Acea S.p.A.

Reference: page 77

The Acea SpA Board of Directors has 13 members: 7 men (54%) and 6 women (46%), with 12 Italian and 1 French. Three members are aged 30 to 50 and 10 are over 50; 10 members (77%) qualify as independent. Only the Chief Executive Officer holds executive positions. Members generally have experience in the Group's energy, water and environmental sectors. Acea adheres to the Corporate Governance Code of Borsa Italiana. The Board defines the guidelines of the Internal Control and Risk Management System so that the main risks, including sustainability risks relevant over the medium to long term, are identified, measured, managed and monitored. The Board has set up three internal committees: the Appointments and Remuneration Committee, the Control and Risks Committee, and the Ethics, Sustainability and Inclusion Committee (ESIC), which provides preliminary, propositional and advisory support on environmental, social and governance topics. The Board also holds specific sustainability competencies, including in the energy transition and climate impacts.

Reference: page 77

At committee meetings, members are updated on sustainability issues relevant to the Group, ongoing actions and developments such as the adoption of policies and the implementation of operational plans. During the year, the Ethics, Sustainability and Inclusion Committee and the Control and Risks Committee addressed topics in terms of impacts, risks and opportunities, including equality, diversity and inclusion, occupational health and safety, business ethics, sustainability in the supply chain, corporate welfare, the sustainability plan, the double materiality analysis, sustainability reporting processes, integrated management systems reporting, anti-corruption, antitrust and consumerism. The ESIC promotes the integration of sustainability into strategy and culture and monitors implementation of the sustainability plan approved by the Board. During 2024, the Chairperson and the Chief Executive Officer prepared a training programme for the Board, including two induction initiatives with external experts focused on the Corporate Sustainability Reporting Directive and its impact on the Acea Group.

Reference: page 78

Acea links variable remuneration to social and environmental results and has strengthened the integration of sustainability into incentive plans. The short-term variable incentive (MBO) scheme and the second cycle of the 2024-2026 Long-Term Incentive Plan have a composite sustainability objective. A 20% share is linked to the composite sustainability target for the 2025 MBO and the second cycle of the 2024-2026 plan. Indicators in the 2025 MBO plan include a reduction in the accident frequency index, optimisation of sewage and water treatment, increased remote control of medium-voltage secondary substations, and increased plastic sent for recovery. The 2025-2027 Long-Term Incentive Plan indicators cover gender diversity representation, a reduction in water leaks, a reduction in sludge production, and increased resilience and upgrades to the low-voltage network. Final results are presented to the Nomination and Remuneration Committee before approval by the Board of Directors. The report also discloses final achievement figures for the 2024 MBO and the 2021-2023 LTIP.

Reference: page 80

Acea is committed to implementing the duty of care to identify, prevent and mitigate the actual and potential negative impacts generated by the operations and business relations of Group companies. The Human Rights Policy sets out Acea's commitment to a due diligence process which, through dedicated tools such as second-level controls and risk mitigation measures, aims to integrate human rights issues into the risk assessment and management model and strengthen the Internal Control System. The Integrated Management Systems and Sustainability Policy reaffirms the commitment to identifying, preventing, mitigating and stopping negative impacts on human rights and the environment. As part of its impact materiality analysis, Acea involves stakeholders from different categories in assessing impacts, including potential negative impacts generated externally. The report provides a table mapping the core elements of the duty of care, including integrating it into governance, strategy and the business model, involving stakeholders, identifying and assessing negative impacts, intervening to address them, and monitoring effectiveness, to the relevant paragraphs of the sustainability report.

Reference: page 81

In 2024, Acea started a process to adapt to Italian Legislative Decree 125/2024 by defining and gradually implementing a risk management and internal controls model on sustainability reporting, aimed at ensuring the reliability of the reporting and its compliance with reporting standards. The Internal Control System on Sustainability Reporting (SCIIS) supports the CEO and the Financial Reporting Officer in issuing declarations on compliance with the ESRS and the EU taxonomy. The SCIIS Model is based on the framework of the Committee of Sponsoring Organisations of the Treadway Commission (the CoSO Report) and its 2023 supplementary guide on sustainability reporting. The methodology identifies the universe of data points subject to disclosure, then assesses and prioritises KPIs through a risk and relevance analysis. Main risks identified in 2024 concerned data completeness and integrity, accuracy of estimates and descriptions, availability and timeliness, authorisation and legal compliance. Controls include approval and management reviews, data reconciliation, automatic checks, and access controls. The process was also digitised using the same application as the Consolidated Financial Statements.

Reference: page 82

Acea is one of the leading Italian industrial groups, listed on the stock exchange since 1999, and pursues sustainable success through appropriate policies, management systems and planning and reporting tools. Its operating model supports strategic lines based on growth in the water market, the resilience of the electricity grid and service quality in the city of Rome, the development of renewable capacity for the energy transition, and the push towards the circular economy. The Parent Company provides guidance and coordination to the operating companies and offers managerial, legal, logistical, technical, financial and administrative services. The Group operates in the water, networks and public lighting, environment and energy industrial chains. At 31 December 2024 the Group had 8,715 employees, of which 7,376 in Italy and 1,339 in Latin America. For the value chain, as the first year of CSRD application, qualitative mapping was carried out of the main upstream and downstream relationships across the Environment, Water, Networks and Public Lighting, Production and Commercial business areas.

Reference: page 90

Acea's organisational structure is based on the principles and values of stakeholder engagement and serves as a centre of specialist competence at Group level. The stakeholder engagement process is regulated by a Group procedure and adheres to the Global Reporting Initiative Standards and AA1000 SES. Tools include the Stakeholder Tree, a mapping of relevant stakeholders developed through analysis of the Group's relational network and the involvement of senior figures and those with operational responsibilities. The Tree is divided into categories and sub-categories such as shareholders and investors, workers, suppliers, customers, citizens, institutions, business partners, new generations and others. The process begins with defining the subject and objectives, identifying and prioritising stakeholders, choosing forms of engagement such as information or consultation, planning, and operationalising activities. Engagement initiatives look for common benefits for both Acea and its stakeholders, including the younger generation, employees and suppliers. At the end of the process a review is carried out and feedback is provided to stakeholders, following the principles of inclusiveness and accuracy.

Reference: page 92

As a result of the double materiality analysis, all ESRS environmental, social and governance issues were found to be material. The remainder of the document provides the disclosures for the different topics with details of policies, strategies, objectives, actions, resources and metrics, as required by the ESRS standards. To quantify the current financial effects of material risks and opportunities, the Acea Group verified the actual occurrence during the year of events corresponding to the scenarios in question and the associated cost and revenue items, assessing them in relation to the ERM financial materiality threshold. The representation of material impacts, risks and opportunities is detailed in each pertinent thematic ESRS. For 2024, no relevant significant ESG risks and opportunities were found. As 2024 was the first year of application of the regulation, information on the expected financial effects has been omitted using the phase-in option. The double materiality process and its outcomes were shared with the relevant committees and approved by the Board of Directors of Acea S.p.A.

Reference: page 92

In 2024, the Acea Group carried out its double materiality analysis in line with the ESRS standards and EFRAG's Materiality Assessment Implementation Guidance, based on the dual perspective of impact and financial materiality. The analysis was led by the Parent Company with the involvement of sustainability and risk owners of the companies concerned. The process involved understanding the context, identifying potentially relevant issues, impacts, risks and opportunities, impact materiality assessment, financial materiality assessment, and aggregation of results into a list of material IROs. Context was understood by studying external documents such as regulatory developments and benchmarks, and internal documents such as the industrial and sustainability strategy. For impact materiality, a multi-stakeholder focus group of 32 people representing 11 stakeholder categories was organised, divided into 6 work tables led by independent facilitators. Stakeholders rated significance on a 1-5 scale, re-weighted to 1-4. For financial materiality, the methodology of the Group's Enterprise Risk Management process was used, considering impact and probability. The process concluded that all ESRS issues were material.

