UNIPORT, the National Union of Port Enterprises, presented a own position paper addressed to government, world of politics, institutions, media and stakeholders focused on labour issues, regulations, terminal concessions, simplifications and sustainable development of infrastructures.

The association explained that the document, which we publish by below, indicates objectives and system proposals with a vision that goes beyond the short term and has already been explained, together with proposals for immediate interventions, the President of the Transport Committee of the Chamber, Salvatore Deidda, to the Undersecretary at the Ministry of the Environment and Energy Security, Vannia Gava, and the Undersecretary at the Ministry of Infrastructure and Transport, Tullio Ferrante.

'Objective of the document and of the institutional meetings that we have started in these days - specified the president by UNIPORT, Federico Barbera - is to raise awareness of the new Government and the new Parliament on the opportunities that our Country has today before it and on the strategic nature of port hubs for the future development of the country. As long as you manage to effectively exploit the extraordinary investments made in this historical phase and to carry out the necessary reforms for a simplification and modernisation of the regulatory framework. There are no port companies without ports, but there are no ports without companies. Of We are convinced."

Among the issues examined, in the field of work the UNIPORT document highlights the need for adequate training and updating of workers and supports the regulatory recognition of "wearing" characteristics to specific port activities, while in terms of concessions terminalistiche the association hopes to be defined in time Short, homogeneous and objective criteria aimed at the assignment and renewal of concessions, the determination of their duration, the modalities of transfer of the plants to the new concessionaire, the identification of the limits of the concession fees, the identification of ways to ensure competition, the exercise of supervisory and control powers.

FISE UNIPORT National Union of Port Companies POSITION PAPER November 2022 PREMISE Ports are infrastructural realities and complex organisational frameworks, essential for economic development and Employment of the Italian system: connection with the markets world, internal links, development of the most important areas disadvantaged, the contribution made to the realization of a model of sustainable development from an environmental, economic and economic point of view social. Through Italian ports transit (embarkation and disembarkation, data 2021) more than 480 million tonnes of goods; 11.3 million TEUs; 43.3 million passengers including 13.5 million cruise passengers; 6,3 millions of Ro-Ro load units. The work units employed (number of direct employees and induced) in the system of national ports amount to over 80,000. Terminal operators and those authorized to carry out port operations and services complementary and ancillary to those Operations - under a regulated market regime - without prejudice to the complexity of the ports mentioned above and the complexity of the ports mentioned above and the multiplicity of public and private entities that compete in different way and extent to carry out the "port phase", are characterized, regardless of their specialties and company size, for the role of hinge between the different mode of transport occupying a central position and qualifying in the individual seaports in which they operate, nodes of the logistics network. There are no port companies without ports but there are no ports without businesses. THE ASSOCIATION UNIPORT- National Union of Port Companies - is the Association that aggregates and represents companies that carry out in the Italian ports, under the authorization regime pursuant to art. 16 of the Law n. 84 of 1994 and subsequent amendments and amendments or concession pursuant to art. 18 of the same law, port operations (loading, unloading, storage and handling in general of goods and any other material), activities ancillary to and complementary to those operations, other port services, traffic terminal management cruisers and passengers. UNIPORT member companies operate in all segments and types of port traffic. Altogether they employ over 4000 workers with a turnover of over 1 billion euros; They handle about 60% of the containers of our ports and represent the main container terminals, bulk and multipurpose cruises. UNIPORT, firm remaining autonomous organizational powers and operational, adheres to FISE - Federation of Service Companies. Since 2022 UNIPORT has also joined Conftrasporto, confederation of Confcommercio, thus entering fully within a network of relationships and representation of Associations of operators of all modes of transport (from road to rail to maritime mode) and logistics, thus making it possible to make more strong and effective voice and representative capacity UNIPORT specification within that of the sector carried out by Conftrasporto. The statutory objective and raison d'être of UNIPORT is support and promote the development of associated enterprises by encouraging comparison between them and aggregation (where possible and interest); represent, assist - and if required - support the associated companies in relations with the OO.SS. of the sector being UNIPORT among the employers' associations stipulating the CCNL of port workers; contribute to creating every useful synergy between associates and operators in general and any other association of operators/companies. Always in the interest of the members and the best development of ports and logistics system, UNIPORT also intends to hold a continuous and constructive dialogue with Institutions, Authorities and national and local public offices. First of all, this availability is addressed to the sector administration (Ministry of Infrastructure and Transport - MIT), to its direct peripheral articulations - the Captaincies of Port - and indirect - the Port System Authorities - AdSP; to the new Minister of the Sea and to a no lesser extent also to the multiple central and territorial offices that have roles