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The Group’s strategic priorities for Sustainability have been arranged into a Sustainability Plan in which the activities performed during the reporting year are presented and compared to the commitments made by the Group for the three-year period of reference.
The year 2011 was particularly significant in A2A’s Corporate Social Responsibility journey: the process to update the Group’s Sustainability Plan began with the aim of preparing a new edition for the three-year period 2012-2014, with the related objectives, commitments and sets of indicators designed to monitor sustainability performance. The Corporate Social Responsibility Organisational Unit performed an analysis of the ratings given by the leading ethical ratings agencies in order to identify the main aspects for improvement compared to international best practice and bring to light the risks and opportunities connected with the question of sustainability. A summarised paper was presented to the two General Managers and subsequently to the representatives of all of the Group’s companies/departments. The two General Managers handed the Social and Environmental Responsibility Organisational Unit the task of meeting the managers of the companies/departments to draft proposals of the objectives, commitments and activities to be included in the Sustainability Plan for the three-year period 2012-2014. The proposed new Plan will be presented to the General Managers.
The following table takes the Sustainability Plan for the three-year period 2009-2011 and provides details in particular of the activities carried out in 2011.

COMMITMENT / INDICATORFIGURE 2009FIGURE 2010FIGURE 2011ACTIVITIES / RESULTS 2011
GOVERNANCE AND SUSTAINABILITY TOOLS
1. To promote the new organisational, management and control model as per Legislative Decree no. 231/01


INDICATOR:
Ratio (%) between the number of people in the companies which have introduced the new model and the total number of people in the companies within the scope
94.0%94.1%95.6%Training on Legislative Decree no. 231/01 in 2011 involved 1,000 employees of A2A S.p.A. (out of a total of 1,428) by means of an online course on this law and on the organisational, management and control model of A2A S.p.A., aimed at all the company’s employees who did not attend the 2010 classroom courses.
In addition, following the adoption/updating of the Legislative Decree no. 231/01 model by certain Group companies specific training sessions were held in the classroom involving 228 employees.

2. To promote the Group’s new Code of Ethics

INDICATOR:
Ratio (%) between the number of people in the companies which have introduced the Group’s new Code of Ethics and the total number of people in the companies within the scope

98.8%98.6%98.2%

The Code of Ethics has been adopted by all the Group companies consolidated in the Sustainability Report except for A2A Coriance and its subsidiaries.

3. To optimise and rationalise the certifications held by Group companies

RealizzatoRealizzatoRealizzatoThe scheduled path for simplifying the certifications panorama was completed in 2011, leading to the unification by Group companies of certificates of the same type (Quality-ISO 9001; Environment-ISO 14001 and Safety-OHSAS 18001) where these exist. This involved the following companies in 2011: Ecodeco, A2A Reti Elettriche, Aprica, AbruzzoEnergia, A2A Ciclo Idrico, A2A Servizi alla Distribuzione.
Further details may be found in the section “Corporate governance tools” on  page 23/24.

4. To increase the activity of listening to stakeholders

RealizzatoRealizzatoRealizzato Numerous stakeholder engagement activities were performed:
- on-line questionnaire to sound out opinions on the 2010 Sustainability Report;
- employee questionnaire to understand the level of appreciation of the Group’s intranet and the use of totems with intranet work-stations for employees without a personal computer;
- focus groups and questionnaires on the differentiated collection system in Brescia;
- meetings with consumers’ associations to sign a framework agreement opposing unfair commercial practices;
- meetings with consumers’ associations to draft and agree the “Guide to reading your bill”;
- preliminary meetings with business federations for adherence to the out-of-court joint settlement system which may be used by customers for unsuccessful claims;
- meetings with the public administration to determine steps aimed at the joint promotion of services for residents.

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COMMITMENT / INDICATORFIGURE 2009FIGURE 2010FIGURE 2011ACTIVITIES / RESULTS 2011
GOVERNANCE AND SUSTAINABILITY TOOLS
5. To publish a single Sustainability Report for the Group consistent with the recommendations of the Global Reporting Initiative (GRI) RealizzatoRealizzatoRealizzatoThe A2A Group’s Sustainability Report, prepared in accordance with the GRI guidelines and verified by an external auditing firm has been published for the fourth consecutive year. In 2011, a total of 157 indicators out of the applicable 162 have been reported.