Reference: page 160

The Annex provides a list of indicators subject to reporting for 2024, defined on the basis of the double materiality analysis with the involvement of the operating companies and Holding company managements and functions, to provide a meaningful representation of all Group businesses. The list maps each ESRS disclosure requirement to the page where it is reported. ESRS 2 cross-cutting requirements covered include BP-1 and BP-2 (page 76), GOV-1 and GOV-2 (page 77), GOV-3 (page 78), GOV-4 (page 80), GOV-5 (page 81), IRO-1, IRO-2, the MDR disclosures on actions, policies and targets, SBM-1, SBM-2 and SBM-3. The list also covers the thematic standards found material: environmental standards ESRS E1 to E5, social standards ESRS S1 to S4, and governance standard ESRS G1, together with entity-specific indicators such as water treated at treatment plants, total Group water losses and total drinking water leaving the aqueduct system.

Reference: page 101

Acea's climate strategy for mitigation envisages a process to reduce climate-altering emissions with a 'Well below 2 degrees C' target, validated by the Science Based Targets initiative (SBTi) and aligned with the trajectories of the Paris Climate Agreement. Targets are aligned with the EU Paris-Aligned Benchmarks, envisaging a reduction in emission intensity of more than 50% from the baseline year and formalised targets on Scope 3 emissions. The commitment was not formalised through a specific 'Climate Change Mitigation Transition Plan' as defined by the ESRS, but was presented to the Board of Directors as part of the Business Plan, of which it is a basic element. The current commitment includes targets to 2032 and will be supplemented in 2025 with climate neutrality targets to 2050. Locked-in emissions are mainly from waste-to-energy plants amounting to approximately 293,000 tonnes of CO2 in 2024. Feasibility studies on CCSU (capture and storage) are underway, with an initial pilot plant planned at the new Santa Palomba waste-to-energy plant.

Reference: page 104

Climate change is a priority for the Acea Group, which is committed to identifying, assessing, managing and, where possible, reducing the impacts and risks generated by its operations or those across the value chain, in terms of both mitigation and adaptation. The Group has formalised a number of commitments over the years. The Code of Ethics defines climate change commitments within the broader sense of 'environmental protection and enhancement', aiming to define a mitigation and adaptation strategy that includes measures to make energy use more efficient, enhance and exploit renewable sources, and increase infrastructure resilience. The Group's commitment is also confirmed in the 'Integrated Management Systems and Sustainability Policy', corresponding to the call for specific focus on this issue in all technical management regulations expressed by the ISO standard setter. Being aware that climate change impacts could affect the protection of human rights, Acea reaffirmed its commitments in the Human Rights Policy. Group policies are described in Section 1.6 of the document.

Reference: page 105

The objectives and investments envisaged in the Sustainability Plan until 2028 are reported with progress at 31.12.2024. For actions related to the strategic lines, only capex was monitored, as opex represents a non-significant portion. Strategic works in water and electricity networks contribute to climate adaptation by increasing infrastructure resilience. The 2024 mitigation actions include commissioning of new Acea Produzione photovoltaic plants mainly in Lazio with an installed capacity of 153.6 MW; upgrading of biogas plants at Roma Nord and Roma Est for biomethane production; purchase of approximately 0.34 TWh of electricity with guarantee of origin (30% of total Group electricity consumption); Acea Energia's sale of approximately 2.5 TWh of electricity with G.O. (46% of total electricity sold) and offsetting of CO2 emissions from methane gas through voluntary carbon credits; and energy efficiency measures at Group offices and facilities. Overall, decarbonisation actions contributing to the SBTi targets involved investments totalling EUR 33.5 million. Abroad, Aguas de San Pedro continues the Merendon reforestation project in Honduras (1,200,000 trees planted to date).

Reference: page 104

The Group has formalised strategic objectives included in the Sustainability Plan. The decarbonisation actions contribute to the targets validated by SBTi to 2032, compared to the base year 2020: Scope 1, reduce the intensity of direct emissions per unit of energy produced by 56% compared to the base year value (0.71 tCO2e/MWh); Scope 2, reduce indirect emissions related to energy withdrawals from the grid by 32% compared to the base year value (301,649 tCO2e); Scope 3, reduce indirect emissions related to the sale and distribution of natural gas by 30% compared to the base year value (439,514 tCO2e); Scope 1+3, reduce the intensity of indirect emissions related to the production and sale of electricity by 56% compared to the base year value (0.42 tCO2e/MWh). The overall commitment is a 'Well below 2 degrees C' target validated by SBTi. Targets to 2032 will be supplemented in 2025 with climate neutrality targets to 2050. Performance monitoring for the first three SBTi years showed significant progress in reducing direct emissions and emissions related to electricity sales.

Reference: page 108

The Group's total energy consumption in 2024 was approximately 3,560 GWh, of which 37% was from renewable sources. Non-renewable sources totalled 2,262,913 MWh and renewable sources 1,315,400 MWh. Of the non-renewable portion, about 20% refers to methane (natural gas, 419,929 MWh), while 36% relates to Solid Recovered Fuel (SRF/FSCs) and pulper for waste-to-energy at San Vittore del Lazio and Terni. Electricity consumption was about 1 TWh, of which about 35% was purchased from certified renewable sources with G.O. (Electricity G.O. 344,996 MWh). The portion of fossil sources in total energy consumption was 63%, nuclear 0%, and renewables 37%. The energy intensity rate for high-impact sectors was 0.0006 MWh/EUR, based on revenue of EUR 3,660,861,000. The Group produces electricity totalling about 982 GWh, with more than 60% (around 600 GWh) from renewable sources; energy production from renewable sources was 598,762 MWh and from non-renewable sources 382,835 MWh.

Reference: page 110

GHG emissions are quantified per the GHG Protocol. For 2024 (CSRD perimeter): Scope 1 emissions were 398,813 tCO2e (13.4% covered by regulated emissions trading systems). Scope 2 location-based emissions were 410,891 tCO2e and market-based 421,755 tCO2e. Total Scope 3 indirect emissions were 2,306,415 tCO2e, comprising mainly Fuel and energy-related activities (1,537,403 tCO2e) and Use of products sold (697,006 tCO2e), plus purchased goods and services (20,745), capital goods (4,517), business trips (336) and investments (46,408). Scope 1 direct emissions mainly originate from the two waste-to-energy plants and thermal power plants; in 2024, 53,450 tonnes (13% of Scope 1) were entered into the EU-ETS. Biogenic emissions amounted to approximately 290,000 tonnes of CO2e. Scope 3 relates mainly to the sale of electricity (67%) and distribution and sale of natural gas (31%). GHG emission intensity (location and market based) was 0.00073 t CO2/EUR.

Reference: page 112

Acea participates in voluntary offsetting projects by purchasing certified carbon credits to offset the amount of methane gas sold on the market. The carbon credits purchased for 2024 funded mitigation projects in Cambodia and Vietnam, totalling EUR 407 thousand credits. The projects were the Southern Cardamom REDD+ in Cambodia (10,000 credits), protecting a key rainforest ecosystem and supporting around 30 villages, and the Dak Psi 3 and 4 Hydropower Project in Vietnam (397,000 credits), a run-of-river hydroelectric project with total installed capacity of 45 MW. In summary, credits amounting to 407,000 tCO2eq were cancelled during the year through certified Verified Carbon Standard (VCS) projects developed outside the European Union. No absorption project was used, and no information is currently available on any credits expected to be cancelled in the future.

Reference: page 113

The internal carbon price is used to assign an economic value to carbon dioxide emissions, helping the company integrate emission costs into investment and management decisions, incentivising emission reduction and supporting the transition to a low-carbon economy. Acea Produzione, the only company in the Acea Group obligated by the EU-ETS market, buys CO2 quotas from Acea Energia, which in turn procures them during the year from external counterparties to diversify the purchase price. The price is estimated during the budget definition phase based on market scenarios acquired from leading rating companies that deal with market forecasting and modelling, and is also used in climate risk analyses according to the ISSB-TCFD system to assess the Carbon Pricing (EU-ETS) transition risk. In 2024, the estimated price used in forecasts and scenarios was EUR 80/tonne, compared to the final average price of EUR 63.7/tonne.

