Governance

ESG assessment of suppliers

ATM is strengthening its oversight of the supply chain by also classifying suppliers according to CO₂ emissions and procurement risk.

As at 31 December 2025, the Group had classified 2.352 suppliers according to CO₂ emissions and procurement risk, understood as the economic impact for ATM and potential disruptions to the supply chain.

The classification identified 53 high-risk suppliers, 351 medium-high-risk suppliers, 594 medium-low-risk suppliers, 959 low-risk suppliers, 329 very low-risk suppliers and 66 non-classifiable suppliers.

All suppliers with more than 25 employees were asked to share Scope 1 and Scope 2 emissions data through the EcoVadis platform. To date, 252 suppliers have already entered this information.

ESG criteria in tenders
and procurement

ESG criteria are increasingly included in the technical assessment of bids, helping to guide tenders and procurement towards more sustainable and responsible choices.

In most tenders awarded on the basis of the quality/price criterion, ATM includes reward criteria linked to compliance with ESG criteria by bidding suppliers.

The elements considered include, for example, the use of environmentally friendly vehicles to carry out the service or works, compliance with Minimum Environmental Criteria, possession of certifications such as SA8000, ISO 14001, EMAS, Ecolabel and ISO 50001, the adoption of corporate welfare systems or work-life balance policies, and the preparation of a DNF or sustainability report.

In 2026, ATM intends to strengthen the supplier selection, assessment and management process through a Responsible Procurement Policy, in line with ESG guidelines and best practices.

Training on anti-corruption,
231 and business ethics

Governance is also strengthened through training programmes dedicated to the 231 Model, anti-corruption, transparency, whistleblowing and business ethics.

Between September 2024 and February 2025, the first year of the new three-year training cycle on 231, Anti-Corruption and Business Ethics was delivered.

The programme involved a base audience of over 400 people, including Middle Managers and contract managers, as well as a specific session for around 50 people, including Top Management and Corporate Bodies.

The training covers the 231 Models, the Group Anti-Corruption and Transparency Model, whistleblowing and business ethics, also through practical cases, ethical dilemmas and active engagement tools.

Behaviour Guidelines
and corporate culture

The Behaviour Guidelines translate the Code of Ethics and corporate values into concrete reference points for the organisation’s everyday life.

Over the three-year period 2023-2025, ATM launched a project to disseminate the Behaviour Guidelines, an expression of the Code of Ethics and corporate values.

After training over 700 managers and operational supervisors and actively involving the leadership team, from 1 January 2025 ATM adopted the Behaviour Guidelines as a contractual addendum in its relationship with each employee.

To encourage widespread and participatory dissemination, 15 Champions were appointed and a call to action was launched for Guideline Experts, with 80 people from 20 different departments responding.