6. To promote the Sustainability Report and sustainability culture

RealizzatoRealizzatoRealizzato

- A navigable web version of the Sustainability Report has been prepared for the first time. The website http://bilanciosostenibilita.a2a.eu/ enables the document to be read by more than one enquiry channel: chapters, stakeholders or GRI indicators. Users can download only the contents that they actually need through the use of “baskets”. The site highlights the Group’s key performance indicators, which are proposed in an interactive version to allow the user to view the graphs in various forms, with other comparative data or by selecting one or more comparative years;
- Article in the internal magazine “inadueà"  and in the periodical published by the public administration “Energia in Comune”.

7. To maintain and consolidate relations with the ethics ratings agencies

Realizzato
RealizzatoRealizzatoThe activity of replying to the requests of the main ethical ratings agencies SAM-CDP-ECPI-EIRIS-VIGEO-SUSTAINALYTICS continued in 2011.
PEOPLE

8. To increase listening to people via the intranet area


RealizzatoRealizzatoRealizzato - The  on-line survey "Measure your sustainability" was published, this promotes the awareness in employees of the usefulness of assuming, particularly at work, “Sustainable” conduct and the benefits deriving from this for them, for their interlocutors and for the Group as a whole;
- Carried out an online survey on the subject of family-work reconciliation in conjunction with the Catholic University of Milan.
9. To implement the training plan for the whole of the Group’s population

INDICATOR:
Total number of training hours/total number of employees 
9.48.613.2A total of 21 managerial courses, 142 conferences, 3 types of English courses and 1 German course were held. In addition to managerial and language courses the Group has also started up an on-the-job training plan, which groups together training courses connected with the experience of a specific sector and directed towards acquiring technical skills and know-how - obligatory and non-obligatory - depending on a person’s role, position or responsibility. The on-the-job training courses, addressed to the whole of the Group’s staff, are grouped by subject. Further details may be found in the section “Development and training on page 89/92.
10. To introduce the recommendations emerging from the “Voices” project
RealizzatoRealizzatoRealizzatoCompletion of the meeting days between the General Managers and middle managers. A total of 329 middle managers were involved. Each of the two General Managers had met with half of the population of middle managers in 2010; in the first four months of 2011 each General Manager met the other half of the middle managers. The average appreciation was 5.7 (on a scale of 1 to 7).
11. To develop knowledge management tools
RealizzatoRealizzatoRealizzatoThe use of the e-learning platform continued in 2011 for advance preparation for classroom training and, in certain cases, for activities following the classroom training. The documentation is made available in suitable areas created for the individual courses and for each class (virtual), thus considerably reducing the distribution of paper material. Further details may be found in the “Development and training” section on page 89/92.
12. To implement a system of key performance indicators

INDICATOR:
People taking part/people in the companies within the scope 
7.10%46.12%46.37%With the extension of the performance assessment tool to the population of white-collar workers, approximately 4,300 people received a performance appraisal in the first part of 2011 together with recommendations to direct their organisational behaviour towards the achievement of increasingly challenging results.
Start-up of the performance management process also for other Group companies (Aspem Energia Srl, Aspem SpA, Gruppo Ecodeco, Partenope Ambiente SpA and Varese Risorse Srl), so that by the end of 2012 the whole population of executives, middle managers and white-collar workers will have received an appraisal.
13. To improve the well-being of personnel through initiatives identified by listening to people
RealizzatoRealizzatoRealizzatoStarting from December 1, 2011 the psychological assistance service has been reintroduced for employees who have the possibility of attending free of charge meetings to share critical moments of their working and non-working lives. This social assistance is available at all of the Milan locations and Cassano d’Adda every two weeks.

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COMMITMENT / INDICATORFIGURE 2009FIGURE 2010FIGURE 2011ACTIVITIES / RESULTS 2011
PEOPLE
14. To increase personnel training and awareness about safety issues in order to reduce the frequency and seriousness of accidents

