Discover the Acea Group online 2019 Sustainability Report
Disclosing Sustaninability: Methodological Note
SUSTAINABILITY PERFORMANCE: LEGISLATIVE DECREE NO. 254/2016 AND GRI STANDARDS
Acea published a Group Sustainability Report on a voluntary, annual basis since 1999 (for the 1998 financial year), the year it was listed on the Stock Exchange. From the early years sustainability report has been written in compliance with the international reference Guidelines1, and submitted for check by a third party. Moreover, since 2011, with the objective of providing a complete disclosure regarding Group performance to both the financial community and concerned parties, publication times for the consolidated financial statements and sustainability report have been aligned.
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. In fact, under the Decree, companies that meet the conditions set out in article 2 are required to publish information on sustainability performance in a non-financial statement – individual or consolidated – which, as stated in the Decree in article 3, paragraph 1 of the Decree: “...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.
This Sustainability Report for the financial year 2019 has been prepared in accordance with the GRI Standards (issue 2016)4: Comprehensive option and therefore called Acea Group’s 2019 Sustainability Report (consolidated non-financial declaration pursuant to Legislative Decree no. 254/2016, prepared in accordance with GRI standards), taking the form of an autonomous document, as permitted by the aforementioned Legislative Decree5.
The Sustainability Report, enclosing a Summary Note, following its approval by the Board of Directors, is available to the supervisory body and submitted for assurance by the indipendent 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 Standards (see Opinion Letter of the independent auditor).
The document is disseminated through the institutional website at the same time as the Consolidated Financial Statements and distributed during the Shareholders’ Meeting.
MONITORING THE MANDATORY NON-FINANCIAL REPORT IN ITALY
The process, subject to a specific procedure, aims at identifying of Legislative Decree no. 254/2016 for annual non-financial reporting by Italian companies subject to the standard, as documented by a Deloitte study published in October 2019, testifies to the level of progress towards sustainability.
Based on the information reported in the latest Non-Financial Statements (NFS 2018), researchers show a significant increase in initiatives put in place by companies on stakeholder engagement as an approach to understand the expectations and needs of stakeholders, in particular for the materiality analysis (45% in 2018 compared to 22% in the previous year). There is also an increase in the number of companies that in their reports mention SDGs (44% in 2018 compared to 21% in 2017) and the adoption of policies on diversity (33% in 2018 compared to 18% in 2017), although SDGs are not always implemented through specific targets, nor is there an increase in senior positions held by women.
The definition of multi-annual sustainability targets has increased slightly (26% in 2018 compared to 19% in 2017), with an interesting perspective of the cases that incorporate them directly into the business plan (65% in 2018 compared to 53% in the previous year). Incentive models referring to sustainability targets are also marginally widespread (13% in 2018).
Other evidence confirms what was learned last year with the first cycle of application of Legislative Decree no. 254/2016: the NFS is mostly considered separate from the Report on Operations, with a separate document (84%), 100% of the companies analysed refer to GRI Standards and the choice for the application of the core option prevails (67%), which is more limited in the scope of information provided compared to the comprehensive option (3%), compared to the remaining 30% which simply refer to the Standard.
MATERIALITY, GRI STANDARDS AND REPORT SCOPE
In light of the evolution of the Group’s strategic, industrial and sustainability guidelines7, during the second half of 2019 Acea conducted a new round of materiality analysis.
The process, subject to a specific procedure, aims at identifying the main financial, governance, social and environmental issues (the so-called “material” issues) related to the company’s business and at defining their prioritisation on the basis of the assessments expressed by stakeholders and the company.
The activity is divided into phases, including:
- analysis of documentation, which was conducted on about 30 documents (scenario, representative of stakeholder, strategic and internal management requests, etc.) and led to the identification of a list of 19 potentially relevant topics, validated by the top management and submitted for the assessment of stakeholders and Group managers;
- the direct involvement of stakeholders (external and internal) identified with the support of the heads of Group Areas/Companies and Functions through a multistakeholder focus group, in the final phase of which the Company Chairman took part, and some one-to-one telephone interviews. Overall, the discussion involved 43 people, representing 11 categories of stakeholders, who assessed the relevance of the proposed topics also with respect to their impacts on stakeholders;
- the direct involvement of Group managers, through a meeting with 22 company managers. After illustrating the main results of the multi-stakeholder consultation, the managers assessed the relevance of the proposed topics also with respect to the risks associated with them.
