2022 Communication on Progress

Prysmian Group

Published date

June 30, 2022

No. of questions

69

Supplemental files

CEO Statement

Signed

  • Governance

    Policies and Responsibilities

    1. Does the Board / highest governance body or most senior executive of the company:

    Optional comment
    https://www.prysmiangroup.com/sites/default/files/atoms/files/DNF_ENG%202021_15.03.2022_1.pdf

    2. Does the company have a publicly stated commitment regarding the following sustainability topics?

    No, this is not a current priority

    No, but we plan to have a commitment within 2 years

    Yes, and the commitment is focused on our own operations

    Yes, and the commitment includes our own operations and the value chain

    Yes, and the commitment includes our own operations and the value chain along with communities and society

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    3. Does the company have in place a code of conduct regarding each of the following sustainability topics?

    No, this is not a current priority

    No, but we plan to have a code of conduct within two years

    Yes, focused on employee conduct

    Yes, focused on employees and suppliers

    Yes, focused on employees, suppliers, and other business relationships

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Optional comment
    https://www.prysmiangroup.com/sites/default/files/atoms/files/Prysmian_Code%20of%20Business%20Conduct_Final_070519.pdf

    4. Has the company appointed an individual or group responsible for each of the following sustainability topics?

    No one is specifically responsible for this topic

    Yes, with limited influence on outcomes (e.g., limited access to internal information, limited decision-making authority)

    Yes, with moderate influence on outcomes (e.g., has access to relevant information, reports to senior manager)

    Yes, with direct influence of some outcomes (e.g., has access to relevant information, includes one or more senior manager with decision making rights

    Yes, with direct influence at the highest levels of the organization (e.g., has access to relevant information, includes most senior members of organization)

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    5. Does the company have a formal structure(s) (such as a cross-functional committee) to address each of the following sustainability topics?

    No formal structure

    Yes, and with limited influence on outcomes (e.g., limited access to internal information necessary to understand risks, poor representation from relevant departments or functions)

    Yes, with moderate influence on outcomes (e.g., it includes representatives of some functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, reports to senior manager)

    Yes, with direct influence on some outcomes (e.g., it includes representatives of functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, it involves one or more members of senior management)

    Yes, and with direct influence at the highest level of the organization (e.g., full access to relevant information, it involves members at highest level of organization)

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Prevention

    6. Does the company have a process or processes to assess risk?

    No, this is not a current priority

    No, but we are planning to develop one in the next two years

    Yes, related to our own operations

    Yes, related to our own operations and entire value chain and other business relationships

    Human rights risks

    Labour rights risks

    Environmental risks

    Corruption risks

    Optional comment
    https://www.prysmiangroup.com/sites/default/files/atoms/files/20210520_PrysmianGroup_Purchasing_SupplyChainStrategy_public.pdf

    6.1. During the assessment of risk, which business relationships are reviewed?

    A few suppliers or business relationships [approximately less than 25 %]

    Several suppliers / business relationships (i.e., first tier or other high priority) [approx. 25 - 50 %]

    Most suppliers / relevant business relationships [approx. 51 - 99 %]

    All suppliers / relevant business relationships outside the supply chain

    Human rights risks

    Labour rights risks

    Environmental risks

    Corruption risks

    Optional comment
    https://www.prysmiangroup.com/sites/default/files/atoms/files/20210520_PrysmianGroup_Purchasing_SupplyChainStrategy_public.pdf

    7. Does the company have a due diligence process through which it identifies, prevents, mitigates, and accounts for actual and potential negative impacts on sustainability topics?

    No, this is not a current priority

    No, but we are planning to develop one in the next two years

    Yes, related to our own operations

    Yes, related to our own operations and entire value chain and other business relationships

    Human rights risks

    Labour rights risks

    Environmental risks

    Corruption risks

    Optional comment
    https://www.prysmiangroup.com/sites/default/files/atoms/files/Prysmian-HRDD-Methodology-criteria-and-outcomes-2021.pdf https://www.prysmiangroup.com/sites/default/files/atoms/files/1-Anti-Corruption-Policy.pdf

    Concerns and grievance mechanisms

    8. Are there any processes through which members of the company’s workforce can raise concerns about the company’s conduct related to human rights, labour rights, environment, or anti-corruption?

    Optional comment
    https://secure.ethicspoint.eu/domain/media/en/gui/105359/index.html

    8.1. Please provide additional detail regarding the process(es) the company has through which members of the company’s workforce can raise concerns about the company’s conduct.

    No

    Yes

    Is the process communicated to all employees/workers in local languages?

    Is the process available to non-employees (e.g., contractors, vendors, suppliers)?

    Is the process confidential (e.g., whistleblowing process)?

    Are there processes in place to avoid retaliation?

    Can concerns be raised about suppliers or other business relationships (e.g., clients, partners, etc.)

