for their fundamental rights, the principles of equal treatment and non-discrimination, protection against child labour, the fight against forced labour, guaranteed minimum wage, limited work hours, etc.).”
108 Acea issues tender procedures for the procurement of works, goods and services in compliance with current legislation (Legislative Decree no. 50/2016), with reference to the ordinary and special water and energy sectors. In particular, for tenders in special areas involving amounts below the EU threshold, Acea applies Internal Regulations consistent with the principles of the EU Treaty for the protection of competition. Finally, for tenders that do not fall within the scope of application of the Code on public contracts (so- called “extraneous or private law”), selection procedures are used which comply with the principles of free competition, equal treatment, non-discrimination, transparency and proportionality.
109 Equal to 82% of the total volumes of the companies in the NFS scope, including those not managed centrally.
110 In compliance with the requirements of the National Anti-Corruption Authority (ANAC) and the so-called “Anti-Corruption Law” (Law 190/2012).
111 Legislative Decree no. 50 of 18 April 2016 and subsequent amendments and additions. Public Contracts Code.
112 The 2022 analysis produced by Administration, Finance and Control also included the companies Gori, AdF and Gesesa, which have provided data even through they are not managed at the centralised level. It was not possible to include Deco for this first year of entry in the NFS scope. The companies Berg, Demap and two photovoltaic companies were also left out of the analysis due to the low share of the costs incurred.
113 The calculation of the figure is a simple average of the difference between the due date of the invoice in the system and the date of actual payment.
114 The calculation of the figure is the result of the average of the difference between the expiry date of the bill in the system and the date of actual payment weighted according to the amount of the bills.
115 The figures for the 2022 dispute refer to all the Companies within the NFS scope (see Disclosing Sustainability: Methodological Note).
116 Consultancy activities are excluded from this calculation.
117 From www.mite.gov.it: “Minimum Environmental Criteria (CAM) are the environmental requirements defined for the various phases of the purchasing process, aimed at identifying the best design solution, product or service from an environmental point of view throughout the life cycle, taking into account market availability. [...] Their systematic and uniform application makes it possible to spread environmental technologies and environmentally preferable products”.