Reference: page 114

To strengthen its commitment to pollution prevention and control, Acea has defined specific strategic objectives and implemented a series of policies to identify, assess, manage and mitigate significant pollution impacts and related risks. The Code of Ethics emphasises environmental protection through pollution prevention and minimisation of environmental risks. The commitment is reflected in the Integrated Management and Sustainability Systems Policy, which defines protection of the natural environment as a priority and commits Acea to define, pursue and monitor specific environmental objectives. Emergency Management Plans for the water, energy and environmental companies set conditions that could prejudice service continuity and quality, classify emergency levels, and identify preventive and remedial measures to limit contamination of air, water and soil. Suppliers are asked to share the commitment to environmental protection, minimise waste and optimise resource use.

Reference: page 116

All Group Companies pursue continuous improvement in processes and resources to reduce environmental impact, including water, air and soil pollution. All plants hold the main environmental certifications (ISO 9001, 14001, 45001, 50001) and the Environment area plants are EMAS certified. Water quality measures in 2024 included interventions by Acea Ato 2 and AdF to improve purified water (ARERA M6 indicator) and drinking water (ARERA M3 indicator), extension of Water Safety Plans, and expanded monitoring for PFAS, emerging organic micropollutants and microplastics; eight additional test methods were validated by Acea Infrastructure for pharmaceutical components. Environment area interventions included completing the revamping of the flue gas treatment line at the Terni waste-to-energy plant, containment basins to limit spills at composting sites, roofing and waterproofing to reduce odorous emissions, and fleet efficiency. Areti continued experimenting with vegetable dielectric oil in transformers to reduce harmful spills.

Reference: page 114

The Group has formalised specific strategic objectives in the Sustainability Plan to manage pollution-related impacts, risks and opportunities, organised around action lines for water quality and innovation in the territory, with progress tracked at 31.12.2024 against 2028 targets. Targets include reducing non-compliant purified water samples (Acea Ato 2 at 7.77% overall progress, AdF at 5.26%), reducing total suspended solids to 91% at Gori (93% progress), improving drinking water quality (ARERA M3), and extending the Water Safety Plan to 265 zones (44% progress, 112 zones reached). Acea Infrastructure targets monitoring of 55 PFAS and emerging organic micropollutant parameters (69% progress, 30 parameters) and 50 microplastic monitorings per year (40% progress). Innovation targets cover reduction of odour emissions through 7 control technologies, 30 odorous species and 12 receptors. Only capex was monitored as opex is non-significant.

Reference: page 116

The quantities of each pollutant measured in 2024 are reported, broken down by air, water and soil. Air emissions were reported by Environment and Production area companies, while water emissions came mainly from integrated water systems above threshold (Acea Ato 2 considered 4 plants over 100,000 population equivalent; Gori considered 7). Ground pollutant emissions were zero, no spills were detected and no microplastics were used or generated. Air emissions totalled 324,383 kg, including nitrogen oxides (NOx/NO2) 206,181 kg, carbon monoxide (CO) 47,327 kg, ammonium (NH3) 14,711 kg, hydrochloric acid 12,685 kg, sulphur oxides 6,104 kg and particulate (PM10) 1,937 kg. Water emissions totalled 23,704,713 kg, including total nitrogen 6,062,602 kg, total organic carbon 4,694,435 kg and total phosphorus 859,861 kg, with Acea Ato 2 responsible for 88% of nitrogen and phosphorus. Soil emissions were zero. Water emissions follow E-PRTR methodology; atmospheric emissions are monitored via Continuous Emission Monitoring Systems.

Reference: pages 116 and 118

The substances of concern and substances of very high concern generated or used during production processes are reported, subdivided by hazard class. The total amount of substances of concern generated, used during production, or acquired was 129 tonnes, while the total amount of substances of very high concern was 0 tonnes. By hazard class, the main quantities were chronic danger for the aquatic environment (77 tonnes), skin sensitisation (51 tonnes) and specific target organ toxicity from repeated exposure (1 tonne); all other classes including germ cell mutagenicity, reproduction toxicity and endocrine disruption were zero. Substances of concern are reported by the company Simam, used mainly for carpentry activities. Chemicals are dosed online with no direct human contact, including iron chloride, sodium sulphide and sodium hypochlorite. Quantities are extrapolated using management software recording purchases per order. Ammonia (NH3) is also used for flue gas treatment at the Terni waste-to-energy plant.

Reference: page 119

Water represents one of the key elements of Acea's business. Confirming the importance it attributes to sustainable water management, the Group adopts a structured approach and defines specific strategic objectives aimed at identifying, assessing, managing and reducing the impacts and risks associated with water, and seeking related opportunities. As stated in the Code of Ethics and the Integrated Management and Sustainability Systems Policy, the company has set as its main objective the sustainable management of water and other natural resources, maximising their uses, optimising reuse and recovery processes, and promoting efficient management of end uses. The commitment is also implemented through individual policies and guidelines of the companies operating the Integrated Water Service, which include specific commitments to ensure high purification quality standards, for example through constant monitoring of discharged water to limit pollution to surface water bodies, prevent environmental damage and protect ecosystems and natural habitats.

Reference: pages 119 and 121

In accordance with its policies, the Group implemented measures in 2024 to achieve its water and environmental protection goals. An action strategy was developed along main lines including containment of physical and commercial losses, efficiency gains in networks and interconnection of aqueduct systems, safeguarding of supply sources, and digitalisation of water networks and measurement methods. All Water area companies continued interventions to reduce losses, mainly through digitisation and district metering, but also water reclamation, meter replacements and pipeline work, reducing losses to about 45% as a calculated average. Resource circularity measures included recovery and reuse of purified wastewater to reduce drinking water consumption, used as technical water at Gori sites, industrial water at Acea Ato 2 sites, and reclaimed wastewater provided by AdF for golf course irrigation. Acea Ambiente sites adopted innovative systems for first rain water recovery; San Vittore del Lazio produces demineralised water from rainwater reused entirely with zero discharge.

Reference: page 119

The management of the Integrated Water Service is a fundamental Acea business, with special attention to protecting water resources in all forms, particularly relevant because all areas where Acea operates are in high water stress as defined by the WRI Aqueduct Water Risk Atlas. The Group has formalised strategic objectives in the Sustainability Plan to 2028 focusing on managing impacts, risks and opportunities in water risk-prone areas including water quality improvement, responsibly managing marine resources, and reducing water consumption. Targets with progress at 31.12.2024 include district metering of 1,930 km of sewerage network (16% progress, 371 km), upgrading purification at 46 treatment plants (20% progress, 9 plants), and reduction in lost water volumes of 93 Mcm versus 2023 (34% progress, 457 Mcm lost versus 489 Mcm baseline; losses 44.7% versus 41.1% target), and 7 Mcm/year wastewater reuse (41% progress, 2.9 Mcm). Only capex was monitored.

Reference: pages 121 and 122

Water resources are used in industrial processes such as electricity production, compost generation, cleaning of treatment and anaerobic digestion compartments, and hygienic uses. In 2024 all Acea Ato 2 industrial water plants became fully operational, allowing recovery and reuse of approximately 2.8 million cubic metres of purified water; of the approximately 3.4 million cubic metres total recycled and reused water, 83% refers to Acea Ato 2. Reported metrics: water withdrawals 4,002,270 m3 (industrial 1,169,225 m3; civil 2,833,045 m3); total volume of recycled and reused water 3,377,247 m3; total stored water 15,252 m3; water consumption 6,284,940 m3 (industrial 4,434,302 m3; civil 1,850,638 m3); water intensity rate 1,472 m3/EUR Mln. The Group Water Balance shows 1,137.6 Mm3 drinking water collected and fed into aqueduct systems, total Group water losses of 499.1 Mm3 (43.9%), and 817.7 Mm3 treated at 632 treatment plants. Consumption is 68% direct measurement, 32% best estimate, 0.1% sampling. All withdrawals are in high water stress areas.