    Other (Please provide additional information)

    Optional comment
    https://secure.ethicspoint.eu/domain/media/en/gui/105359/index.html https://www.prysmiangroup.com/sites/default/files/atoms/files/Prysmian%20Group%20-%20Helpline%20Policy_11102019%20%28003%29%20IF%20logo_final_%4029112019.pdf

    9. Does the company provide or enable access to effective remedy to right holders / stakeholders where it has caused or contributed to the adverse impact?

    No process to enable remedy to stakeholders

    Remedy available to some stakeholders (i.e., some geographies, employees only)

    Remedy is available to all affected stakeholders

    Remedy is available to all stakeholders, and suppliers are expected to have similar policies

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Lessons

    10. How does the company capture lessons regarding each of the following sustainability topics?

    No lessons are regularly captured

    Conducts root cause analyses/investigation of major incidents

    Conducts root cause analyses/investigation and changes organizational policies, processes, and practices accordingly

    Systematically conducts root cause analyses/investigation and leverages learnings to influence both internal and external affairs

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Executive Pay

    11. Is executive pay linked to performance on one or more of the following sustainability topics?

    No, and we have no intention to change

    No, but we plan to within two years

    Yes

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Optional comment
    https://www.prysmiangroup.com/sites/default/files/atoms/files/prysmian-remuneration-report-2022-eng.pdf

    Board Composition

    12. Percentage of individuals within the company’s Board / highest governance body by:

    Number/Percentage

    Not applicable (Please provide additional information)

    Total number of board members (#)

    12

    Male (%)

    58

    Female (%)

    42

    Non-binary (%)

    0

    Under 30 years old (%)

    0

    30-50 years old (%)

    8

    Above 50 years old (%)

    92

    From minority or vulnerable groups (%)

    17

    Executive (%)

    15

    Independent (%)

    75

    13. Do you produce sustainability reporting according to:

    Corporate Governance from Borsa Italiana

    Data Assurance

    14. Is the information disclosed in this questionnaire assured by a third-party?

    Prysmian Sustainability Report pag. 202-204 https://www.prysmiangroup.com/sites/default/files/atoms/files/DNF_ENG%202021_15.03.2022_1.pdf

  • Human Rights

    Materiality / Saliency

    1. Which of the following has the company identified as material human rights issues connected with its operations and/or value chain, whether based on their salience (i.e., the most severe potential negative impacts on people) or another basis?

    Optional comment
    As reported in the materiality matrix published in our Sustainability Report, the Respect for human rights and workers’ rights is considered as one of the main material topic. As an international business operating in many countries and communities, Prysmian strives with passion to respect and safeguard the human rights of all employees and all those affected by our activities. The objective is to ensure that the Prysmian Group is not involved in any way, either directly or indirectly, in activities that violate human rights. With this objective in mind, the Group Human Rights Policy was introduced in 2017. This policy is based on various international standards (such as the Universal Declaration of Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, the United Nations Global Compact, etc.) and applied at all locations and in all Prysmian activities. The Group Human Rights Policy identifies the following material human rights issues: non-discrimination, child labour, forced, bonded and compulsory labour, freedom of assoxiation and recognition of the right to collective bagaining, health & safety, working conditions, fair wages and equal compensation . In addition, as reported in the materiality matrix, diversity,inclusion and equality is considered as a standalone material topic. In particular, Prysmian has identified the promotion of diversity and equal opportunities, through the development of an increasingly inclusive organisation, as a strategic objective for the management of human resources. In light of this commitment, the Prysmian Group has adopted a global “Diversity & Inclusion Policy” and is developing a number of supporting initiatives. Human Rights Policy: https://www.prysmiangroup.com/sites/default/files/atoms/files/prysmian_group_human_rights_policy_eng_firma-vb.pdf Sustainability report pages 47-49; 93-96:

    Commitment

    2. Does the company have a policy commitment in relation to the following human rights issues?

    No, and we have no plans to develop a policy

    No, but we plan to in the next two years

    Yes, included within a broader policy

    Yes, articulated as a stand-alone policy

    Rights of women and/or girls

    2021

    Freedom of expression

    Rights of refugees and migrants

    Digital security / privacy

    Rights of indigenous peoples

    Access to culture

    Free, prior and informed consent

    Access to water and sanitation

    2.1. For each human rights policy, is it:

    Aligned with international human rights standards?

    Publicly available?

    Approved at most senior level of the company?

    Applied to the company’s own operations?

    Applied to the company’s supply chain and/or other business relationships?

    Developed involving human rights expertise from inside and outside the company?

    Other (Please provide additional information)

    Freedom of expression

    Digital security / privacy

    Rights of women and/or girls

    Access to culture

    Rights of indigenous peoples

    Free, prior and informed consent

    Rights of refugees and migrants

    Access to water and sanitation

    Prevention

    3. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following human rights issues?