Following the meetings, which were led by a qualified facilitator, the opinions expressed by the stakeholders and the Company were elaborated in the 2019 materiality matrix: a two-dimensional chart showing the distribution of the 19 economic, governance, social and environmental issues of low, medium and high importance (prioritisation). In particular, 16 topics are located in the high significance area (score 68-100) and 3 in the medium significance area (score 33-67) (see chart no. 1).
All “material” issues are consistent with the Group’s strategic sustainability planning.
In addition to being presented in a report to the stakeholders and managers involved, the materiality analysis process and its results were shared with the Group’s top management and explained to the members of the Ethics and Sustainability and Control and Risk Committees in joint session with the members of the Board of Statutory Auditors.
CHART NO. 1 – RELEVANT TOPICS FOR THE COMPANY AND ITS STAKEHOLDERS: ACEA “MATERIALITY MATRIX” – 2019
Besides being a strategic reference, the identification of the “Acea materiality matrix” through direct discussions with the stakeholders is necessary to identify the aspects to be included in the sustainability report in greater or lesser depth depending on the results of prioritisation, and to select the indicators required by the adopted standards.
To prepare the Sustainability Report in accordance with the GRI Standards (ed. 2016): Comprehensive option, indeed, it is necessary to illustrate the issue performance in light of:
- “Universal Standards”, which include the reporting principles (GRI 101: Reporting principles) and the 56 general standards (GRI 102: General information);
- the “Specific standards” referring to the economic, environmental and social dimension (GRI 200: Economic, GRI 300: Environmental, GRI 400: Social) considered to be material (“material topics”) and related indicators selected from among the 33 topics envisaged in the specific Standards;
- the management approach (GRI 103: Management approach) for each of the specific topics considered material.
In order to be able to select GRI Material Specific Standards, consideration was given8 to both their correlation with Acea’s “materiality matrix” and the meaning thereof conferred by international Standards, in some cases tracing them back to the corporate context and in others establishing their non-applicability9.
Following the assessments described above, 26 specific Standards10 were identified this year out of a total of 33, as consistent with Acea material topics of high significance (see table no. 1). Furthermore, among all the indicators envisaged in the specific Standards considered as “material”, only 2 were considered as not pertinent and excluded from the analysis11.
Only one Acea material topic of high relevance is not correlated to the specific Standards, this being the Consolidation of elements of sustainability in corporate governance, which however, is fully consistent with the general standards dedicated to aspects of governance (GRI 102: General information).
Lastly, also regarding Acea material topics of medium significance present in the report on a less descriptive basis, consistencies were found, albeit not highlighted in the table, with both the material specific Standards and the standards of the General information.
TABLE NO. 1 – CONSISTENCY WITH GRI “MATERIAL SPECIFIC STANDARDS” AND ACEA “MATERIAL TOPICS” OF HIGH SIGNIFICANCE
|GRI 200: ECONOMIC||ACEA MATERIAL|
|GRI 300: ENVIRONMENTAL||ACEA MATERIAL|
|Economic performance in 2016||2, 4, 7, 8, 10, 11, 13||Material in 2016 (301-1 AND 301-2)||1, 4, 6, 12|
|Indirect Economic Impacts in 2016||2, 4, 5, 6, 7, 9, 15||Energy in 2016 (FROM 302-1 TO 302-4)||1, 4, 10, 12, 13|
|Procurement Procedures in 2016||2, 5||Water in 2016||1, 4, 12|
|Anti-corruption in 2016||8||Biodiversity in 2016||1, 10, 12, 13|
|Anti-Competitive Conduct in 2016||8||Emissions in 2016||1, 10 12, 13|
|Effluents and waste in 2016||1, 6, 12|
|Enviromental Conformity (COMPLIANCE) in 2016||1, 8, 10, 12, 13|
|Enviromental assessment of Suppliers in 2016||5|
|GRI 400: SOCIAL||ACEA MATERIAL|
|Employment in 2016||11, 16||No discrimination in 2016||8, 16||Marketing and labelling of Products and Services in 2016||8, 9|
|Industrial Relations in 2016||11, 16||Local Communities in 2016||7, 15||Customer Privacy in 2016||8, 9|
|Occupational Health and Safety in 2016||3, 5||Social Assessment of Suppliers in 2016||5||Compliance in 2016||8, 9|
|Training and Education in 2016||11||Public Policy(POLITICAL|
CONTRIBUTIONS) in 2016
|Diversity and Equal Opportunity in 2016||11, 16||Customer Health and Safety in 2016||1, 8, 9|
NOTE The economic, environmental topic, and social GRI “Specific standards” shown in the table are only those assessed as being “material”. When indicators are placed in brackets next to a GRI topic this means that only the indicators shown in the table apply, or, where not specified, all the indicators related to the topic apply (also see the GRI table of contents). For “Acea material topics” as identified in the table by a number, reference should be made to the figure showing the materiality matrix (chart no. 1).
