Respect for human rights

Italgas carries out its business activities with careful consideration for the acknowledgement and safeguarding of the dignity, freedom and equality of human beings, and the protection of labour and trade union rights, health and safety in the workplace and the environment.

Italgas commitment

Italgas carries out its business activities with careful consideration for the acknowledgement and safeguarding of the dignity, freedom and equality of human beings, and the protection of labour and trade union rights, health and safety in the workplace and the environment.

Italgas upholds and promotes respect for all human rights, to be understood, in accordance with the Code of Ethics, as inalienable and essential prerogatives of human beings and the basis for the construction of societies founded on principles of equality, solidarity, the repudiation of war and protection of civil and political rights, social, economic and cultural rights and third-generation rights (right to self-determination, peace, development and the safeguarding of the environment).

The Group has a Human Rights Policy, which sets out the reference principles and the actions undertaken for the protection of Human Rights while undertaking its activities, included in the due diligence process in light of any acquisitions or expansions of the Group and, in general, in any context in which the People of Italgas and the Business Partners operate. The Dignity of Group Personnel Policy and the Diversity and Inclusion Policy reinforce the commitment of the group to the protection of Human Rights.

The actions carried out by Italgas for the protection of human rights are developed, also in the context of alignment with the first and second principles of Global Compact, within the reference framework of the United Nations’ Universal Declaration of Human Rights, the ILO (International Labour Organization) Conventions and the OECD Guidelines for Multinational Enterprises.

The due diligence process

Italgas and all other companies of the Group have adopted an organisational, management and control model – the Model 231, pursuant to Legislative Decree no. 231 of 8 June 2001 – which aims to prevent offences being committed in the interest or to the benefit of the company. The Model 231 is the tool adopted to prevent the administrative liability of the entity and is intended for members of Italgas’ corporate bodies, management and employees, as well as those operating to achieve Italgas’ objectives.

The Model 231 of Italgas and the other Group companies is updated constantly as legislative reforms are implemented, which alter the list of relevant predicate offences in accordance with Legislative Decree 231/2001. The most recently updated version of the Model 231 was approved by the Company’s Board of Directors on 14 December 2022.

The offences envisaged by the legislation, and therefore evaluated by Italgas through an in-depth assessment, include the following:

  • Employment of other citizens who are staying illegally in the country (with reference to the issues of: forced labour, child labour, freedom of association, right to collective bargaining, human trafficking).
  • Racism and xenophobia, in relation to the issue of discrimination.
  • Crimes against individuals, including modern slavery (forced labour), unlawful intermediation and the exploitation of labour (in relation to the issues of forced labour, child labour, freedom of association, right to collective bargaining, human trafficking, disabilities, fair remuneration).

The assessment carried out, which also includes the aforementioned offences, comprises of the following activities:

  • As-is analysis carried out to identify the processes and activities where there is a risk of the offences envisaged by the Decree being committed, including through interviews with Process Owners.
  • Self-evaluation of the risk of the offences being committed and of the existing control system to prevent unlawful conduct/actions.
  • Identification of an improvement plan for the relevant/applicable offences that are eventually identified

Furthermore, the Group Security Department analyses, verifies and promptly reports risks, threats, hazards and other useful information daily in order to support the Italgas Group in the protection and development of its goods, people and interests. It supports the company structures through reputational due diligence activities intended to identify developments related to shareholders, partners, suppliers and customers and companies that may be subject to M&A and to support them in their decision-making processes. Based on a Risk Approach methodology, the due diligence activities assess and highlight the aspects of attention by considering 120 types of offences, including more than 30 types of offences related to the issue of Human Rights: human trafficking, child labour, forced labour, discrimination, including in relation to disabilities. The Reputational Due Diligence process has been formalised through a dedicated Manual that describes the activities performed by the Italgas team and the components of the digital infrastructure that supports and enables the most accurate and timely development of alerts and reports, according to the risks addressed by the Group, comprising the Human Rights perspective. Risks relating to human rights and their assessment are also integrated into the Enterprise Risk Management Model (ERM).