and ports competences. It is also essential to start a comparison with the Transport Regulation Authority whose role is strongly increasing in view of the debate and the forecasts developments in the regulation of concessions. UNIPORT does not deny or underestimate the role of ART, Indeed, it acknowledges that some regulatory interventions can contribute to outline a more certain and favourable framework also for port companies. It also notes that the amendments made over time to the founding standard of ART and the most Recent jurisprudential rulings tend to reduce the margins of possible litigation and, above all, the possibility of rulings favourable to operators. Nevertheless, in view of the fact that the measures regulation adopted by ART, particularly in terms of ports, have had and have as first recipients the AdSP, and consequently but gradually terminalists and port companies, UNIPORT considers it necessary for the legislator to take note of this consequently relieving operators from the payment of the costs of operation of ART, or alternatively, it resizes significantly the share borne by the operators. PROPOSALS AND PROGRAM OF THE ASSOCIATION In a national system composed of many ports having functional characteristics, traffic levels, composition (mix) highly differentiated product and types of loads, UNIPORT considers this multifunctionality and differentiation a added value as it can offer support essential to the development of the national economic system and sector itself capable of generating wealth and employment in virtue of a complex of enterprises - small, medium and large - operating in different ports within a regulatory framework - essentially Law 84 of 1994, as subsequently modified, and the Navigation Code - which is homogeneous but declinable and effectively declined according to operating practices and diversified organizational methods. ---------- UNIPORT considers it essential to ensure that diversity is guaranteed. based on a balance of own-account concessionaire undertakings or third parties, of undertakings operating under the authorisation system on "public" docks (i.e. not in concession) with the addition (but not necessarily in all ports) of a single temporary work provider selected according to criteria Public. ---------- 1. The work UNIPORT has among its primary statutory tasks the protection of interests of member companies with regard to the issues of trade union and labour law nature. On this front it is firmly contracting party of the CCNL of port workers and gives the collective agreement the function of an instrument intended at the same time ensuring fair conditions of competitiveness between companies, quality of service offered, protection of workers, flexibility inherent in the trend not linear port activities. Precisely because of the value that recognizes the CCNL in its wholeness, with similar determination, UNIPORT affirms and requires to the counterparty the enforceability of all forecasts contractual and, to those responsible for verifying the correct application, which takes charge of it. In line with this vision UNIPORT is open and available for comparison with other employers' associations, with workers' organizations and with all public bodies and offices responsible and competent in the field of training, safety and protection of workers in every office and assembly, starting from the Institution Bilaterale Nazionale Porti - EBN - of which it is a constituent part and to whose activities it makes a constructive contribution. The same applies to the proposes to actively contribute to the establishment of the Finalized Fund support and incentives for early retirement of employees of concessionary companies pursuant to art. 18, authorized ex art. 16 of Law 84/94 and concessionaires of maritime stations passengers, with the aim of creating an instrument that, at the mercy of the contribution of professionals with recognized abilities techniques, allow to make the most of the resources put in place field for that purpose to a greater extent by companies thereby achieving an objective of interest to workers but also of companies. Without prejudice to what has been said here regarding the value of the Fund, In view of the characteristics of port work which with reference to some professional figures preserves - although in the Evolutionary context - characteristics of non-burdensomeness negligible, UNIPORT strongly supports any targeted action to recognize in a normative way the characteristics of wear and tear to specific and clearly identified activities, all the more so Taking into account that the ever-increasing incidence of workers with Partial incapacities in several realities affect significant way on the organization of work of enterprises, on the capacity of the port labour provider temporary and consequently still on the organization of undertakings, terminal equipment and costs falling within head of the community in general for the additional number of IMA days that follow. Still on the subject of work, UNIPORT does not question the Legally envisaged model based on combination/coexistence of concessionaire, authorized companies and a single supplier of port work. However, it considers it necessary that, on the one hand, the conditions of improper improper are not created competition of the person authorized to supply - exclusive - of temporary port work pursuant to art. 17 compared to companies authorized ex art 16 and in this regard asks the AdSP in the ports administered by these and to the Maritime Authority in the others airports, which exercise effective control in this regard. On the other hand, it also considers it essential that the subject providing temporary port work, where it is Having identified the need to set it up, in the form of an undertaking, or of the agency: has an organic consistency consistent with the start-ups that are actually requested by companies, and terminal operators, considering the cost of the Missed Compensation Start-up - IMA - on the public budget as well as the difficult social climate that can determine a large number of days not worked; is constantly able to provide figures having professional profiles and qualifications appropriate to the standards the