Ethics and sustainability management

Our sustainability management model is transparent and integrated along the entire value chain

Sustainability, made tangible

We integrate sustainability into our business model thanks to a transparent and rigorous governance system. This commitment was solidified in 2021 with the publication of our first Sustainability Policy.

Independent Directors
Advanced anticorruption policy (including whistleblowing)
ESG Performance as part of the remuneration criteria
ESG Criteria as part of the acquisition process

Sustainability Policy

We are certain that the creation of sustainable and durable value must also respect the ethical principles of legality and fairness, integrity and honesty, and impartiality and transparency. At the same time, consistent improvement methodologies must be applied, as well as operational and managerial efficiency criteria.

In March 2021, we published our new Sustainability Policy: a document which explicitly outlines the paths we will take to achieve our sustainability strategy and to properly manage our operations.

Particularly, our Sustainability Policy reinforces and defines the terms which are essential for us to carry out our business. This includes:

  • quality of services offered;
  • protection of the environment;
  • responsibility towards our stakeholders;
  • a responsible and ethical means of conducting business;
  • a consistent commitment to innovation and digital transformation.

Discover our Sustainability Policy

Sustainability Management

We guarantee a governance system aligned with the best management practices, and is integrated with our sustainability profile. That’s why we have put into place a rigorous collection of rules and governance systems integrated at all levels of the company. This guarantees company management which is coherent with corporate objectives and the company’s vision for sustainability.

Our Control, Risks and Sustainability Committee supports the Board of Directors in defining the guidelines of internal auditing and risk management systems, as well as in the evaluation of the efficiency and effectiveness of the system, in the drafting of financial and non-financial documents, and in sustainability policies.

Through a vision which is integrated and aligned with ESG objectives, all of our corporate structures contribute to the improvement of the Company in terms of sustainability. In fact, we have configured virtual and inter-functional governance models which ensure an active, coordinated, and widespread supervision over our ESG objectives.

The Investor Relations and Sustainability department, supported by contributions from Institutional Relationships and Corporate Social Responsibility, is responsible for the ESG component within the company. It coordinates and monitors corporate structures in the overall development of actions and planning in terms of sustainability.

The solidity of our internal structure also allows for the diffusion of a culture integrated with risk auditing and management; this is supported by our Enterprise Risk Management (ERM) system. In particular, the system identifies, evaluates, and prioritises corporate risks, developing response actions and supporting management in making predictions and strategic decisions.

Integrated Management

We believe it fundamental that our activities are compatible with the health and safety of our workers, the landscape, natural resources, and the environment. That’s why we certify our management systems, so that our business can be conducted in full respect of health, safety guidelines, as well as the environment around us. In 2020, the entire Environmental and Safety Management System was subject to a re-certification from external body RINA, who confirmed all certifications already earned by the Company:

  • ISO certification 14001 relating to the environmental management system;
  • ISO certification 45001 in substitution of the OHSAS 18001, which certifies the Management of Worker Safety.

Privacy and Cybersecurity

In compliance with the applicable legal provisions, Rai Way has adopted a policy and a management model relating to the protection of personal data acquired and processed within the company, which provide for, inter alia:

  • the identification of organisational controls and security measures, also in relation to IT aspects, in compliance with the applicable provisions of law (in particular: Regulation (EU) 2016/679 and Italian Legislative Decree no. 193/2006 as amended by Italian Legislative Decree no. 101/2018);
  • the continuous monitoring and updating of business processes in compliance with the provisions of Regulation (EU) 2016/679 and in general with the provisions on the protection of personal data, thanks also to the support of a dedicated Working Group;
  • the performance, at least every two years, of independent external risk assessments and audits, in addition to internal audits, aimed at ensuring compliance and improving the effectiveness of the personal data management model;
  • regular training of all staff, both permanent and non-permanent, on the processing of personal data, with a further focus on all subjects authorized to data treatment. In addition, the legal department, as part of its competences for privacy issues, conducts specific courses on an infra-annual basis.

Ethics and Anticorruption

We at Rai Way pursue every corporate objective – including those related to sustainability – governed by two of our core principles: ethics and transparency.

Remuneration Policy

We have adopted a remuneration policy which supports company strategies and objectives, in order to create value relating to sustainability.

Responsible Supplier Management

We share our values with our commercial partners, committing to the sustainable management of our supply chain. This is achieved by:

  • implementing an obligation for 100% of suppliers to adhere to the company’s Sustainability Policy, Environment, Health and Safety Policy, and Privacy Management Policy, as well as adhering to the principles of the Code of Ethics, the Organisational Management and Auditing Model ex D.Lgs. 231/2001, and the Anticorruption Policy;
  • establishing, within certain specifications, the ESG parameters which characterise our services and products. Sustainable suppliers are used as a title of merit within MEAO procedures (Most Economically Advantageous Offer), or as a requirement in lower-priced procedures (ex. D.Lgs. 50/2016);
  • defining pacts of integrity with suppliers who participate in reliability procedures compliant with art. 4 and 15 D.Lgs. 50/201;
  • adopting an auditing system for the morality and reliability profiling of suppliers, through consistent monitoring against specific requirements as well as through the exclusion of any suppliers condemned definitively for any crimes under art. 80 of D.Lgs. 50/2016 (e.g., tax or social security avoidance, exploitation of minors, workplace safety violations);
  • establishing supply procedures which allow a synergy between small- and medium-sized companies and their participation in aggregate form, appreciating also the territoriality of the supplier. Learn more
  • adopting an e-procurement system which has made the supply process entirely traceable, and which favours digital communication with all suppliers. Learn more
  • implementing specific engagement initiatives with the suppliers included in the List (see box below), as well as implementing more relevant value in contracts (e.g., regular virtual meetings, requests for filling out questionnaires and the collection of relevant sustainability policies).

Rai Way Suppliers List and ESG Policies

In 2020, we implemented the Rai Way Suppliers List, making it operational in the same year. The list refers both to the architectural and engineering services carried out on our towers and to specific merchandising categories related to industry contracts for electronic communication, ex art. 15 of D.Lgs. 50/16.

In that respect, to permanently sign up to the Rai Way Suppliers List, each supplier is expressly requested to indicate the environmental and social policies implemented within their company, as well as following the specific policy adopted by Rai Way itself. All suppliers contracted by Rai Way are obliged to respect Rai Group’s Code of Ethics, organisational model, and auditing and management system ex D.Lgs. n. 231/2001, as well as the Anticorruption Policy. They must also follow, by the same regulations, obligations dictating the violation hypothesis for the reason of initial suspension and, in the case of recurrence, successive removal from the List, pursuant to the termination clause expressed in accordance with that outlined in art. 1456 c.c.