Disclosing sustainability: methodological note

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

Acea publishes a report on the Group’s social and environmental performance since 1999, the year when the Parent Company was listed on the stock exchange. The document, prepared annually, is drafted according to International Guidelines¹ and is verified by third parties. 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.

Acea is also subject to the reporting obligations required by the progressive application of Regulation 2020/852⁴ (the “European Taxonomy”), which “establishes the criteria for determining whether an economic activity can be considered environmentally sustainable” and imposes the publication of reporting on the Taxonomy “eligible” and “aligned” activities performed by the company and on the economic quantitative performance indicators (KPIs) – quota of turnover, CapEx and OpEx – attributable to them⁵. In particular, for the third year of application of the Regulation⁶, the disclosure should include the outcomes of the eligibility and alignment analysis of the activities carried out by the Group related to the two climate-related environmental objectives, and eligibility only for the remaining four environmental objectives, including the related economic KPIs; however, Acea established that it would voluntarily anticipate the application of the regulation by also providing for the alignment analysis of the activities performed by the Group related to the four new environmental objectives governed.
This Sustainability Report, for the financial year 2023 has been prepared in accordance with the GRI Standards⁷: and is therefore called Acea Group’s 2023 Sustainability Report (Consolidated Non-Financial Statement pursuant to Legislative Decree no. 254/2016, prepared in compliance with the GRI Standards), taking the form of an autonomous document, as permitted by the aforementioned Legislative Decree⁸ (later in the document, “NFS” or “Sustainability Report” or “Consolidated Non-Financial Statement”). The Consolidated Non-Financial Statement also includes the disclosure envisaged by Regulation 2020/852 and by Commission Delegated Regulations 2021/2178 (supplemented by Commission Delegated Regulation 2023/2486), 2021/2139 (supplemented by Commission Delegation Regulations 2022/1214 and 2023/2485) and 2023/2486. The disclosure will involve the same set of Companies included in the NFS scope, considered to be significant and an adequate representation of the Group pursuant to Legislative Decree no. 254/2016 (see below for the paragraph on Materiality, GRI Standards and scope of reporting). The findings that emerged are reported in the chapter 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 standards⁹; the limited assurance does not concern the information and data relating to the European 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.

MATERIALITY, GRI STANDARDS AND REPORT SCOPE

Acea conducted a materiality analysis cycle in 2022 intended to identify the main economic, governance, social and environmental (so-called “material topics”) topics, linked to the Group’s businesses, and to prioritise them, considering their associated impacts (on business, natural environment, society, and stakeholders themselves), through consultation with stakeholders and managers. The analysis process is repeated every two or three years, or more often when the opportunity arises, and the resulting material topics, therefore also valid for 2023, have strategic value (see chart 1 and table 1).

The analysis was carried out using an updated method, taking into account the changes made to the reporting standards.
In particular, the direct engagement of stakeholders (internal and external) was developed, by increasing their number and introducing an online survey to evaluate ESG topics and the associated impacts, which supplemented focus groups and one-to-one interviews. To identify the ESG aspects with the greatest impact on the Company (performance, results, development, etc.), in addition to acquiring the perspective of managers, the most recurring areas in analyst evaluations were considered and further synergy was developed with the Enterprise Risk Management Unit in analysing critical issues and opportunities presented by the managers. Furthermore, the focus on the impacts associated with the material topics was emphasised and the new criteria for evaluating their relevance were applied: significance, extent of the impacts, remediability/probability, etc.

The materiality analysis conducted in 2022 involved the following stages:

• a document analysis, conducted on around 30 documents (re- lated to the scenario, representative of stakeholder requests, strategic and internal management, etc.), led to the identification of 15 potentially relevant topics and their main areas of impact. These topics were shared with top management and subsequently submitted for evaluation by the Group’s stakeholders and managers;
• identification of the (external and internal) stakeholders to be involved in the analysis using the Group Stakeholder Register, carried out in collaboration with a large number of structures at the holding and the operating companies, which led to a focus on the following stakeholder categories: institutions, peers and competitors, business partners, associations, scientific community, suppliers, customers and consumer associations, employees, trade unions, the media, new generations;
• the direct engagement of (external and internal) stakeholders, carried out using an online survey to evaluate the topics (accompanied by a glossary illustrating their broadest meaning) and the associated areas of impact found in the document analysis (141 respondents), the creation of two multistakeholder focus groups (69 people involved) – one at business level (stakeholders identified by the operating companies) and one at corporate level (stakeholders of the holding company) – during which the impacts associated with the topics evaluated in the survey were discussed and explored, and 17 one-on-one interviews, mainly held with institutional stakeholders;
• the direct engagement of Group managers through the survey to evaluate the topics and associated effects and a special meeting attended by 36 company managers. During the meeting, the managers, who were presented with the main results of the multistakeholder consultation, evaluated, also on the basis of several suggestions put forward by the Enterprise Risk Management Unit, the relevance of the topics proposed and the critical issues and opportunities created for the Group.