    No engagement on this topic

    To better understand the risks/ impacts in question

    To discuss potential ways to prevent or mitigate the risks/ impacts in question

    To agree on a way to prevent/ mitigate the risks/ impacts in question

    To assess progress in preventing /mitigating the risks/impacts in question

    To collaborate in the prevention/ mitigation of the risks/ impacts in question

    Rights of women and/or girls

    Freedom of expression

    Rights of refugees and migrants

    Digital security / privacy

    Rights of indigenous peoples

    Access to culture

    Free, prior and informed consent

    Access to water and sanitation

    Optional comment
    https://www.prysmiangroup.com/sustainability/our-people/diversity-and-inclusion/prysmian-group-s-enclusion-week-2021 https://www.prysmiangroup.com/en/company/ethics-integrity/human-rights/human-rights-in-prysmian-group/prevention-and-mitigation

    4. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this human rights issue?

    Provided internal training/ capacity building for the direct workforce

    Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)

    Conducting an audit process and/or corrective action plan

    Collective Action with peers or other stakeholders to address the issue

    Collaboration with governmental or regulatory bodies

    Other (Please provide additional information)

    No action within reporting period

    Rights of women and/or girls

    Freedom of expression

    Rights of refugees and migrants

    Digital security / privacy

    Rights of indigenous peoples

    Access to culture

    Free, prior and informed consent

    Access to water and sanitation

    Optional comment
    https://www.prysmiangroup.com/en/people-and-careers/why-prysmian/diversity-and-inclusion

    5. Who receives training for the following human rights issues?

    No training provided

    Select employees

    All employees

    Contractors

    Direct suppliers of the organization

    Indirect suppliers of the organization

    Other – such as partners, clients, etc.

    Rights of women and/or girls

    Freedom of expression

    Rights of refugees and migrants

    Digital security / privacy

    Rights of indigenous peoples

    Access to culture

    Free, prior and informed consent

    Access to water and sanitation

    Optional comment
    Sustainability Report 2021 pages 93-96. https://people.prysmiangroup.com/sites/people.prysmiangroup.com/files/2022-03/DNF_ENG%202021_15.03.2022.pdf https://www.prysmiangroup.com/en/people-and-careers/why-prysmian/diversity-and-inclusion

    6. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following human rights issues?

    No monitoring of progress

    Review issues on ad-hoc basis

    Set annual targets/ goals, track progress over time (internal programs only)

    Set annual targets/ goals, track progress over time (internal and external programs)

    Other (Please provide additional information)

    Rights of women and/or girls

    Freedom of expression

    Rights of refugees and migrants

    Digital security / privacy

    Rights of indigenous peoples

    Access to culture

    Free, prior and informed consent

    Access to water and sanitation

    Optional comment
    In 2021 Prysmian announced the new Social Ambition targets. New 2030 targets support delivery of Prysmian’s Social Ambition objectives and further align the Group with the United Nations Sustainable Development Goals. The main areas of focus of the Group’s new Social Ambition include commitments to improving diversity, equality and inclusion; digital inclusion; empowerment of communities; employee engagement and upskilling. The Company defined several annual and long terms targets measured through several KPIs that are publicly disclosed. https://www.prysmiangroup.com/en/sustainability/social-ambition

    Response

    7. During the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to adverse impact associated with the following human rights issue(s)?

    Yes

    No

    Choose to not disclose

    Not applicable (Please provide additional information)

    Rights of women and/or girls

    Freedom of expression

    Rights of refugees and migrants

    Digital security / privacy

    Rights of indigenous peoples

    Access to culture

    Free, prior and informed consent

    Access to water and sanitation

    Optional comment
    The company has not caused or contributed to any adverse impact associated with rights of women and/or girls

    8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the human rights principles, including any challenges faced and actions taken towards prevention and/or remediation.

    Please check all our findings, actions and remediation at our dedicated webpage: https://www.prysmiangroup.com/en/company/ethics-integrity/human-rights/human-rights-in-prysmian-group/prevention-and-mitigation

  • Labour

    Commitment

    1. Does the company have a policy commitment in relation to the following labour rights principles?

    No, and we have no plans to develop a policy

    No, but we plan to in the next two years

    Yes, included within a broader policy

    Yes, articulated as a stand-alone policy

    Not applicable (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    2017

    Forced labour

    2017

    Child labour

    2017

    Non-discrimination in respect of employment and occupation

    2017

    Occupational safety and health

    2017

    Working conditions (wages, working hours)

    Optional comment
    https://www.prysmiangroup.com/sites/default/files/atoms/files/20200724_PRY_HumanRightsPPT_final.pdf

    1.1. For each labour rights policy, is it:

    Aligned with international labour standards?

    Publicly available?

    Approved at most senior level of the company?