Reference: page 124

A new integrated transition plan is being developed that will include climate, resources and nature, and will be completed by 2025. The preservation and enhancement of biodiversity are among the environmental priorities of Group companies, which are committed to containing factors responsible for biodiversity loss, avoiding overexploitation of natural resources, the introduction of invasive species and pollution of air, water and soil, and implementing measures to restore ecosystems where possible. Group companies manage processes in compliance with environmental authorisations, safeguarding flora and fauna and adopting best available technologies. Integrated Water Service activities aim to maintain optimal environmental conditions; sites near springs are managed with attention to conserving existing ecosystems. For hydroelectric power stations, Acea Produzione manages withdrawals and releases under concessions, defines management projects with impact studies for protected areas, and protects habitats to mitigate the effect of dams on fish migration and riverbed sedimentation, ensuring living conditions for resident and migratory birds.

Reference: page 125

The Acea Group recognises the priority importance of protecting the environment and is committed to managing environmental risks through policies to ensure the integrity of ecosystems and the protection of biodiversity, and to assessing and managing relevant impacts, risks, dependencies and opportunities. The Code of Ethics defines the objective of protecting the territories in which Group companies operate, with specific attention to combating deforestation, and extends this commitment to the value chain by requiring suppliers to share the principles of biodiversity and ecosystem protection. The protection of the natural environment, biodiversity and ecosystems is confirmed in the Integrated Management and Sustainability Systems Policy, which guides the operations of management systems on the subject, and in the Human Rights Policy. These documents formalise Acea's commitment to safeguarding the integrity of ecosystems while respecting the community and the intergenerational pact, including through environmental and energy management systems that define objectives, improvement programmes and monitoring tools.

Reference: page 126

Acea planned several projects in 2024 to protect ecosystems, focused where applicable on high biodiversity priority areas. In the Water area, the Sarno basin reclamation programme continued, with two discharges eliminated in Gragnano and two in Castellammare di Stabia, and swimming in the Gulf of Castellammare became possible again after 50 years. Acea Ato 2 monitoring at Peschiera-Capore aqueduct and major purification plants (Roma Nord, Roma Sud, Cobis, Ostia, Roma Est, Fregene) showed positive ecosystem roles, and peregrine falcon monitoring continued at Villa Borghese and Villa Pamphili. In the Environment area, the UrBees bee bio-indicator project at San Vittore del Lazio continued, and native tree species and beehives were established at Terni and Orvieto Ambiente plants. In Networks and Public Lighting, Areti removed 49 pylons in the Decima Malafede and Litorale Romano nature reserves, restoring 200 m2 of soil. Acea undertook no biodiversity offsets in 2024.

Reference: page 125

With a view to managing the relevant impacts, risks and opportunities related to biodiversity and ecosystem protection, the Group has formalised specific strategic objectives, in line with the policies adopted, included in the Sustainability Plan, which also outlines the actions and investments planned up to 2028. The objectives address impacts and dependencies in terms of ecosystem services and impacts on the extent and condition of ecosystems, organised under the Biodiversity action line. Targets with progress at 31.12.2024 include removal of 115 high-voltage pylons by Areti (43% progress, 49 pylons removed), reclamation of 620 m2 of land in high biodiversity areas (32% progress, 200 m2 reclaimed), and elimination of 69 unlawful discharges through the Sarno basin reclamation by Gori (6% progress, 4 discharges eliminated). For actions related to these strategic lines, only the capex was monitored because opex represents a non-significant portion.

Reference: pages 126 and 127

Acea identified its sites and plants located in high biodiversity areas, namely nationally-derived protected natural areas (EUAPs) and Natura 2000 network sites, mapping the infrastructure of the Group's main companies. Analysis of over 23,000 sites/plants and 1,472 km of electricity grid showed 2,290 sites/plants in protected areas (10%) and 404 km of grid (27%); 1,145 sites with potential impact (5%) covering 223.4 hectares, across 130 protected areas intersected (55 EUAPs, 61 SIC-ZSC, 14 ZPS). Twelve priority zones were identified using the Environmental Fragility Index (IFA). Reported metrics for sites in or near protected or major biodiversity areas negatively affected by the business: by area, owned 439 hectares, leased 0, managed 278; by number, owned 543, leased 21, managed 2,131. The hectares refer 41% (about 300 hectares) to areas under the Casoli dam owned by Acea Produzione, 19% (about 140 hectares) managed by Gori, and 18% (about 130 hectares) managed by Acea Ato 2.

Reference: page 128

The use of resources and the circular economy are a priority issue for the Group, which is committed to assessing, managing and reducing related impacts and risks and to developing related opportunities, focusing on resource circularity. The Integrated Management and Sustainability Systems Policy includes the objective of sustainably managing energy, water and other natural resources, enhancing their uses, reuse and recovery processes with a view to the circular economy. Acea is committed to a business model based on resource circularity, focusing especially on the Environment area with waste recovery programmes and the Water area with commitments to conservation and protection of water, leakage and waste reduction, water recovery and reuse projects, and consumer education. The Sustainable Procurement Policy promotes a virtuous supplier ecosystem aimed at reusing resources and minimising waste, supporting sustainability performance monitoring systems such as Ecovadis. The Code of Ethics and procurement contracts require suppliers to properly manage waste in compliance with regulations.

Reference: page 130

In accordance with its policies, the Group implemented a series of measures and interventions in 2024 contributing to the circular economy, mainly in the Environment and Water areas. In the Water area, measures to reduce sewage sludge amounted to EUR 8.9 million, including the commissioning of the Roma Sud treatment plant, revamping of sludge silos at Cobis and Montagnano, and construction of the dewatered sludge treatment plant at Roma Est, plus completion of the soil washing plant for sand recovery at Acea Ato 2. In the Environment area, the San Vittore del Lazio and Terni waste-to-energy plants integrate circular economy and resource efficiency, plastic and metal materials are recovered (Demap, Ferrocart, Meg, Tecnoservizi), and whey is recovered for food reuse (Iseco). Community-based composting plants (Smart Comp) produced more than 100,000 tonnes of quality compost. Simam reduces impact from the design phase with modular mobile plants. All sites implement separate waste collection.

Reference: page 128

The circular economy is of priority importance to the Group and, in line with adopted policies, includes a dedicated strategic objective in the Sustainability Plan with specific lines of action for the various businesses, focused especially on the Environment area. The Group has formalised specific strategic objectives covering circularity of resources, with measures and investments for lines of action developed by operating companies. Targets with progress at 31.12.2024 include increasing the volume of processed waste to 1.9 Mt/year at Acea Ambiente (1.7 Mt balance 2024), End of Waste recovery with material recovery above 85% of input volumes by AS Recycling (83% achieved), recovery of 65% of purification sand via soil washing at Acea Ato 2 (plant to launch), and reduction of sewage sludge by 40% versus 2023 (18% progress, 123,419 tonnes versus 149,770 tonnes baseline). For actions related to these strategic lines, only the capex was monitored because opex represents a non-significant portion.

Reference: page 130

Incoming flows mainly include various types of materials and waste arriving at Environment Area plants and the chemical resources used for process management, from wastewater treatment at water companies to production plants. Of incoming materials, 47% are biological resources, mainly biomass at the Aprilia and Monterotondo Marittimo composting sites (about 160,000 t), the Orvieto Ambiente composting line (112,000 t) and the biological component at the San Vittore del Lazio and Terni waste-to-energy plants (174,000 t). Other incoming liquid waste involves Simam and Chiusi (380,000 t total). Non-organic materials total about 986,000 t. Deco's MBT plant received more than 245,000 t of municipal solid waste; Cavallari about 110,000 t; Tecnoservizi more than 95,300 t; Areti about 4,100 t of electromechanical materials; technical chemicals about 41,500 t. Reported metrics: overall total weight of products used during the reporting period 1,911,281 tonnes; total secondary components 0; biological materials 46.5%; secondary components 0%. Data derives from certified weighing systems and purchase invoices.