INDICATOR:
Number of hours per person of “Safety and accident prevention” training
 3.8 4.34.9
Courses on safety carried out for a total of 44,497 training hours on first aid, fire prevention, prevention and use of equipment. Specific training started up in Amsa as a guide for employees using company vehicles for waste collection.
15. To develop the involvement of personnel in socially useful activities (e.g. A2A Civil Protection)
Realizzato
Realizzato
Realizzato
The most significant initiatives carried out in 2011 by A2A personnel regard the volunteer groups of A2A Civil Protection. Further details may be found in the “Communities of reference” section on page 143.
16. To develop a talent management system to identify and manage people with greater potential who are critical for the businessRealizzato
Realizzato
Realizzato
Creation of development centres for young professionals aimed at extending skills, aspirations and motivation. The planned development centres are intended to be a path for development and gaining strength, when the moment for observation and appraisal is combined with that for training and self-awareness.
17. To develop a system for measuring the professional and managerial capital in the GroupRealizzato
Realizzato
Realizzato
- Consolidated certification systems for the selection phases;
- Introduced the staff appraisal process/development centres, with priority given to the areas affected by reorganisation projects;
- Consolidated documenting for the whole Group critical and high potential staff (especially starting from the young professionals in the Group), including through appraisal/development centres;
- Extended the performance appraisal system to all of the Group’s employees (excluding blue-collar workers) by skill appraisal;
- Defined the scheme of professional families useful for implementing career plans.
CUSTOMERS AND SOCIETY
18. To define and develop quality policies common to all Group companies by type of service (energy, environment)RealizzatoRealizzatoRealizzatoAll Group companies providing customer services ISO 9001 certified.
19. To define systems for regular surveys to assess the degree of customer satisfactionRealizzato
Realizzato
Realizzato
Numerous customer satisfaction surveys carried out:
- customer satisfaction analysis on a sample of gas and electricity customers in the Milan and Brescia areas, separated between domestic customers, self-employed customers and SMEs, carried out by the Databank Energy Observatory-Cerved Group;
- analysis of customer satisfaction with the A2A Energia call centre carried out by the AEEG;
- survey in Brescia on the appreciation of the waste collection system with street bins operated by an electronic key.
20. To maintain and develop activities regarding the provision of information aimed at energy saving, environmental protection and safetyRealizzato
Realizzato
Realizzato
Numerous environmental education initiatives carried out in schools and for the community as a whole. Further information may be found in the section “Environmental Education” on page XXX.
To encourage differentiated collection the following initiatives with new tools were proposed in 2011:
- the creation of promocards on waste, in conjunction with the Milan cartoon school;
- the travelling ecological station for differentiated collection (Mobile Environmental Centre - CAM) and the mobile office, used for various local initiatives;
- awareness and information campaigns on the correct way of disposing of the various types of waste, promoted in conjunction with the various Consortia.

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COMMITMENT / INDICATORFIGURE 2009FIGURE 2010FIGURE 2011ACTIVITIES / RESULTS 2011
CUSTOMERS AND SOCIETY
21. To reduce disputes (also by encouraging the use of settlement procedures)

INDICATOR:
Number of settlement files
604436
In 2011, the settlement agreement was extended further with the signing of the protocol of understanding with the business federations. During the year A2A Energia was involved with 36 settlement requests, with a positive outcome (meaning that agreement was reached) in 58.3% of the cases (27.8% consist of situations where settlement is in progress but has not yet been finalised).
22. To develop the possibilities for non-Italians and the disabled to have access to Group information 
Realizzato
Realizzato
Realizzato
- Availability of multilingual information booklets at the commercial desks of A2A Energia.
- Operators capable of dealing with multilingual relations.
- Availability of DPS telephones (telephone devices for the hard of hearing) at the service of call centres.
- Printing of bills in Braille for the visually impaired.
- Desks with priority access for people with specific needs (the disabled, pregnant women, the elderly and the needy).
23. To strengthen the business site guided tour service to reinforce the Group’s transparency policy

