VALENTE Sustainability Report

Materiality matrix:

The identification of the current and potential impacts of Valente’s activities was carried out by analysing the context in which the company operates and evaluating the activities carried out and policies promoted in the ESG field.

Each impact was quantified by the ESG team on the basis of criteria of severity, magnitude and likelihood, as more fully explained in the Methodological Note and its annexes.

Based on the quantification of impact and likelihood of occurrence, a risk analysis was then carried out, which is presented in the graphs below, broken down by reporting area.

The size of the dot indicates the financial component.

With reference to the ENVIRONMENTAL AREA:

In relation to the SOCIAL SECTOR:

With reference to the GOVERNANCE AREA:

ENVIRONMENT

Due to the nature of the activity carried out, the impact of Valente’s activity on the environment is particularly limited and can be attributed to the issues of energy and greenhouse gas emissions, the use of resources, mainly steel, emissions into the atmosphere (for which it has a special permit) and the proper management of the quantities of waste produced, 99% of which is recycled in any case.

Biodiversity and soil contamination are not considered relevant as the site is not located in a protected or vulnerable area and there is no potential risk of pollution, desertification or land consumption. Water consumption is also not considered relevant as it is only used for civil purposes.

In addition, Valente operates in a sector that is particularly sensitive to sustainability issues, the railway industry, and relies on international steel suppliers that are already well on their way to becoming a more sustainable industry.

A RESOURCE-CONSCIOUS SECTOR
(B7- Use of resources)

VALENTE S.p.A. uses 1430 tons/year of steel for the production of rails, 165.4 tons/year (or 286950 pcs) of fastening systems, 24 tons/year (or 192000 pcs) of Screws, and 1290 of elastomers for interlayers.

We have contacted the various suppliers of steel for railways (which accounts for 90% of the material processed at VALENTE S.p.A.) or checked what they state in their environmental reports, where available, regarding the percentage of recycled steel in the material sold to VALENTE S.p.A., and it can be stated that it is in line with industry guidelines, which certify the use of 30% recycled material.

With regard to other incoming materials (packaging and paint products), it should be noted that their contribution is marginal compared to the amount of material handled, but in any case Valente reuses 80% of packaging materials such as wood and cardboard and 20% of plastic packaging for its shipments.

Given that the rail sector is particularly sensitive to the issue of sustainability, in which it is a protagonist due to its lower impact compared to other modes of transport, it is likely that increasingly stringent requirements will be imposed in terms of the materials used and compliance with delivery times. Considering that, from a financial point of view, any difficulty or anomaly in the procurement of materials could have serious consequences for the company (with damage ranging from a 10% loss in the value of the order itself to the non-acceptance of the order) and is a possible eventuality, it is considered fundamental to have a range of suppliers who are always able to meet Valente’s production needs on time and with the quality required by the market.

For this reason, VALENTE S.p.A. proposes to carry out an in-depth market analysis in order to identify a number of suppliers in different countries who can provide appropriate guarantees in terms of sustainability, so that the company can meet the parameters set by the customer, both in terms of quality and delivery times. To this end, the possibility of using qualification questionnaires or verifying the availability of information on, in particular, the quality of the material supplied, the energy supply methods and any initiatives planned to better manage climate risks will be evaluated.

CLIMATE CHANGE AND ENERGY USE
(B 3 – Energy and greenhouse gas emissions)

The energy consumption and indirect greenhouse gas emissions (scope 2) calculated for the year 2022 show the following values, taken from utility bills:

It should be noted that heating is only used in the offices, not in the production halls, and is not used in any process step.

The total energy intensity for each tonne of rails and components produced is therefore 395 kWh/year, taking into account all the company’s energy consumption.

From 2024 the company will sign a certified energy supply contract to use energy from renewable sources and thus reduce indirect greenhouse gas emissions.

In addition, the company has three company cars that travelled a total of 46,000 km in 2022 with an energy consumption of 21512 kwh and direct Scope 1 GHG emissions of 3.4 tonnes of CO2 _eq.

