Stakeholders and materiality

First, we analysed the Group’s internal and external context, considering its business model, value chain, the national and European legal and regulatory framework and the main trends relevant to the maritime and shipbuilding sectors.

We then identified the impacts, risks and opportunities (IROs), drawing up an initial list of potentially material IROs based on the evidence gathered through the context analysis and on the Group’s activities, products, services and relationships throughout the value chain. The study was enhanced by analysis of the Risk Universe developed within the Enterprise Risk Management (ERM) system.

The identified elements were mapped to the topics required by the ESRS and assessed using specific methodological approaches:

• Impacts were assessed by 40 company Functions and bodies based on their severity and likelihood, following an initial analysis by the Sustainability Function. The process was supplemented by external stakeholder engagement through interviews with opinion leaders and representatives of trade associations, as well as a survey of trade union representatives concerning impacts on the Group’s own workforce;

• Risks were assessed within the Group’s Enterprise Risk Management (ERM) system through a dedicated risk assessment involving around 100 internal stakeholders and considering the likelihood of occurrence and potential financial effects in the short, medium and long term;

• Opportunities were identified and assessed by examining the streams in the Business Plan and involving the relevant Stream Leaders, taking into account the Group’s business model and strategic directions.

The double materiality assessment conducted in 2025 enabled the identification of 42 material impacts, 38 material risks and 11 material opportunities, which were subsequently mapped to the ESRS topics identified as material for the Group and to the corresponding strategic topics of the 2026-2030 Sustainability Plan.

 

The Group’s activities generate impacts associated with greenhouse gas (GHG) emissions from its own operations and the ship use phase. At the same time, the development of advanced technologies, improvements in energy efficiency and the increased use of energy from renewable sources contribute to reducing emissions throughout the value chain.

The main risks concern potential misalignment in the adoption and implementation of emerging technologies, including those related to the green transition, and technological lag compared with competitors and/or market demands. Opportunities arise from the development of more efficient products and services with reduced GHG emissions and from the adoption of new technologies, including digital and Artificial Intelligence (AI) solutions, to improve energy efficiency and reduce emissions and operating costs.

Industrial operations generate impacts associated with pollutant emissions into the atmosphere, with potential consequences for the environment and people’s health. The main risks include inadequate management of atmospheric emissions and the potential contamination of soil, subsoil and seawater due to accidents or spills.

Increased water consumption at the Group’s shipyards, particularly at sites located in water-stressed areas, represents a negative environmental impact and may contribute to increased pressure on local water resources, with potential effects on ecosystem resilience and ecological balance. In this context, the Group promotes the responsible management of water resources through the implementation of dedicated policies, the adoption of water reuse and recovery technologies, and the continuous identification of sustainable solutions aimed at reducing water consumption and protecting water resources, particularly in areas exposed to water stress.

The Group’s production activities may lead to a decrease in the variety of species present in areas surrounding production sites, the deterioration of natural habitats and the alteration of ecological balance. The development of underwater solutions geared towards the security, surveillance and monitoring of submarine infrastructure represents an opportunity to increase the Group’s competitiveness.

Positive impacts relate to initiatives aimed at reducing the amount of waste and increasing the share of waste sent for recovery through the implementation of new agreements and technologies.

The main risks include inadequate management of hazardous and non-hazardous waste and the potential scarcity of critical raw materials, which may expose the Group and its supply chain to business continuity risks and cost fluctuations. The opportunity lies in adopting circularity principles to optimise resource use, improve product quality and reduce operating costs.

The main impacts relate to increased employee well-being and a better work-life balance, skills development and the promotion of an inclusive working environment, including for individuals with disabilities. Training, information and awareness-raising programmes also contribute to increasing health and safety awareness. Actual or potential negative impacts are associated with accidents and occupational illnesses, potential accidents during business trips, inadequate enforcement of existing labour regulations, discrimination and harassment, discriminatory and unfair behaviour and practices in recruitment, career progress and remuneration procedures, and incorrect handling of the confidentiality of employee data.

The main risks include non-compliance with requirements relating to adequate wages, working time, freedom of association, health and safety, diversity, inclusion and personal data protection. Further risks relate to relations with trade union representatives, the safety and security of personnel travelling on business, inadequate career growth paths and the loss of key personnel.

The main opportunities involve strengthening the Group’s competitiveness, attractiveness, profitability and reputation by promoting well-being, safety, inclusion and skills development. The adoption of new technologies, such as robotics, may also help create safer working environments and reduce accident-related costs.

The main impacts concern potential human rights violations throughout the supply chain arising from inadequate working conditions, inadequate enforcement of existing labour regulations or the use of child and forced labour. Further impacts relate to health and safety, discrimination and harassment. At the same time, training, information and awareness-raising activities contribute to strengthening technical skills and increasing awareness and knowledge of ESG and health and safety matters among workers in the value chain.

The associated risks include the employment of workers not covered by regular employment contracts, unhealthy working environments, exposure to potentially harmful substances, non-compliance with occupational health and safety requirements, discrimination, harassment, child or forced labour and the unavailability of external skilled labour required to meet production needs.

Opportunities arise from responsible supply chain management through the assessment and monitoring of compliance with sustainability principles, thereby strengthening the robustness, reliability and resilience of the supply chain.

Impacts include potential disruption to communities in relation to social inclusion and integration processes in areas characterised by a high level of cultural heterogeneity among the workforce. Positive impacts arise from social initiatives, charitable activities and sponsorships, educational guidance and employment initiatives, and agreements with institutions aimed at promoting legality and combating unlawful activities.

Risks relate to the potential deterioration of relations with local communities due to the social and environmental impacts of the Group’s activities. Opportunities involve strengthening the Group’s reputation and contributing to the economic development of local areas, including through the creation of new jobs related to emerging skills required by the market.

The main impacts relate to the promotion of ethical and transparent conduct, including through cooperation between countries and international partnerships in the maritime sector. Negative impacts are associated with unethical conduct, incidents of corruption or bribery, breaches of the confidentiality of data and information, the non-application of ESG criteria in supplier selection and ineffective control actions across the supply chain. The active participation of suppliers and supply chain partners and the development of initiatives to facilitate access to finance contribute to promoting sustainability values and supporting supply chain growth.

The most significant risks include non-compliance with anti-corruption legislation and Italian Legislative Decree No. 231/2001, the potential occurrence of corruption or bribery, failure to maintain ISO 37001:2016 anti-corruption certification and the establishment of relationships with suppliers of dubious integrity, suppliers that do not meet the ESG criteria defined by the Group or suppliers included in relevant international sanctions lists. Further risks relate to conflicts of interest in purchasing relationships with suppliers.

Opportunities focus on increasing supply chain resilience and reducing costs through the development of a more ESG-aware and mature supply chain, supported by a structured programme of engagement initiatives.

Positive impacts relate to the development of advanced AI-based technological solutions to support workers in performing their tasks and mitigate labour shortages, as well as the development of digital technologies to prevent and reduce the impacts of cyber-attacks on ships and their on-board systems. The development of specific security plans and systems also contributes to increasing the protection and security of data and systems for internal and external stakeholders.

The main risks concern the competitive advantage that competitors may gain by adopting AI earlier, Advanced Persistent Threats involving cyber espionage by organised and/or state-sponsored groups, and non-compliance with national and international cyber security legislation, including data protection requirements, military regulations and the National Cybersecurity Perimeter.