Human Rights

It is a core commitment for our Group to ensure and promote respect of human rights in the context of our operations and business relationships.

Since 2019, we have voluntarily adhered to the 10 Principles of the United Nations Global Compact, undertaking to promote responsible practices in the following areas:

• Human rights: promoting and respecting universally recognized human rights, ensuring that we are not complicit, even indirectly, in any abuses.

• Labor: upholding workers’ freedom of association and the right to collective bargaining, combating all forms of forced and compulsory labour and child labour, and preventing any form of workplace discrimination.

• Environment: adopting a precautionary approach to environmental challenges, promoting initiatives that foster greater environmental responsibility, and encouraging the development and dissemination of sustainable technologies.

• Anti-Corruption: opposing all forms of corruption, including extortion and bribery.

These principles guide our commitment to sustainable and responsible development, contributing to a fairer and more prosperous future for all. In this regard, they are embedded into our Human Rights Policy – Commitment to Respect Human Rights and Diversity, which draws inspiration from several key international instruments, including:

• The United Nations International Bill of Human Rights;

• The European Convention on Human Rights;

• The Fundamental Conventions of the International Labour Organization (ILO);

• The EU Corporate Sustainability Due Diligence Directive (CS3D).

The Policy reflects our ongoing attention to the expectations of institutions, society, and the market. To capture and address these evolving needs, we periodically review the document. In confirmation of this commitment, on 30 September 2024, the Board of Directors of Fincantieri S.p.A. approved its most recent update.

Aligned with the UNGP Reporting Framework, the latest version of the document focuses on the Salient Human Rights Issues, i.e., the principal potential negative impacts that our operations and business relationships could have on human rights. The new structure of the Policy stems from the Human Rights Risk Assessment (HRRA), which identified the areas most exposed to such risks. The updated Policy is therefore based on the following salient issues:

Our Policy has always placed a strong focus on Diversity, Equity and Inclusion and has introduced targeted measures to address them.
As part of the UNI/PdR 125:2022 certification, Fincantieri Group applies the Human Rights Policy, within the certified scope, as its gender equality policy, in line with the provisions of the relevant Reference Practice.
To highlight its strategic importance, the principles set out in the Policy are actively promoted throughout the supply chain — that is, among our suppliers and partners — both through specific contractual clauses and via the Suppliers’ Code of Ethics, which serves as a key tool for sharing and disseminating our core values.

In 2023, we assessed the effectiveness of our human rights measures, anticipating the requirements set forth by the European Parliament and Council Directive on corporate sustainability due diligence (CSDDD). In this context, we conducted a Human Rights Risk Assessment (HRRA).

During its preliminary phase of saliency assessment – which led to the identification of the Salient Issues integrated into our Human Rights Policy – a people-centered risk perspective was adopted, rather than one focused solely on the Company, actively involving internal stakeholders.

The HRRA process consisted of a due diligence exercise exclusively focused on human rights compliance and was conducted across our Italian and European production sites, including contractors and Tier 1 suppliers with whom Fincantieri maintains commercial relationships. This activity was carried out through a structured analysis of actual and potential negative impacts, following a risk-based approach.

The analyses performed within the HRRA allowed us to map the main risk elements along the value chain to be monitored and managed, assigning specific risk levels based also on market segments and geographical areas of operation. Possible human rights violations are indeed closely linked to the political and social conditions of the countries where Fincantieri operates.

Specifically, the activities focused on Fincantieri S.p.A., Marine Interiors S.p.A., and the VARD group, covering 14 of the Group’s 18 sites, representing 78% of the total. As part of this process, human rights compliance was also assessed through the review of corporate documentation and engagement with internal functions of Fincantieri S.p.A., Marine Interiors S.p.A., and the VARD group.

In this context, the HRRA placed specific emphasis on groups potentially exposed to these risks, including:

• Our own employees

• Women

• Third-party employees

• Local communities

Based on the HRRA results, in 2024 we defined a structured monitoring plan aimed at ensuring systematic data collection and in-depth analysis of information related to salient issues. The plan foresees the adoption of proactive indicators designed to anticipate potential risks and facilitate timely and targeted interventions. These initiatives will be progressively implemented in 2025, actively involving internal stakeholders and the supply chain, with the objective of further strengthening human rights protection.

In parallel, the HRRA process is subject to periodic reviews following a systematic risk mapping approach, aimed at identifying any new areas of exposure, including in connection with the initiation of new business relationships, such as mergers, acquisitions, or joint ventures.

Furthermore, since 2019, among the measures implemented along the supply chain, a continuous second-party ESG audit program has been conducted at the Group’s priority/strategic suppliers. ESG audits are performed using two checklists, one of which investigates health, safety, and human rights topics. This checklist also assesses compliance with the Suppliers’ Code of Ethics, which includes “Labor and Human Rights” as a key pillar.

ESG audits represent one of several tools Fincantieri has implemented to safeguard human rights throughout the value chain, alongside the supplier qualification process (which also monitors compliance with labor laws) and the whistleblowing system (accessible also to workers in contracting and subcontracting roles).

Human rights: 2023-2027 Sustainability Plan objectives and target

Commitment to creating the socio-economic conditions to ensure respect for human rights throughout the value chain