INDICATORE:
Number of plant visitors 
 30,075
25,582
22,842
The year 2011 saw the continuation of A2A’s School Project, aimed at younger residents, to which important new items were added:
- membership of the Italian Environment Fund (FAI), the foundation for safeguarding Italy’s cultural and natural heritage, was offered to all students and teachers visiting the plants, together with the School Learning Kit;
- at the beginning of the school year, schools were sent a 2011/2012 academic year poster-calendar dedicated to differentiated collection;
- the way of booking visits has been simplified by setting up a section on the A2A website dedicated to the School Project, where teachers can apply for a guided tour of the Group’s plants online.
24. To create and promote products which respect environmental and social needs Realizzato
Realizzato
Realizzato
The sustainable commitment of A2A Energia and Aspem Energia continued in 2011 with the proposal to provide their customers with ‘green’ energy, namely energy produced from renewable sources.
Further details may be found in the caption “New certificates of origin for green energy” on page 60.
25. To create and promote products and services with a correct quality/price ratio RealizzatoRealizzatoRealizzatoThe fidelity programme aimed at the domestic customers of A2A Energia and based on the Asmea, Bas Omniservizi and Tidonenergie  brands was renewed for the fourth consecutive year and at the end of 2011 had around 25,000 members. The programme was supported by awareness initiatives, such as the promotion of eco-sustainable products and services (supply of green energy, low consumption lamps, composters, domestic photovoltaic, ‘bio and zero km.’ products). During the two events organised in Brescia and Bergamo, ecological ‘gadgets’ were given as a present to those registered for the programme consisting of 4,000 biodegradable shopping bags and 2,000 cotton shopping bags.
26. To limit the inconvenience caused to residents by worksites

INDICATOR:
Number of reports (MI)
 581 7421,107
To reduce the time for replying to inconveniences, since 2010 A2A receives reports directly from the city police via the Municipality of Milan and this has led to a considerable increase in reports. Further details may be found in the section “Dealing with complains about road works” on page 130.
SHAREHOLDERS AND INVESTORS
27. To improve the area of the website reserved for shareholders, with emphasis also being given to retail investors and small shareholdersRealizzatoRealizzatoRealizzato- Extension of the Investor Relations website area with the addition of new pages (in particular those dedicated to interest rate risk). Constant updating of the information included in the website area.
- Marking of internet pages dedicated to financial education.
28. To increase the quality of relationships with retail investorsRealizzato
Realizzato
Realizzato
- Preparation of the Investor Annual Review for the first time in Italian.
- Correspondence activities (mainly by e-mail) to answer the most frequent questions raised by retail investors.
- Training in the Investor Relations unit of a person dedicated to this type of investor.
29. To maintain the intensity of relationships with professional investorsRealizzato
Realizzato
Realizzato
Organisation of conference calls in the presence of top management, other telephone calls, one-to-one meetings, group meetings.

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COMMITMENT / INDICATORFIGURE 2009FIGURE 2010FIGURE 2011ACTIVITIES / RESULTS 2011
SUPPLIERS 
30. To create a single Group supplier databaseRealizzatoRealizzatoRealizzatoInitiated a process of supplementing the Group’s Register of Suppliers with internal cross-border systems to guarantee the usability of the information for all the internal functions (e.g. block on the issue of contracts with unqualified suppliers).
31. To check that suppliers belong to certification systems
Realizzato
Realizzato
Realizzato
Initiated the systematic collection of information relating to the ISO 9001 (Quality), ISO 14001 (Environment), and OHSAS 18001 (Safety) certifications. This information is always taken into consideration in the vendor list for under-threshold purchase procedures.
32. To encourage suppliers to comply with the principles inspiring A2A’s organisational modelRealizzatoRealizzato
RealizzatoIn all contracts, requests for an offer or letters of invitation to take part in public and non-public tenders, reference is made to the principles adopted by the Group and compliance is required with these principles.
33. To develop supplier listening channels (suggestions, etc.)Realizzato
Realizzato
Realizzato
- Tools for monitoring reports arriving at customer care/the helpdesk from suppliers have been introduced on all matters relating to the recording and use of electronic trading instruments and/or those for qualification.
- In conjunction with other functions meetings with suppliers have been held to highlight the potential risks/effects that their activity may have on environmental aspects.
34. To support, where possible, the development of purchasing processes having eco-sustainability features
RealizzatoRealizzatoRealizzato- Continuation of the process of circulating electronic negotiating tools to replace, where possible, the traditional paper process: over 40% of purchase procedures in 2011 were channelled through the e-procurement platform.
-  Introduction of the requirement to use digital signatures on documents required for the purpose of the Group’s Register of Suppliers.
- Testing carried out on the requirement for the use of digital signatures also for tenders, to encourage an increasing level of dematerialisation.
35. To define and promote a supplier assessment system and the corresponding supporting measure
 Non realizzato RealizzatoRealizzato- Extension to all contract managers of a post-event assessment system for supplier performance with homogeneous criteria at a Group level.
-Creation of a monitoring tool (updated daily) which enables the assessments given to suppliers to be controlled and constantly reviewed.
ENVIRONMENT
36. To develop the district heating plan in
Milan