segment of activity in which they are started and the companies that require them. Terminal operators in particular, even more so the more structured ones less and less need "traditional" or "generic" ports. For these training and professional updating needs UNIPORT points out to all concerned that it is essential a careful and punctual application of forecasts already present in the law. In particular to the AdSP (and to the Authorities UNIPORT asks that determine an adequate quantitative and qualitative consistency the staff of the temporary port work provider; vigilino with regularity and adequate periodicity the activity training and updating of its staff; Adoptino and Curino the updating of the intervention plan for port work provided for in art. 8, c. 3-bis of Law 84; monitor the conditions of equilibrium of the subject referred to in Article 17, Law 84/1994 and, if it is necessary to implement a restructuring, verify its precise implementation. For this purpose UNIPORT believes that it cannot be ignored, indeed must be maximally valued, the contribution that can be given by a comparison that is not merely formal with the companies that require temporary port labor and other stakeholders Public. Among the various topics that can be traced back to the great theme Work, of undoubted importance and pressing topicality there is that of self-production. The norm that was last (now more than two years ago) introduced in Law 84 of 1994 - paragraph 4-bis of art. 16 - In the light of the litigation produced, it has shown the its application limits, therefore UNIPORT wishes to rectify it which, however, safeguards and hopefully also allows a further development of traffic always guaranteeing interests and activity levels of all actors Employment levels and safety are involved. ---------- 2. Regulation and costs In line with the founding purpose of the association to support and promote the development of associated enterprises, operating in a strongly and rapidly evolving market, of size supranational, UNIPORT considers essential to create and strengthen more and more conditions of clarity, certainty, and simplification of rules and a cost-cutting system consistent with market rules; all elements that appear indispensable for ensure competitiveness and development of the entire system national logistics - focused on ports - as well as enterprises. 2.1 Procedures and costs of terminal concessions One of the main aspects to be re-evaluated with a view to making clearer, certain, simpler and cheaper system and - undeniably - that of concessions, a topic among others subject to recent regulatory interventions that foreshadow innovations of considerable scope in a short time. In this regard, it is recalled, first of all, what is established in the new Article 18 of Law 84 of 1994 as amended by art. 5 of the Law no. 188 of 5 August 2022, or to define in a short time homogeneous and objective criteria aimed at the assignment and renewal of concessions, the determination of their duration, the arrangements for transferring the installations to the new concessionaire, identification of fee limits concessionaires, to identify the modalities aimed at ensuring competition, the exercise of supervisory powers and control. UNIPORT welcomes this understanding translated into provision of law, since it considers that, if adequately declined the criteria indicated by the legislator in the new art. 18 of law 84, will allow to equip the portualità of Suitable tool to overcome visions and consequent regulations several adopted over the years by the Port Authorities, before, and from the AdSP then, conditions sometimes even different between ports administered by the same AdSP because of ancient legacies and the Failure to adopt the regulation of terminal concessions (which was originally envisaged). Even with this vision, intended to give guarantees and certainties to companies - therefore to make it more "expendable" and competitive system of Italian ports in a market not circumscribable within national borders, indeed for its nature market of global dimensions - UNIPORT considers essential adequately flexible regulation that does not upset consolidated organizational and operational models and Working. Prior to this, however, there is the mandatory need to safeguard - under the conditions laid down - the concessions and authorizations currently in place until their natural expiration. New rules, although apparently more solid in line theoretical or principled, can not be a reason to induce new and not budgeted burdens/obligations/constraints for companies or tool to force revisions of activity programs, levels of expected results, other. With regard to concessions, however, it is not possible to hide the perplexity deriving from the overlapping/simultaneity of the initiation of the ART's "call for input" on the document "Determination of methodologies and regulatory criteria for ensuring fair and non-discriminatory access to infrastructure dockers". UNIPORT, as mentioned, does not disavow or underestimate the role of ART. However, the risk for the whole and complex world of ports - but first of all for the companies - that a scenario is realized in which the issuance of part of the MIT of the decree provided for by the new art. 18, c. 2 of the law of reference for the port follow further (and we cannot exclude different addresses and indications ART. In line with the need for clarity and certainty for associated companies, UNIPORT asks that MIT and ART define the respective roles on a matter that is delicate because conditioning the life of companies that support the economy of the entire country. Specific aspect of the multifaceted concessions argument is that of determining the fees for such concessions. Reiterated the imperative need to safeguard - conditions laid down and until their expiry - concessions and authorizations currently in place; firm while also remaining the appropriateness of appropriately flexible regulation, Nor do unitary measures of the canons sometimes appear logical more that strongly differentiate between one port and another. It is not intended to claim the application of a identical uniform fee at national level. It is, however, Logically weak difference