Respect for human rights is part of the very foundation of sustainable progress. Enel’s business model is based on the generation of sustainable value, together with its internal and external stakeholders, on continuous innovation, the pursuit of excellence and respect for human rights throughout the value chain. This translates into the rejection of practices such as modern slavery, forced labor and human trafficking, and the promotion of diversity, inclusion, equal opportunity and ensuring that people are treated with dignity and valued for their uniqueness, whether they work within the Company or elsewhere along the value chain in which the Group operates. The main international standards inspiring Enel’s commitment are the United Nations framework “Protect, Respect, Remedy”, outlined in the guiding principles on business and human rights, and the guidelines for multinational companies of the OECD. This commitment is clearly reflected in the human rights policy drawn up and adopted back in 2013. In 2021, this document was updated to take account of the evolution of international reference frameworks and the operational, organizational and management processes of the Group. The document strengthens and expands the commitments already present in other codes of conduct adopted by Enel such as the Code of Ethics, the Zero-Tolerance-of-Corruption Plan and global compliance models. The update was approved by the Board of Directors of Enel SpA and then adopted by the subsidiaries. Enel undertakes to comply with these principles in every country in which it operates, respecting local cultural, social and economic diversity, requiring each stakeholder to adopt conduct in line with these principles, paying particular attention to high-risk environments or those exposed to conflicts.
Stakeholders are all those who have a direct or indirect interest in the activities of the Enel Group, such as customers, employees of any type or level, suppliers, contractors, partners, other companies and trade associations, the financial community, civil society, local communities and indigenous and tribal peoples, national and international institutions, the media, as well as the organizations and institutions that represent them.
The update, similar to the 2013 version, involved a process of consultation with stakeholders relevant to the Company (internal, other companies, suppliers, human rights experts, think tanks, NGOs) conducted in accordance with the criteria contained in the ‘‘UN Global Compact Guide for Business: How to Develop a Human Rights Policy’’. The updated code identifies twelve principles (compared with the previous eight), again divided into two macro-themes: work practices and community relations.
The Human Rights Policy is a commitment to:
- proactively consider the needs and priorities of people and society in general because this makes it possible to innovate processes and products, a key factor in an increasingly competitive, inclusive and sustainable business model, including through the adoption of the principles of circularity, the protection of natural capital and biodiversity;
- promote the engagement of our main external and internal stakeholders in order to enhance their awareness and develop a constructive dialogue that can provide a valuable contribution to the design of solutions to mitigate climate change.
In addition to the commitment to the contribution to achieving the United Nations Sustainable Development Goals, the updates include: (i) a reminder of how environmental degradation and climate change are interconnected with human rights, in that the implementation of measures to mitigate the effects of human activities on the environment cannot take place without taking account of their social impact; (ii) the strengthening of the principles of “respect for diversity and non-discrimination” and “health and safety” in the part relating to psychological and physical well-being and work-life integration; (iii) an increase in the granularity of our commitment in our relations with communities, with particular regard to local communities, indigenous and tribal populations, privacy and communication.
Enel has undertaken to monitor application of the Human Rights Policy (i) by employing a specific due diligence process in the various countries in which we operate; (ii) by promoting conduct consistent with a just and inclusive transition; and (iii) by enhancing communication with regard to the action plans developed to prevent and remedy situations in which critical issues could arise.
More specifically, the due diligence process for the management system, which is structured into three-year cycles and has been developed in accordance with the main international standards such as the United Nations Guiding Principles on Business and Human Rights, the OECD guidelines and international best practices, enables us to identify opportunities for improvement and develop specific action plans for each country in which we have a presence, accompanied by a plan for improvement at the central level in order to harmonize and integrate processes and policies defined at the global level and applied at the local level. All of these improvement plans are also integrated into the Sustainability Plan.
In the 2020-2022 cycle, some 170 actions have been identified, covering 100% of operations and sites.
With regard to the sustainability of the supply chain, Enel’s purchasing processes are based on fairness, transparency and collaboration, and for this reason the Group’s suppliers are required not only to guarantee the necessary quality standards but also to commit to adopting best practices for human rights and the impact of their activity on the environment. These include those concerning working conditions, health and safety, appropriate working hours, rejection of forced or child labor, respect for personal dignity, non-discrimination and the inclusion of diversity, freedom of association and collective bargaining and respect for privacy by design and by default. All of this is delineated by a clear framework of codes of conduct, including, in addition to the Human Rights Policy, the Code of Ethics, the Zero-Tolerance-of-Corruption Plan and global compliance programs. Furthermore, specific clauses are included in all contracts for works, services and supplies, updated periodically to take account of the regulatory developments and ensure alignment with international best practices. The General Terms of Contract comprise a general part, containing the clauses applicable to all countries, supplemented by Country Annexes containing the specific clauses applicable in each country. The General Terms of Contract cover current regulations governing remuneration, contributions, insurance and taxation for all workers employed in any capacity in the execution of a contract by the supplier. Furthermore, specific reference is made to the principles set out in ILO Conventions and legal obligations regarding: the protection of child labor and women; equal treatment; prohibition of discrimination, abuse or harassment; freedom of trade union membership, association and representation; rejection of forced labor; safety and environmental protection and hygienic-sanitary conditions. In the event of a conflict between the latter and the ILO Conventions, the more restrictive rules shall prevail. The clauses also provide that suppliers shall undertake to prevent any form of corruption.