Sustainability Governance

At Prima Electro, sustainability is backed by an evolving governance framework designed to embed accountability, risk management, and regulatory compliance within our corporate processes. Our journey is driven by defined targets and a multi-year development plan, enabling the progressive structuring of ESG models, tools, and responsibilities. A cross-functional committee coordinates these activities, monitors performance, and supports management in integrating sustainability criteria into operational and strategic decision-making.

Our governance evolves through the adoption and reinforcement of management systems and frameworks—including our Integrated Management System, Decree 231 Model, NIS2 Directive requirements, and reporting standards such as VSME—aimed at consolidating long-term resilience, transparency, and risk management capabilities.

Sustainability Governance: Committees and Responsibilities

Target 16.6 - Develop effective, accountable and transparent institutions at all levels

At Prima Electro, sustainability management is overseen by a dedicated governance structure that ensures continuity, consistency, and accountability in executing our ESG strategy.

Overall coordination is managed by a dedicated sustainability function, led by an ESG Manager who serves as the key point of contact—both internally and externally—for all Environmental, Social, and Governance matters. To ensure sustainability is embedded across the entire organization, the ESG function is supported by a network of focal points within key corporate departments (including Executive Management, HSE, HR, and Procurement). This cross-functional framework collaborates actively to integrate sustainability criteria into decision-making, monitor progress toward defined goals, and translate strategy into daily operational actions—spanning engineering, production, procurement, and human resources.

Operating with Integrity: 231 Model (D.Lgs. 231/01) and Cybersecurity

• Target 9.1/9.c - Develop quality, reliable, sustainable and resilient infrastructure, to support economic development and human well-being, with a focus on affordable and equitable access for all
• Target 16.5 - Substantially reduce corruption and bribery in all their forms
• Target 16.6 - Develop effective, accountable and transparent institutions at all levels
• Target 16.10 - Ensure public access to information and protect fundamental freedoms

Prima Electro’s governance is anchored in an internal control system that oversees two complementary dimensions: corporate administrative liability and the security of digital infrastructure.

The Organization, Management, and Control Model pursuant to Legislative Decree 231/2001 is adopted by Prima Electro as a tool to prevent corporate offenses and safeguard corporate integrity. The Model—available for consultation on our website—defines the operating procedures, control protocols, and the disciplinary system applicable in the event of a violation. It is supported by the Code of Ethics, which translates corporate values into binding behavioral principles for all personnel and business partners.
Compliance with both documents is a mandatory condition for operating with and for Prima Electro—and is explicitly referenced in our Supplier Code of Conduct as an obligation extended across the entire supply chain.

On the digital security front, Prima Electro has completed its alignment process with the NIS2 Directive (Network and Information Security), effective from 2024 for organizations operating in critical sectors or within their supply chains. This alignment involved cyber risk mapping, the implementation of protection measures for both IT and OT infrastructure, and the definition of incident management procedures—safeguarding operational continuity and ensuring the confidentiality of customer and partner data.

Integrated Management and Reporting

• Target 9.4 - Upgrade infrastructure and retrofit industries to make them sustainable
• Target 12.6 - Encourage companies, especially large and transnational companies, to adopt sustainable practices and to integrate sustainability information into their reporting cycle

The credibility of an ESG strategy is measured by the ability to translate commitments into verifiable data and communicate them with transparency. Prima Electro is formalizing the tools that enable this transition.

Our Integrated Management System (IMS) unifies existing certifications into a coherent framework—ISO 9001:2015 (Quality), ISO 14001:2015 (Environment), and ISO 45001 (Occupational Health and Safety, currently undergoing certification)—defining shared policies, objectives, and performance indicators across all corporate functions. The IMS Policy, currently being formalized, will serve as the reference document translating the company’s strategic vision into measurable quality, environmental, and safety targets.

Regarding ESG reporting, Prima Electro has initiated the adoption process for the VSME (Voluntary Standard for non-listed Small and Medium Enterprises), the European framework developed by EFRAG specifically for SMEs wishing to report their sustainability performance in a structured and comparable manner. For Prima Electro, the VSME serves as a proactive tool to respond to the ESG transparency demands of customers, banks, and investors—anticipating regulatory requirements that will progressively extend across the value chain to companies not directly subject to the CSRD. With this outlook, we have already undertaken the data collection and analysis process in compliance with current regulations, aiming to publish our first Sustainability Report based on the VSME standard within the next two years.