Acea has set up a System for receiving, analysing and processing reports of alleged violations (Whistleblowing).
In Acea there is a system in operation for receiving and managing reports (so-called “Whistleblowing”), that can be activated either by employees or by external parties, relating to any non-compliance with the law, internal rules, the Code of Ethics and the Human Rights Policy, as well as matters pertaining to the Internal Control System, Corporate Reporting, the companies’ Administrative Liability (Legislative Decree no. 231/2001), fraud and conflicts of interest.
This procedure ensures the highest degree of confidentiality and privacy in the processing of communications received, with a view to protecting the reporting party, the reported party and the persons involved.
Following the coming into force of Legislative Decree no. 24/2023, Acea and its subsidiaries adopted the “Policy for handling Acea Group reports – whistleblowing”, also taking account of the indications contained in the “Guidelines with regard to the protection of persons who report breaches of Union law and the protection of persons who report breaches of national regulations” as approved by the National Anti-Corruption Authority (ANAC) in July 2023.
Acea Group Whistleblowing Policy (only italian)
Acea Group Privacy Policy (only italian)
The reports may be submitted by parties within or outside the organisation, such as for example employees, associates, independent contractors, trainees, consultants, suppliers, customers, shareholders or persons with administration and control functions in the ACEA group companies, such as Board Directors or members of the Board of Auditors.
In accordance with the provisions set forth by Legislative Decree 24/2023, through the system adopted, it is possible to report behaviour, acts or omissions that harm the public interest or the integrity of Acea and the Group’s subsidiaries, comprising:
The scope of alleged violation reports that can be submitted through the reporting system adopted by Acea and the Group companies is wider than that set forth by Legislative Decree no. 24/2023, which is extended to also include alleged violations of the Code of Ethics, the Human Rights Policy and the body of internal regulations adopted by the various companies.
In order to enable the responsible parties to perform the appropriate analyses and investigations, it is important that the report is timely and detailed and provides specific information with regard to the alleged violations being notified. For example, the report should include details such as date, time, place of the incident, the names of the persons involved and a precise description of the events that took place.
The “whistleblowing reports” do not include communications other than the above mentioned cases and particularly those referring to requests, complaints and grievances regarding activities of a technical/commercial nature (for example complaints connected with bills, invoices, disruptions, etc.) which, in order to ensure that the same are handled in accordance with existing regulations, must be sent to the competent Company departments through the appropriate dedicated channels.
For sending written or oral communications or requesting a meeting with the party handling the report, a Communicate Whistleblowing IT platform has been set up, which is able to guarantee data security and protection and the confidentiality of information.
Set out below are the external channels contemplated by Legislative Decree no. 24/2023, which can be activated by the reporting parties on a residual basis with respect to the internal channel and only in particular circumstances as indicated in the extended policy:
https://www.anticorruzione.it/-/whistleblowing;
Reports concerning alleged violations of the Code of Ethics and the Human Rights Policy, the Internal Control and Risk Management System (ICRMS) and Legislative Decree no.24/2023 on the part of Acea and the Group’s subsidiaries are sent to the Ethics Officer, an independent collegial body responsible for managing the same, as internal party for Acea SpA and external party for the Group’s individual Subsidiaries.
The Ethics Officer, appointed by decision or resolution of the company’s administrative body, comprises the acting Chairpersons/Heads of the following Acea SpA Bodies/Committees and organisational structures:
Find out more about the Ethics Officer's other responsibilities
Reports concerning relevant unlawful behaviours for the purposes of Legislative Decree 231/2001 and breaches of the organisation and management models on the part of Acea and the Group’s subsidiaries are sent to the Supervisory Body of the Company to which the 231 violations refer, in its capacity as external party.
The 231 Supervisory Body is appointed by resolution of the Board of Directors of Acea and the Group’s subsidiaries.
In the case of reports involving a party appointed to fully or partially receive and handle the same, the said party is excluded from processing the report and, in any case, shall abstain from participating in the analysis and investigation procedures.
Reports received by persons who are not deputised to handle the same must be forwarded to the competent parties within 7 days of receipt, at the same time informing the reporting party.
The safeguards of the whistleblower include:
2021 | 2022 | 2023 | 2024 | |
|---|---|---|---|---|
Number of relevant reports received during the year divided according to the case being reported | 14 | 24 | 45 | 22 |
Supplies & Relationship with Supplies | 7 | 6 | 9 | - |
Sales & User Management | 4 | 11 | 12 | |
HSE | 2 | 7 | 2 | 1 |
Human Resources | 4 | 2 | 16 | 9 |
Other (protection of assets, company regulations, etc.) | 1 | 5 | 7 | - |
Number of relevant reports dealt with during the year divided according to investigation outcome | 14 | 24 | 45 | 22 |
Unfounded | 6 | 14 | 34 | 6 |
Dismissed¹ | 7 | 2 | 4 | 9 |
Well-founded | 1 | 7 | 3 | 4 |
Suspended² | 1 | 4 | 2 |
1 . Reports are classified as dismissed based on the reported facts: they cannot be qualified as detailed / verifiable since, in the light of the results of any preliminary checks carried out, there is no possibility of starting the subsequent assessment phase.
2 . Investigation suspended pursuant to the Whistleblowing procedure.
Any reports referring to cases of a technical/commercial nature (for example, commercial services, contract management, claims. invoicing, meter readings, transfers, lack of water or power, breakdown reports, etc.) must be sent to the competent structures of the various Group Companies through MyAcea, the reserved area dedicated to Acea Group customers, and/or via the contacts listed in the section Contacts and Assistance.
Detailed document ‘Whistleblowing disclosure’ (only Italian version)
How to make a report