Reference: pages 130 to 133

Resource outflows mainly relate to Environment area plant activities, including quality compost produced at Monterotondo Marittimo, Aprilia and Orvieto Ambiente sites used in agriculture, and Solid Secondary Fuel (CSS) produced mainly by Deco and Cavallari. Reported outflow metrics (weight of products released on the market 275,414 tonnes): compost 43,047 t; SRF 102,285 t; milk powder 1,384 t; waste water 72,100 t; other 56,597 t. Weight of recycled content was reported as not available. Secondary raw materials produced include Ferrocart (about 20,500 t), Cavallari (about 16,500 t), Meg (about 9,600 t, converting at least 70% by weight) and Tecnoservizi (about 7,400 t of EoW paper). Recyclable content in products was 1%, in product packaging 0%, and non-recycled waste 91.2%. Product durability is not applicable given the Group's business.

Reference: pages 130 to 133

Total waste produced in 2024 was 898,010 tonnes, of which 58% was recovered and the remainder destined for disposal. The most significant category is sludge from water companies, with Gori producing about 65,500 t (42% of total sludge) and Acea Ato 2 almost 45,000 t (29%); sewage sludge totalled 157,476 t. Other major categories: other materials 237,484 t, FSCs (combustible waste) 124,648 t, plastic 106,359 t, leachate 57,308 t, hazardous bottom ash 50,584 t and excavated earth and rocks 24,163 t. Waste not intended for disposal (non-hazardous) included recycling 68,291 t and other recovery operations 118,997 t; hazardous waste preparation for re-use 52,045 t. Waste intended for disposal (non-hazardous) included landfill disposal 167,962 t and other recovery 184,148 t. Non-recycled waste totalled 819,071 t (91.2%), hazardous waste 70,591 t and radioactive waste 0 t. Environment area companies sending significant waste to recovery included Deco (22%), Tecnoservizi (15%) and the two waste-to-energy plants (10%); Water area companies sent more than 120,000 tonnes to recovery (23%). San Vittore del Lazio produces about 86% of total hazardous waste.

Reference: page 135

The Charter of the Person and Participation, signed by Acea with the trade unions, is the reference protocol for managing employee relations and defines common values and commitments on adequate working environments, skills enhancement, well-being, work-life balance and a culture of safety at work. The Group's commitment to human rights is formalised in the Code of Ethics and the Human Rights Policy, overseen by a collegiate body, the Ethics Officer. The Human Rights Policy sets out principles on rejecting child and forced labour, adequate working conditions and remuneration, and non-discrimination on the basis of gender, age, ethnicity, sexual orientation and identity, disability and religious faith, further reiterated in the Equality, Diversity and Inclusion Policy. Policies reference the International Charter of Human Rights, the UN Guiding Principles, the OECD Guidelines, the ILO Core Conventions and the Global Compact. In 2024 Acea Ambiente, areti, Acea Ato 2, Acea Infrastructure and Acea Energia obtained gender equality certification under UNI PdR 125:2022, and the Group obtained Top Employers Italia Certification for the third consecutive year. Most companies have an occupational safety management system certified to UNI ISO 45001:2023.

Reference: page 136

Acea has adopted a high-profile engagement model managed by the Parent Company's Human Resources and Organisation department, which has operational responsibility for ensuring the involvement of workers' representatives and that results guide the company's approach. The model is based on systematic discussion and bilateralism, taking the form of Committees, Bodies, Commissions and Work groups made up of company members and trade union representatives. These joint bodies are responsible for training, retraining, welfare, inclusion and equal opportunities. During the year, social partners were involved in meetings on valuing people, adapting workspaces, revising working hours, smart working and desk sharing, and training financed by inter-professional bodies. Trade unions at national, regional, territorial and company level were also involved in a specific event to present the 2024-2028 Business Plan. In line with regulatory requirements, workers' representatives are regularly involved in occupational health and safety matters through the Unitary Trade Union Representatives (RSU) and the Workers' Safety and Environmental Representatives (RLSA). In 2024 Acea launched the internal communication campaign "Every gesture can make a difference", which included an internal survey carried out with INAIL on workers' perceptions of risk.

Reference: page 136

To address impacts, particularly negative ones, Acea has adopted structured employee relations management processes. The Human Resources and Organisation function, in coordination with Group companies, manages personnel administration, defines the remuneration policy including performance appraisal and meritocratic plans, manages industrial relations, defines training plans from a needs survey, and sets commitments and plans for inclusion and diversity. On workplace safety, the Parent Company's Health, Quality, Safety and Environment department provides coordination and guidance, monitors regulatory application and draws up the Group's annual accident report. Each company is responsible for operational safety management, staff training, accident monitoring and preparing the Risk Assessment Document (RAD). For reports of alleged breaches of the Code of Ethics and the Policy on Human Rights at Work, Acea has activated the "Comunica Whistleblowing" platform, guaranteeing confidentiality, with reports forwarded to the Ethics Officer. The Group also set up dedicated e-mail addresses on the company intranet allowing workers to raise concerns about injuries and accident rates, with structured processes to analyse reports, identify solutions and verify effectiveness.

Reference: page 137

To manage relevant impacts, risks and opportunities, the Group has formalised specific strategic objectives in the Sustainability Plan, with Opex of approximately EUR 2.4 million realised in 2024 for these strategic lines. Action lines cover employee well-being (Welfare enhancement), skills development (Corporate Academy, Training), People Engagement (People Survey), diversity and inclusion (gender equality, improving D&I culture) and health and safety (culture of safety, HSE process optimisation, innovative safety equipment such as the Youcare kit and man-down device). The Centrality of People objective addresses appropriate salaries, training and skills development, work-life balance, health and safety, secure employment, gender equality and equal pay, and freedom of association. To counter the risk of conflict with trade unions, the Group established bilateral bodies including the Bilateral Inclusion and Equal Opportunities Committee, the Bilateral Welfare Committee and the Training, Health and Safety Observatory. To address difficulties in sourcing key competencies, Acea reorganised the selection process, enhanced the use of digital platforms and extended the search to new territorial areas. Safety training programmes and customised protocols were implemented to reduce accident rates.

Reference: page 137

The Sustainability Plan defines targets to 2028 with reported progress. Welfare: increase in service users versus the previous year, target reached (from 3,954 to 5,942 people). Corporate Academy: 6,500 people/year trained (5,045 trained) and 140 internal faculties involved (31 internal lecturers). Training: 15 digital training courses with 5,000 participants (14 courses, 3,184 participants); 22 hours of training per capita/year excluding foreign countries (100%, 27h); 100 people certified as "Sustainability Professionals" (22%). Gender equality: 32.6% women managers among executives and middle managers (30.17%). D&I culture: one campaign and one initiative per year (4 initiatives). Culture of safety: accident frequency and severity indices below the three-year average (IFI above average, IGI below average); more than 90% Near Misses resolved (52% resolved). HSE process digitisation for 100% of Group companies (in progress). Foreign countries: safety training 90% of employees involved (100%); specialised training 97% course attendance (86%); D&I culture participation rate 90% (100%).

Reference: page 140

The effective workforce at 31 December 2024 numbered 8,715 employees, of which 78% were men and 22% women, corresponding to a personnel cost of EUR 328,524,000. Employees by country: Italy 7,376, Peru 891, Honduras 419 and Dominican Republic 29. By contract type, employees with open-ended contracts totalled 5,988 men and 1,823 women, and fixed-term contracts 829 men and 75 women, giving totals of 6,817 men and 1,898 women. 90% of employees are employed under open-ended contracts, confirming employment stability, and all employees from operating companies in Italy are covered by National Collective Labour Agreements (CCNL). The composition confirms the prevalence of the male component, referring mainly to technical activities. The exit turnover rate was 11% for companies operating in Italy, mainly due to the exit of the water company Acquedotto del Fiora from the scope of consolidation. For the foreign companies in Latin America, which recorded 782 staff departures, the rate was 58%, mainly due to termination of the contract with Consorcio Acea. A total of 781 employees left the operating companies in Italy, including 148 voluntarily, 19 due to dismissal, 115 due to retirement and 12 due to death in the line of duty.

