The map below shows for each country the level of perceived risk and the main topic areas to be monitored in the field of human rights, with an indication of the relative level of assessment of the policies and procedures in place. In all the cases highlighted, however, the level of priority to be given to improvement actions was medium or low.
Areas of improvement and action plans
During the due diligence process, opportunities for improvement were identified to strengthen the Company’s commitment to respect human rights in the conduct of its industrial and commercial activities. Specific action plans have been developed for each country where Enel operates, together with an improvement plan to be managed centrally aimed at harmonizing and integrating processes and policies at the global level and applied at the local level. In total, around 160 actions have been planned, covering 100% of the operations and sites. The implementation of these plans started in 2018 and is expected to be completed by the end of 2019: in December 2018, 67% of all planned actions had been completed. Below are some examples of actions that have been or are being developed. At a global level, both an operational procedure relating to the management of human rights due diligence and a new policy on “harassment in the workplace” are being issued, which will apply to Enel people, suppliers and partners. This policy enshrines a series of behaviors considered intolerable by Enel and for which sanctions, even severe ones, are provided for in the event of violation. In particular, two macro-categories of harmful behavior have been identified: (a) moral harassment (e.g. discrimination on the basis of gender identity, age, disability, nationality, ethnicity, color, political opinions, religious opinions, language, marital status, sexual and personal orientation, etc.); (b) sexual harassment: (unwanted sexual advances; jokes, teasing, insinuations or sexually explicit or sexually oriented jokes; condescending or paternalistic attitude with sexual implications that undermine dignity, etc.).
Finally, an analysis category dedicated to human rights aspects in the vendor rating of suppliers was also added to the purchasing processes (for more details see the chapter “Sustainable supply chain”). In December 2018, an innovative training course was launched specifically dedicated to the subject, described in the following section “Training and information”. In Spain, a Community Relationship Function has been set up at the individual plant level; in Italy, the policy’s advertising channels were strengthened, also through publication on the institutional website; in Romania, workshops were organized with the different areas of the Infrastructure and Networks Business Line in order to define the most appropriate ways of involving stakeholders; in Russia, information on human rights performance was included in the periodic presentations to top management. In South American countries, too, numerous actions have been taken following the approval of the due diligence improvement plan: in Argentina and Brazil, communication campaigns were carried out to promote and disseminate the use of the reporting channel (see also the section on “Reports by Stakeholders”); in Peru, a procedure dedicated to the management of reports has been issued (operating procedure no. 655); in Chile, specific training sessions dedicated to top management were organized; in Colombia, training sessions were organized with coal suppliers to raise their awareness of human rights issues. Analyses were also carried out on individual sites. Finally, with respect to labor rights topics, these are on average perceived to be less risky and the operations and processes that they control also comply with both the principles of the most common international guidelines and the Group’s internal policies.
However, minor areas of improvement have also been identified on these issues in some countries, as shown in the table below.
|Topic||Business lines||Countries||Areas of improvement|
Freedom of association and collective bargaining
Chile, Colombia, Italy,
Controls on the performance of suppliers with an active contract.
|Rejection of forced labour|
People and organization/Legaland
Apply the due diligence process for any recruitment agencies used.
|Rejection of child labour|
|Chile, Romania, Russia|
Supplement controls of suppliers, to check for any
“Taking the Voluntary Principles on Security and Human Rights as its reference, Enel is committed to ensuring that private security forces operating to protect Group personnel and property in their areas of activity act consistently with applicable national laws and international rules and standards, while encouraging law enforcement agencies to act in the same manner” (paragraph 2.2.1 of Enel’s Human Rights Policy). In general, according to national regulations, the security service can only be entrusted to public or private forces in the absence of legislative provisions.
Security management at Enel is entrusted to a dedicated Holding Unit and to specific units in the various countries in which the Group operates. The principles of action concern:
- Proactivity: continuous collection of data and information for the detection and interpretation of weak signals;
- Holistic Vision: integrated assessmentand management of securityrisks for all potentially exposed assets(people, infrastructure, intangibleassets);
- Open Power: cooperation with Business Lines, reference institutions and other operators of critical infrastructure;
- Resilience: adoption of measures to ensure the continuity of the system’s operation and not only its passive protection;
- Integrated Response: coordinated incident management between all the components involved (communication, security, institutional affairs, technical lines).
In all cases where it is not possible to rely on public forces and it is necessary to resort to private security guards, Enel ensures that all human rights assessments are made, that the workers of security service providers have received appropriate training, that contracts include human rights criteria and that adequate equipment is provided to security guards.
Training and information
During 2018, approximately 800,000 hours of training on sustainability issues were provided, of which human rights is a fundamental part. In particular, the courses mainly addressed environmental and occupational health and safety is- sues, with an average of 11.9 hours training per capita, up from the 2017 figure (8.2 hours). A new online training course on human rights was also launched. This course is Enel’s way of renewing its commitment to this topic, involving all Company people by sharing experiences and good practices that highlight the key role played by human rights. Lastly, to mark the 70th anniversary of the Universal Declaration of Human Rights, an internal communication campaign was run on the 30 articles of the Declaration, involving top management and internal and external experts, who illustrated examples of the principles being adopted in business processes.
For further details see the following chapters: “Sustainable supply chain” (forced and child labor), “Our people and their value” (diversity), “Community and sharing of value” (Relations with local communities) and “Occupational health and safety” (occupational health and safety).