This page sets out the objectives of the ATM Group’s Sustainability Policy, defined and monitored using measurable indicators consistent with the business plan and applicable reporting standards.

Sustainability is integrated into the Group’s business model and guides its strategic, operational and investment decisions, with the aim of creating long-term value for the city, people and stakeholders.

Sustainability Strategy and Policy

The ATM Group’s Sustainability Policy sets out guidelines and improvement objectives across the main environmental, social and governance (ESG) areas.

These objectives are structured around six pillars:

1. Decarbonising mobility: progressively reduce greenhouse gas emissions and local pollutants associated with transport services through technological advances in the fleet, energy efficiency and lifecycle emissions management (Scopes 1, 2 and 3).
2. Responsible consumption: improve the use of water and material resources through efficiency improvements, recovery and measures to maximise their value, with quantitative objectives defined and monitored over time.
3. Inclusive mobility: ensure accessible, integrated mobility services, promoting comfort, improving inclusion and encouraging the use of multimodal and digital solutions.
4. Great workplace: promote safe, inclusive working conditions, valuing people’s skills, diversity and professional development.
5. Responsible supply chain: integrate environmental, social and ethical criteria into procurement and supplier assessment processes, with the aim of progressively improving ESG performance across the supply chain.
6. Responsible organisation: integrate ESG factors into decision-making processes and corporate control systems, ensuring transparency, accountability and alignment with regulatory developments.

All objectives are supported by performance indicators and periodic monitoring and reporting activities.

Contribution to the Sustainable Development Goals (SDGs)

The ATM Group has identified the areas in which its activities can make a significant contribution to the United Nations Sustainable Development Goals, in line with its strategy and operating context.

The priority SDGs were identified by considering their relevance to the business, the impacts generated and stakeholder expectations. This assessment is updated over time as the context and the Group’s activities evolve.

Sustainability objectives (KPIs)

1) Decarbonising Mobility

Objective: progressively reduce the Group’s greenhouse gas emissions and pollutants through fleet improvements, greater energy efficiency and stronger systems for monitoring direct and indirect emissions (Scopes 1, 2 and 3), with improvement targets defined and updated over time.

In 2025, emissions calculations were significantly updated, particularly following the inclusion of the new Greek company Thema, which operates the Thessaloniki metro, within the Group’s reporting boundary. At the same time, a new analysis and calculation methodology was introduced, aligned with the requirements of the Science Based Targets initiative (SBTi), resulting in the recalculation of emissions across all Scopes (1, 2 and 3).

For Scope 3, the analysis was extended to all specified categories, replacing the previous approach, which considered only those deemed most relevant. In addition, approximately 90% of categories moved from a spend-based to an activity-based methodology, increasing the accuracy of the calculations.

	Reference year	% Decrease - Increase as of 2024	2025 results
Scope 1 - Group Direct emissions (t/year) Greenhouse gas emissions generated by direct energy consumption – for ATM, consumption of natural gas, diesel and LPG	2019	- 32%	58.9 k
Scope 2 - Italy Indirect emissions (t/year), market-based *target with the cogeneration unit in operation	2019	- 24%	0.3 k
Scope 3 - Group Indirect emissions from the company’s value chain	2023	- 33%	169.5 k

2) Responsible consumption

Objective: improve efficiency in the use of water and material resources, promoting waste recovery and the optimisation of operational processes, with quantitative objectives monitored and, where necessary, revised in response to technological and organisational developments.

	Reference year	% Decrease - Increase as of 2025
% of total waste recovered – Italy *maintenance processes – target to be redefined to identify how to improve our processes	2019	-16,7%
% of washing facilities that recover water - Milan – ATM S.p.A. *No investment in washing facilities planned for 2025	2019	+8 facilities
Biodiversity - ATM S.p.A. Tree planting, green walls/roofs	2023	+550 trees planted +350 m² of vertical greenery

 

3) Inclusive mobility

Objective: progressively improve the accessibility, quality and integration of transport services, providing increasingly inclusive, multimodal and digital mobility solutions, in line with the service contract and the needs of the community.

	Reference year	% Decrease - Increase as of 2025
% of kilometres operated on routes certified to UNI EN13816 - Milan service contract	2019	+59,3%
% of tickets and travel passes sold through digital channels – Milan	2024	+16%
Vehicle accessibility (for people with mobility impairments) - Milan service contract • Surface transport • Metro	2019 2019	+6,4% +20%

 

4) Great workplace

Objective: develop a safe, inclusive working environment that values people through training initiatives, skills development and the promotion of diversity and equity, while monitoring indicators relating to workforce composition and wellbeing.

	Reference year	% Decrease - Increase as of 2025
% of women in the workforce – Group	2019 (8,9%)	+42,7%
Increase in training hours on DE&I topics - ATM S.p.A. Training for OS staff and metro trainers on inclusive mobility and disability.	2023	Bias (managers, executives) PDR 125 (managers, executives, operational staff)
Implementation of a programme to prevent discrimination and abusive behaviour - ATM S.p.A. Training on ethical conduct, alignment with corporate values and behavioural guidelines.	2023	PDR 125 certification Establishment of the PARI association Campaign against violence against women

 

5) Sustainable supply chain

Objective: progressively integrate environmental, social and ethical criteria into supplier selection and assessment processes, promoting improved ESG performance across the supply chain and involving partners in initiatives to monitor and reduce impacts.

	Reference year	% Decrease - Increase as of 2025
% of tenders awarded on the basis of the most economically advantageous offer that include environmental and social certifications among their scoring criteria – Italy	2019	1.150%
% of companies awarded contracts on the basis of the most economically advantageous offer that meet more than one ESG requirement – Italy	2024	/
Number of suppliers engaged in the decarbonisation programme (>25 employees) – Group	2024	+252 (absolute value)

 

6) Responsible governance

Objective: strengthen governance and control systems by integrating ESG factors into decision-making processes, ensuring transparency, data traceability and continuous performance monitoring, including through indicators such as customer satisfaction and corporate reputation.

Customer Satisfaction surveys are a strategic indicator for measuring how satisfied customers are with the services provided. The indicator is based on the average response to the question: “Overall, on a scale of 1 to 10, how satisfied are you with the transport service provided?”. The objective for 2030 is to consistently maintain a score of 7.7 or above.

	Reference year	% Decrease - Increase as of 2025
Customer satisfaction: Score from 0 to 10	2023	Maintain a stable score (above 7) over the years
Corporate reputation	2023	Maintain a stable score over the years