ESG / Sustainability Report / 2022 ESG / Sustainability Report / 2022 internal control and risk management system and the topic Furthermore, particularly with reference to conflicts of human rights and labor, equal opportunities and inclusion: facts reported. Furthermore, to support the organization of of sustainability. One of the Committee’s responsibilities interest, the company does not have an internal policy the protection of employees and collaborators from activities, the Technical Secretariat of the Whistleblowing is to examine the Sustainability Report prepared every formally governing the management of these cases. all discriminatory conduct linked to ethnicity, national, Committee will be established. year by Engineering, in addition to expressing opinions on Nonetheless, within the Board of Directors, any conflicts regional or social origin, religion, disability, gender, sexual annual and multi-year sustainability targets and monitoring of interest are managed in compliance with regulations in orientation, family responsibilities, civil status, trade The 231 Organization and Management Model is subject national and international initiatives and best practices on force. In 2022, there were no communications of conflicts union membership, political opinions, age or any other to continuous updates (the most recent one dates back to sustainability, reporting to the BoD in this regard.of interest to stakeholders.condition which could give rise to discrimination. These January 2021), which reflect the regulatory evolution of the For years now ESG topics have also played an important principles are aligned with the SA8000 Ethics Certification Decree, changes in case law and legal theory, experience role in business strategies, requiring the increasing With regard to remuneration, while for the BoD it is management system, explicitly referring to observance of gained and changes in the company’s organization. involvement of the top management. In particular, in 2022 defined by the shareholders’ meeting, for the rest of the the conventions of the International Labor Organization the leadership team dealt with sustainability aspects top management, until 2022 there was no consolidated (ILO), the Universal Declaration of Human Rights and In 2022, the risk analysis was performed for the Parent by discussing materiality analyses and evaluating ESG internal process in place or benchmarking with the national legislation on labor and non-discrimination.Company, considering the types of offense pursuant to certification pathways.external market. To handle this situation, during 2022 an Italian Legislative Decree 231, correlating them with the in-depth analysis was performed with the involvement of An additional tool for spreading an ethical approach is the company’s internal processes. The establishment of the Control, Risks and Sustainability roughly 12,000 employees and 60 managers, aimed at Policy for the Prevention of Corruption, which applies to all Committee represents an additional guarantee that formally defining the company’s job architecture. On the Group companies and is an integral and substantial part of In September 2023 an Integrated Risk Assessment Engineering offers to stakeholders on its assumption strength of this widespread and precise structure, starting the Organization and Management Model (“231 Model”). project will be launched which will also consider, inter of responsibility to comply with the ESG-related values from 2023 Engineering is able to assign a specific rank alia, risks relating to the types of offense pursuant to of ethics and transparency. Engineering has also to each employee in order to more easily evaluate their Engineering has implemented a whistleblowing process. Italian Legislative Decree 231, the results of which will be outlined specific methods for managing relationships position with respect to the external market and assign Anyone who becomes aware of facts that may constitute considered for a new update of the 231 Model. Ethics and governance with customers, which are formalized in the “Customer remuneration to each that is as suitable as possible for their a breach of the Code of Ethics, laws or company policies, Complaint Management Procedure”, updated during 2021. skills.or can generate potential harm for occupational health and The Code of Ethics, the Policy for the Prevention of safety or the environment, is required to report them to Corruption and the 231 Model are published on the This procedure allows for the proper management of There are also specific pay policies linked to objectives and the organization through the established whistleblowing company website, are visible to all (via the internet and complaints received from customers, supporting a good performance in place for the top management. In particular, channels disclosed according to the methods established the intranet) and are disseminated and illustrated to new communication process from outside to inside the confines short-term (MBO) and long-term (LTI) incentives have been by law, also in anonymous form. hires during training sessions dedicated to apprentices. A of the company, accompanying the implementation of an defined which, however, at the moment are not yet linked total of 265 apprentices participated in the various training internal process of continuous improvement while focusing to ESG topics.In the course of 2022, the Supervisory Body received and sessions held in 2022. the Group’s attention on any critical issues identified, analyzed one whistleblowing report. Ethics and governancetowards which it should direct its efforts. Any corrective In general, all Engineering Group employees are required actions are then managed on the basis of a dedicated Our structure for monitoring legalityAs part of the process of continuous improvement and in to attend training sessions relating to the 231 Model, the corrective and preventive action management procedure.compliance with Group governance, in 2023 innovation Anti-Bribery Management System and the Privacy Code. was promoted in the process of receiving and managing The data for 2022 on the attendance of such courses, To confirm the strong and increasing oversight of ESG GRI 2-26 2-27reports for the communication of conduct enacted in made available in web training mode and accompanied by topics, on January 1, 2022 a Chief Sustainability Officer violation of the principles of ethics and conduct, laws and final tests on knowledge, are provided below. (Chief Group Public Affairs, Corporate Communication & Engineering has always believed that ethics and integrity company procedures, aligning it with best practices on Sustainability) was also appointed who, in coordination with represent the necessary prerequisites of its business the matter and the new regulatory aspects introduced by the Chief Executive Officer, handles the implementation activities. Indeed, the Engineering Group operates in full Italian Legislative Decree no. 24/2023 in implementation Course Title Attendance in 2022 of the Company’s ESG policies and the management of compliance with laws in force and according to approaches of European Directive 2019/1937. The Decree introduces sustainability impacts. that protect the personal and financial rights of all the new whistleblowing regulations and combines Transversal Apprentice Training 265 stakeholders.within a single regulatory text the entire set of rules on L. Decree 231/2001_2 961 In 2022, a year in preparation for the full establishment whistleblowing channels and the protections recognized to Anti-corruption 3,169 of ESG governance, no performance assessments In October 2022, the Engineering BoD approved a new whistleblowers in the public and private sector.Privacy 989 were carried out on impact management for the Chief version of the Code of Ethics, which defines rights and Cyber Security 8,595 Sustainability Officer or for the BoD. fundamental duties and establishes the ethical and social With this aim, Engineering has established the Group values and responsibilities (internally as well as external Whistleblowing Committee, with the duty of examining all Communications on impacts from the Chief Sustainability to the company) respected and applied by employees, reports while ensuring the confidentiality of the information Officer to the Board of Directors are not sent regularly, but executives, directors, members of the Board of Statutory they contain and with a view to confirming or otherwise the are transmitted when deemed necessary or in conjunction Auditors, members of the Supervisory Body, temporary with CRSC meetings. In the course of 2022, there were or ongoing external collaborators, partners, suppliers no communications about significant problems relating to and customers. The updates made bear witness to and impacts on sustainability. confirm our focus on and monitoring of topics relating to 62 Engineering © Engineering © 63