The principle of materiality was also applied to the definition of the “report scope”, as envisaged both by the standards adopted for reporting 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”.To define the reporting scope, the same approach was used as in previous editions, subject to a specific procedure. In particular, the adequacy of the criteria of strategic materiality/significance was verified in order to identify the Companies that ensure an understanding of the activities and impacts generated by the Group, taking into account the main business areas and the region where these activities are mainly carried out. As an indicator of commitment in the medium- and long-term, it was considered appropriate to add the value of the investments to quantitative criteria12 (such as the weight of turnover on the consolidated revenue, value of energy consumption expressed in TOE, etc.), already identified and applied previously. Qualitative criteria (such as a relevant and current role in the qualifying companies, presence in the region 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) highlight the specific role and relevance of the Company in question13.
Both types of criteria14 were applied to the Companies included in the scope of consolidation15 of the Parent Company in 2019 (see table no. 2) resulting in a proposal of scope that, having heard the opinion of the Head of the Legal and Corporate Affairs Function and the CFO, was shared with Top Management, defined after further data verification and finally explained to the Ethics and Sustainability and Control and Risk Committees.
The companies that are representative for the purposes of reporting the 2019 non-financial information (in accordance with Legislative Decree no. 254/2016 and the GRI Standards), include, in addition to all those present in the previous edition of the document, Gori SpA (see table no. 3)16.
TABLE NO. 2 – COMPANIES INCLUDED IN THE PARENT COMPANY’S FULL CONSOLIDATION AREA (2019)
|Acea Ambiente Srl||Via G. Bruno, 7 – Terni|
|Aquaser Srl||P.le Ostiense, 2 – Rome|
|Berg SpA||Via delle Industrie, 38 - Frosinone|
|Bioecologia Srl||Via Simone Martini, 57 – Siena|
|Iseco SpA||Loc Surpian, 10 – Saint Marcel (AO)|
|Demap Srl||Via Giotto 13 – Beinasco (TO)|
|Acque Industriali Srl||Via Bellatalla, 1 – Ospedaletto (PI)|
|Acea Energia SpA||P.le Ostiense, 2 – Rome|
|Acea8cento Srl||P.le Ostiense, 2 – Rome|
|Cesap Vendita Gas Srl||Via del Teatro, 9 – Bastia Umbria (PG)|
|Umbria Energy SpA||Via B. Capponi, 100 - Terni|
|Acea Energy Management Srl||P.le Ostiense, 2 – Rome|
|Parco della Mistica Srl||P.le Ostiense, 2 – Rome|
|Acea Dominicana SA||Avenida Las Americas – Esquina Mazoneria, Ensanche Ozama – Santo Domingo, Repubblica Dominicana|
|Aguas de San Pedro SA||Las Palmas, 3 Avenida 20y 27 calle – San Pedro, Honduras|
|Acea International SA||Avenida Las Americas – Esquina Mazoneria, Ensanche Ozama – Santo Domingo, Repubblica Dominicana|
|Acea Perù SAC||Calle Amador Merino Reyna – 307 Miraflores – Lima, Perù|
|Consorcio Acea-Acea Dominicana||Avenida Las Americas – Esquina Mazoneria, Ensanche Ozama – Santo Domingo, Repubblica Dominicana|
|Consorcio Servicios Sur||Calle Amador Merino Reyna - San Isidro – Lima, Perù|
|Acea Ato 2 SpA||P.le Ostiense, 2 – Rome|
|Acea Ato 5 SpA||Viale Roma, snc – Frosinone|
|Acque Blu Arno Basso SpA||P.le Ostiense, 2 – Rome|
|Acque Blu Fiorentine SpA||P.le Ostiense, 2 – Rome|
|Acquedotto del Fiora SpA||Via A. Mameli, 10 - Grosseto|
|Crea Gestioni Srl||P.le Ostiense, 2 – Rome|
|Crea SpA (in liquidazione)||P.le Ostiense, 2 – Rome|
|Gesesa SpA||Corso Garibaldi, 8 - Benevento|
|Gori SpA||Via Trentola, 211 – Ercolano (NA)|
|Lunigiana SpA (in liquidazione)||Via Nazionale, 173 – Massa Carrara|
|Ombrone SpA||P.le Ostiense, 2 – Rome|
|Pescara Distribuzione Gas Srl||Via G. Carducci, 83 – Pescara|
|Sarnese Vesuviano Srl||P.le Ostiense, 2 – Roma|
|Umbriadue Servizi Idrici Scarl||Strada Sabbione zona ind.le – Terni|
|Areti SpA||P.le Ostiense, 2 – Rome|
