PROCESSES COMMON TO ALL MACRO-THEMES

MOTIVATIONS AND BOUNDARIES

The material issues were identified by applying the principles for defining the contents of the Report and through the processes of stakeholder engagement and materiality analysis described in detail in the second chapter of the Sustainability Report, “Materiality and methodology”. For each material theme of PSC has been identified the perimeter within which the potential impact can fall:

• Within company boundaries: in this case the impact primarily influences internal stakeholders
• Outside the company boundaries: in this case it is mainly external stakeholders who are affected by the impact
• Inside and outside company boundaries: Impact affects all stakeholders.

In the management of material issues, PSC considers both the possible impact that it can cause directly and that which can indirectly result from its work.

TOOLS FOR THE MANAGEMENT

POLICIES AND COMMITMENTS

The Group is administered in the logic of recognition of the social role that the company has within the community, through the implementation of innovative solutions to improve the quality of life and the environment.

PSC has developed a common policy for the entire Group, published on 1 January 2021, regarding quality, environment and safety in line with the international standards ISO 9001, ISO 14001, ISO 45001.

In the policy on quality, the environment and health and safety at work, it is stated that:
"The future of Prima Sole Components depends on the ability to establish and maintain stable and satisfactory relationships with customers.
The satisfaction of customers› needs and the acquisition of new market areas are achieved through a continuous improvement in the quality of products, services and cost-effectiveness.
Prima Sole Components, in carrying out its activities, considers human health, environmental protection and safety at work an indispensable duty, a continuous commitment and a constant component of its mission.”

Prima Sole Components, the group’s holding company, also defines the vision, mission and strategies for the medium and long term in the new Group Business Plan 2021-2022. The operational plans of the business units and the sites linked to them are then developed along these lines. In the Industrial Plan the strategic directives are: competitiveness, technological innovation and globalization. At the level of the business unit and following for each production site, the activities are defined in line with the strategic guidelines of PSC according to the following logical process: analysis of the business plan, analysis S.W.O.T. for the determination of strengths and weaknesses, as well as opportunities and risks, risk assessment and definition of the business plan.

• The Business Plan covers the corporate network of all PSC Group sites.
• The last date of revision of the Business Plan is March 2021.

Following the re-organisation of the Group in recent years, the organisation and management model, in accordance with Legislative Decree 231, was the subject of an update process in 2020 and in 2021 it was implemented in the PCIT BU and all its sites. New content developed on the basis of the path taken by PSC towards greater sustainability of its activities has been introduced. By June 2022, the PCIT Supervisory Body will complete its audits and the model may be extended to the rest of the Group.
With the publication of the sustainability report, PSC intends to demonstrate its willingness and commitment to embark on a new path towards sustainability in the economic, social and environmental fields. This will and this commitment are born from the company management, and are transmitted in all plants and at all levels of the company.
The commitment to respect the legitimate interests of its stakeholders and the community in which all PSC establishments is enshrined in the Group’s Code of Ethics, updated in September 2020.

OBJECTIVES AND TARGETS

The objectives and goals that PSC sets itself in its path towards sustainability are found in this Report and concern all PSC sites. The objectives are of an improvement in relation to national legislation and will be monitored annually. Other more specific objectives are identified in the improvement plans of each company site, drawn up in accordance with the standards of quality, environment and safety.

RESOURCES

The responsibility for allocating human and financial resources lies with the director of the business unit who, together with the plant manager, draws up an approved investment plan at the holding company level.

COMPLAINT MECHANISMS

The ISO 9001, ISO 14001 and ISO 45001 certified PSC sites have complaint collection systems provided for by the management systems. PSC activated, through 231 model recently developed organization, a whistleblowing system: each model recipient is required to inform the Supervisory Body in a detailed and timely manner of any breach of the organisational model of which he is aware, or functional anomalies or irregularities potentially relevant for the purposes of Decree 231/01. The principles of protection of the employee or collaborator who reports wrongdoing are defined. Stakeholders may make requests and complaints at the contact point indicated in this report.

SPECIFIC ACTIONS

PSC publishes the Sustainability Report in accordance with the main international reference standard for sustainability reporting, the GRI-Standards. PSC is also committed to maintaining up-to-date and applied quality, environment and safety policies that are the reference for all the Group’s plants, in order to pursue continuous improvement in all areas.

MANAGEMENT ASSESSMENT

The results of the first and third party audits carried out on the management systems will be used to monitor the effective adequacy of the management of material issues. In addition, the GRI Standards policies reported in this Report, in the previous and subsequent ones will be used as management evaluations. In order to more effectively monitor some of the significant aspects, PSC has developed Key Performance Indicators (KPIs) that allow to evaluate the performance of these aspects over the years at Group level.

RESPONSIBILITY

The commitment to a more sustainable approach unites both the President and the Chief Executive Officer and involves all business units, individual plants and all functions and company employees. Responsibility for the implementation of policies, the implementation of commitments and the achievement of objectives is entrusted to the directors of each business unit and the directors of the individual production units. The achievement of the specific objectives, identified in the improvement plans, is delegated to those responsible for the implementation of the specific planned activities.

MANAGEMENT TOOLS

POLICIES AND COMMITMENT

In the policy of quality, environment and health and safety at work, the principles of which are the reference for all the Group’s sites, it is stated that the following commitments are central:

• Integrating economic objectives with stakeholders’ needs and meeting applicable requirements
• Improve processes and products and overall system performance by implementing specific projects to increase performance in every area, thinking about the impact that the product can have throughout its life cycle
• Maintain constant compliance with current legislation, respecting the health and safety of workers and environmental protection.
• Promoting sustainable behaviour throughout the production and supply chain

The guiding principles in the relationship with suppliers, with the community and with customers, to ensure the development of a responsible supply chain, high levels of customer satisfaction and an open dialogue with communities, are honesty, fairness, transparency and impartiality. These principles have always animated PSC, are presented in the recently updated Code of Ethics and will be formalized with the implementation for the whole Group of the organizational model consistent with Legislative Decree 231/2001.
PSC’s willingness to carry out its activities in an ethical manner, respecting its guiding principles in its relations with stakeholders, is stated in the Code of Ethics.