Also within direct scope 1 GHG emissions, the company added 1 kg of R32, a new generation refrigerant gas, in 2022 with a CO2 _eq emission of 0.68 tonnes.

Although not required to do so, a process to assess energy consumption and emissions outside the organisation was initiated to start evaluating the issue, focusing on employee mobility and transport. Based on the number of kilometres travelled and the type of vehicle used, the following results were obtained:

• The 22 employees travel a total of 387,200 km/year (based on 220 working days), consuming 93500 kWh/year and emitting 25 tonnes of CO2_eq/year, taking into account the different means of transport.
• Goods are mainly transported by ship (184,500 km/year) and by land (37,600 km). Based on the conversion factors proposed by the GHG Protocol, this results in the emission of 402 tonnes/year of Co2_eq

In terms of climate change adaptation, a risk assessment was carried out using the Derris tool, provided by Unipol in collaboration with ANCI and other relevant associations, to evaluate Valente’s exposure to climate change:

Interestingly, the same tool also proposes improvement activities aimed at reducing the level of risk to which the company is exposed with regard to extreme climatic events, and it is estimated that within the next two years, it will be necessary to: review the civil protection plan developed by the municipality to understand what measures are planned in the area where the company is located; Create green areas inside the factory with planting and/or hedges to reduce the heat island effect; install water conservation systems such as flow regulators to reduce water consumption for sanitary purposes; have a technician check the level of lightning self-protection of the entire shed.

From a financial point of view, the energy issue has been given particular attention, as both the procurement of materials and the transport of the finished product can have a significant impact on the company’s revenue, with an incidence of up to 20% of the order value. Moreover, with the entry into force on 1 October 2023 of the CBAM (the European regulation on the Carbon Border Adjustment Mechanism, which provides for the gradual adjustment of the price of goods imported from outside the EU in order to compensate for the production of CO2 in the places where the goods are produced), it will be increasingly necessary to carry out an accurate study of the CO2 emissions generated by the processes of foreign suppliers in order to provide the register that will be set up with timely information and to pay the correct contribution.

In order to properly identify the preventive measures that need to be taken, we intend to carry out a life cycle assessment of the railways over the next three years, which will enable us to identify critical points in the process and implement alternative measures where necessary and, above all, possible.

We are also investigating the possibility of carrying out an energy audit of the building to identify possible energy efficiency measures, although the majority of energy consumption, given the process and operating methods, takes place outside the company perimeter.

We would also like to include in the qualification process for raw material suppliers an assessment of the energy supply methods and the carbon footprint of the process, in order to understand the degree of energy independence of individual suppliers, which will become an increasingly important element in a sector such as steelworks, and to collect the correct information to be reported to the CBAM register.

However, given the confidentiality of the information, we believe it is unlikely that our suppliers will cooperate.

A LOW-POLLUTION PROCESS
(B 4 – Air pollution)

The material treatment process used by Valente Spa does not involve any potential pollution of soil or water resources, nor does it involve the use of substances of concern or of high concern. For the treatment of the material produced, which amounts to approximately 1600 tonnes/year, paints are used that contain 480 kg/year of solvent, equivalent to 0.013 kg_solvent/kg_product.

For the grinding and welding activities, sampling is carried out twice a year, which confirms full compliance with the prescribed limits for dust emissions (6.5 mg/nm3 < 10 mg/nm3).These particularly small quantities allow us to consider the potential air pollution, which is in any case managed in accordance with the derogation authorisation obtained in 2012, as insignificant, and therefore the risk as insignificant.

The financial impact related to this issue is due to the administrative penalty of a maximum of 10,000 euros that the company could incur in the event of non-compliance with the requirements of the authorisation, rather than the suspension of the specific activities covered by the authorisation for 3 months in the event of its expiry. For this reason, control tools (timetables and assistance from the qualified consultant) have been defined to eliminate this possible risk.

