2022 Communication on Progress

Xenia S.p.A. SB

Published date

September 12, 2022

No. of questions

49

CEO Statement

Signed

  • Governance

    Policies and Responsibilities

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

    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

    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

    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

    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?

    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

    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 (#)

    7

    Male (%)

    86

    Female (%)

    14

    Non-binary (%)

    0

    Under 30 years old (%)

    0

    30-50 years old (%)

    14

    Above 50 years old (%)

    86

    From minority or vulnerable groups (%)

    0

    Executive (%)

    28

    Independent (%)

    72

    13. Do you produce sustainability reporting according to:

    We produced for Y2021: Sustainability Report (Y2021 is the first year). B Impact Assessment (with B Impact Score 99.8. The auditing process to become a B-Corp is on going).

    Data Assurance

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

    Limited assurance engagement

  • 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?

    Response

    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.

    The major evidence of Xenia’s commitment towards human rights principles has been the company change (24th March 2021) into a benefit corporation by chosing to provide: - accommodation for the disadvantaged, elderly people living alone, differently able people, and all those in need; (SDGs 1 No poverty | 10 Reduced inequalities | 11 Sustainable cities and communities) - healthcare for those in need; (SDGs 3 Good health and well being | 10 Reduced inequalities) - schooling and training for anyone experiencing educational poverty (SDGs 1 No poverty | 4 Quality education 5 Gender equality | 8 Decent work and economic growth | 17 Partnerships for the goals) This firm, concrete, and tangible commitment takes shape through our cooperation with Ente Morale Cottolengo Piccola Casa della Divina Provvidenza in Turin, a multi- service charity to which we devote 20% of our net profits each year. In addition, for each overnight stay in one of our PHI Hotels we donate € 0.30 to Cottolengo and offer our guest the chance to make a further independent, certified donation, promoting a new model of hospitality that cares about the common good (www.welcomeaid.com) Other actions refer to: - The Foundation of the Technical High School 'Tourism and Culture' of the Abruzzo Region, in partnership with the University of Teramo, Confindustria and other companies, as a founding partner. The objective is to create a high training structure for the enhancement of the Region, with the possibility for young people to enter the labour market, within a broader project for the tourism sector in Abruzzo. - The participation in a Guaranteed Mobility Project (referring to the area where Xenia has its headquarter) with the contribution, together with other local entities, to the purchase of an equipped vehicle for social services, the transport of the disadvantaged, elderly, disabled people and of those who have limited mobility for physical, psychic, social or family reason. - Panfilia Impresa Sociale S.r.l., a company made possible through cooperation between the non-profit Piccola Casa della Divina Provvidenza-Cottolengo and Xenia S.p.A. SB which has a particular focus on providing accommodation, assistance, and services to individuals and both public and private organizations. The idea behind Panfilia springs from our clear awareness of the importance of social responsibility within businesses and the economy. - Panfilia brings together charisma, meaning divine grace, and expertise: through its work, it uses innovative methods to pursue Cottolengo's mission while drawing on the strength of Xenia's experience in tourism and hospitality and its vision, as applied to social issues and sustainability. - The SA8000 certification, planned to be achieved within 2022.

  • 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

    2019 - Code of Ethics

    Forced labour

    2020 - 231/2001 Organisational model

    Child labour

    2020 - 231/2001 Organisational model

    Non-discrimination in respect of employment and occupation

    2019 - Code of Ethics

    Occupational safety and health

    Health and safety policy (first issue 2018). Regularly updated according to Italian legal provisions (including DVR - risk assessment document).

    Working conditions (wages, working hours)

    2019 - Code of Ethics

    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

    This issue is covered by the general provisions of our Code of Ethics and Organizational Model 231 and by the relevant operating procedures.

    Child labour

    This issue is covered by the general provisions of our Code of Ethics and Organizational Model 231 and by the relevant operating procedures.

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    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

    All employees received training about the provisions of the Organizational Model 231, which covers this issue as a general subject

    Child labour

    All employees received training about the provisions of the Organizational Model 231, which covers this issue as a general yet key subject.

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    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)

    Performance

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

    Percent of employees (%)

    Unknown

    Employees covered under collective bargaining (%)

    100

    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 (%)

    12.5

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

    Percent of women (%)

    Unknown

    Senior leadership level position

    75

    Non-executive board

    14

    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 (%)

    88

    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

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

    Incident rate

    Unknown

    Choose to not disclose

    Incident rate

    1.2

    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)

    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.

