Dear Secretary-General

Anas is the managing company for Italian roads and highways and is owned by the Italian Ministry of Economy and Finance and is subject to the technical and the operational control and supervision of the Italian Ministry of Infrastructure and Transport. Anas also works abroad and offers its skills and working ability in Colombia, Qatar, Libya and Paraguay.

We are proud to be part of the UN Global Compact and we have the primary objective of operating in compliance with the Global Compact Ten Principles, which are deeply integrated into our business strategic plan, corporate governance system and the stakeholders’ engagement.

Anas is committed to acting as a primary sustainability operator in accordance with the expectations of farsighted People and Governments. We are aware that the implementation, monitoring and widespread disclosure of the Global Compact Ten Principles represent the tools necessary to achieve the primary objectives of ethical and sustainable development.

Thanking you in advance for your kind consideration.

Yours faithfully

Pietro Ciucci
CEO Anas Spa

Anas operates principally in Italy where the constitution and the laws are compliant to The Universal Declaration of Human Rights and the Conventions issued by ILO.

During the necessary activity to achieve its own mission, Anas is compliant to the principles of the Ethic Code and of the internal guidelines that set up the ethical principles required of all stakeholders. In line with the firm’s policies and procedures, Anas is committed to the widespread application of the principles of the Ethic Code also the application of the principles of a system of sanctions.

Procedures supporting human rights are represented by the inclusion of clauses on human rights respected in the supply agreements. During 2011, Anas has not been subjected to inquiries, litigations, fines and other significant events related to the Human Rights.

Policies and procedures to manage Anas staff are totally compliant with Italian regulation with reference to:
• upholding the freedom of association;
• elimination of all forms of forced and compulsory labour;
• not employing child labour;
• elimination of discrimination in employment and occupation.

Anas employees remuneration is identified on this criteria:

• recognizing the responsibility and the expertise
• ensuring a remuneration related to the level of individual performance
• assessing the achievement of efficiency results and service quality.

Training represents a significant tool with which to sustain the process of scientific research and the transmission and widespread promotion of the firm’s values. Training contents are related to the know- how as a cultural – professional asset, good technical and operational skills, behavior, the needs and the values of the person in his/her relationship with the Organization.

Anas industrial relations are based on the rigorous and timely respect of the provisions and the indications emerging from the regulatory framework, considering innovations and the evolutions succeeded during the time, essentially through constant and constructive comparison with the trade unions.

The commitment to build a work background aimed at evaluating the contribution derived from people through development tools, communication and education led the firm to establish some guiding principles for business activity:
• people first;
• people protection;
• focus on competencies and skills development;
• achievement of potential thanks to the full expression of energy and creativity;
• creation of a work background that offers all people the same opportunities according to merit criteria and without discrimination.
The deep connection between: prevention activity and the litigation management, typically of the industrial relations subject matters, and the areas of coverage of significant attention of the labor law litigations led to the improvement of the integration between the activities in charge of the Industrial Relations division and those in charge of the Human Resource division. The relationships between Anas and the trade unions have been articulated though information events held at the level of the single, regional and national business unit.

In 2011, Anas has no recorded events of discrimination of race, sex, religion and political opinion.
Anas, together with the trade unions, has provided the institution with equal opportunities whose scope is to:

• create conditions of equal opportunities among Anas workers;
• remove every act of discrimination.

In this respect, it should be noted that different and systematic moments of comparison with the unions have been made during 2011 in order to pursue the firm’s objectives and to increase over time the efficacy, the efficiency and the quality of the service offered to the final users, with the scope of valuing and developing the human resources engaged in the firm.
In order to manage and to reduce progressively the health and safety risks, Anas adopted an organizational model compliant with the requirements of the British Standard OHS – Occupational Safety and Health. After the important changes of the discipline on health and safety introduced by the legislative decree 9/4/ 2008 e by the legislative decree n. 81 3/8/ 2009, a new regulation was introduced in 2011 that introduces the discipline of fire prevention with the D.P.R. 1/8/2011, n. 151. The regulation introduces important elements of fire prevention, in particular regarding the balance of the significant interests related to the security and the integrity of the assets along with the administrative simplification and the reduction of charges for the citizens.
The balance is possible by the principle of proportionality that considers the magnitude of the risk, the legal nature of the recipient of the law and the business dimension.