With regards to the Group’s supply chain, Italgas has adopted a specific system to verify the sustainability of companies, to promote the creation of shared value and, at the same time, for the purposes of periodic monitoring, as required by the law, the Group’s Code of Ethics, the Ethics and Integrity Agreement and the organisational model pursuant to Legislative Decree 231/2001.

In this context, Italgas implements activities to guarantee respect for human rights throughout its supply chain: 

  • During qualification: thanks to the Vendor Management system, a careful selection is made of the companies that intend to participate in the procurement procedures, by assessing aspects related to health and safety, environment and human rights, as well as technical, financial/economic and legal aspects. All Italgas suppliers must accept and support the principles of the Code of Ethics, the Ethics and Integrity Agreement and the Model 231, starting with respect for and protection of human rights, occupational health and safety, the environment and sustainability, as well as compliance with the law.
  • During assessment and monitoring: verification of the operational assessment of performance and assessment of the reputation of the supplier’s profile, through due diligence work that includes the operational vendor rating, third-party audits at sites, HSEQ technical audits, reputational checks, sustainability indices and the constant monitoring of open disputes and accident indices. The reputational checks carried out include, among others, aspects linked to the regularity of the workforce employed and compliance with the provisions for disabled employees.

As part of the due diligence process, the following vulnerable groups are considered as part of the analyses performed, listed above:

  • Employees
  • Women and children
  • Migrant workers
  • Contractors of third parties
  • Local communities
  • People with disabilities or pertaining to protected cathegories

Due diligence on the previous issues is also conducted in the case of M&A operations, including on topics relating to remuneration and labour issues.

The annual review of the due diligence process on the protection of human rights was carried out also in 2022.

Results of the due diligence process and mitigation actions implemented

The activities described as part of due diligence in relation to human rights, including the mapping of ERM risks, the Model 231 and reputational due diligence, are conducted on all operations and Group Companies, covering all employees. 

Aspects associated with human rights are also addressed in the context of the qualification process and the subsequent evaluation and monitoring system of the supply chain, as per Model 231. In the last four years, all Tier-1 contractors and suppliers have undergone these evaluations. Human rights risks have been assessed as very low throughout the Group’s value chain, therefore no specific mitigation action has been put in place, but rather Group-wide remedial actions focused on strengthening and increasing the existing risk mitigation measures.

From the analysis carried out, also in the latest update of the Model 231 run in 2022, the risks related to human rights, including those concerning certain crimes relevant for the Italian Decree 231/2001  have been assessed as very low level in all Group activities and along the entire value chain, therefore in the Model 231 no specific mitigation nor remediation action has been implemented, but rather oversight activities focused on reinforcing the risk management process at Group level, such as:

  • Recruitment system that by policy only hires adults older than 18 years old.
  • Constant revision and update of the Code of Ethics focusing also on human rights protection and training on the values contained therein for all employees. The last review of the Code of Ethics took place in 2022.
  • ICT applications in order to respect national legislation on disabilities (e.g. impaired sight).
  • Achievement of ISO 37001 and ISO 45001 certifications for Italgas and all Group companies and related improvement plan;
  • Adoption and maintenance of a management system compliant with ISO standards (ISO 37001, ISO 45001)
  • Audit of compliance on integrated HSEQ (including ISO 45001) and ISO 37001 systems.
  • Constant update and monitoring of the Data Protection Organisational Model, including audits, ensure the adequacy also in terms of compliance with the applicable regulations.
  • Requirements to all suppliers to sign and follow the “Supplier Code of Ethics”, which requires a commitment from suppliers, inspired, among other things, by the international provisions of the UN Universal Declaration on Human Rights, the Declaration on the Fundamental Principles and Rights at Work and the Conventions issued by the International Labour Organization (ILO) and the Ten Principles of the UN Global Compact, in addition to the contents of the UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises.
  • Technical audits on suppliers and contractors during qualification and normal business in order to guarantee proper working conditions (and therefore the absence of forced and child labour, respect for the freedom of association and collective bargaining, the absence of discrimination, the respect for disabled workers in accordance with national legislation and respect for foreign/immigrant labour).
  • Supplier awareness campaign for the achievement of SA8000 (Social Responsibility).
  • Presence and update of whistleblowing channels and dedicated procedures in order to guarantee and manage adequately any violation or potential report regarding human rights.
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