    Applied to the company’s own operations?

    Applied to the company’s supply chain and/or other business relationships?

    Developed involving labour rights expertise from inside and outside the company?

    Other (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    Optional comment
    Pages 3 and 9 Group Human Rights Policy https://www.prysmiangroup.com/sites/default/files/atoms/files/prysmian_group_human_rights_policy_eng_firma-vb.pdf https://www.prysmiangroup.com/en/company/ethics-integrity/human-rights/human-rights-in-prysmian-group https://www.prysmiangroup.com/sites/default/files/atoms/files/20200724_PRY_HumanRightsPPT_final.pdf

    Prevention

    2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following labour rights issues?

    No engagement on this topic

    To better understand the risks/ impacts in question

    To discuss potential ways to prevent or mitigate the risks/ impacts in question

    To agree on a way to prevent/ mitigate the risks/ impacts in question

    To assess progress in preventing/ mitigating the risks /impacts in question

    To collaborate in the prevention/ mitigation of the risks/ impacts in question

    Other (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    Optional comment
    https://www.prysmiangroup.com/en/company/ethics-integrity/human-rights/human-rights-in-prysmian-group/prevention-and-mitigation https://www.prysmiangroup.com/sites/default/files/atoms/files/20200724_PRY_HumanRightsPPT_final.pdf https://www.prysmiangroup.com/sites/default/files/atoms/files/Prysmian%20Group%20-%20Helpline%20Policy_11102019%20%28003%29%20IF%20logo_final_%4029112019.pdf

    3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this labour rights issue?

    Provided internal training/ capacity building for the direct workforce

    Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)

    Conducting an audit process and/or corrective action plan

    Collective Action with peers or other stakeholders, in particular workers' organizations, to address the issue

    Collaboration with governmental or regulatory bodies

    Other (Please provide additional information)

    No action within reporting period

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    Optional comment
    Regarding the freedom of association we collaborated with the European Worker's council. Collective Bargaining p.105 of NFD21. https://www.prysmiangroup.com/sites/default/files/atoms/files/DNF_ENG%202021_15.03.2022_1.pdf

    4. Who receives training for the following labour rights issues?

    No training provided

    Select employees

    All employees

    Contractors

    Direct suppliers of the organization

    Indirect suppliers of the organization

    Other – such as partners, clients, etc.

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    5. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following labour rights issues?

    No monitoring of progress

    Review issues on ad-hoc basis

    Set annual targets/ goals, track progress over time (internal programs only)

    Set annual targets/ goals, track progress over time (internal and external programs)

    Other (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    Optional comment
    Sustainability Report pages 15-17; 106 https://www.prysmiangroup.com/sites/default/files/atoms/files/DNF_ENG%202021_15.03.2022_0.pdf

    Performance

    6. What is the percentage of employees covered under collective bargaining agreements?

    Percent of employees (%)

    Unknown

    Employees covered under collective bargaining (%)

    62
    Optional comment
    The percentage includes both employees in a trad union and covered by collective bargaining agreements

    7. What is the percentage of employees in a trade union or other workers' organization?

    Percent of employees (%)

    Unknown

    Not applicable (Please provide additional information)

    Employees in a trade union or on a worker committee (%)

    62
    Optional comment
    The percentage includes both employees in a trad union and covered by collective bargaining agreements

    8. In the course of the reporting period, what was the percentage of women in:

    Percent of women (%)

    Unknown

    Senior leadership level position

    13.5

    Non-executive board

    55
    Optional comment
    Sustainability Report pag. 97 https://www.prysmiangroup.com/sites/default/files/atoms/files/DNF_ENG%202021_15.03.2022.pdf

    9. What was the average ratio of the basic salary and remuneration of women to men (comparing jobs of equal value) during the reporting period?

    Salary ratio (%)

    Unknown

    Choose to not disclose

    Women / Men (%)

    7
    Optional comment
    Remuneration Report pag.12 https://www.prysmiangroup.com/sites/default/files/Prysmian%20Remuneration%20Report%202022%20ENG_compressed_compressed.pdf

    10. In the course of the reporting period, how frequently were workers injured (injuries per hour worked)?

    Frequency of injury

    Unknown

    Choose to not disclose

    Frequency of injury

    1.55
    Optional comment
    We have reported the frequency index in accordance with our NFD disclosure. Sustainability Report pag. 107 https://www.prysmiangroup.com/sites/default/files/atoms/files/DNF_ENG%202021_15.03.2022_1.pdf

    11. In the course of the reporting period, what was the company’s incident rate?

    Incident rate

    Unknown

    Choose to not disclose

    Incident rate

    47.19
    Optional comment
    We have reported the severity index in accordance with our NFD disclosure. Sustainability Report pag. 107 https://www.prysmiangroup.com/sites/default/files/atoms/files/DNF_ENG%202021_15.03.2022_1.pdf

    Response and Reporting

    12. In the course of the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to the adverse impact associated with the following labour rights issues?