Following the focus groups, conducted by qualified facilitators, the results were analysed considering the opinions and contributions of stakeholders and managers in light of the impact measurement criteria defined by the GRI Standards (significance, extent, remediability, etc.), the output was processed, creating the materiality matrix and preparing the list of material topics and associated impacts, as perceived by the stakeholders¹⁰.
The materiality analysis process performed in 2022 and its results have been returned with reports dedicated to stakeholders and managers involved and shared with the Ethics, Sustainability and Inclusion¹¹and Control and Risk Committees and the Board of Statutory Auditors.
The materiality matrix represents the topics according to the materiality perspective of stakeholders and managers¹². The matrix distributes the 15 economic, governance, social and environmental topics¹³ into low, medium and high relevance (prioritised on a scale from 0-4). In particular, 14 topics are located in the high significance area (score 2.8-4) and 1 in the medium significance area (score 1.5-2.7) (see Chart no. 1).
The positioning of the topics was determined by considering, as a whole, the significance evaluations expressed by stakeholders and managers on the impacts associated with each material topic.

Chart no. 1 – Relevant topics for the Company and its stakeholders: Acea materiality matrix – 2023

Table 1 contains the list of the material topics, in order of significance, defined on the basis of the joint consideration of the multistakeholder and managerial perspective and their correspondence with the reporting disclosures.
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 “specific disclosures” required by the GRI Standards.
The drafting of this Sustainability Report in accordance with the GRI Standards¹⁴ implies the illustration of performance according to:

• the set of “Universal Standards”, which include: the reporting requirements and principles (GRI 1: Foundation 2021), the 30 disclosures of the “General Standards” (GRI 2: General Disclosures 2021) and the methods for identifying and managing material topics (disclosures envisaged by GRI 3: Material Topics 2021);
• the individual disclosures of the “Specific Standards” (referring to economic and governance, social and environmental issues) related to the material topics of high significance for Acea, selected, by virtue of such correlation and for the purpose of best representing the organisation’s main impacts, from the 85 total disclosures included in the 31 Specific Standards¹⁵.

The analysis to select the specific GRI “material” disclosures, considering their correlation with the Acea material topics of high significance and the meaning attributed to them by the International Standards¹⁶, led to the identification of 71 specific “material” disclosures, included in 23 Specific Standards, which are related to all Acea material topics of high significance; the only material topic found to be of “medium significance” – Responsible Finance – is also discussed in the report, but in less depth¹⁷ (see table 1).

Table no. 1 – List of the Acea “material topics” in order of significance and GRI “specific disclosures” related to topics of high significance

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 again been measured in 2022, confirming 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 social and environmental data (customers and CO2 emissions). In-depth analyses were also carried out on the Water Business, given its strategic importance, verifying, for the companies included, a minimum sector coverage of 90% on relevant data (drinking water dispensed, waste water treated), as well as on the Environment Business, detecting a coverage of around 80% of waste treated.
As regards the companies included in the scope of line-by-line consolidation of the Parent Company 2022 (see Table no. 2), the analysis led to a scope proposal, presented to the competent board committees and to the Board of Statutory Auditors. As a result, the scope was completed and, after consulting with the CFO, shared with top management and finally presented to the Ethics and Sustainability and Control and Risks Committees and to the corporate control body.
In light of the above factors, the scope for the 2022 Acea Consolidated Non-Financial Statement (NFS), using the scope of the 2021 NFS, for which all companies were reconfirmed net of those that left the scope of line-by-line consolidation²¹, provides for the entry of Deco SpA, a new company in the Environment Segment, in line with the ongoing expansion of the business, and SF ISLAND Srl in the Generation business unit (photovoltaic energy), albeit not yet operational²² (see Table no. 3)²³.