The purpose of doing business with the commitment to the environment comes in all the different phases of the activities carried out by Anas. The design of new roads combines the principles of environmental protection and the responsible use of resources; during the construction of the roads, activities of control and monitoring the work are generally designed, typically these activities are aimed at quantifying the impact of water pollution, land use, air use and noise emissions both during and after the construction comparing this data with the environmental characterization registered at the period before the start of construction work.
The environment is therefore considered in all stages of the road life cycle and the importance of this topic for Anas increases along with the awareness of its business activities impacts. As of today, the primary objective is the enforcement of the field1 environmental legislation.
The construction of a new road is seen by Anas as a development consistent with a broader transformation of the territory and the landscape. This requires a planning in context, no longer based on purely technical, functional, regulatory choices, but also decisions deriving from the relationship between the road and the environment, the landscape and territory to which ineluctably the road belongs.

Anas, as the main contracting authority at national level for the construction and the maintenance of roads and highways, performs an activity that has a very close relationship with the environment. The road manager is called upon to meet the mobility needs in the most efficient and sustainable way, interfacing directly with the environmental matrix.
Given the type of activity, Anas determines the direct impact on the environment, which falls within its direct control and which depends on the ordinary management of the company premises (including the head office, the local offices around the country), from traveling to work carried out by staff in the activities associated with the management of the road and motorway network.
Much more relevant to the specific characteristics of Anas are the indirect impacts associated with the many activities that Anas outsources to external parties, both for the construction of new road infrastructure and the ordinary and extraordinary maintenance of the existing road network.
With regard to indirect impact, in line with the main existing international methodological approaches, Anas is committed to identifying and, where possible, reporting in a quantitative way the indirect impact of its own activity.
In this context, the inclusion of particular specifications for the agreements with general contractors is in the approval process, these specifications provide the execution of audit activities addressed to the general contractors.

Significant matters are also the research and the development of:
• mapping critical sites and the definition of methods for noise reduction,
• detection of advanced solutions that allow, for example, the reuse of existing materials and the use of those marginal to reduce the consumption of inert fine,
• the implementation of automated systems for the relief of conditions of mobility on the network, which is the first step towards a future optimized management of the mobility.

During the design phase, system solutions for the reduction of energy consumption during operation are adopted.
For the purposes of proper implementation, these design choices have already been implemented at the level of technical specifications.
The main solutions for reducing energy consumption are:
• systems to regulate the flow of the lamps inside and outside of the tunnels in the service of interchanges;
• use of lamps with high luminous efficiency (high pressure sodium, LED);
centralized systems for the optimization of power ventilation of tunnels;
• use of variable message signs with LED light sources.

Anas follows the planning of new roads from the award of the tender and of the contract until their realization and throughout the operating phases.

In order to operate effectively in the direction of responsible business management, reducing environmental impact, pollution prevention and continuous improvement of its environmental performances, in October 2011 Anas began the project of implementing an environmental management system in accordance with UNI EN ISO 14001.
To achieve the objective of the integrated design of the infrastructures contextualized with an integrated assessment of the environmental, social and economic aspects, on the one hand capable of reformulating creatively the relationship between the conservation of environmental, historical and cultural resources and, on the other hand, answering the needs arising from the technological, formal, economic innovation, Anas Engineering Territory Unit of the Central Division Planning has sought to develop and to adopt a new design strategy through the implementation of:
• a new approach to the integrated planning, that abandoning the sectorial orientation to the road design can exceed the ex-post environmental assessment limits set forth in the practice;
• a new methodology for the evaluation of sustainability, that could also provide quantitative indicators such as assessment of the sustainability choices made in the design of the road and in relation to the whole life cycle of the work.
The methodology developed for the evaluation of the sustainability of the infrastructure projects takes into account the entire life cycle of the work in order to consider in an overall assessment the different choices related not only to the phases of design and of construction, but also to those related to the operation phase, maintenance and disposal; in order to find the most sustainable overall solution.
This approach, consistent with the integrated design methodology, allows us to move from the environmental logic, as an examination of the impact and negativity caused by construction, to sustainability logic, aimed at an integrated assessment of the environmental, economic and social aspects of the infrastructure project.
In summary, we proceed to the determination of the actual environmental balance of the road, showing not only the items taken from the environment, but also the benefits arising from the construction project.

The application of the method involves quantifying the level of sustainability of the project, by calculating, for each identified indicator, the ratio between a representative basis of the design data (Qp), (to be understood as the environment demand) with a reference magnitude (Qr), (to be understood as the environment supply), which represents the amount at which it is necessary to relate in order to perform the estimation of the sustainability of the project.

In all contracts entered into by Anas standard clauses are included which explain the behavior required of suppliers / contractors with reference to current environmental legislation. In special contract specifications are inserted the requirements set by the VIA (environmental assessment).
In general as regards the specifications and the selection of the criteria of the contractors’ agreements, Anas abides as expressly required by law.
In 2011 the text to use as basis for the preparation of special specifications for tenders has been prepared, the text provides a specific article that regulates aspects related to environmental monitoring. In particular, projects above the threshold of euro 50 million, will include these requirements for the contractors:
• prepare and maintain a manual of environmental management of construction sites;
be in possession of an Environmental Management System that complies with the criteria of ISO 14001 or EMAS regulation;
• perform all tasks scheduled in the project environmental monitoring;
appoint an environmental manager.