OBJECTIVES AND TARGETSI

The objectives and targets taken for the material themes of this macro-theme are developed following what is described in the section “Processes common to all macro-themes”.

RESOURCES

The staff and financial resources for the management of this macro-theme are assigned in a structured manner by all the Group’s management with coordination and control actions carried out by the Chairman and CEO of PSC.

COMPLAINT MECHANISMS

The mechanisms by which it is possible to make any complaints related to this macro-theme are developed following what is described in the section “Processes common to all macro-themes”.

SPECIFIC ACTIONS

Periodically, the PSC Chief Executive Officer and the directors of the business units and subsequently the Board of Directors assess the economic performance of the individual business units and the PSC and analyse any risks and opportunities.

MANAGEMENT ASSESSMENT

The evaluation mechanisms on the management of material issues related to the macro-theme “Value generated” are developed following what is described in the section “Processes common to all macro-themes”.

RESPONSIBILITY

The responsibilities for the management of material issues related to the macro-theme “Value generated” are assigned following what is described in the section “Processes common to all macro-themes”.

MANAGEMENT TOOLS

POLICIES AND COMMITMENT

The principles set out in the PSC’s quality, environment and safety policies are of reference for all the Group’s sites and are in line with the strategic guidelines of the Business Plan.
In the field of quality, environment and health and safety at work, the central commitments include:

• romote any initiative to reduce to zero, in every activity, the occurrence of accidents that can compromise the safety of employees and neighboring communities also through consultation and active participation of all workers
• Promote the active involvement of all staff in the process of continuous improvement, through consultation and active participation of all those who can make a constructive and innovative contribution

PSC’s commitment to the enhancement of human resources, to guarantee their rights and to encourage their development and personal growth is declared in the Group Code of Ethics.

OBJECTIVES AND TARGETS

The objectives and targets taken for the material themes of this macro-theme are developed following what is described in the section “Processes common to all macro-themes”.

RESOURCES

The personnel and economic resources for the workers management shall be assigned to the individual business units through the definition and approval of the annual budget.

COMPLAINT MECHANISMS

The mechanisms by which it is possible to make any complaints related to this macro-theme are developed following what is described in the section “Processes common to all macro-themes”.

SPECIFIC ACTIONS

Prima Sole Components ensures the control, monitoring and possibly the mitigation of negative impacts on the health and safety of workers according to the reference legislation. Internal and external audits and periodic reviews shall also be carried out in establishments that have a management system in place.
The human resources of the individual business units, in collaboration with the directors of the production units, manage vocational training programs and personnel for employees, new employees and in administration at the production sites. Such programs shall be developed according to business needs. The priorities for the individual worker are identified by HR managers and executives, according to work demands
In those sites, where a management system is active at least once a year, a review is carried out involving the directors of the business units, the directors of the production units and the heads of the various business functions. Following the review, the results of the audits, the non-conformities, the corrective actions implemented, the objectives and the indicators, as well as improvements shall be enhanced.

MANAGEMENT ASSESSMENT

The evaluation mechanisms on the management of material issues related to the macro-theme “Workers” are developed following what is described in the section “Processes common to all macro-themes”.

RESPONSIBILITY

The responsibilities for the management of material issues related to the macro-theme “Workers” are assigned following what is described in the section “Processes common to all macro-themes”.
Individual managers of business units, as employers of staff, have responsibility for health and safety.
In each production unit, the directors have legal power of attorney on issues related to the environment and safety and have a wide delegation regarding the management of these aspects. Each Group company has an RSPP that handles safety issues and workers elect one or more RLS (or RLSSA in companies with rubber and plastic contracts).

MANAGEMENT TOOLS

POLICIES AND COMMITMENT

Among the central themes for SGP, declared in the policy of quality, environment and health and safety at work, is the commitment to “protect and enhance the environment and take all the necessary measures to prevent pollution”.

OBJECTIVES AND TARGETS

The objectives and targets taken for the material themes of this macro-theme are developed following what is described in the section “Processes common to all macro-themes”.

RESOURCES

The administrator of the business unit is responsible for allocating human and financial resources, according to the instructions of the plant manager who draws up an investment plan.

COMPLAINT MECHANISMS

The mechanisms by which it is possible to make any complaints related to this macro-theme are developed following what is described in the section “Processes common to all macro-themes”.

SPECIFIC ACTIONS

Most of the plants have adopted an environmental management system certified in accordance with ISO 14001 that, thanks to an audit process and periodic reviews shall include monitoring, monitoring and, where appropriate, mitigation of negative impacts on the environment.
The Group adopts tools to evaluate and quantify energy and environmental loads and the potential impacts of products and processes through:

• External analysis laboratories for the assessment of the main environmental impacts (emissions, discharges, noise, waste), dedicated internal resources and external consultancy for the energy assessment of individual sites
• Involvement of all professional skills necessary for the development, management and control of activities
• Adoption and maintenance of an environmental management system.

MANAGEMENT ASSESSMENT

The evaluation mechanisms on the management of material issues related to the macro-theme “Natural resources and environment” are developed following what is described in the section “Processes common to all macro-themes”.

RESPONSIBILITY

Responsibility for the management of natural resources and environment issues is also entrusted to the directors of the business units. As part of the management system, the issue is addressed by entrusting management responsibility to the site manager who is accompanied by a manager of the management system and an operational structure.