|Acea Produzione SpA||P.le Ostiense, 2 – Rome|
|Acea Liquidation and Litigation Srl||P.le Ostiense, 2 – Rome|
|Ecogena Srl||P.le Ostiense, 2 – Rome|
|KT4 Srl||Viale SS. Pietro e Paolo, 50 – Rome|
|Brindisi Solar Srl||Via Paolo da Cannobio, 33 – Milan|
|Solaria Real Estate Srl||Via Paolo da Cannobio, 33 – Milan|
|Compagnia Solare 2||Via Paolo da Cannobio, 33 – Milan|
|Compagnia Solare 3||Via Paolo da Cannobio, 33 – Milan|
|SPES Srl||Via Paolo da Cannobio, 33 – Milan|
|Acquaviva Srl||Via Paolo da Cannobio, 33 – Milan|
|Luna Energia Srl||Strada degli Alberi, 7 – Galliera Veneta (PD)|
|Sisine Energia Srl||Strada degli Alberi, 7 – Galliera Veneta (PD)|
|Acea Solar Srl||P.le Ostiense, 2 – Rome|
|Marche Solar Srl||Via A. Grandi, 39 – Concordia sulla Secchia (MO)|
|Urbe Solar Srl||Via Ciasca, 9 - Bari|
|Urbe Cerig Srl||Via Ciasca, 9 - Bari|
|Trinovolt Srl||Via T. Columbo, 31 d - Bari|
|Acea Sun Capital Srl||P.le Ostiense, 2 – Rome|
|Acea Elabori SpA||Via Vitorchiano, 165 – Rome|
|Technologies for Water Services SpA||Via Ticino, 9 – Desenzano del Garda (BS)|
|Acea Innovation Srl||P.le Ostiense, 2 – Rome|
TABLE NO. 3 – SCOPE OF THE ACEA GROUP CONSOLIDATED NON-FINANCIAL STATEMENT FOR 2019 (PURSUANT TO LEGISLATIVE DECREE NO. 254/2016 AND GRI STANDARDS)
|Acea SpA||P.le Ostiense, 2 – Rome|
|Acea Ambiente||Via G. Bruno 7 – Terni|
|Aquaser||P.le Ostiense, 2 – Rome|
|Acea Energia||P.le Ostiense, 2 – Rome|
|Acea8cento||P.le Ostiense, 2 – Rome|
|Acea Ato 2||P.le Ostiense, 2 – Rome|
|Acea Ato 5||Viale Roma, snc – Frosinone|
|Gesesa (*)||Corso Garibaldi, 8 – Benevento|
|Gori (*)||Via Trentola, 211 – Ercolano (NA)|
|Areti||P.le Ostiense, 2 – Rome|
|Acea Produzione||P.le Ostiense, 2 – Rome|
|Ecogena||P.le Ostiense, 2 – Rome|
|Acea Elabori||Via Vitorchiano, 165 – Rome|
(*) Gesesa and Gori provide data on areas of sustainability in a progressive manner.
The scope of the Acea Group’s 2019 Sustainability Report is therefore consistent with what was defined the year before, guaranteeing continuity and comparability as well as coverage of the Companies that ensure full understanding of the Group’s activities and most significant sustainability performance. Furthermore, such Companies represent at least: 90% of the turnover, 84% of the average number of employees and 88% of the costs for materials and services of the full consolidation area of Acea Group (including the Parent Company and excluding the companies that had entered that area in the last quarter of the year).
Lastly, in compliance with the principle of completeness required under GRI Standards, the 2019 Sustainability Report includes qualitative and quantitative information regarding corporate and environmental matters of certain companies that are not included within the scope of the Non-Financial Statement. Specifically, this concerns foreign activities and the following companies operating in the water area: Acque, AdF, Publiacqua and Umbra Acque, which were included in some Group data and described in a dedicated chapter (Water Company Profile and abroad activities), giving clear evidence of their individual contribution.
DOCUMENT STRUCTURE AND DISSEMINATION
The 2019 Sustainability Report is divided into three sections: Corporate identity, Relations with the stakeholders and Relations with the environment, supplemented by the Environmental Budget. The latter comprises about 400 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.
It is important to note that where the document recalls the main economic-financial data and describes corporate governance, data and information 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 Industrial Areas, Companies and responsible Functions (data owner), they are processed – and possibly reclassified with application of the reference Standards – by the internal workgroup which draws up the document and then submitted it once again to the Areas/Companies/Functions responsible for final validation, formalized by the issuing of a specific certificate.