Reference: page 140

At 31 December 2024, the total number of employees covered by collective labour agreements was 89%. Within the European Economic System, 50% of employees were registered as trade union members, and employees covered by collective labour agreements in companies within the European Economic System represented 85% of the total workforce (Italy). Outside the European Economic System, coverage was 0% in Peru, 5% in Honduras and 0% in the Dominican Republic. All employees from the operating companies in Italy are covered by National Collective Labour Agreements (CCNL).

Reference: page 141

Group personnel with senior management roles, consisting of managers in positions n-1 from top management, are 74% male and 26% female (representing 42% male and 15% female by number). On age distribution, 8% of the workforce is under 30 years old, 51% are between 30 and 50 years old and 42% are over 50. By age bracket, employees number 660 under 30 years old, 4,435 in the 30-50 bracket and 3,620 over 50 years old.

Reference: page 141

All Group employees receive an appropriate salary in line with applicable benchmarks: the National Collective Labour Agreements (CCNL) in Italy, and the Labour Code and collective and industry agreements abroad. The remuneration Acea pays its employees applies the National Collective Bargaining Agreements (CCNL), ensuring minimum salary levels by professional category, plus a merit-based remuneration policy in line with the Performance Management Model that determines remuneration above the minimum salaries set by the CCNL. Employees are eligible for an annual performance bonus, a variable payment linked to qualitative and quantitative results.

Reference: page 141

At 31 December 2024, the percentage of disabled persons among employees, subject to legal restrictions on data collection, was 5% male and 11% female, with 0% reported for other and not reported categories. Appropriate actions are planned for the training of staff with disabilities, including through the provision of sign language, and the Talks Academy on Disability was held during the year.

Reference: page 141

A total of 226,195 training hours were provided to Group personnel during the year, of which 24% was provided to female staff and 76% to male staff (171,972 hours to men and 54,223 hours to women). Per capita training hours were 29 for women and 25 for men. A total of 85% of the Group's personnel were involved in performance and competence appraisal systems during the year. By number, 5,617 male and 1,760 female employees participated in regular performance and career development reviews, equivalent to 82% of men and 93% of women. The Group is committed to a high-level training centre, the "Acea Academy", and the "Pianetacea" e-learning platform. In 2024 it implemented leadership courses including the Manager programme (150 participants) and the Growth Programme for talents (350 people).

Reference: page 142

At 31 December 2024, 95% of employees were covered by the management system for health and safety, with 8,236 employees covered (Italy 7,376, Peru 860, Honduras 0, Dominican Republic 0). All Group companies operating in Italy have adopted certified occupational safety management systems covering all employees. In 2024, no Group company in Italy or abroad recorded deaths among its staff due to work-related injuries and illnesses or fatal accidents. The number of occupational accidents totalled 135 (Italy 86, Honduras 31, Peru 18, Dominican Republic 0). The rate of work-related injuries, calculated as recordable work-related injuries per 1,000,000 hours worked, was 6 in Italy, 34 in Honduras, 10 in Peru and 0 in the Dominican Republic.

Reference: page 142

Acea operates in compliance with legislation on leave for family reasons, governing days off and economic support connected with maternity, paternity and adopted and fostered children. 100% of employees are entitled to this leave in Italy. In the Dominican Republic, where Acea Dominicana operates, this type of leave is not covered by local legislation, so the percentage of employees entitled to family leave at Group level drops to 99.7%. Of eligible employees who took leave for family reasons, 5% were male and 4% were female, with 0% for other and not reported categories.

Reference: page 143

Remuneration metrics are reported by country (Italy, Peru, Honduras, Dominican Republic). The gender pay gap compares the difference between average male and average female gross hourly remuneration relative to the average male figure; the annual total remuneration rate is the ratio of the highest paid person's total remuneration to the median remuneration of employees. In Italy, the gender pay gap is 1% in favour of men and the total annual salary of the highest paid person is 24 times the median. In Honduras, women are paid 9% more than men (pay gap -9%) and the remuneration ratio is 12. In Peru, the gender pay gap is 25% in favour of women (-25%) and the ratio is 8. In the Dominican Republic, men earn 39% more than women (pay gap 39%) and the ratio is 8.

Reference: page 143

In 2024, three reports were submitted by company employees through dedicated channels relating to human rights issues: one related to an alleged case of harassment, which was closed after further investigation, and two relating to human resources management. No human rights related sanctions or fines were imposed on the Group. Incidents of discrimination totalled 1, consisting of one case of harassment, with zero incidents recorded for gender, race or ethnic origin, nationality, religion or personal beliefs, disability, age, sexual orientation and other forms. Complaints submitted through the channels provided for own workers to raise concerns numbered 2, with 0 serious labour-related human rights problems and incidents of non-compliance with the UN Guiding Principles, the ILO Declaration and the OECD Guidelines. Fines, sanctions and compensation following incidents of discrimination including harassment were EUR 0, and fines for serious human rights problems related to own workforce were EUR 0.

Reference: page 144

Acea recognises that its extensive, often delocalised supply chain can generate negative impacts on supplier workers, such as child labour, forced labour and workplace safety failures, and has adopted value codes and policies to manage these risks. The Code of Ethics sets out reference principles for relations with suppliers, contractors and subcontractors, including verification processes for reputational and corruption risks, protection of workers' human rights (decent conditions, health and safety), environmental safeguards, and respect for privacy and quality. Suppliers issue a declaration of acceptance committing to the Code, which forms part of the contract and allows Acea to act if principles are breached. During the year Acea adopted a Sustainable Procurement Policy to integrate ESG criteria into procurement. The Human Rights Policy, inspired by the International Bill of Human Rights and ILO conventions, includes the principle of Responsible Management of Supplier Relations covering dignified working conditions, the fight against child and forced labour, minimum wages and limits on working hours. In contracts with suppliers in at-risk countries, clauses require compliance with specific social obligations.

Reference: page 145

In defining trade union agreements and protocols that include supply chain issues, Acea engages through the industrial relations structures of the Human Resources and Organisation Department of the Parent Company. It interacts with the main trade union representatives of supplier company workers and with trade associations in defining and signing specific agreements that address supply chain matters, including health and safety in the workplace, employment protection, combating unlawful forms of work, and compliance with contractual regulations. This engagement allows the perspectives of value chain workers, represented through their trade unions, to inform the agreements and protocols Acea adopts.

Reference: page 145

For several years Acea has signed a Water Contracts Protocol covering employment protection (proper application of the trade union clause in contract changes), combating unlawful work or work not complying with national labour contracts, workplace health and safety, and compliance with contractual regulations. A Contracts Protocol signed between Acea and the trade unions ensures high levels of legality and efficiency in handling contracts, strengthens occupational health and safety protection, and supports stable, quality employment. It defines rewarding criteria for tender assignment, including a lower number of subcontractors, minimum percentages of women and young people, use of permanent employment contracts, gender parity policies and the trade union clause, with incoming contractors committing to absorb outgoing contractor staff. The Protocol references the National Framework Protocol to support legality signed by Acea and the Ministry of the Interior. Acea has activated the Comunica Whistleblowing platform, accessible to external stakeholders, to collect reports of alleged breaches of the Code of Ethics and Human Rights Policy, including work-related matters, with reports forwarded to the Ethics Office for investigation.

