...Our report did not address a particular legal entity and did not differentiate between the domestic law frameworks of Italy and Russia. We addressed Buzzi Unicem as an international group and its Russian business, which it does through its Russian subsidiary SLK Cement.

We recognise that the parent company – Buzzi Unicem SpA – operates under a different legal framework than SLK Cement and may therefore enjoy limited liability for SLK Cement’s conduct. However, we are surprised that Buzzi Unicem’s response is based on formal arguments...

According to Buzzi’s 2022 full year results presentation, 2022 half-year financial report and trading update September 2022, Buzzi continued to consolidate the financial results of its Russian subsidiary in its group accounts. International Financial Reporting Standards (IFRS 10), in compliance with which Buzzi’s consolidated financial statements are prepared, establishes control as the basis for consolidation. According to IFRS 10, a company controls its subsidiary if it has the power, exposure and the ability to affect the subsidiary’s returns.

Given the above and based on our understanding, consolidating SLK Cement’s results into group account suggests that Buzzi still exercises control of its Russian subsidiary. If this understanding is not correct we kindly ask Buzzi to clarify the matter.

It came to our attention that the photos, published by the SLK Cement on its vk.com social media platform regarding the supply of its employees mobilized to the Russian army, were removed after we released our report. This casts our doubts about Buzzi’s claim of no involvement in operations carried out by SLK Cement...

The point of our report is not to diminish Buzzi’s humanitarian efforts in Ukraine, but to draw management’s attention to the necessity of standing for international law, moral and ethical business conduct, human rights, UN principles and distancing itself from the terrorist regime, which commits war crimes in a peaceful country...