Table no. 2 – Companies included in the Parent Company’s full consolidation area (2023)

Table no. 3 – Scope of the Acea Group Consolidated Non-Financial Statement for 2023 (pursuant to Legislative Decree no. 254/2016 and the GRI Standards)

The scope of the Acea Group’s 2023 Sustainability Report, albeit wider, guarantees continuity and comparability with the year before²³, 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 2023 Sustainability Report includes qualitative and quantitative information regarding corporate and/or environmental matters of certain companies that are not included within the scope of the Consolidated Non-Financial Statement. In particular, this data relates to the production of electricity from photovoltaic plants attributable to AE Sun Capital, a subsidiary not consolidated on a line-by-line basis, and environmental and social data and information for overseas activities and for the following companies operating in the Water Business: 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 2023 Sustainability Report, in line with previous years, is divided into three main sections: Corporate identity – which also integrates the information required by Regulation 2020/852 –, 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 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 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).

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

Pierfrancesco Latini

RISK MANAGEMENT, COMPLIANCE & SUSTAINABILITY FUNCTION

1 Also following other guidance, in 2002 Acea opted to comply with the guidelines issued by the Global Reporting Initiative (GRI), now known as the GRI Standards, applying their changes over the years.
2 Article 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
3 3 Legislative Decree no. 254/2016 as amended, in particular articles 2, 3, paragraphs 1, 4.
4 As 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, Regulation 852/2020 was approved, in force since 12 July 2020. Article 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 identified by the Regulation 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 ecosystems. The Regulation has governed the first 2 objectives, on climate change, through the “Climate Delegated Act” (Commission Delegated Regulation 2021/2139), which was supplemented, in 2022, by the “Complementary Delegated Act” (Commission Delegated Regulation 2022/1214) with the introduction of activities related to the use of gas, fossil fuels, and nuclear in the energy sector. Subsequently, in June 2023, the other 4 environmental objectives were governed through the publication of the “Environmental Delegated Act” (Commission Delegated Regulation 2023/2486), which also made changes to the “Disclosure Delegated Act” (Commission Delegated Regulation 2021/2178); furthermore, Commission Delegated Regulation 2023/2485 made amendments to the Climate Delegated Act (Commission Delegated Regulation 2021/2139).
5 Regulation 2020/852, 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". The “Disclosure Delegated Act” (Delegated Regulation 2021/2178), adopted in July 2021, was “intended to specify the content, methodology and presentation of information that must be communicated by companies”.
6 Article 10 of the Disclosure Delegated Act (2021/2178), adopted by the European Commission in July 2021, also governed the gradual entry into force of the Regulation: for the first year of application (2022 using 2021 data), non-financial undertakings were required to “only disclose the proportion of Taxonomy-eligible and Taxonomy non-eligible economic activities in their total turnover, capital and operational expenditure and the qualitative information referred to in Section 1.2 of Annex I relevant for this disclosure” in relation to the first two climate-related environmental objectives. In 2023, for financial year 2022, the disclosure was also extended to the data related to “Taxonomy-aligned” activities, in relation to the same climate-related environmental objectives. Lastly, from 1 January 2024 (for financial year 2023), companies are required to disclose the outcomes of the eligibility analysis on the remaining four environmental objectives.
7 When the previous version of the Guidelines (GRI-G4) were superseded, the Global Reporting Initiative (GRI) published the GRI Standards - Consolidated set of GRI Sustainability reporting standards 2016. Since then, GRI has 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 last relevant update was made in the new edition of the “Universal Standards - GRI 1: Foundation 2021, GRI 2: General Disclosures 2021, and GRI 3: Material Topics 2021 - compulsory application of which began in 2023, and the changes were therefore already adopted in the previous reporting cycle. GRI 1 indicates the requirements to be followed for reporting “in accordance with the GRI Standards”. For more information, go to www.globalreporting.org.
8 Legislative Decree no. 254/2016, art. 4 and art. 5, paragraph 3 b.
9 Legislative 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 (…)”.