Reference: page 145

Actions form part of the Supply Chain Evolution objective in the Sustainability Plan, with lines of action on strengthening sustainable procurement and on workers' health and safety. To protect workers' rights and counter child and forced labour, in 2024 Acea adopted the Sustainable Procurement Policy, including the Work and People principle calling on suppliers to comply with labour regulations and refrain from illegal, forced or child labour; the policy is submitted to suppliers at qualification. Monitoring of supplier performance on environment, labour, human rights, ethics and sustainability continued through the EcoVadis platform, with 783 suppliers assessed at 31.12.2024. Acea held its first Vendor Day to engage suppliers on the 2024-2028 Business Plan. On occupational health and safety, Acea conducted about 15,000 work site safety audits during the year across major and smaller maintenance contracts in water and electricity, and organised the Safety Walk and Talk and Contractor Safety Day to spread a safety culture. Economic commitments to implement these actions are not significant in capex/opex terms.

Reference: page 145

The Sustainability Plan sets targets to 2028 with progress reported at 31.12.2024. Under sustainable procurement, the target of applying sustainability rewarding criteria to 90% of tendering procedures stood at 60% application, and the target of 80% EcoVadis-accredited suppliers stood at 71%. Under supplier health and safety, the target of an accident incidence rate below the average of the last three years was not met, with the rate above that average; digitisation of the ITP technical and professional qualification verification process for all Group Companies stood at 12%; and the target of a 5% annual increase in construction site inspections versus 2023 was exceeded at plus 5.3%, with approximately 15,000 inspections. For suppliers in foreign countries, the target of 90% attendance for supplier safety and prevention training courses (Consorcio Agua Azul) stood at 67%.

Reference: page 147

Acea manages relations with stakeholders according to the principles of integrity, transparency, fairness, impartiality and inclusiveness, as set out in the Code of Ethics, the Human Rights Policy and the Integrated Management Systems and Sustainability Policy. The aim is to build relationships based on listening, dialogue and mutual understanding, encouraging stakeholder engagement in defining strategic priorities and addressing critical or conflict situations promptly. Any significant negative impacts are not systemic but relate to individual projects linked to infrastructure developments. Acea respects the rights of local communities and contributes to their advancement, promoting the socio-economic development of the contexts in which it operates and protecting the natural environment and ecosystems. The Group enhances the territory by supporting socially useful initiatives with cultural, social, environmental, sporting, recreational and charitable purposes, including projects supporting the inclusion of people in disadvantaged social contexts, supported financially. As set out in the Human Rights Policy, Acea undertakes to ensure no infringement occurs, developing processes to identify potential or current human rights risks and impacts, prevent breaches and remedy them. In 2024 there were no reported cases of non-compliance with the UN Guiding Principles, the ILO Declaration or the OECD Guidelines.

Reference: page 147

Participation by communities takes place at different stages and with different stakeholders depending on the initiative. The stakeholder engagement process requires the owner of the initiative to identify stakeholders through stakeholder mapping, assign relevance and define engagement priorities, then define the forms of engagement and operational tools in agreement with relevant corporate structures, taking account of the subject and objectives. Stakeholders are involved through invitations to work tables and other communications. Initiatives frequently involve educational institutions, local administrations, consumer associations and environmental associations, which represent the needs of the territory. In the water sector, direct involvement is pursued through regular meetings with local administrations, such as the Conference of Mayors. In the energy grids sector, discussions were developed with local community stakeholders including citizens, energy communities and universities on flexibility services and the grid's evolution. Initiatives involving schools support environmental and water education. Operational responsibility lies with top management and management; planning is approved by the organisational structure owner and higher-level managers up to top management for especially significant initiatives. Acea monitors effectiveness through direct and indirect feedback and participation levels, with feedback and follow-up phases regulated.

Reference: page 148

Acea ensures communities are heard on matters involving Group activities that may concern stakeholders. Various channels are in place, ranging from commercial channels and emergency and breakdown reporting to physical contact, social channels and apps that allow real-time updates and interaction. Use of these tools is promoted via corporate websites, communication campaigns and social channels. Operating companies have structures to oversee territories, managing the collection, analysis and response to requests from municipalities and other territorial stakeholders. Reports, enquiries and complaints received through official channels are recorded, analysed and managed by the relevant corporate structures according to type and priority, monitoring the entire process until resolution, ensuring updates to reporting stakeholders and using the data to improve processes and prevent future critical issues. For possible reports of breaches of internal and external regulations, the Group has adopted a whistleblowing system that safeguards the whistleblower against retaliation, usable by all stakeholders via a compliant digital platform, with reports analysed and processed under a specific procedure providing feedback. Group companies have implemented Environmental and Energy Management Systems (ISO 14001, ISO 50001) to control and monitor risks and impacts on local communities.

Reference: page 148

Actions related to communities fall under the Sustainability Plan objective Value for the Territory, with action lines on innovation in the territory and on listening to and supporting communities. All Group companies are committed to preventing negative impacts, enhancing positive impacts, generating value in territories and mitigating risks of non-acceptance, through processes and tools for managing stakeholder relations and receiving community requests. Where significant negative impacts may emerge from acquiring land for plants and networks, Acea undertakes cost-benefit analyses to reduce potential negative impacts. Initiatives raise community and younger-generation awareness on responsible use of natural resources and green skills, including, under a three-year Memorandum of Understanding with the Ministry of Education and Merit, a new Water Education project for primary and secondary schools across several regions with a digital platform and guided tours, plus free training for young people up to 35 and unemployed adults in Lazio. Environmental chain companies opened main waste treatment plants for stakeholder visits, and a new WhatsApp channel was activated in Rome for breakdown and maintenance information. Abroad, training and awareness activities focused on hygiene, health and natural resources. Opex of approximately EUR 0.7 million was realised in 2024 for stakeholder engagement actions.

Reference: page 148

The Sustainability Plan sets targets to 2028 with progress reported at 31.12.2024. Under innovation in the territory, the target of 102 new water house installations stood at 30 kiosks installed, the target of 229 new electric mobility stations stood at 50 stations installed, and the target of 1-2 communication campaigns per year on environmental issues was exceeded at 7 campaigns. Under stakeholder engagement, the target of one territorial dialogue project per year was met with one territorial project, one primary and secondary school programme per year was met with one educational programme, artistic lighting at 8 interventions per year reached 24 events, and 20 sponsorship projects per year reached 50 projects. For foreign countries, school training (Consorcio Agua Azul) of at least one campaign per year and 2,780 school kits distributed in poorer areas reached its annual target, and supporting local communities through hygiene-sanitation training (Aguas de San Pedro) of 25 workshops per year, plus fire prevention training of one team and 30 new hydrants, both reached their annual targets.

Reference: page 151

Acea is committed to correct, transparent and non-discriminatory behaviour towards customers, consistent with the Code of Ethics and the Integrated Management Systems and Sustainability Policy. Contracts and communications are based on clarity, simplicity and completeness of information to enable informed choices, and suppliers are required to guarantee high quality standards, accessibility, safety and efficiency. Acea treats customer data confidentially in line with competition, privacy and data protection legislation, having established a Group Privacy Governance Model compliant with EU Regulation 2016/679 (GDPR) using a preventive risk-based approach with continuous monitoring. An Antitrust Compliance Programme is in place, including the Antitrust Compliance and Consumer Protection Manual, with specific guaranteed protection for vulnerable consumer groups such as minors and the disabled. As stated in the Human Rights Policy, Acea recognises it provides public utility services underpinning fundamental rights and plans investments to develop accessible and functional services that improve quality of life. The whistleblowing platform for reporting possible violations is available to all stakeholders, including downstream value chain parties. Acea designs infrastructure and delivers products to protect customers' health and physical integrity, paying careful attention to quality controls for drinking water intended for human consumption.