The adoption of this text for the special specifications is scheduled for early 2012.

Sustainability has declined in the early stages of the supply chain, in particular:

• the way in which they are manufactured (eg Company stationery, mass clothing, PPE, furniture);the verification of all contractors in the field of human rights;
• the introduction of specific items in the contract that stimulate suppliers to offer products with the best environmental performance in the market; upstream supply analysis is performed aimed at promoting, where possible, the introduction of the procurement of specific elements that encourage providers to offer products with the best environmental performance in the market. The approach taken by the Purchase Unit is to carry out assessments of the evidence of socio – environmental sustainability provided by participants in the race, equating environmental certification system for product certification. According to a panel interview of 3,176 suppliers carried out in the month of March 2010 (of which 698 responded), only 8% of the vendors involved were said to be in possession of a certificate of "environmental sustainability" pursuant to article. 44 of Legislative Decree 163/2006 and subsequent amendments (eg UNI EN ISO 14001/2004, EMAS environmental statement, etc..);
• the dematerialization of documents and the use of technology (digital signature in racing and in signing contracts, digitization supplier lists and archives);
• the purchase of products / services that have a low or minor impact on the environment; the use of sustainable criteria for the evaluation of bids, pursuant to art. 44 of Legislative Decree 163/2006 and subsequent amendments.
According to the preventive approach to environmental challenges, the objectives of undertaking initiatives to promote greater environmental responsibility and encourage the development and diffusion of technologies respecting the environment, in 2012 the CEO of Anas signed the Anas Environmental Policy.

Anas through the business unit “Legacy and Transparency”(hereinafter “the business unit”) has conducted its own activity against corruption also thanks to a synergistic relation with the local prefect’s offices, the police authorities, identifying the best preventive control forms also considering the local criminal events. By information procedures and documental transmission, the business units ensure the monitoring of local offices’ anti-mafia law compliance.
Anas has set up an Organization, Management and Control Model, which is a set of rules, tools reasonably designed to prevent any criminal behavior carried out by the top management or those under the direction / supervision of the top management. This model consists of a general part and a special part on several different types of crimes provided by the Decree n. 231.
Anas Watch Structure (hereinafter "ODV") is responsible for ensuring compliance, adequacy and updating the model for the prevention of crimes adopted in compliance with the provisions of the aforementioned decree and the observance of the principles set out in the Code of Ethics.

Regarding the improvement of control tools relating to sensitive areas, it is reported that at the end of the year, the CEO, after the pushing of the ODV, issued a policy on the subject matter of the Public Administration relations
The policy follows the further implementation of the protocols described in the Special Part A "Offences against the Public Administration" of the 231 Model. The policy, drawn up on the basis of a benchmarking with some major companies listed and unlisted, was sent to the "Referrals 231" and aims to establish a quarterly report that allows Anas to take a census of the relationship with the Public Administration.

The business unit created a database (hereinafter “CE.ANT”) that gathers the data of the executive people of the work in progress construction (natural and legal person) and indicates the people hit by prohibitive measures. Ensuring a rigorous control of the data of the Anas supply chain, this database has been built in the last few years and today it represents a tool to help the local police, engaged with anti-mafia operations.
During 2011 the CE. AT. operational has been tested, the results of testing demonstrated the efficiency of the database. Furthermore, in 2011 the database has been implemented and updated using the data of the entities hit by prohibitive measures. In this way, Anas has become the first station contracting that has got a complete database of the people hit by these kind of measures.
People hit by prohibitive measures are ousted from the life cycle of the work in progress during the prequalification phase and during the execution phase. In order to be compliant with resolution n. 58/2011 an update of the CE. ANT. is being defined in order to make the functions of the database match the guidelines for the anti-mafia controls issued by the Coordination Committee of the Big Infrastructure (Comitato di Coordinamento delle Grandi Opere - CCASGO); in particular this update provides the identification of a responsible for each construction that sends to the prefects’ office and to the police the details of the activities expected for each work week. This communication contains the information on the firms that execute the construction, the tools used and the names of employees and the people that have the access to the construction site, and represents a further tool to work against mafia infiltration.
In the second half of 2011 the issue on a more precise set of rules was also addressed applying the 10% penalty against the companies affected by disqualification mafia, proposing to manage Anas to the sums thus enforced.
Furthermore in 2011 the monitoring of the obligations arising from anti-mafia legislation continued, with special reference to:
• the training programs to the institutions involved in the monitoring process of corruption (police and inter-groups),
• the monitoring of financial data (tracking financial data) on the supply chain of subcontractors,
• the inclusion in the calls for tenders and in the procurement specifications of special reference to the legislative protocols.