    Please find following the description of some practical actions regarding labour rights principles taking during year 2021. Safety and Health Depending on the workers' assignments, the following training courses were provided at the prescribed deadlines: Basic Occupational Safety Course, Specific Low Risk Safety Training, Covid-19 Safety, Fire Fighting, First Aid, Food Safety. The Physician for Health and Safety carried out an on-site inspection at company premises to detect any changes in health risk factors, as well as the health checks required by Legislative Decree 81/08, issuing the relevant certificates of suitability for specific task for all employees. As part of the adopted health and safety measures, an indoor air quality monitoring campaign was conducted (on an initial sample of 80% of the company premises). The assessment of a number of parameters provided useful information on environmental conditions in relation to the spread of microorganisms. A final report was drafted for each monitored area, followed by a rating in terms of very low - low contamination. Comfort A supervised ventilation system has been installed in all working areas. It provides - in addition to filtering the incoming air - a continuous recirculation of the air, with the entry of clean air and the expulsion of stale air via a heat exchange unit. The intervention considerably improves the healthiness of working environments. In order to increase the brightness, comfort and functionality of the working areas, as well as greater adherence to aesthetic and energy-saving criteria, we have optimised the spaces and inserted glass partitions. In addition, to reduce the consequent and normal acoustic reverberation, sound-absorbing panels were inserted achieving the desired degree of decibel acoustic comfort. Remuneration analysis As part of the drafting of our Impact Report as a benefit company, we conducted a pay equity analysis by gender which led us to commit to improve this performance metric. Smartworking For the company premises where this is applicable, Xenia asked employees to express their opinion on the adoption of smartworking by means of an anonymous questionnaire, followed by individual interviews. While guaranteeing the availability of secure workplaces (as envisaged by the anti-Covid 19 regulations and also assuming the presence of all employees), following the carried out investigations the company formalised the possible use of such solutions even beyond the state of emergency; therefore, all employees are able to request SW for extemporaneous periods.

  • 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

    Environmental Policy (since 2017) + Sustainability report 2021 + ISO 14001:2015 Certification (since 2018)

    Water

    Environmental Policy (since 2017) + Sustainability report 2021 + ISO 14001:2015 Certification (since 2018)

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    Environmental Policy (since 2017) + Sustainability report 2021 + ISO 14001:2015 Certification (since 2018)

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

    Environmental Policy (since 2017) + Sustainability report 2021 + ISO 14001:2015 Certification (since 2018)

    Energy & Resource Use

    Environmental Policy (since 2017) + Sustainability report 2021 + ISO 14001:2015 Certification (since 2018)

    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

    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

    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

    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

    Climate Action

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

    Scope 1 Emissions

    Emissions (tCO2e)

    420.92

    Scope 2 Emissions

    Emissions (tCO2e)

    653.62

    Scope 3 Emissions

    This kind of emissions is currently not tracked.

    Emissions (tCO2e)

    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 (%)

    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

    1

    Technology

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

    Percent of total revenue (%)

    Sector-specific Questions

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

    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.

    Kindly take note that our practical actions are described in the answers provided for question E.4.1. Moreover, please refer to our Sustainability Report 2021.

  • Anti-corruption

    Commitment

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

    Code of Ethics (2019) - 231/2001 Organizational Model (2020) - Legality Rating Two Stars + (2020)

    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?

    Prevention

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

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

    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
    None.

    Confirmed during the current year, and related to this year

    0
    None.

    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?

    Legality Rating (achieved on a voluntary basis). Score: Two Stars +

    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.

    Xenia is committed against active and passive corruption and works to detect and prevent potential acts of corruption, thus protecting our integrity and reputation, by means of tools such as the Code of Ethics, the Organisational Model 231/01 and the Whistleblowing procedure. In particular, an internal training and information activity was carried out in 2021 for all employees; a follow-up is scheduled for 2022. Moreover, we are updating the Model in order to align the document with our current organisational structure in the light of any risk elements generated by Xenia’s new status as a benefit corporation and the social enterprise “Panfilia” of which it is a shareholder along with the Cottolengo Piccola Casa della Divina Provvidenza non-profit organization. On Xenia’s voluntary basis, Sustainability Report 2021 has been subject of a limited engagement assurance undertaken by PricewaterhouseCoopers S.p.A. whose conclusions are that “based on the work performed, nothing has come to our attention that causes us to believe that Xenia’s Sustainability Report for the year ended 31 December 2021 is not prepared, in all material respects, in accordance with the requirements of the GRI Standards as illustrated in the “Note on Methodology” section of the Sustainability Report. Again on a voluntary basis, in 2021 Xenia has been subject to an audit undertaken by Crif Ratings credit rating agency which assigned a “B” long-term issuer rating with “Stable” outlook.