Reference: page 152

Through the Institutional Affairs and Business Development Function of the Parent Company, Acea interacts in a structured manner with consumer associations operating in the territory, in particular those recognised by the National Council of Consumers and Users (CNCU). The Association Relations Unit oversees the relationship with consumer representatives, receives requests from the territories, and forwards them to Acea SpA functions and operating companies for analysis and possible actions. It organises regular meetings with consumer representatives and dedicated meetings on specific needs, and the ADR Acea SpA - Consumer Associations body falls under the Unit, dealing with out-of-court dispute management under a conciliation protocol signed between Group companies (6 for the Water Sector and 2 for the Energy Sector) and CNCU-registered consumer associations. Acea has a corporate procedure formalising customer experience measurement, carrying out periodic customer and citizen satisfaction surveys (quality perceived) with a market research company, distributed throughout the year, plus a continuous call back survey method. In 2024 Acea was among the first Italian listed companies to receive RINA Services certification confirming compliance with ISO 10004 guidelines for customer satisfaction monitoring. Water companies adopt the Service Charter, recognising users' right of access to information and outlining complaint and conciliation procedures.

Reference: page 153

Acea adopts responsible marketing styles, guiding consumer choices without manipulative or deceptive intent, and operates the ADR Body Acea SpA - Consumer Associations which, under the Conciliation Protocol with consumer associations registered with the CNCU, handles out-of-court management of disputes. In the commercial sector, business partners' marketing processes are monitored and complaints about disputed contracts are followed up with corrective measures. For customers in hardship, support instruments such as social bonuses ensure water and energy services remain affordable. Most Group companies have ISO 9001-certified quality management systems, with aspects causing dissatisfaction reported as non-conformities and corrective actions initiated. Acea ensures consumers are heard through various channels, from commercial and emergency reporting to physical contact, social channels and apps allowing real-time interaction, promoted via websites and campaigns. Reports, enquiries and complaints through official channels are recorded, analysed and managed by relevant corporate structures by type and priority, monitored until resolution, with updates to stakeholders and data used to improve processes. For possible breaches of internal and external regulations, the Group has adopted a whistleblowing system safeguarding the whistleblower against retaliation, usable by all stakeholders via a compliant digital platform with feedback provided.

Reference: page 153

The Sustainability Plan defines objectives to manage relevant impacts including information-related impacts, social inclusion and personal safety of consumers and end users; certain objectives are common with the Communities involved section as most services to consumers correspond to services to the community, and the impact on human health from inadequate quality monitoring is addressed in the Water and Marine Resources section. To mitigate negative impacts and enhance positive ones, companies developed new tools such as chatbots, artificial intelligence and an interactive fault map. In electricity distribution, the meter replacement campaign helps users increase consumption awareness through real-time communication. To protect customers, Acea Energia works to prevent unfair, deceptive and aggressive commercial practices by verifying that sales agents conduct themselves correctly, that contract presentation is clear and that customers are aware of their choice and their right of withdrawal. Communication actions promoted awareness of innovative products including the Luce 100% Green and 0% CO2 tariffs. In 2024 Acea obtained ISO 10004 certification for its customer satisfaction monitoring processes. On personal data protection, the Register of Processing Activities was updated during the year, specifying data subjects, personal data processed, systems used and security measures.

Reference: page 153

The Sustainability Plan sets targets to 2028 with progress reported at 31.12.2024. Under innovation in the territory, the electricity grid customer management target (areti) of a 20% reduction in non-recurrent complaints stood at a 12% reduction, and the RomeFlex flexibility activation target (areti) of 890 interruptions avoided was exceeded with 904 interruptions avoided. Under digitalisation, the 2G meters target (areti) of 770,000 installed meters, toward a total of over 1,750,000 by 2028, stood at 58% with 446,351 meters installed against a 2023 baseline of 986,291. Management of impacts related to loss of customer data due to privacy breaches and economic damage to customers from unfair, deceptive and aggressive business practices is addressed through the Group's policies described in the Business Conduct section. Operating companies sign an Integrated Water Service Charter defining quality levels for drinking water, public sewage and purification that operators must observe.

Reference: page 155

Acea expresses its value orientation through the Code of Ethics, which sets out the principles and rules of conduct guiding all persons who work in the interest of the Group. Every employee, collaborator and top manager must know, formally accept and comply with it, and subsidiaries adopt it by Board resolution. The Code is implemented through linked policies including the Integrated Management Systems and Sustainability Policy, the Human Rights Policy, the Equality, Diversity and Inclusion Policy and the Whistleblowing Management Policy. Acea SpA holds an anti-corruption policy aligned to UNI ISO 37001:2016. A whistleblowing system handles reports of alleged violations of the Code, Legislative Decree 231/01, the Anti-Corruption Guidelines and other policies, with confidentiality and protection from retaliation. The Ethics Officer oversees the reporting system and publishes an annual report. Compulsory e-learning on the Code of Ethics, anti-corruption and whistleblowing is provided to all employees, with participation monitored through entry and exit tests.

Reference: page 157

Acea promotes a partnership relationship with suppliers and embeds sustainability into procurement. The Procurement Function defines policies and manages purchasing of goods, services and works. The Code of Ethics governs relations with suppliers, contractors and subcontractors, who must issue an unconditional declaration of acceptance of its prescriptions and of the Group Organisational, Management and Control Model. Internal procedures include verification processes to identify reputational and corruption risks. Supplier qualification uses a QASER self-assessment questionnaire on Quality, Environment, Safety, Energy and Social Responsibility systems, with general and specific requirements such as ISO 9001, ISO 14001, ISO 45001 and SA 8000 certifications for given supplier lists. In 2024 Acea adopted a Sustainable Procurement Policy whose signing is a mandatory condition for the business relationship. The Group applies the EcoVadis sustainability assessment model, inviting suppliers to register and be scored, and includes the rating as a tender awarding criterion to reward the most virtuous companies.

Reference: pages 158 and 159

Acea has implemented a series of compliance measures to prevent unlawful conduct, particularly in activities most exposed to corruption risk. The Parent Company implemented a Management System for the prevention of corruption, achieving UNI ISO 37001:2016 certification in 2023. The Acea Group Anti-Corruption Guidelines define the anti-corruption framework, information flows, principles of conduct and applicable controls, and apply to Group Companies, suppliers, partners and associates through contractual compliance clauses. Sensitive macro-areas include purchasing, recruitment, donations, sponsorships, gifts and hospitality, M&A operations, relationships with public administration and tender procedures. An Anti-Corruption Officer is appointed for each Group company. Internal Audit carries out controls under the Board-approved Audit Plan; in 2024 around 88% of Plan activities concerned processes exposed to risks under Legislative Decree 231/2001, including corruption. Mandatory refresher training on corruption prevention is held at least every 24 months, covering ISO 37001.

Reference: pages 158 and 159

Acea reports on confirmed incidents of corruption and bribery. In 2024, there were no cases of convictions for violations of anti-corruption laws. Investigations into corruption allegations that may also lead to breaches of the 231 Model (for example active corruption) are handled by the respective Supervisory Bodies, while corruption offences that may not constitute infringements of the 231 Model are managed by the Ethics Officer. Periodic audits cover processes related to corruption risks, including sponsorships, consulting, personnel selection, purchasing and payments, and out-of-court settlements across subsidiaries that adopted the Model under Legislative Decree 231/2001. Anti-corruption training is delivered to functions at risk, senior executives and other workers, with topics covering ISO 37001 and the Management System for the Prevention of Corruption.

Reference: page 159

Acea reports on payment practices with suppliers. Considering the Group's corporate perimeter, which net of foreign companies covers 94% of consolidated external costs, payments made on time account for 45% of the total. For the Group companies whose payments are handled by the Parent Company, representing 91% of the consolidated perimeter, the average payment time is 39 days, weighted on the amounts. This figure is compiled from the date the invoice was registered and the main payment classes stipulated in contracts (30, 60, 90, 120 days). During the year, thirty proceedings were pending for late payment by suppliers. For the main Italian Group companies, by order value, suppliers accounted for 50.9% of works, 35.3% of services and 13.8% of goods. For the main foreign operations, standard contractual payment terms include various time categories and invoices are generally paid within the prescribed limits.