Since this is an aspect whose management has been largely consolidated over time and whose operating methods have remained constant over time, it is not considered necessary to implement any additional measures other than to maintain the current emission control procedure, which provides for the monitoring of the deadlines foreseen in the permit, the assistance of the qualified consultant, who draws up the relevant report every two years, and the performance of biannual sampling.

Next year, the company expects to obtain ISO 14001 certification, as a further guarantee not only of full compliance with legal requirements, but also of the adoption of an approach aimed at continuous improvement in the management of environmental aspects.

ONLY 5% OF INCOMING MATERIAL BECOMES WASTE
(B 7 – Waste Management)

The activities carried out at VALENTE S.p.A., mainly cutting, finishing and assembly, result in a particularly low waste production of 5% of the incoming material, and of this already low percentage, more than 99% is made up of materials destined for recycling, such as iron and steel. In addition, 80% of the packaging material in which the raw materials arrive is recycled in subsequent transports. The loading and unloading register data for 2022 show the following

• CER 170405: iron and steel waste 80 tonnes
• CER 120109* emulsions 530 kg
• CER 150202: packaging 300 kg

In general, less than 1 tonne/year of emulsions are purchased and used for the rust protection or retouching required on wagons or other work-in-progress material, and are used until exhausted. In sporadic cases where more extensive use is required (as in this case where extensive painting work was required on some wagons), any waste is sent for disposal rather than recycling.

Considering that the production of scrap represents a waste of raw materials for Valente and therefore a financial cost, the production of waste is already carefully monitored with the aim of constantly reducing it. Staff have also been trained in the correct management of temporary waste storage, the correct registration of movements and the qualification of suppliers for transport and disposal, in order to avoid incurring penalties related to waste management regulations.

SOCIAL

RECRUITMENT, REMUNERATION POLICY AND TURNOVER
(VSME ESRS B 8 Personnel – General characteristics)

People are central to Valente’s business. Due to the nature of the company, the impact on the workforce is limited and mainly relates to the issue of employee health and safety.

In terms of the number of people employed during the reporting period, the company has 20 employees and one co-worker.

One of Valente’s main objectives is to offer a stable and continuous working relationship, as the positive effects of the contractual aspect on the workforce have a particular impact on employee satisfaction and therefore productivity, which in turn has a positive financial impact.

VALENTE S.p.A. has an open-ended employment contract with 85% of its employees.

The stability of the employment relationship is also reflected in the fluctuation figures for the reporting period, in which there were 2 new hires and no retirements, dismissals or resignations.

This positive figure should be read in conjunction with the age distribution of the workforce. This data reflects Valente’s desire to encourage the employment of young people, while at the same time ensuring the heterogeneity of its resources in order to maintain a balance between experience in the company and generational turnover.

An inclusive working environment

In terms of gender diversity within the workforce, Valente employs 16 male and 5 female workers. In terms of the type of activity carried out, it should be noted that the majority of men in the workforce are to be found in the role of labourers, a circumstance that is inherent to the type of activity carried out and in line with the reference sector. On the other hand, the presence of women is greater in the administrative area, which is a positive factor.

VALENTE S.p.A. guarantees its employees fair treatment based on merit, without any discrimination based on nationality, gender, sexual orientation, gender identity, disability, race, religious beliefs, political or trade union affiliation, personal and social conditions, in accordance with the applicable legislation and in particular the Equal Opportunities Code pursuant to Legislative Decree no. 198 of 11 April 2006.

The risk analysis carried out in this area shows that the care of the working environment and the protection of the integration and, more generally, the well-being of employees have a direct impact on the company’s productivity levels and its ability to attract (current and potential) employees.

For this reason, the Company considers it essential to continue to invest activities and resources to ensure the protection of its workforce.

In line with this objective, Valente plans to adopt a Code of Ethics in 2023, as detailed below, in which it undertakes to:

• Apply criteria of merit, competence and, in any case, strictly professional criteria to any decision concerning an employee;
• Select, recruit, train, reward and manage employees without discrimination of any kind.
• To create a working environment in which personal characteristics cannot give rise to discrimination.

