Ethics at the A2A Group

The Code of Ethics sets out the values and principles that guide the A2A Group in providing essential services that improve people's quality of life across the energy, water and environmental sectors. At its core is the recognition of the fundamental role of people, supported by a clear commitment to protecting human rights, developing skills and expertise, safeguarding health and safety at work, and protecting the environment, local areas and communities.

In line with this approach, the Group also regards the protection of personal data as an essential element of trust and responsibility. Personal data are processed in compliance with applicable legislation and with individuals' fundamental rights and freedoms, through appropriate measures designed to ensure security, confidentiality and lawful processing.

The same principles underpin the Group's governance of artificial intelligence. The A2A Group promotes and uses AI in accordance with the principles of transparency, accountability, security and a people-centred approach. To this end, A2A has established dedicated governance arrangements and internal rules to ensure that artificial intelligence is used in compliance with applicable legislation, the Group's ethical principles, cybersecurity standards and personal data protection requirements.

Within this framework, the Group has adopted a policy governing the cataloguing and classification of applications that use artificial intelligence systems, ensuring their visibility, ongoing monitoring and assessment of the associated risk profiles, in line with the European regulatory framework. Supporting processes have also been introduced to identify, review and continuously update AI solutions, together with dedicated tools to manage and track compliance obligations.

The Group has also adopted a policy governing the corporate use of generative artificial intelligence, with the aim of promoting its innovative, effective and responsible use while safeguarding information confidentiality, data security, compliance with applicable legislation and the rights of individuals. Among other aspects, the policy establishes the authorisation criteria for approved AI tools, the rules governing the management of AI inputs and outputs, and the responsibilities associated with their use.

To complete this governance framework, the Group promotes training and awareness initiatives for its people, aimed at fostering a culture of responsible innovation and strengthening understanding of both the opportunities and the risks associated with artificial intelligence. The Group also carries out continuous monitoring of regulatory and technological developments and has established dedicated control and reporting mechanisms to oversee the appropriate use of AI tools.

Through these initiatives, A2A aims to ensure that the development and use of artificial intelligence contribute to the creation of sustainable value while fully respecting fundamental rights, human dignity, fairness, inclusion and non-discrimination, which underpin the Group's way of operating.

Particular importance is also attached to relationships with suppliers, consultants and business partners, who represent a key part of the Group's value chain. Their selection and management are based on the principles of transparency, fairness and impartiality, with particular attention to health and safety, environmental protection, human rights and decent working conditions, while actively preventing all forms of exploitation. Compliance with the principles of the Code of Ethics and with the Group's standards of responsibility and sustainability forms a specific contractual commitment, including through the signing of a dedicated Integrity Pact.

To ensure that these principles are fully embedded in day-to-day operations, the Group promotes continuous training, recognising that the dissemination of an ethical culture is essential to ensuring responsibility, consistency and integrity across the organisation.

The A2A Group firmly rejects any conduct that may constitute, encourage or facilitate corruption in any form. Preventing corruption is an integral part of the Group's identity: it is not only a legal obligation but also a clear commitment to integrity that protects the Group's reputation, strengthens organisational credibility and contributes to creating a fair, transparent and responsible working environment.

Within this framework, the Anti-Corruption Policy clearly defines what constitutes corruption, the different forms it may take, and the principles and standards of conduct to be adopted to prevent, identify and address it.
 

The Policy focuses in particular on activities that are more exposed to corruption risk, including dealings with Public Administration, relationships with suppliers and business partners, the management of gifts, sponsorships and charitable donations, as well as recruitment and selection processes. For each of these areas, it identifies the expected behaviours and the relevant internal rules that translate the Policy's principles into operational measures and specific controls.

Training also plays a central role in this area. Raising awareness, strengthening the ability to recognise corruption risks and promoting consistent behaviours are essential to ensuring that the principles of the Policy are properly understood, shared and applied throughout the organisation. To support this objective, dedicated training courses are provided on a regular basis, tailored separately for operational and non-operational personnel, with ongoing monitoring of participation and understanding. In particular, the course designed for non-operational employees includes, within the module on offences against Public Administration, a dedicated section on the Anti-Corruption Policy aimed at reinforcing awareness of the expected standards of conduct.

Respect for human rights is a fundamental ethical commitment for the A2A Group, underpinning all its business activities and shaping the way it engages with its people, local communities, customers and business partners.

The Human Rights Policy is based on internationally recognised principles and standards relating to human rights, labour, business ethics and corporate responsibility, translating them into practical objectives and behavioural principles. Within this framework, the Group promotes safe, fair and inclusive working conditions, opposing all forms of discrimination, violence, harassment, forced labour and child labour, while safeguarding the health, safety and freedom of association of every individual.

The Group's commitment also extends throughout its value chain. Suppliers and business partners are expected to share and uphold these principles, which represent an important consideration in the selection, qualification and management of third parties.

A2A monitors over time its human rights impacts and the related risks, integrating them into its governance and management processes. The Group also promotes training and awareness initiatives to strengthen, at every level of the organisation, a culture founded on respect, responsibility and the dignity of every individual.