Crime prevention

Hera SpA has adopted, since February 2004, the organisation and management model pursuant to Legislative Decree 231/01 (the "231 Model"), in line with the ethical principles expressed in the Code of Ethics and in compliance with the commitments made to stakeholders. Model 231 is aimed at preventing offences involving liability for legal persons in whose interest or to whose advantage the offence was committed, as provided for in Legislative Decree 231/2001.

Model 231 was subsequently extended within the Hera Group and expanded and updated in relation to the new cases included in the scope of application of Legislative Decree 231/2001 and in accordance with the evolution of the Group and the business activities performed.

Model 231 consists of a General Section and Protocols that make up the Special Section and regulate sensitive processes.

The Model adopted by the Hera Group is consistent with the contents of the guidelines drawn up on the subject by trade associations and with the indications of Italian and US internal auditing associations.

The Model 231 adopted, which is unique for the entire Hera Group, provides for information and training activities for those involved in sensitive processes in order to make them aware of prohibited and obligatory conduct, create awareness in relation to "ethical" conduct and promote a culture of control and prevention in the management of corporate risks. The Hera Group has set up a Supervisory Board that oversees the Model and carries out audits independently through the Internal Auditing Department.

The Hera Group promotes the fight against corruption by making its commitment to "zero tolerance" of corruption and fraud in any form, reaffirmed both in the Code of Ethics and in the Quality and Sustainability Policy.

Model 231, which already included measures to combat and prevent corruption, has been supplemented with the 'Model for the Prevention of Corruption'. The top management and the management of the Hera Group are personally committed to complying with the Model for the prevention of corruption, also by carrying out activities to raise awareness and disseminate the principles of the rules aimed at preventing corrupt acts within its structures.The Model for the prevention of corruption concerns all the people who work for the Hera Group.

Hera SpA in 2019, obtained the ISO 37001:2016 certification of the Management System for the prevention of corruption and the Supervisory Body took on the role of Compliance Function.

Any suspected breach of the Model for the prevention of corruption, alleged offence, fraud, bribery or other wrongdoing, whether or not relevant for the purposes of liability under Legislative Decree 231/2001, or any other information useful for preventing offences may be reported through the following channels

Hera Group Whistleblowing reporting portal Ordinary mail addressed to the Internal Auditing Department of Hera SpA Viale Berti Pichat 40127 Bologna with the indication "Confidential" on the envelope; oral reporting, by appointment to be requested by email to presidente.odv@PEC.gruppohera.it or by using the portal.

In any case, the confidentiality of the reporter's identity will be guaranteed, without prejudice to legal obligations and the protection of the rights of the Company or of the persons involved in the report.

The Hera Group is committed to ensuring that no-one suffers discriminatory treatment for refusing to be complicit in corrupt acts or crimes or for reporting in good faith the occurrence or possible occurrence of such conduct.

Discriminatory treatment includes, but is not limited to, dismissal, disciplinary measures, threats or other punitive behaviour in connection with a report.