Currently, the company has not implemented tools such as Smart Working or Agile Working in the company, partly because of the scope of its operations, which require the daily physical presence of employees in the company.

However, in the next three years, Valente intends to increase both the possibility of flexible working hours for its employees and the possibility of a reduction in working hours, in consultation with the department concerned, and will consider introducing a written procedure in the future, if this does not involve a slowdown and/or reduction in activity.

This type of measure aims to support the work-life balance of its employees, also with a view to increasing their satisfaction and hopefully increasing productivity.

OCCUPATIONAL HEALTH AND SAFETY
(VSME ESRS B 9 – Workforce – Health and Safety)

The protection of the health and safety of employees is a key issue for Valente, which has implemented a health and safety management system that is fully compliant with applicable national legislation.

In the year under review, the company recorded only one accident (fracture due to a fall at work). As a result, the accident rate recorded by the company in the reporting period is 5%, which is a decrease from the previous year’s figure of two accidents with a rate of 10%.

The financial impact related to this issue is due to the criminal and administrative sanctions imposed by Legislative Decree 81/08, the so-called Consolidated Law on Health and Safety at Work, which the company could incur in the event of non-compliance with the provisions of the law or in the event of litigation. The company is aware of the risks in this area and has taken both financial and management measures.

Financial measures, because in recent years Valente has invested in the improvement of its facilities and the safety measures adopted in the company, in order to significantly reduce the possibility of accidents at work.

Management measures, because the company periodically carries out a detailed company study to assess and manage the factors that expose employees to the risk of accidents.
This study and monitoring phase culminates in the Risk Assessment Document – last updated in October 2021.

The company has also adopted specific policies. In particular, it has

prepared a procedure for dealing with fire emergencies;

1. Carried out evacuation drills involving the entire workforce;
2. Provided the firefighting course in 2022;
3. adopted a document on the provision of PPE (Personal Protective Equipment);
4. prepared written health and safety procedures on: general safety rules; use of PPE; manual handling of loads; use of overhead crane; use of circular saw; first aid.
5. In addition, in order to implement a continuous monitoring of accident trends, Valente reports in the Risk Assessment Document – a section entitled “Accident Register” with a summary of the accidents that have occurred from 2015 to the date of the document, distinguishing them by the year in which they occurred and by the outcome.

The effectiveness of the management and prevention system in place is evidenced by the trend in workplace accidents reported above.

In addition, the company intends to adopt a strategic plan over the next three years that will make it possible to implement a system aimed not only at reducing risks but also at preventing them.

In particular, the company intends to

• adopt measures to improve working methods and practices, such as activities to review, expand and update internal
• health and safety regulations and procedures
• Increase specific training;
• Introducing new and additional training courses on a voluntary basis;
• increasing the tools needed to achieve better working conditions, such as manuals and/or operating instructions.

GOVERNANCE

The Company is managed by a Board of Directors (BoD) consisting of three members, who may or may not be shareholders, as decided by the Annual General Meeting, and whose term of office does not exceed three financial years.

The BoD currently consists of

The governance system adopted follows the “traditional” management and control model.

The planning, management and control rules and methods that make up the corporate governance system are defined by the Board of Directors in accordance with the regulations to which the Company is subject and with the best national and international reference practices.

The Board of Directors is vested with the broadest powers for the ordinary and extraordinary management of the Company, with the power for the appointed directors to perform all acts, including acts of disposition, that they deem appropriate for the implementation and achievement of the Company’s objects, excluding only those that the law reserves exclusively to the Shareholders’ Meeting.

The Company is represented by the Chairman of the Board of Directors, Mr Alberto Menoncello.

Valente has appointed a Board of Statutory Auditors composed of 3 permanent members and 2 substitute members:

Company organisation chart

Business integrity and value creation
(VSME ESRS B 11 – Convictions and sanctions for bribery and corruption)

For VALENTE S.p.A., corruption represents a serious threat – as well as a negative (potential) impact – on the development of economic and social relations, and it promotes the fight against it, both in relations with public officials and with private individuals.