    Yes

    No

    Choose to not disclose

    Not applicable (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    Optional comment
    We organized a safety week: https://www.prysmiangroup.com/en/safety-week We had remediation after two fatalities which happened in the group. Sustainability Report pag. 107: https://www.prysmiangroup.com/sites/default/files/atoms/files/DNF_ENG%202021_15.03.2022_1.pdf

    13. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the labour rights principles, including any challenges faced and actions taken towards prevention and/or remediation.

    The group has launched its social ambition, which aims at reducing inequealities, boost diversity and inclusion, curb the pay gap, re-balance gender in the company and bring the numeber of accident towards zero. Please find out more on our webpage: https://www.prysmiangroup.com/it/sostenibilita/social-ambition

  • Environment

    Commitment

    1. Does the company have a formal policy on the following environmental topics?

    No, and we have no plans to develop a policy

    No, but we plan to in the next two years

    Yes, included within a broader policy

    Yes, articulated as a stand-alone policy

    Not applicable (Please provide additional information)

    Climate Action

    2020

    Water

    2020

    Oceans

    The Group does not have a policy in place as this aspect is not material.

    Forests / Biodiversity / Land Use

    2020

    Air Pollution

    2020

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    2020

    Energy & Resource Use

    2020
    Optional comment
    2020

    1.1. For each environmental policy, is it:

    Aligned with international environmental standards?

    Publicly available?

    Approved at most senior level of the company?

    Applied to the company’s own operations?

    Applied to the company’s supply chain and/or other business relationships?

    Developed involving environmental expertise from inside and outside the company?

    Other (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    Optional comment
    The Group HSEE Policy is publicly available (https://www.prysmiangroup.com/sites/default/files/atoms/files/HSEE%20Policy_2020_signed.pdf) and applies to the whole Prysmian Group. The HSEE Policy is signed by the CEO , demonstrating leadership and commitment of the Top Management with respect to continual improvement in terms of environmental and natural resources management. The Policy is aligned with international environemental standards, including UNI EN ISO 50001:2018 and UNI EN ISO 14001:2015.

    Prevention

    2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following environmental issues?

    No engagement on this topic

    To better understand the risks/ impacts in question

    To discuss potential ways to prevent or mitigate the risks/ impacts in question

    To agree on a way to prevent/ mitigate the risks/ impacts in question

    To assess progress in preventing/ mitigating the risks/ impacts in question

    To collaborate in the prevention/ mitigation of the risks/ impacts in question

    Other (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    Optional comment
    With reference to the Group's main material aspects (Climate action and energy), Prysmian assesses progress in preventing/ mitigating the risks/ impacts in question thanks to specific supplier engagement initiative. The strategic management of the Prysmian Group supply chain is based on a defined process that takes ESG factors in account: • risk assessment; identification of critical suppliers; • supplier management and performance evaluation; • search and selection of the supplier according to standardized processes. Since 2014, Prysmian uses the Desk Analysis, as a process aiming to assess and rate commitment of suppliers on ESG factors. Based on the Desk Analysis, the Group elaborated a tailored Risk Analysis. This second step of the assessment has the target to re-evaluate the performance of these suppliers. Prysmian’s aim is to detect potential sustainability and environmental-related risk and implement adequate action to mitigate them. In doing so, Prysmian attempts to mitigate reputational risks. From the supplier assessment, Prysmian is able to monitor the sustainability of the supply chain and reduce possible negative impact adopting improvements and mitigation actions in order to optimize its supply chain in a sustainable way while avoiding noncompliance risks. In order to guarantee the quality and the low carbon impact of the materials purchased, the Group is committed to use only those raw materials approved by the responsible technical functions following laboratory tests and extended processing trials conducted both in-house and by qualified suppliers. Regarding to water - related issues, considering the quantity and quality of water sources, the type of usage, the recycling systems used and, in general, assessment of the environmental aspects and impacts as part of the Environmental management system, it is clear that the most significant water-related impact is not directly associated with organisational activities, but rather with the supply chain and, in particular, with the production cycles of base metal suppliers. For this reason, in addition to continuing to track and audit “critical” suppliers with reference to sustainability criteria and indices, Prysmian extended assessment of the risks related to the availability of water to the entire supply chain in 2021 and is considering the introduction of specific rating systems, including the CDP Water Security Questionnaire, in order to assess the management of water resources within the supply chain. In general, for all ESG aspects, the sustainability strategy of the Prysmian Group is founded on continuous dialogue with our stakeholders. The pursuit of corporate goals requires the development of forms of dialogue and ongoing interaction with both internal and external stakeholders. This is necessary in order to understand their needs, interests and expectations, anticipate changes and identify emerging trends, thus enabling the Group to pursue its own sustainable development goals and generate shared and consistent added value in the long run. Multi-stakeholder engagement initiatives are an integral part of the Group’s growth strategy, as well as an effective communications channel. The purpose of these initiatives is to: • identify ideas for improvements that lead to product and process innovation; • improve the management of reputational and other risks; • inform, engage and build the awareness of stakeholders regarding various aspects of importance to the Group and the society in which it works; • identify the needs, problems and expectations of stakeholders, integrate them into the Group’s strategy and develop a relationship based on trust and transparency.