INDICATOR:
Volume connected (Mm3)
15.0
16.9
18.7
Further development of the exiting networks, in particular the Canavese network towards the town centre, with
 the connection of the Palace of Justice.
Connection of the thermal power station serving the San Siro quarter to the Figino network.
Construction of the new district heating network plant at the M. Melloni hospital, the first Milan hospital complex attached to the network.
37. To improve the efficiency and environmental impact of the heating plant in buildings owned by the municipality and managed by A2A

INDICATOR:
Municipal plant converted from diesel to gas or connected to district heating
17 for
17,690
kW
3 for
5,200
kW
18 for
18,900
kW
The following municipal buildings were attached to the district heating network: ARPA (Bg), Freedom Palace (Bg), Calvi Elementary School (Bg), CCIAA – Contract Palace (Bg), “M. Rota” Hospital Entity (Bg), Bank of Italy (Bg),  Prefects’ Offices (Bs), Palace of Justice (MI), Macedonio Melloni Hospital (MI). In addition the following buildings were converted to natural gas: Foreigners’ Office (MI), Middle School (MI), KIndergarten (MI).
38. To increase urban waste differentiated collection activities

INDICATOR:
Differentiated collection index
37.8%
36.6%
37.4%
The results of differentiated collection depend on the type and means of collection defined in the service contracts by the Municipalities. Further information may be found in the section “Urban waste” on page 67/68.
39. To adopt new Group guidelines and procedures for environmental management

INDICATOR:
Stage of completion
80%90%95%An update of the “Managing excavated material” provision was published which incorporates the recommendations of the new consolidated environmental law (Legislative Decree no. 205/2010).
The provisions “The management of the special waste of A2A in the role of producer” prepared but not yet published.

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COMMITMENT / INDICATORFIGURE 2009FIGURE 2010FIGURE 2011ACTIVITIES / RESULTS 2011
ENVIRONMENT
40. To develop economic accounting for environmental management

INDICATOR:
Stage of completion
10%
30%
30%
Objective proposed again in the 2012-2014 plan.

41. To study a means of calculating avoided CO2 emissions on an actual basis

INDICATOR:
Stage of completion 

30%
100%
ndRealised in 2010.   
42. To extend environmental certifications as part of the programme set out for QES systems in the “Sustainability Tools” section

INDICATOR:
Stage of completion compared to planned  
80%
100%
ndActivities completed as stated in the 2010 Sustainability Report (page 28). The Ministerial procedure for Ecodeco’s EMAS registration is in progress.
43. To construct a biogas energy recovery plant at Villafalletto

INDICATOR:
Percentage construction of the plant
100%
ndndCompleted in 2009.
44. To carry out collection measures at the purification plant at Verziano and in 29 other municipalities in the province of Brescia

INDICATOR:
Number of municipalities connected
5
5
5
No new connections.
45. Partecipare allo studio sull’emissione delle polveri ultrafini e nanoparticelle da impianti di Termovalorizzazione

INDICATOR:
Stage of completion
100%
ndndRealizzato nel 2009.
46. To take part in a study on the emission of ultrafine dust and nanoparticles by  waste to energy plants

INDICATOR:
Stage of completion compared to planned
42,500
42,050
12,000 little trout +16,605 kg of adult trout
In the Valtellina the repopulation was managed directly by A2A, in the Brescia area it was carried out by the provincial administration thanks to the economic contribution made by A2A.
47. To set up nature trails at the springs of the Bergamo aqueduct system

INDICATOR:
Stage of completion compared to planned
100%
ndndCompleted in 2009.
48. To monitor the acoustic impact of the Group’s activities on a constant basis
RealizzatoRealizzatoRealizzatoMonitored in 2011: Centrali di Monfalcone (GO), Cassano d'Adda (MI), Lamarmora (BS), purifier at Verziano (BS), waste platform at Vobarno (BS).

