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Ethics Committee

The Ethics Committee, appointed by Hera S.p.A.ís 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 Committee.
The Ethics Committee is composed as follows:

Massimo Giusti, Director's Board of Hera S.p.A.
Filippo Bocchi, Head of Hera S.p.A.'s Corporate Social Responsibility 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

Reports to the Ethics Committee
Other stakeholders6111000

In 2016 the Ethics Committee examined overall 22 reports.

The 7 feedback reports from workers can be categorised under 3 main headings: those focusing on internal customers and workers, worker response times and the relationship between colleagues.

In 6 cases, the Ethics Committee met/contacted the worker in order to investigate the report. In 2 of them, the Committee made recommendations to the sites involved on the need to provide a reply to the internal client and on the urgency of promoting dialogue between workers. For 6 of the reports, the Committee has been promoting solutions with the involvement of the sites involved and/or has encouraged collaboration and dialogue between those involved. In the remaining case, the Committee furnished a reply clarifying the query raised.

Reports from customers, which rose from 11 in November 2015 to 14 in 2016, involved 4 main issues, including estimated bills, the conduct of sales agency personnel, timescales for responding and/or delivering services, and communications that were not always clear and easy to understand. When handling the reports, the sites and companies concerned were always involved: Hera Comm, AcegasApsAmga and INRETE Distribuzione.

For 3 of the reports, the Committee held a meeting providing in-depth guidance on how sales agencies should manage databases.

For another 3 cases, the Ethics Committee sent the recommendations to the relevant directors/companies involved to encourage greater collaboration between the company's departments and with the aim of providing prompt and satisfactory feedback to the customer.

The Committee was also involved in running two seminars for raising awareness of corporate responsibility, involving the participation of more than 23 workers.


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

The Committee has also been involved in running two seminars for raising awareness of corporate responsibility, involving the participation of more than 23 workers.

  • Violations can be reported verbally or in writing to the Ethics Committee as a whole or to one of its members. The Committee ensures the confidentiality of the identity of the whistleblowers.

    It is not the job of the Committee to give an opinion on the interpretation of the law or contractual clauses, and so if the matter presented to the Committee falls within this domain, it defers the case and its handling to specific management bodies, communicating this to the person that submitted the report.

    Based on the report received the Committee assesses whether to begin proceedings, archive the report or defer the case to the competent company department.

    The whistleblower is duly informed in each of these cases. If proceedings are opened, the Committee has 60 days to reach a decision.

    The opening of proceedings involves recording in the appropriate register and the performance of investigations. As regards the execution of these investigations, the Committee may avail itself of the support of other departments or company individuals and witnesses, including Hera employees. Witnesses shall be informed that their testimony may be disclosed.

    At the end of the investigations, the Committee can issue the judgment of a breach or non-breach which may concern an employee or one or more organisational areas. The recognition of a breach by the Committee may derive from an official reprimand which may be written or verbal, and which may involve a level of publicity deemed suitable by said Committee (for example, in order to underline the negativity of conduct that was deemed widespread plus the individual case). The Committee presents the results of its judgment to the whistleblowers.
    The Committee may also officially proceed with the opening of proceedings.

    The actions of the Committee are periodically communicated to Hera S.p.A.'s Board of Directors and, each year, the Committee proposes an information and training plan to the Board on the contents of the Code aimed at its recipients.

Page updated 5 April 2019

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