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Code of ethics

TESTATA Codice etico

Code of ethics

Contenuto 1 - Code of ethics

The Code of ethics: our reference point

Our company purpose is embodied in the Code of ethics, which is a reference point for us and all the people we work with. The Code of Ethics contains the goals we strive for and was adopted by all our subsidiaries in 2007.

What is a Code of ethics?

A Code of ethics is one of the instruments of a company’s corporate responsibility. It is instrumental in implementing practices of good conduct, a reference point, and a guide for all those who work at Hera and those who have stakes in its achieving its purpose and mission.

It expresses the commitments and responsibilities Hera employees assume in executing all company activities.

It aims to direct individual behaviour and the management of activities according to the purpose, the mission, the ethical values and operating principles defined to build a positive corporate reputation through unequivocal behaviour and the satisfaction of stakeholder needs.

As per Article 8 "Validity of the Code", a Code of ethics is valid for three years, after which it must be reviewed and revised if necessary. After the first review in 2010, the second update was carried out in 2013, the third in 2016, the fourth in 2019 and the fifth in 2022.

A fair environmental and digital transition, the personal and professional well-being of the people working at Hera, the care for our most vulnerable customers and the importance of dialogue and listening are also some of the elements that characterise the latest update of the Code, which saw the involvement of all the Hera Group's workers.

Our goal

The goal of our Code of ethics is to foster virtuous behaviour for the benefit of Hera people, customers, suppliers, investors, communities and the environment and to strengthen our reputation.
As required by the Qualification System, since 2006 we have shared our Code of ethics with all our suppliers: in fact, the contracts drafted by the Group' companies include termination clauses in the event of failure to comply with its principles.

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Contenuto 2 - Code of ethics

Ethics and Sustainability Committee

The Ethics and Sustainability Committee has the task of monitoring the dissemination and implementation of the Code of Ethics and of exercising the functions of supervising the sustainability aspects associated with the exercise of the company's business. In particular: receives reports of violations of the Code and evaluates whether or not a proceeding can be opened, monitors the implementation of sustainability policies, formulates, at the request of the Board of Directors, an opinion on specific sustainability issues, examines the corporate procedures on social and environmental matters, and examines in advance the sustainability report to be submitted to the Board of Directors.

Who is it composed of?

The Committee is made up of 4 members, including at least one independent director of Hera Spa, the Director of the Shared Value and Sustainability Department and at least one external member who is an expert on social responsibility and sustainability.

In the meeting of the Board of Directors of Hera S.p.A. of 10 May 2023, the members of the Ethics and Sustainability Committee were appointed:

  • Alice Vatta, Director of Hera S.p.A. with the functions of President
  • Francesco Perrini, Director of Hera S.p.A.
  • Filippo Maria Bocchi, Head of the Shared Value and Sustainability Department of Hera S.p.A.
  • Nicoletta Tranquillo, expert in corporate social responsibility (external member)

who will remain in office until the date of approval of the Financial Statements for the year 2025.

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Contenuto 3 - Code of ethics

Reporting to the Ethics and Sustainability Committee

N. 2020 2021 2022 2023
Workers 3 3 5 7
Customers 5 3 2 5
Suppliers 3 1 1 0
Other stakeholder 6 0 1 2
Total 17 7 9 14


In 2023 the Ethics and Sustainability Committee received 14 reports. Seven reports came from workers, five from customers and two from other stakeholders; 285 reports have been examined by the Ethics and Sustainability Committee since 2008.

The seven reports from workers concerned compliance with current environmental regulations for two company offices, remote-working management also relating to specific cases (workers with children under 14 and compatibility with law 104/1992), overtime, holidays and sharing of individual performance by the manager with their team, job enhancement, diligence and efficiency in the use of company resources, work-life balance and communication between managers and employees. The reports received from workers at 31 December 2023, were all closed with the exception of the report received in December. The Committee’s contribution consisted of: verifying the compliance of the behaviours reported with the Code of Ethics, in one case facilitating dialogue between workers and their Department, in another case, directing the Department towards the right channels, in particular the Whistleblowing channel, which is also for environmental offences within the scope of law 231.

The five reports received from customers were related to the clarity and completeness of communication with customers, the fairness of trading practices, the attention paid to customer needs, the continuity of service and the relationship with the customer. The reports received from customers at 31 December 2023 are all closed. The Committee’s contribution, in summary, consisted of: evaluating the findings of Hera Comm (and EstEnergy) that were not fully compliant with the principles of the Code of Ethics and suggesting an increase in clarity, completeness and proximity to the customer when responding to complaints, as well as evaluating the potential of increasing the efficiency and effectiveness of direct telephone contact with the customer with the aim of avoiding repeated complaints. The Committee successfully facilitated dialogue between the whistleblower and the company, reassuring the whistleblower of the Group’s focus on the fair trading conditions of its sales agencies.

The two reports received from residents (other stakeholders) were related to the topic of waste service management. The Committee found no violations for one report and for the other it found no link to the Code of Ethics.

In particular, it should be noted that no violations were found in relation to: corruption, discrimination and harassment, customer privacy data, conflict of interest, money laundering and insider trading.

The Committee maintained a high level of interaction and collaboration with Departments/Companies, always aimed at identifying and sharing, where possible, opportunities for improvement, as well as promoting good corporate practices even externally.

The Committee, whose members changed in 2023, followed its work plan relying on the support of the Shared Value and Sustainability Department.

In 2023, in line with the shared work plan, the Committee discussed the sustainability report project by validating the materiality analysis and examining the main contents before the Board of Directors, and it examined the specific sustainability reports “In buone acque” (In good waters)” and “Sulle tracce dei rifiuti (Tracking Waste)”, and it explored the new elements of the CSRD (Corporate Sustainability Reporting Directive) and the related ESRS (European Sustainability Reporting Standards) application standards.

How to make a report

The Ethics and Sustainability Committee is the Group's channel responsible for collecting any reports regarding possible conduct that does not comply with the Code of Ethics.
Reporting to the Ethics and Sustainability Committee: how to make a report

The Whistleblowing reporting portal is the Group's channel responsible for collecting any suspected violation of the Model for the prevention of corruption, alleged crime, fraud, corruption or other offence of a relevant nature.

The Whistleblowing reporting portal is the Group's channel responsible for collecting any suspected violation of the Model for the prevention of corruption, alleged crime, fraud, corruption or other offence, whether or not relevant for the purposes of liability pursuant to Legislative Decree 231/2001 or any other information useful for the purpose of preventing crimes.

Reporting to the Whistleblowing Reporting Portal: how to make a report

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Page update on 27 June 2024

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