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

Acea takes great care with workplace safety, throughout the supply chain. In particular, organisational structures, both within the holding company and the operating companies, carry out activities to monitor and control safety management by suppliers.

The Work Safety Unit¹³⁰, in Acea Infrastructure, 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 Ambiente131), ensuring compliance with the highest standards and with regulations¹³². 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 co- ordination during execution;
• services ancillary to safety inspection activities.

Site safety inspections are 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 contracts¹³³. 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:

• 18 Safety coordinators in the execution and design phase, assigned to specific worksites as needed;
• 17 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 2023, the Work Safety Unit:

• carried out the activities in support of the technical and professional audits of 1,051 companies (45% of contractors and 55% of subcontractors and operated equipment rentals¹³⁴), in line with 2022 (1,045 companies);
• activated Safety Coordination in the Execution phase for 435 tasks and carried out Safety Coordination in the Design phase for 67 tasks;
• carried out 14,252 on-site safety¹³⁵ inspections.

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

Workplace health and safety audits carried out as part of inspections in 2023, allowed for the identification of a total of 1,432 non-conformities¹³⁶, of which 959, or 67%, of “minor importance”, 370 of “medium importance” and 103 of “major importance”, confirming the trend already seen in recent years of a constant decrease in the per- centage represented by “major importance” non-conformities (7% in 2023) out of all non-conformities identified during the year¹³⁷.

Additionally, for Engineering, Procurement and Construction (ECP) sites for which it acts as the contractor, and based on the service contract signed with Acea Ato 2, Acea Infrastructure carries out high vigilance audits and inspections to ensure:

• safety conditions for the work assigned and application of the provisions and instructions found in the safety and coordination plans (SCP);
• the professional and technical suitability of companies performing the work, pursuant to annex XVII of the Consolidated Law on Workplace Safety;
• the effective implementation of health and safety provisions with reference to work site logistics;
• access control, work site fencing and storage of materials;
• the worksite is maintained in an orderly fashion.

To that end, Acea Infrastructure has created the role of High Vigilance Monitoring Manager (REMAV), who ensures compliance with the prevention and protection measures by contractors and companies carrying out work, and has designed and implemented a High Vigilance System using general check-lists for work site activities and specific check-lists to ensure application of the various safety and coordination plans. To support these activities an app has been adopted for digital safety checks (Vigilance 4.0), based on specific check-lists in line with the instructions found in the safety and coordination plans (SCP) for each work site. In 2023, 16 High Vigilance monitoring actions were carried out, as well as 134 operational vigilance actions, by the workers assigned to monitor the work of contractor companies and by the Worksite Coordination Managers, using digitalised checklists specific to each work site. Use of the app has made it possible to ensure controls are uniform and precise, even if carried out by various entities, as well as ensuring inspection results can be traced, to allow for a review of overall safety management and continuous improvement of work site activities. During 2023, among other activities, the High Vigilance Monitoring Manager organised training on the use of the Vigilance 4.0 app for work site personnel and on proper use of the check-lists, received operational monitoring notes from assigned workers and quarterly reports from the delegated safety executives, in turn preparing reports with feedback on the results of the monitoring, which did not identify any critical issues.

The Acea Infrastructure Work Safety Unit and the other Group Companies that independently manage site audits¹³⁸, either in whole or in part, also contribute to protecting the safety of contractors working on the construction sites, also 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 in 2023 carried out 1 training/coaching courses aimed at contractor sta, for a total of 30 hours of training on the correct use of systems for the recovery in emergencies for sta operating in the workplace, through the preparation of specific anchor lines for each type of plant.

Additionally, for many years the Training Camp has been a constant within Acea, a space dedicated to educating and training personnel, both internal (see the chapter Personnel) and contractor sta to demonstrate how to safely perform activities such as climbing/ descending from MV/LV power line pylons, entering confined spaces underground, and ensuring systems are safe when works are required.