The fight against corruption is aimed at avoiding possible sanctions or repercussions on the Company, in order to protect its reputation, in full compliance with the principles of loyalty, fairness, transparency, honesty and integrity that animate the behaviour of its employees.

The company has not been convicted or fined for violating anti-corruption and anti-bribery laws during the reporting period.

It is also acknowledged that the company will voluntarily adopt its own Code of Ethics by 2023, which will set out the essential principles for conducting business, such as legality, integrity, transparency, diligence, professionalism, confidentiality, social fairness and the value of the person.

In particular, the Code of Ethics will govern the following areas:

• Ethics in the conduct of business and corporate activities, whose values are: legality, integrity, loyalty, transparency and respect for human dignity;
• Work ethics, protection and promotion of employees, whose values are: commitment to improvement, confidentiality, absence of conflicts of interest, health and safety at work, equal opportunities and professional development;
• Commitment to sustainable development and responsibility towards the community, whose values are: promotion of sustainable development, responsibility towards the community;
• Ethics in the conduct of business.

The principles that inspire all the company’s activities are:

• Legality: all employees and collaborators are required to respect the laws and regulations in force in the countries in which they operate, the Code of Ethics and the Company’s internal rules, and to apply them honestly and fairly;
• Integrity: in their relations with third parties, they undertake to act in a correct and transparent manner, avoiding misleading information and behaviour that takes undue advantage of the weakness or lack of knowledge of others. In the pursuit of maximising our own economic and financial results, we are committed to establishing correct business relationships with third parties, lasting relationships with customers and suppliers, and appropriate recognition of the contribution of our own employees and collaborators;
• Loyalty: External relations, as well as relations with our own employees and collaborators, must be characterised by the utmost loyalty, i.e. by keeping one’s word, promises and agreements, and by acting responsibly in order to increase and protect the company’s assets;
• Transparency: all actions and relations with stakeholders and shareholders must be conducted in such a way as to guarantee the accuracy, completeness, uniformity and timeliness of information;
• Respect for human dignity: respect for people’s fundamental rights by protecting them and guaranteeing equal opportunities;
• Work ethics and protection of employees: absence of conflicts of interest.

All employees and collaborators are expected to conduct themselves in accordance with the following principles:

• Commitment to Improvement: Employees and collaborators undertake to perform to the best of their ability and to continuously improve their professional skills.
• Confidentiality: Employees and collaborators undertake to treat all information obtained in the course of their work as confidential and not to disclose it except in the course of their work.
• Absence of Conflicts of Interest: Employees and collaborators shall ensure that any business decision is taken in the interest of the Company and shall undertake to avoid any situation of conflict of interest between personal or family economic activities and the job they hold, which could affect their independence of judgement or choice. If an employee finds himself or herself in a situation that may constitute or lead to a conflict of interest, even potentially, he or she must immediately report it to his or her line manager and to the Supervisory Board so that its actual existence can be assessed and any necessary action can be determined.

Finally, the company has adopted and intends to further implement a financial and tax strategy aimed at taking advantage of all available subsidised financing opportunities and tax credits for investments aimed at increasing sustainability in all ESG matrices (i.e. investments and hiring).
The company is considering increasing its involvement in community initiatives and supporting local social causes.

Reporting methodology and results

This document has been prepared in accordance with the European Sustainability Reporting Standards for non-listed Small and Medium-sized Enterprises (VSME ESRS) endorsed by the European Financial Reporting Advisory Group (EFRAG) for reporting on an organisation’s sustainability performance in order to assess the economic, environmental and social impacts of Valente’s operations.

The information in this Sustainability Report covers the period from 1 January 2022 to 31 December 2022 and reflects the principles of accuracy, completeness, timeliness, comparability, balance, verifiability, clarity and sustainability context.

The company has opted for option b) of the VSME ESRS standard, namely the basic module and the narrative PAT module.

Finally, it is acknowledged that this Sustainability Report has been prepared on an individual and non-consolidated basis.