    3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with these environmental topics?

    Provided internal training/ capacity building for the direct workforce

    Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)

    Conducting an audit process and/or corrective action plan

    Collective Action with peers or other stakeholders to address the issue

    Collaboration with governmental or regulatory bodies

    Other (Please provide additional information)

    No action within reporting period

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    Optional comment
    In order to prevent and mitigate environmental risks, the Group has adopted an ISO14001-certified environmental management system at 90% of its production locations. Environmental matters are managed centrally by the Health, Safety & Environment (HSE) function. In coordinating the local HSE functions, this function adopts systems intended to guarantee strict compliance with the regulations in accordance with best practices, collects and analyses environmental data using a centralised platform, monitors the exposures to risk using specific indicators, organises specific training and carries out audit work at the production locations.

    4. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following environmental topics?

    No monitoring of progress

    Review issues on ad-hoc basis

    Set annual targets/ goals, track progress over time (internal programs only)

    Set annual targets/ goals, track progress over time (internal and external programs)

    Other (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    Optional comment
    Progress against targets is tracked monthly at Group level and reported internally to the high levels of the Group, including the most senior level. Furthermore, progress is reported externally at least yearly in the Non Financial Disclosure.

    4.1. For each environmental topic in which the company sets timebound goals / targets, what kind of targets has the company set?

    Description of targets (e.g., what is the target, absolute vs. intensity, externally verified, on track, etc.)

    Climate Action

    Absolute redcution of Scope 1, 2 and 3 emissions by 2030 with respect to 2019 baseline: • - 46% Scope 1 and 2 (market based) by 2030, with respect to 2019 baseline (870 ktCO2) • - 21% Scope 3 (categories 1 and 11) by 2030, with respect to 2019 baseline Net Zero Target for Scope 1&2 in 2035 and for Scope 3 in 2050.

    Energy & Resource Use

    Reduction of energy consumption: -3% by 2022, with respect to 2019 baseline (9845 TJ)

    Water

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Increase of percentage of waste recycled: 65% by 2022, with respect to 63% in 2019.

    Oceans

    Optional comment
    The challenging targets reported are published in the Sustainability Report 2021, within the Group's official Sustainability Scorecard. With reference to the GHG reduction targets, these have been formally validated by the Science Based Initiative, as reported also on the official website of the SBTi.

    4.2. For each environmental topic in which the company sets timebound goals / targets, how is progress against target / goal tracked?

    Progress is reviewed against goals annually or more frequently

    Progress is reported internally to the most senior level

    Progress is reported externally

    Other (Please provide additional information)

    Climate Action

    Energy & Resource Use

    Water

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Oceans

    Optional comment
    Progress against targets is tracked monthly at Group level and reported internally to the high levels of the Group, including the most senior level. Furthermore, progress is reported externally at least yearly in the Non Financial Disclosure.

    5. In the course of the reporting period, has the company been involved in providing or enabling remedy for any actual impacts associated with the following environmental issue(s)?

    Yes

    No

    Choose to not disclose

    Not applicable (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    Optional comment
    As publicly reported in the Sustainability Report 2021, during the period 2019-2021, the Group did not receive any significant penalties (monetary or other) for regulatory non-compliance in the environmental field.

    Climate Action

    6. What were the company’s gross global greenhouse gas emissions for the reporting period?

    Scope 1 Emissions

    Emissions (tCO2e)

    319467

    Scope 2 Emissions

    Emissions (tCO2e)

    358395

    Scope 3 Emissions

    Emissions (tCO2e)

    284562292
    Optional comment
    Regarding Scope 2 emissions, the reported figure refers to market - based approach. https://www.prysmiangroup.com/en/sustainability/climate-change-ambition/environmental-performance/greenhouse-gas-emissions

    7. What percentage of the company's revenue was invested in R&D of low-carbon products/services during this reporting period?

    Percent of revenue (%)

    44
    Optional comment
    Estimate done based on the Climate Bond Taxonomy

    8. Has the organization acted to support climate change adaptation and resilience?

    Energy / Resource Use

    9. Please report the company's renewable energy consumption as a percentage of total energy consumption in the reporting period.

    % of total energy consumption

    27

    Technology

    10. What percent of the company's revenue came from environmentally friendly products / services during this reporting period?