The Companies that carried out site inspections during the year, above and beyond the work of the Work Safety Unit, took the Parent Company’s guidelines into consideration. In particular, Acea Ato 2 assigns inspections to its Supervision and Inspection Unit, and 1,926 inspections were conducted during the year (2,467 in 2022) at contractors, with no serious critical issues detected. Acea Ato 5 has further strengthened its auditing activity and, in 2023, through its Internal Safety Team (Risk & Compliance and Safety Unit) carried out 745 inspections (544 in 2022) intended to verify supplier compliance with reference to workplace health and safe- ty, environment and work quality; the results of the inspections are shared with the relative companies, to increase awareness, including through dedicated meetings. During 2023 Areti also carried out verification activities, with 2,005 inspection visits at work sties (2,312 in 2022).

This also applies to non-centrally managed companies: AdF, through its Technical Management Systems Unit, performed 248 checks during the year (503 in 2022) to verify safety conditions, identifying a total of 6 deviations regarding a lack of documentation, with no procedural issues and/or lack of PPE; Gori and Gesesa both significantly increased health and safety inspections at work sites in 2023: Gori performed 4,934 checks (2,953 in 2022) and Gesesa performed 58 inspections (31 in 2022), identifying and resolving 11 anomalies.

With reference to health and safety along the value chain, for some years now Acea has prepared and progressively implemented a project known as Sustainability and Safety, a virtuous pair, intended to actively involve contractors, offering training sessions and helping them to improve, in particular, the process of collecting and reporting injury data. The project was coordinated by the parent company's Risk Management, Compliance & Sustainability Department and the Work Safety Unit, developed in synergy with the units of the holding company and operating companies responsible for monitoring supplier relations in various ways.

To render the process uniform and expand injury statistic monitoring to a growing number of contractors, in 2023 data collection was integrated into quarterly feedback through which the RSPPs of the Group's operating companies record the safety performance of contractors.

Analysis of the resulting data¹³⁹ indicated that injuries during the year in question, with reference to contractor sta (14,877 people), excluding those occurring during commutes, totalled 27, specifically 20 occupational incidents (of which 17 with minor injuries) and 7 non-occupational incidents (all of which with minor injuries). The main causes of injuries were tripping, bumping, slipping, cuts, crushing, mistakes in manual movement of heavy loads, inappropriate movements and road accidents.

The frequency index¹⁴⁰ of total accidents is 2.36 and the severity index is 0.06.
Additionally, there were no fatal accidents during the year, nor were there any occupational diseases involving contractor staff.

Involvment of suppliers also in other sentsitive issues

Some Group companies carry out activities to improve the involvement and awareness of suppliers with respect to other aspects, in particular concerning technological developments implemented as well as the Group's values or operating guidelines, to ensure constant alignment and adequate training of partners working on behalf of the Company.

Areti, involved suppliers in 2023 in certain specialised sessions dedicated to “IP and LV connections”, in mixed classes combining internal and contractor sta, training 20 operators from contractors, with 120 total training hours. These initiatives occurred in person in the Training Classroom and the “Cabin of the Future” at the Mag- liana headquarters, with assistance from four external instructors. Every year, Deco engages with suppliers on aspects envisaged by the standard SA 8000 or the economic, social and environmental impacts of its activities, 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 sustainability and social responsibility aspects, associated in particular with the protection of workers’ rights.

Finally, 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 free 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 2023 Acea Energia carried out a training programme for a total of 683 hours, of which 534 hours were delivered to 855 door-to-door sellers, for a total of 153 days, and 149 hours delivered to 50 telemarketing agency workers (front end, back oce and supervisors).

130 The Unit (previously the “Site Safety” Unit) changed its name in December 2023.
131 For Acea Ambiente, the Work Safety Unit mainly carried out Safety Coordination during execution (CSE) activities on a smaller number of sites.
132 Legislative Decree no. 81/08 “Consolidated Act on Safety”, as amended.
133 Such as electrical or electromechanical maintenance work carried out on plants, meter changes, road repairs, video-inspections and sewerage pumping, etc.
134 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.
135 The number includes visits for all types of contracts, both main ones and “minor ones”.
136 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 (gen- erally 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.
137 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). In 2022, over 14,724 inspections, 1,686 non-conformities were recorded (of which 1,178, or 70%, of minor importance; 380 of medium importance, and 139, or 8%, of major importance).
138 Note that the company Deco had no site activities in the year in question.139 The figure for hours worked when no precise number is available has been estimated using methods identified by the individual companies.
140The 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.