Downstream of the audit activities by the appointed indipendent auditor, the report distributed by means of 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). It is also distributed together with the consolidated financial statements in a kit: to the shareholders, during the annual Shareholders’ Meeting upon closure of the financial year, to directors and middle management of the Group and the public concerned during events.
For further information about the Sustainability Report and its contents, it is possible to write to the following email address: RSI@aceaspa.it.
Mr. Giuseppe Sgaramella
Mr. Antonio Sanna
RISK & COMPLIANCE FUNCTION
1 After also following other guidance, Acea opted for compliance with the guidelines issued by the Global Reporting Initiative (GRI), applying them starting with the 2002 Sustainability Report with the highest level of “compliance” possible and following its progressive development.
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 Legislative Decree no. 254/2016 as amended, in particular articles 2, 3, paragraphs 1, 4.
4 In 2016, when the previous version of the Guidelines (GRI-G4) were superseded and further developed, the Global Reporting Initiative (GRI) published the GRI Standards – Consolidated set of GRI Sustainability reporting standards 2016 – requiring their adoption with respect to the 2018 financial year. Acea has anticipated such application, with the Comprehensive option, since the 2017 Sustainability Report. In October 2019 GRI made the Italian translation of the GRI Standards available on the website www.globalreporting.org (Raccolta consolidata dei GRI Sustainability Reporting Standards 2018).
5 Legislative Decree no. 254/2016, art. 4 and art. 5, paragraph 3.b.
6 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 (...)”.
7 In April 2019, the Acea SpA Board of Directors approved the 2019-2022 Business Plan, and in December 2019 the 2019-2022 Sustainability Plan.
8 It is important to consider that both the specific GRI Standards – each of which includes a description of the management method and a number of indicators – and Acea material topics both refer to contents that are far more complex and detailed than their brief name may suggest which, given their level of detail, cannot be presented at this time. See the GRI Standards – Consolidated set of GRI Sustainability reporting standards for 2016 – on the website www.globalreporting.org (now also in Italian translation: Raccolta consolidata dei GRI Sustainability Reporting Standards 2018).
9 This led, for example, to the exclusion of the Specific standards related to Presence on the Market and Human Rights which, according to the meaning given to them by the GRI, are more pertinent to multinational enterprises and not suited to the reality of the Group’s most significant operations.
10 One more than the last sustainability report. In particular, by virtue of the results of the materiality analysis that brought the topic of Company well-being, diversity and inclusion to the forefront, the specific GRI Standard No discrimination was also selected.
11 Two more indicators have been included in the reporting compared to the last reporting cycle, relating to the specific GRI Material and Biodiversity Standards, see The GRI Table of contents.
12 Thresholds of significance were defined for each of the quantitative elements considered.
13 “Inconsistent” elements were also identified for qualitative criteria, focusing on materiality (such as “vehicle” companies, companies under liquidation with non-determining positions for the purposes of operations, companies operating outside of the territory of reference, etc.).
14 The conditions of contemporary presence of quantitative and qualitative factors were also established, aimed at defining the strategic significance of a Company for the Group and its representative ability for the purposes of disclosing non-financial information.
15 As required by Legislative Decree no. 254/2016, art. 4, para. 1: “To an extent necessary for ensuring an understanding of the group’s activity, its performance, results and the impact it produces, the consolidated declaration includes data about the parent company, its fully consolidated subsidiary companies”.
16 In light of the applied criteria, the following Companies are outside of the scope of the consolidated non-financial Statement for 2019: AdF, Berg, Bioecologia, Iseco, Demap, Acque Industriali, Cesap Vendita Gas, Umbria Energy, Acea Energy Management, Parco della Mistica, Acea Dominicana, Aguas de San Pedro, Acea International, Acea Perù, Consorcio Acea-Acea Dominicana, Consorcio Servicios Sur, Acque Blu Arno Basso, Acque Blu Fiorentine, Crea Gestioni, Crea, Lunigiana, Ombrone, Pescara Distribuzione Gas, Sarnese Vesuviano, Umbriadue Servizi Idrici, Acea Liquidation and Litigation, KT4, Brindisi Solar, Solaria Real Estate, Compagnia Solare 2, Compagnia Solare 3, SPES, Acquaviva, Luna Energia, Sisine Energia, Acea Solar, Marche Solar, Urbe Solar, Urbe Cerig, Trinovolt, Acea Sun Capital, Technologies for Water Services and Acea Innovation.