Code of ethics

What Is the Code of Ethics

The Code of Ethics was first published in 2007 and is revised every three years with the involvement of people of Hera and selected stakeholders. It represents a trust-based agreement and outlines the ethical conduct expected of everyone who contributes to the company’s activities in any capacity, in line with Hera’s values and principles. It serves as a guide for those who wish to actively pursue the Group’s purpose and mission.

The Code sets forth the commitments and responsibilities that people of Hera undertake in carrying out all company activities.

The Code of Ethics: our guiding principle

The importance Hera places on the Code of Ethics stems from its recognition of the benefits it brings in three key areas: increased internal cohesion and consistency in individual behavior, which in turn lead to greater organizational efficiency and a positive corporate reputation among its stakeholders.

The Code of Ethics, based on Article 8 “Validity of the Code,” establishes a three-year validity period for the document, at the end of which it is subject to review and possible revision.
Following the first review in 2010, triennial updates have been implemented, leading to the current sixth revision of the document.

In this latest update of 2026, greater emphasis has been placed on topics such as the digital transition and artificial intelligence, the company’s social role, the importance of dialogue and trust between Hera and local communities, and Hera’s environmental responsibility in its commitment to Net Zero emissions, circular economy, resource regeneration, and resilience of managed services. Furthermore, with regard to Hera’s people, the value of intergenerational dialogue has been affirmed, along with the importance of the link between well-being, professional and personal development, and productivity. Finally, it was deemed necessary to emphasize everyone’s role in the implementation and dissemination of the Code.

Code of Conduct – Supplier Sustainability Agreement

The contents of the Code of Ethics constitute the foundations of the "Code of Conduct – Supplier Sustainability Agreement".
By way of a true sustainability pact, Hera asks its suppliers to share the same ethical references, in order to reach a correspondence between Hera’s commitments and those taken on by its suppliers, from the shared perspective of creating shared value and protecting the environment and people.

Reporting to the Ethics and Sustainability Committee

In 2025, the Ethics and Sustainability Committee received six reports: three from employees, two from customers, and one from a supplier. The issues reported by employees related to the following articles of the Code of Ethics: 6 – Responsibility for disseminating and implementing the Code, 12 – Valuing diversity and commitment to inclusion, 26 – Protection of individuals and relationships between colleagues, 32 – Listening, dialogue and engagement, 33 – Protection of health and safety, 50 – Working conditions, health and safety of suppliers’ workers, and 57 – Environmental initiatives. The issues reported by customers, on the other hand, related to the following articles: 12 – Valuing diversity and commitment to inclusion, 19 – Attention to customer needs, 21 – Quality, continuity and safety of service, and 23 – Fairness in contracts and business relations. The issue reported by the supplier related to Articles 53 – Selection criteria and tenders and 54 – Fairness in the management of contracts.
It is specified that reports are handled by protecting the confidentiality of the identity of the whistleblower, who must be informed that information and testimonies given may, with consent, not remain confidential for the purposes of carrying out investigations.
With regard to sustainability activities, in accordance with the agreed work plan, during 2025 the Committee:

• Reviewed the Sustainability Statement in advance of its submission to the Board of Directors, including the results of the double materiality assessment;
  
• Supervised the work on the three-yearly update of the Code of Ethics – 7th edition.
  Furthermore, it shared and deepened
  
• the Code of Conduct – Sustainability Pact with Suppliers;
  
• thematic sustainability reports: In Good Waters, Tracking Waste, Creating Shared Value;
  
• the 2025 Green financing framework;
  
• sustainability training activities, including those related to the Code of Ethics;
  
• the functions of Sustainability Committees in other Italian and foreign companies.

During the first sessions in 2026, the Committee shared the repercussions on reporting of the double materiality assessment and the main contents of this Sustainability Statement. Finally, again in 2025, the annual meeting with the Supervisory Board was held to discuss common issues for effective and mutual cooperation.

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