Detailed information on the indicators can be found in Appendix 1, Materiality Analysis, which presents the information collected in relation to the year 2022, the impact assessment with the criteria for quantifying it, the risk analysis with the criteria for quantifying it, and the stakeholder assessment of the various issues considered applicable.

Stakeholder engagement was carried out through interviews and questionnaires, initially limited to the most relevant employees and customers, as well as through interviews with the various corporate functions representing the other external stakeholders.

As this is the first year of data collection, comparisons with previous years are not possible.
Relevant material issues were identified from the list provided in Appendix B of the VSME ESRS standard: List of Sustainability Issues Used for Materiality Analysis, which for some items was further refined by reference to the materiality issues reported in the Guidelines for Listed SMEs.

With regard to the environmental area, data was collected from purchase and sales invoices, utility bills, emissions register, loading and unloading register and MUD, analysis of kilometres travelled by employees and goods, as well as analysis of contracts with employees and their pay slips. In particular, the calculations of Scope 3 emissions related to mobility and transport are presented in the tables below (GHG emission tables), using the conversion factors provided by the GHG Protocol.

The Derris platform, developed by a number of institutions in collaboration with Unipol, was used to quantify the risk of climate change, with the aim of helping SMEs to assess the risk of abnormal climatic events in relation to the physical location of the company and the way in which it operates.

With regard to social and governance issues, data for the reporting period was collected from company documents, organisation chart, contracts and staff pay slips, training data, DVRs, health and safety documents and procedures.

Metrics – Environmental (ENVIRONMENTAL)
VSME ESRS

Greenhouse gas emissions table for maritime freight transport:

CO2 emissions from Average container ship tonne.km 0.01612
CO2 emissions with Vans > 3.5 ton 0.57 ton.km
Goods coming by ship_ 431 + 239 + 23 = 693 in 30 trips, so an average of 23 tons per trip

TOT: 77.9 tons Co₂ sea + 106 overland = 184 tons Co₂

Greenhouse gas emissions table for goods delivered by road:

CO₂ emissions with Vans > 3.5 tons 0.57 ton.km
Total goods by land: 1430-693= 737

13 tons on average on vehicles

Metrics – Social Issues (SOCIAL AREA)
VSME ESRS B 8 – Personnel – General characteristics

Total number of employees by type of contract

Total number of employees by gender

Total number of employees by age group and contract type

VSME ESRS B 9 – Workforce – Health and Safety

The recordable accident rate is calculated using the following mathematical operation:

1/40.000 ∗ 200.000 = 5

VSME ESRS B 10 – Personnel – Remuneration, collective bargaining and training

The recordable accident rate is calculated using the following mathematical operation:

1/40.000 ∗ 200.000 = 5

Relationship between entry level and minimum wage

Ratio = entry-level salary/minimum wage

Regarding the position of Worker, the ratio between the entry-level and the minimum wage as defined by collective bargaining for the reporting period (Level D1) is as follows:

𝑅𝑎𝑡𝑖𝑜 = 1.572,91/1.509,07= 1,04

Regarding the position of Employee, the ratio between the entry-level and the minimum wage as stipulated by collective bargaining for the reporting period (Level D1) is as follows:

𝑅𝑎𝑡𝑖𝑜 = 1.791,82/1.509,07= 1,18

Percentage gap between female and male employees

(Percentage Gap=(Average Hourly Wage for Men-Average Hourly Wage for Men/Average Hourly Wage for Women​)×100

(16 − 17)/17∗ 100 = −6,25%

Collective bargaining coverage

100% of the workers employed by the company are covered by national collective bargaining and are specifically classified under the CCNL Metalmechanics.

Number and hours of training courses offered to workers

Metrics – Business Conduct (GOVERNANCE AREA).
VSME ESRS B 11 – Convictions and penalties for bribery and corruption.

The company had no convictions or fines for violations of anti-corruption and anti-bribery laws.

The company had no convictions or fines for violations of anti-corruption and anti-bribery laws.