    Percent of total revenue (%)

    44
    Percentage of annual revenues from low carbon-enabling products totalled 44% in 2021, estimate done based on the Climate Bond Taxonomy . Please be aware that the Group defined an official target tpublished in the Prysmian Sustainability Scorecard, planning to achieve 48% to 50% by 2022.

    Sector-specific Questions

    11. Which sector(s) does the company operate in? If diversified, choose top 3 by revenue.

    Sector-specific: Water

    12. Please provide details regarding the company's water withdrawal and consumption (own operations) during the reporting period.

    Water withdrawal (volume of water in megaliters):

    Mega-liters

    Unknown

    Not applicable (Please provide additional information)

    Total

    8642

    Groundwater:

    7411

    Surface water:

    1231

    Rainwater:

    0

    Wastewater:

    0

    Percentage of water withdrawn in regions with high or extremely high water stress (%)

    28

    Water consumption (volume of water in megaliters):

    Mega-liters

    Unknown

    Not applicable (Please provide additional information)

    Total

    8642

    Groundwater:

    7411

    Surface water:

    1231

    Rainwater:

    0

    Wastewater:

    0

    Percentage of water consumed in regions with high or extremely high water stress (%)

    28
    Optional comment
    As a precaution, Prysmian assumes that water consumption is equal to the volume of water drawn: the Group began to collect data in 2019 about the quantity of water returned to surface reservoirs; this data was only provided by a limited number of operating units and, accordingly, was not considered representative at Group level.

    13. Please provide details about the company’s water intensity of products in regions with high or extremely high water stress.

    Water intensity of products (cubic meter/$):

    0.0006
    Optional comment
    Please be aware that the intensity figure reported (in cubic meter/eur) refers to the 2021 total water withdrawal divided by the 2021 total Group's revenues, including both regions with water stress and regions without water stress.

    Sector-specific: Air pollution

    17. Where applicable, please report the company's emissions of the following pollutants during the reporting period.

    Emissions (tCO2e)

    Unknown

    Not applicable (Please provide additional information)

    NOx

    The emissions associated to the air pollutants above are not significant for the Group, thus not publicly reported as provided in GRI 305-7 Standard. However, please be aware that each productive site monitors these air pollutants in accordance with local regulations.

    SOx

    The emissions associated to the air pollutants above are not significant for the Group, thus not publicly reported as provided in GRI 305-7 Standard. However, please be aware that each productive site monitors these air pollutants in accordance with local regulations.

    Volatile Organic Compounds (VOC)

    The emissions associated to the air pollutants above are not significant for the Group, thus not publicly reported as provided in GRI 305-7 Standard. However, please be aware that each productive site monitors these air pollutants in accordance with local regulations.

    Hazardous air pollutants (HAP)

    The emissions associated to the air pollutants above are not significant for the Group, thus not publicly reported as provided in GRI 305-7 Standard. However, please be aware that each productive site monitors these air pollutants in accordance with local regulations.

    Particulate matter (PM10)

    The emissions associated to the air pollutants above are not significant for the Group, thus not publicly reported as provided in GRI 305-7 Standard. However, please be aware that each productive site monitors these air pollutants in accordance with local regulations.

    Persistent organic pollutants (POP)

    The emissions associated to the air pollutants above are not significant for the Group, thus not publicly reported as provided in GRI 305-7 Standard. However, please be aware that each productive site monitors these air pollutants in accordance with local regulations.

    Other (please specify in text box)

    Sector-specific: Waste

    18. Please report the company's total weight of waste generated in metric tonnes during the reporting period.

    Waste Generated (t)

    212704
    Optional comment
    The quantity of waste produced by the Prysmian Group in 2021 totalled 212,703,640 kilograms, as formally reported in the Sustainability Report 2021. According to the GRI 306 Standard, Prysmian has carried out a more in-depth analysis of the disposal method used for different categories of waste produced. Downstream of the analysis, it emerges that 69% of the 2021 total waste is recycled, while 21% is sent to landfills.

    19. Please report the percentage of the company's waste that was hazardous waste (i.e., hazardous waste ratio) during the reporting period.

    Hazardous Waste Ratio (%)

    6
    Optional comment
    The quantity of hoazardous waste produced by the Prysmian Group in 2021 totalled 13,466,833 kilograms, as formally reported in the Sustainability Report 2021.

    20. Please report the company's estimated metric tonnes of single-use plastic consumed wherever material along the value chain during the reporting period.

    Single-use plastics (tonnes)

    Single-use plastic consumption is actually not material for the Group thanks to the many initiatives launched to ensure its elimination. Some years ago, the Group launched its “Plastic Free” pilot project , eliminating all single use plastic at its Milan headquarters where around 700 people work. That means 700,000 less plastic objects to throw away and recycle each year, making a small contribution to the growing problem of plastic waste. Water vending machines are being replaced by water dispensers. The project has been launched at other offices too, as part of the sustainable culture that characterizes the Group.

