The protection of human rights

Although the Group, because of its activities and the geographical location, is not exposed to particularly significant risks inherent to the issue of human rights violations, there are areas within the Group in which, for reasons related to their critical infrastructure nature and for being sensitive objectives, the staff receives a specific protective attention aimed at maintaining very high standards of safety. Without these precautions, their rights would not be protected in compliance with the obligations of the employer codified in Article 2087of the Italian Civil Code, expressive of constitutional concepts regarding the protection of the dignity and integrity of the worker and in the exercise of the activity of the company - even more so if public - aimed at the social utility. This applies both to the protection of the life and the safety of the staff and of the third parties who even occasionally find themselves in the ENAV infrastructures - in consideration of the so-called "criminal risk" to be considered in the analytical assessments of Legislative Decree No. 81/2008 in which the employer must prevent, eliminate or mitigate any risk that may interfere with the constitutional values of human life and safety -, but also as a logical extension of the concept of "workplace", to protect the staff of the Group working for particular tasks, in potentially dangerous countries, in particular due to the effects of political instability, the actions of terrorist groups or also for critical health and sanitation conditions.

The other particularly sensitive area concerns the treatment of individual information and the safeguard of the rights of confidentiality, according to the framework of privacy protection established at national and European levels, whose founding principles are fully accepted and explained in the highest Group policies. In this context, the Group places attention on the legislative compliance of the prohibition of indirect control of workers, as enshrined in Law No. 300/1970 ("Worker's Charter"), in particular with regard to the remote control of workers using surveillance and the use of security guards. For the first, introducing a wider and more transparent dialogue with the labour unions and the use of the instruments in a fair transparent form; and for the second introducing expressly the relative prohibition as an integral part of the special specifications that regulate the procurement of the supervisory services. Moreover, the systems of computer protection, which can provide for forms of verification and control, are consistent with the principles of Article 4 of Law No. 300/1970, as amended by Article 23 of Legislative Decree No. 151/2015, with regard to which ample and transparent information is given to the personnel and to the trade union representatives.

An important note is the coordination action carried out with the institutions. In fact, because of the delicacy of the role played by the staff of the ENAV Group, there is a need to reinforce the protection of the worker from any external factor that could be considered as a risk inherent in the work performance or the workplace. With this regard, the systems of prevention and protection from criminal risk are supplemented by special agreements with the Ministry of the Interior - Department of Public Safety and broken down into special procedures aimed at the protection of life, safety and safeguard of the dignity of the worker, also in relation to acts of conflict that may be generated within the workplace.

With regard to specific safety risks for the personnel on mission abroad, there is a special procedure that ensures the preventive assessment of the risk for this type of activity, supplemented by the connection with the Crisis Unit established at the Ministry of Foreign Affairs and International Cooperation.

Moreover, ENAV's attention to the issue of human rights is evident, not only considering the constant monitoring of the Human Resources department, but also looking at the application of what is established in the Code of Ethics that expressly stipulates that “relations between employees are based on the values of civil society and on respecting the rights and freedoms of the individual and the fundamental principles that affirm equal dignity without discrimination on the grounds of nationality, language, gender, race, religious belief, political or union affiliation, physical or mental conditions".

In relation to Techno Sky, the protection of human rights is applied through some general principles (guaranteeing freedom of association, the equal opportunities, prohibiting, both in internal and external relations, behaviours that have discriminatory content, protecting the right to life, both of its employees as well as of third parties, putting at the centre of their attention the protection of health and safety in the workplace, etc.) which are monitored carefully through constant and constructive interactions with the staff.