10 The detailed list of material topics and related effects is in the Report in "Stakeholders and Their Involvement" section.
11 In 2022, it was still named the Ethics and Sustainability Committee.
12 In addition to providing the list of material topics and their associated impacts, Acea also decided to continue to represent them in a matrix (no longer required by the GRI Standards), specifically due to the greater efficacy in showing the perspective of relevance expressed by stakeholders and managers
13 Each topic, mentioned briefly here, has a broader meaning, given in a glossary provided to all stakeholders involved in the analysis process. Compared to the previous reporting cycle, the material topics decreased from 19 to 15. Nevertheless, the topics Governance for sustainable success, Protection of ecosystems and biodiversity, and Technological innovation and digital transformation, in their broadest sense submitted to the stakeholders, now incorporate the aspects previously covered by the topics Performance management systems for sustainability in the medium and long term, Integrated risk management (threats and opportunities), Protection of air quality, Innovation of smart utility processes, infrastructure and services, and Business evolution through open innovation.
14 In particular, the review of the Universal Standards – GRI 1: Foundation 2021, GRI 2: General Disclosures 2021 and GRI 3: Material Topics 2021, which were issued to revise and succeed the previous GRI 101: Foundation, GRI 102: General Disclosures and GRI 103: Management approach.
15 Until 2021, Acea had prepared the Sustainability Report according to the Comprehensive option, the highest level of compliance envisaged by the GRI Standards. This option has been replaced by the change in the framework which, from 2022, provides for the possibility to prepare a sustainability report in accordance with the GRI Standards by meeting 9 “compliance requirements”, defined in GRI 1: Foundation 2021, or to prepare a report with reference to the GRI Standards and therefore one that is not fully compliant.
16 The meaning attributed to the disclosures by the International Standards led, in some cases, to adapting them to the corporate reality and in others to ruling out their materiality. For example, the exclusion prevailed in the case of specific disclosures more relevant to the operations of multinational enterprises or not suited to the reality of the Group’s most significant operations
17 The topic Responsible Finance is nevertheless paired with specific disclosures (201-1, 201-4, 203-1) already related to topics of high significance and, therefore, reported
18 The figure relating to customers rises to 92% when the companies operating in Italy are considered.
19 The figure for drinking water dispensed rises to 97% when the companies operating in Italy are considered.
20 On 1 March 2023, Orvieto Ambiente was established, wholly owned by Acea Ambiente, into which the business unit for the mechanical sorting, composting and waste disposal plant at the site in the Municipality of Orvieto was transferred.
21 The hypothetical inclusion in the NFS 2023 of a PV company, albeit not yet operational, is essential to highlight the importance of the business and to measure its economic KPIs for the purpose of the disclosure required by the European Taxonomy; the same companies were not included in the scope of the NFS 2022 because they had entered the scope of line-by-line consolidation in the final quarter of the year. Furthermore, it should be noted that the data relating to the production of electricity from photovoltaic plants, linked to the company AE Sun Capital Srl, 40% owned by Acea Produzione and 60% by the investment fund Equitix Investment Management and not consolidated on a line-by-line basis, will not be illustrated in the non-financial report in a different manner
22 In light of the applied criteria, the following companies are outside of the scope of the 2023 Consolidated Non-Financial Statement: A.S. Recycling, Cavallari, Consorzio Servizi Ecologici del Frentano “Ecofrentano”, Ferrocart, Iseco, Meg, S.E.R. Plast, Tecnoservizi, Acea Energy Management, Umbria Energy, Acea International, Consorcio Agua Azul, Consorcio Acea, Consorcio Servicios Sur, Acea Dominicana, Consorcio Acea Lima Norte, Consorcio Acea Lima Sur, Aguas de San Pedro, Acea Perù, Consorcio Acea-Acea Dominicana, Adistribuzionegas, Notaresco Gas, Acque Blu Arno Basso, AQUANTIA, Acea Molise, Sarnese Vesuviano, Acque Blu Fiorentine, ASM Terni, Agile Academy, Ombrone, Servizi Idrici Integrati, Umbriadue Servizi Idrici, A.Cities, Acea Liquidation and Litigation, Simam, Technologies for Water Services.
23 It should be noted that the business areas represented in the non-financial report within the NFS 2023 are reported in continuity with the previous financial year, in that the names have simply been changed in the Group’s new Strategic Plan (Environment, Water, Engineering & Infrastructure Projects, Commercial, Production, Networks & Smart Cities), approved at the end of financial year 2023, without leading to substantial changes in the scope