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.
Ethics and sustainability management
Our sustainability management model is transparent and integrated along the entire value chain
Sustainability, made tangible
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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.
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.
In 2023, we integrated the Sustainability function into the ERM function (now known as ERM&S). This created synergies to foster the physiological integration of business risk analysis and the execution of Sustainability Plan initiatives, and ensure a qualitative improvement in the oversight of both activities.
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.
Learn more about our internal Risk Auditing and Management System
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 2023, the entire Environmental and Safety Management System was subject to a re-certification from external body CertiW, who confirmed all certifications already earned by the Company:
- ISO certification 14001 relating to the environmental management system;
- ISO certification 45001 which certifies the Management of Worker Safety.
Information Security and Privacy
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.
Furthermore, the following have been adopted as of 2023:
- Guidelines for the classification of tangible and intangible processing of information’;
- the ‘Guidelines for the storage of personal data’
Cybersecurity
Rai Way recognises the strategic value of information in all its forms and fully understands the implications of inadequate protection. Since the protection of information is crucial to ensuring correct business decisions, preserve reputation and avoid legal risks, the company has been on a path to strengthen information security and ensure compliance with applicable regulations for some years now.
During 2023, significant progress was made in the cybersecurity organisation, with a focus on formalising an Information Security Policy that aims to strengthen our ability to effectively manage the life cycle of cybersecurity and information security processes, identifying key objectives such as aligning the cybersecurity strategy with the corporate strategy, complying with regulatory requirements, defining roles and responsibilities, adopting appropriate security measures, training staff and managing risk.
Furthermore, Rai Way rigorously tests its systems and measures on a regular basis, with third-party and internal and external assessments. The Company also provides cybersecurity training courses for all permanent and temporary personnel.
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:
- the publication of the Sustainable Supply Chain Policy
- 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). In 2023, Rai Way Top Suppliers (top 50 Suppliers by contract in 2023) and the Suppliers registered in the Rai Way Supplier List (excluding professionals) were monitored by conducting training/informative webinars and filling out questionnaires on ESG issues. No. 70 Suppliers among those listed above, accounting for 64.8% of those on the list, were engaged through training/information webinars on ESG issues.
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.
Sede legale: Roma via Teulada 66 cap 00195 | Capitale sociale euro 70.176.000,00 interamente versato | Ufficio del Registro delle Imprese di Roma Codice Fiscale 05820021003 | Società soggetta ad attività di direzione e coordinamento di RAI - Radiotelevisione italiana Spa Rai Way S.p.A. © 2023