As of December 31, 2011 Anas, in close collaboration with the prefectures, general contractors as well as some agencies (Autostrade Centro Padane S.p.A., Sitaf S.p.A., Autocamionale della Cisa S.p.A. and SAT S.p.A.), signed, also through the participation of unions of the building for monitoring the flow of labor, 38 legality protocols on the entire national territory. In addition, procedures have been defined for the subscription of further 2 protocols of the regional (Lazio and Abruzzo), 5 legality protocols for individual work (SS 640 ag / CL, Cosenza, Palermo, Catania, and Savona) and 2 protocols legality with Concessionaires (SITAF S.p.A. and Autocamionale della Cisa S.p.A.).
Continuing the work undertaken in previous years, in addition, the business unit has actively participated in political mafia infiltration prevention, in cooperation with the Anas Centre for Higher Education (Centro per l’Alta Formazione Anas) n. 4 training workshops for police forces took place in Milan, Venice, Palermo and Reggio Calabria. The training, involving approximately 80 staff of Police (SP, GdF, CC), were intended to illustrate the role of Anas in the fight against criminal infiltration, to offer a complete treatment of the relevant legislation in the field of public construction and the tools for basic technique faces the execution of targeted checks on construction sites.
Furthermore the unit participated in hearings and meetings at the CCASGO and at the Global Compact Italy. In particular, in 2011 Global Compact meetings it was agreed on the need to sensitize the Ministry of Interior to have information (CERVED and certified company registration certificate mafia) in order to improve internal company processes to select ethical suppliers and to verify customers.
About the updating of the Organization, Management and Control Model should be noted that in 2011 the Odv has completed the review of the Special Part “C” of the Model with reference to the crimes on health and safety in the workplace, under ex art. septies 27 of the Decree. The review takes into account the changing organizational structure of the Company and implements the provisions of the Compliance Model (MOG) prepared pursuant to art. 30 of Legislative Decree no. 81/08. By December 2011 the procedures related to health and safety are in scope with the Quality Management System of the Central Resources, Organization and in accordance with the UNI EN ISO 9001:2008. The updated version of the Special Part “C” of the Model was approved by the CEO in March 2012.
With regard to the recent introduction of the environmental crimes in the category of the "crimes" of the administrative responsibility of the entities (Article 25 undecies of Legislative Decree no. 231/01) and in connection with the proposed implementation of an environmental management system, launched in October 2011 by the Central Organization and Resources and the Directorate of Administration and Finance, Anas Watch Structure started the activities aimed at the updating of Model 231. The project will be completed between 2012 and the first quarter of 2013.
Furthermore, regarding the updating of the Model, different business processes, aimed at monitoring corporate areas sensitive to the risk of 231 crime, have been issued / revised, these procedures are an integral part of Model 231.
It is pointed out that the ODV, through the 231 working group, evaluates the adequacy of the new procedures with regard to the principal sites that with reasonable assurance could prevent the commission of 231 crimes. In this context, in 2011 n. 52 procedures have been developed/ updated, the procedures concern, inter alia, the following areas:

• personnel management,
• information systems,
• litigation,
• business,
• accounting and budgeting,
• road cadastre,
• property maintenance and new construction,
• exercise,
• design,
• new construction,
• evaluation of suppliers.

Reviewing the activity of the supervision and the monitoring of the implementation and compliance of the 231 Model, it is noted that, at the request of the ODV, an audit by Internal Audit Unit (the "monitoring 231") on the adequacy of the organizational measures to prevent the commission of the crimes under art. 24 bis of Legislative Decree 231/01 was performed. As a result of the audit, some suggestions, mainly organizational, have been identified, the scope is to address to the relevant corporate structures the reasonable prevention of the crimes in question, together with the relevant suggestions.
With regard to the training - essential tool for the dissemination of the principles of the Legislative Decree no. 231/01 and for the effective implementation of the model In 2011 online course (mode with E-learning) "the Leg. 231/01” continued, the objects of the learning were: widespread framework and model of organization, management and control model adopted by Anas S.p.A.", these activities were carried out with the support and coordination of the Center for Higher Education management Resources Unit, Organization and Systems and Vice Management Information Systems and Equipment.
The trainings were completed in the first months of the year under review, with the provision of 26 planned editions addressed to Anas personnel belonging to the categories of managers and supervisors. In this period the recovery editions trainings were provided for those people who, for various reasons, have asked to postpone the training, this recovery also considered the news of the introduction of the e-learning methodology, in the complex and articulated environment of Anas. As of December 31, 2011, at the conclusion of the course, 1,271 employees have completed the course and have passed the tests.