    Overall Environment

    21. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the environment principles, including any challenges faced and actions taken towards prevention and/or remediation.

    In 2020, the Group began work on the development of science-based objectives for the emissions generated by its activities worldwide (Scope 1 and 2) and for the emissions of the broader value chain (Scope 3). These objectives were validated by the SBTi (Science Based Target Initiative) in 2021. Therefore, with the Climate Change Ambition, the Prysmian Group rolls out a new strategy, aligned with the Paris Agreement, and commits to a 2035 “Net Zero” target for emissions from its own operations (Scope 1 and 2), and 2050 for value chain emissions (Scope 3). The company will invest 100 million euros in this initiative over the next 10 years. As part of the decarbonisation strategy, Prysmian Group is involving all sites and activities worldwide in actions that include an assessment of the opportunities for energy efficiency, the purchase and production of renewable energy, and the reduction of SF6 gas emissions. These opportunities will be addressed by a Group-wide project coordination and implementation programme. The progress made and new decarbonisation opportunities will be examined continuously, as part of our normal business processes. In this regard, the Group invested 15 million € in environmental initiatives to reduce GHG emissions and, in general, Prysmian's environmental impact in 2021, compared with 4 million € invested in 2020, including: • initiatives for the reduction of energy consumption and GHG emissions • initiatives for the reduction of water consumption • initiatives for the reduction of waste production More details are ported in the 2021 Sustainability Report - page 150.

  • Anti-corruption

    Commitment

    1. Does the company have an anti-corruption compliance programme?

    2021
    Optional comment
    ISO 37001 Anti-bribery Management

    2. Does your company have policies and recommendations for employees on how to act in case of doubt and/or in situations that may represent a conflict of interest, e.g. with regard to gifts and hospitality, donations, sponsorship, or interactions with public officials?

    Optional comment
    COI policy + Annual COI Campaign (respond to 4 Key questions and reviewed by Compliance Team, with Hr and Manager if needed)

    Prevention

    3. Who receives training on anti-corruption and integrity?

    Optional comment
    All employees have received Anti bribery and corruption, and Gifts & Entertainment training in 2021; all external Sales Agents received online training on anti bribery and corruption; on a bi-annual basis all employees receive Code of Ethics online training; All employees are required to sign off on the Company's Code of Ethics; All Business Partners are required to sign off on the Company's Code of Conduct and an Anti-corruption Acknowledgement

    3.1. How often is such training provided?

    One time only

    Every year

    Every two or more years

    We do not collect this data

    All employees

    Select employees

    Contractors

    Direct suppliers of the organization

    Other – such as partners, clients, etc.

    Indirect suppliers of the organization

    Optional comment
    Please provide additional explanation: All employees have received Anti bribery and corruption, and Gifts & Entertainment training in 2021; all external Sales Agents received online training on anti bribery and corruption; on a bi-annual basis all employees receive Code of Ethics online training; All employees are required to sign off on the Company's Code of Ethics; All Business Partners are required to sign off on the Company's Code of Conduct and an Anti-corruption Acknowledgement

    4. Does the company monitor its anti-corruption compliance programme?

    Optional comment
    ISO 37001 Anti-bribery Management System Certification attained

    Response and Reporting

    5. Please report the company's total number and nature of incidents of corruption during the reporting year.

    Number of incident(s)

    Unknown

    Choose to not disclose

    Confirmed during the current year, but related to previous years

    0
    The Prysmian Group has had no confirmed cases of corruption in FY2021

    Confirmed during the current year, and related to this year

    0
    The Prysmian Group has had no confirmed cases of corruption in FY2021

    6. Within the reporting period, what measures has the company taken to address suspected incidents of corruption independently or in response to a dispute or investigation by a government regulator?

    7. Does your company engage in Collective Action against corruption?

    . Prysmian signed the Europacable Industry Charter in 2015 that commits to ethics, sustainability and quality standards. The Code of Business Conduct, the Code of Ethics and the Human Rights Policy are necessary to assess sustainability along the value chain in the long-term - https://www.prysmiangroup.com/staticres/Nexst-2015-4/articles/endorsing-the-europacable-industry-charter.html - https://www.prysmiangroup.com/en/europacable-industry-charter-endorsed Company has ISO 37001 anti- bribery certification https://www.prysmiangroup.com/en/insight/peopleandlife/prysmian-group-achieves-iso-37001-anti-bribery-management-system-certification

    8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the anti-corruption principle, including any challenges faced and actions taken towards prevention and/or remediation.

    Prysmian Group is ISO 37001 certified for its Anti bribery and corruption management systems and we follow the tenets required for certification. Additionally, all Business Partners are vetted through our Third Party Policy and program which reviews potential compliance risk.