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COMMITMENT / INDICATORFIGURE 2009FIGURE 2010FIGURE 2011ACTIVITIES / RESULTS 2011
ENVIRONMENT
49. To finalise documentation of the details of the biodiversity sensitive areas adjacent to the Group’s properties

INDICATOR:
Percentage of the areas documented
90%
90%90%The stage of completion in 2011 is the same as that of the previous year. 
50. To encourage innovation aimed at respecting the environment and sustainabilityRealizzatoRealizzatoRealizzatoInitiatives reported in the section  "Research and innovation" of the chapter "Environmental responsibility", amongst which:
- intervention on the desulphurizer at the Lamarmora power station: during the first stage, carried out in 2011, the sleeve filter was strengthened, increasing its surface area by 38% by increasing the number of sleeves and their length. These measures will enable a significant reduction to be obtained in the concentration of sulphur oxides (SO2) in the fumes and allow the best performance currently defined in an IPPC environment as the Best Available Technique to be achieved;
- the project to inertize the fly ash of the Brescia waste to energy plant; the treatment enables heavy metals to be stabilised with an inert material called Cosmos being obtained that can be used as the filler in materials such as cement, rubber and ceramics for use in various applications.
.
REFERENCE INSTITUTIONS AND COMMUNITIES
51. To develop the use of more efficient and evolved technologies in local activitiesRealizzatoRealizzatoRealizzato- Extension of the district heating network in the Municipalities of Milan, Brescia, Bergamo and Varese: A2A’s district heating development plan in Lombardy envisages reaching a total of around 100 million cubic metres of volume served by 2014;
- A2A obtains TEE recognition annually thanks to the heat produced with cogeneration and the energy recovery in certain plants in the Milan area (Famagosta , Cassano d’Adda and Sesto San Giovanni) which feed the district heating networks and cause a reduction in the consumption of gas by end users;
- completed the construction of the new system for the catalytic reduction of nitrogen oxides (DeNOxSCR) on Group 3 of the Lamarmora power station (multi-fuel unit);
- Ecodeco has introduced planning solutions and engineered systems aimed at maximising the recovery of recyclable material;
- a series of plant improvement measures are currently being carried out at the Milan Silla 2 waste to energy plant and at the Bergamo waste to energy plant which will enable the quantity of heat transferred to the district heating network to be significantly increased;
-replacement of halogen and incandescent lamps with led lighting at the Cassano d'Adda thermoelectric power station;
- use of only recycled water at the Gissi thermoelectric power station and adoption of specific planning decisions to minimise water withdrawal.
52. To increase communication channels with all institutional interlocutors at an international, community and local level and make them continuous 
RealizzatoRealizzatoRealizzatoAmong activities in 2011:
- continued the publication of "Energia in Comune", the Group’s magazine which deals with environmental and sustainable development issues and is circulated to around 2,500 recipients consisting of administrators, public managers and technicians of local authorities and associations;
- in 2011 top management of A2A took part in hearings of the Senate industry committee as part of the fact-finding investigation on the Legislative Decree on renewable sources and regarding the draft Directive of the European Parliament and the Council on energy efficiency;
- specific assistance provided to the government, in conjunction with all the other operators concerned, on the subject of “means and criteria of tenders for hydroelectric concessions”;
A2A has continuous contact with the representative (Electricity and Gas Authority) and antitrust (The Italian Antitrust Authority) authorities.

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COMMITMENT / INDICATORFIGURE 2009FIGURE 2010FIGURE 2011ACTIVITIES / RESULTS 2011
REFERENCE INSTITUTIONS AND COMMUNITIES

53. To encourage the activity of the Foundations of the A2A Group



INDICATOR:
Loans granted (€ million) 
34
4
Among the main initiatives carried out by Foundations of the Group were the following:
- Smart Tree, the Christmas tree set up in Piazza Duomo by the Municipality of Milan in conjunction with A2A, Amsa, the AEM Foundation and Expo2015;
- Green Race, the leading ecological race event in Italy hosted by the Lombardy capital;
- First meeting of former Amsa employees, held at the new “Twentieth Century Museum” in Milan;
- Publication of the ASM Foundation on sustainable development, to which has been linked a competition to stimulate people to go into further detail on the issues treated;
- Area of youth growth, by means of two training paths addressed to young university students “Twenty for Twenty” and “The energy trades”.

54. To increase collaboration with the agencies of the Optimal Territorial Ambit (ATO) of the integrated water cycleRealizzatoRealizzatoRealizzatoA2A Ciclo Idrico has specific contact with the ATO to resolve critical matters and exchange information. In addition regular coordination meetings are held.

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