Code of Ethics

The Code of Ethics is a company social responsibility tool, a reference point and a guide for those working for Hera and those interested in pursuing its mission. The Code of Ethics is designed to shape the management of the Group according to the ethical values and operating principles defined in the Charter of Values, to promote unique guidelines for conduct targeted at meeting the needs of stakeholders and consolidating a positive company image.

In 2010, at the end of the experimental three-year period (started in 2008 with publication of the document), the company checked the document was up-to-date, coordinated by the Ethics and Sustainability Committee, the body responsible for the dissemination and implementation of the Code’s contents. In 2013, the company checked again the document was up-to-date.

The third update to the Code of Ethics was approved by the board of Directors of Hera S.p.A on 15 February 2017.

Since 2006 supplier qualification and assessment checks the technical, economic, and organisational quality requirements, compliance with environmental and safety regulations and corporate social responsibility requisites, as well as acceptance of the Group Code of Ethics.

Ethics and Sustainability Committee

The Ethics and Sustainability Committee, appointed by Hera S.p.A.’s Board of Directors on 14 May 2008, is responsible for monitoring the dissemination and implementation of the Code of Ethics.It receives reports on breaches of the Code, assessing whether or not it is possible to open proceedings.

At the meeting of Hera S.p.A.’s Board of Directors (renewed on 27 april 2017) on 10 may 2017 the company again appointed the members of the Ethics and Sustainability Committee.

The Ethics and Sustainability Committeeis composed as follows:

Federica Seganti, Director's Board of Hera S.p.A.
Massimo Giusti, Director's Board of Hera S.p.A.
Filippo Bocchi, Head of Hera S.p.A.’s Shared Value and Sustainability Department
Mario Viviani, company social responsibility expert (external member).

At the meeting on 9 June 2017, the Committee elected Massimo Giusti as Chairman.

Reports to the Committee

Reporting to the Ethics and Sustainability Committee (Whistleblowing)

In 2018, the Ethics Committee examined overall 18 reports. Ten reports were received from employees, 7 from customers and 1 from suppliers; the Ethics Committee has examined 223 reports since 2008.

The 10 reports of the employees concern the relationship between colleagues and between manager/workers, the collaboration between company departments and the communication to the employees, the valorisation of the human resources, the safeguarding of the individuals and equal opportunities and the work environments. With regard to seven reports, in the preliminary investigative phase, the Ethics and Sustainability Committee assessed the need to involve the Central Personnel and Organisation Department as well as the reference structures of the reporting party. In five cases, within the sphere of the preliminary investigation of the report, the Committee contacted/met the person making the report. Four reports as of 31 December 2018 were not yet concluded while for one the Ethics and Sustainability Committee resolved not to proceed with the opening of the preliminary investigative phase due to limits of the competence of the Committee (Art. 70). Consequent to one report, the Committee resolved to adopt a disciplinary measure vis-à-vis a worker who was responsible for seriously offensive conduct vis-à-vis the party making the report.

Customerreports regarded the commercial conduct of sales agencies and the response times and/or the time required to carry out the services (payment instalments, termination of supply, invoicing adjustments). With regard to one report, the Ethics Committee requested Hera Comm to include the failure to observe the principles of the Code of Ethics among the clauses for termination of the agency mandate. With regard to five reports, thanks to the collaboration of the structures involved, a positive response to the request of the customers was achieved. With regard to one report, the intervention of the Ethics and Sustainability Committee led to the formulation of a reply clarifying the position of the company.

The only report from suppliers did not lead to any preliminary investigation since, in agreement with the Procurement and Tenders Department, the firm in question was included in the 2018 suppliers audit plan, drawn up in accordance with the matters envisaged by the integrated management system.

Page updated 5 April 2019