significant among unit charges of ports belonging to a system administered by the same AdSP, or to a system that for its nature serves or is potentially intended to serve the same territory/catchment area, or between terminals of a single system having the same function. Considering that the legal system already provides for a fee of unitary concession below which no Authority can go down, but it seems logical that, where intends to deviate from that minimum by adopting (as done from most of the AdSP) higher unit fees, that decision is taken - after a comparison (not only formal but effective and deepened) between the single AdSP and the terminalists of the single port system - with acts adequately motivated and based on objective principles: characteristics techniques of the good granted; any charges charged to the concessionaire; interventions to enhance the asset granted that the concessionaire undertakes to realize; Miscellaneous government revenue from the fee and employment (direct and indirect) generated. To this end, we are calling on the competent ministers to issue guidelines. of address to the AdSP for the ports administered by them and to the Maritime Authority for other ports of call and verify respect. 2.2 Other efficiency improvements. As regards regulation (and/or costs) clarity, certainty, simplification and cost-effectiveness, we believe they should be principles and methods applied also for other aspects and activities specific to the port phase. UNIPORT in fact considers necessary: overcoming and resolving duplication not only apparent tasks that, depending on the subjects can concern MIT and ART; AdSP and Maritime Authority; AdSP and ASL; other; the establishment of certain response times of the Public administrations, compatible with requests from whom - how to terminal companies - operates in a market context in continuous and rapid evolution. Lengthening adoption times of acts and choices of regulators can lead to losses of market; slowdowns in investment; review of the control system not in the sense of deregulation but of the uniqueness of moments checks and their speeding up, also adjusting, where necessary, the consistency of the staff of public offices in charge of those controls (Customs, Border Police, offices sanitaryware, other); effective and effective digitalisation of procedures in the sense of simplification. In summary, not so much the revival of new systems and unique procedures; a sort of "big brother" of ports or logistics, which is added or for some information duplicates others systems (eg that of the Customs Agency now for more procedures already tried and tested) moreover obliging companies and operators in general to duplication of obligations (eg. "upload" the same information to multiple systems), even (and it would be even worse) imposing unjustified additional management costs or to equip themselves with systems / platforms Additional. Rather, it is asked to move towards creation. a network to enable dialogue and integration between Public systems with diversified purposes and business systems contain sensitive, if not sensitive, information that they often constitute a corporate asset, all favoring an "once" approach; the identification of homogeneous principles (which do not ignore the objective differences between one port and another) by the different AdSP for the regulation and determination of fees, rights and similar other than concession fees. Even here we do not think yes should ignore the fact that depending on where produced/offered the The same service may have different costs. But even in this case it is not always clear on the basis of which principles themselves activities see adjustment patterns (and consequently tariffs or taxable persons) differing from one port to another, and this It appears even more illogical in the case of services with Typical characteristics of service of general interest of the port (if not even of service of general interest tout court). ---------- 3. Port and network infrastructure UNIPORT looks with great interest at the many projects that it is expected to be implemented quickly (by 2025-2026) using the resources of the PNRR and the PNC. Only hopes for the Compliance with that timing and further interventions of simplification and speeding up if they emerge system criticalities that presage delays or Slowdowns. Particular attention to the Simplification as a function of speeding up efficiency of the port system we believe should be reserved for dredging interventions (maintenance and not only maintenance). This is an aspect that has already been achieved in recent years. subject to regulatory interventions; We do not give any judgment on those, we just note that to date some important Excavation projects are suffering significant delays and that, even Regardless of specific episodes you can not run the risk that for delays even of simple dredging interventions maintenance, ports (and companies) lose traffic flows and job opportunities. In particular if this happens to advantage of airports and companies in other countries. UNIPORT, considering that terminal companies and Port operators generally operate in a context that is par excellence area in which the change of mode is carried out transport and that a modern port is a node of a network logistics, strongly supports an efficient and rapid development connections between ports, major roads and - especially - railways, connections with centers interportual, well aware that these are among the conditions necessary for the expansion of the reference basin of each port and their operators. In line with the importance that is recognized to the connection of ports with networks (and with the railway network above all) We consider it of the utmost importance according to the desired Evolution of the Italian logistics system to a real platform - from a side (south) projected to the center of the Mediterranean, and on the other (north) "anchored" and projected towards industrial areas and consumption also beyond the Alps - highlight the need for priorities to be reviewed as soon as possible of the interventions of the rail network manager in operation of the need, dual and not graduable from the point of view time, of: filling the deficit (in some cases even the total absence of rail connections to the ports of the Noon; adapting the connections of the nearest ports to the areas of Central and Eastern Europe, thus offering all components of the logistics system similar levels of connection and the ability to best deploy all the their potential. All this also in line with the objective of leading to completion of the process of creating SEZs and FTAs according to the vision desired by the legislator of areas not necessarily within ports but in any case centered on a port, then adequately connected to it. We also consider it essential that, in the context of a design, planning of relevance of the AdSP to be realized in synergistic collaboration with local administrations, yes programs and promptly establish a network of local connections suitable for overcome interference and overlap - mutually penalizing - between traffic of goods / people in access / exit to/from the port with the mobility of the surrounding urban areas harbours. In addition to the infrastructural aspect, UNIPORT annexes large importance, as far as rail connections are concerned, to the aspect of service management. It therefore hopes that, where necessary, managers of the maneuver according to objective criteria favoring the optimal mix value for money. ---------- 4. The environment UNIPORT welcomes measures to protect the overall environment (water matrices, air soil) Bearing in mind that this makes it possible and facilitates the positive perception and added value that the realities port workers provide to the territory in which they are inserted, so helping to overcome a so-called "NIMBY" approach in some territories. UNIPORT, however, looks at environmental protection not in a logic merely binding-conservative but in the perspective, much more current / evolved, sustainability, or of a progressive path aimed at achieving models operational, organizational, structural and +infrastructural able to increase in a reasonable period of time the best combination of economic development, protection of natural resources and of people In this regard, the public decision-maker is therefore asked to adopt choices consistent with this vision and with the irrepressible need for business balance by favouring policies incentives that also take into account, once again, the global scale of maritime trade. ---------- 5. Revision of the port regulations UNIPORT notes that the debate has begun concerning the change in the legal nature and tasks of the AdSP. Given the importance and extreme delicacy of the subject - again Object of deepening within the association - we believe essential that any choice the Government and Parliament will consider adopting, both after an in-depth comparison with the various stakeholders - first and foremost operators and port terminal operators - whose need is above all that of to look at a model of subject with the ability to act and give answers in the times of the market and of a particularly market and rapidly evolving global dimensions, which is that of port maritime logistics, also providing for an order "special" that allows you to actually overcome Logics and modes of action with an outdated imprint Bureaucratic. However, UNIPORT hopes that this comparison does not slow down (as unfortunately occurred on similar previous occasions) the current activities of the AdSP and in particular the realization of the Infrastructural upgrading of ports and others on the logistics network, starting with those financed under the PNRR-PNC. Secondly, although we do not evaluate with disfavor - indeed - a Evolution of management bodies towards a company model public, considers that this possible new model should not constitute the premise for transforming the authoritative subject and regulator in a competitor (in any case superordinate position and therefore of advantage) compared to (regulated) companies operating in market regime. EMERGENCIES The current scenarios, which have seen after a two-year period marked from the global pandemic emergency - during which However, ports and businesses have ensured functionality of the logistics chain - the Russian-Ukrainian crisis, or a an event which, although geographically more geographically important, has had equally global effects and the amendment of the expectations and main economic indicators of the whole Europe (and beyond), as well as blocking entire logistics chains for individual national ports and production districts that gravitate on those ports, still remaining the system objectives of which it is Having said that, they make it essential to address the effects induced by these emergencies. First of all, given the fact that port operations in Genre (and certain types of loads in particular) has markedly energy-consuming characteristics, considered essential specific measures, in addition to general measures so far adopted, intended to relieve terminals and operators from unpredictable and disproportionate energy over-costs that well It is hardly conceivable to overturn on the goods or on the loaders. It is no less urgent to foresee, for the time being, at least with regard to the three-year period 2023-2025, if not a reduction at least one sterilization the annual indexation of state concession fees. It seems completely impossible even to imagine, after a increase for the year 2022 of more than 8%, increases that given The expected inflation rate could be similar to that. Nor can it be postponed is the opening of a debate in Consequence of the latest provisions on the taxation of AdSP introduced with art. 4-bis of Law 108 of 2022 (conversion of Decree-Law 68/2022). About UNIPORT hopes that the new regulatory provisions will be such as to allow the overcoming and definitive closure of a "conflict" with the EU. But above all UNIPORT considers it essential that a measure intended to adapt the tax treatment of the AdSP to the principles and practices adopted in other EU Member States is not a prerequisite for a increase in the cost of our portualità. Considering that the aforementioned art. 4-bis contains the provision of a decree for the determination of minimum and maximum limits of anchorage and port fees and that for the release of the authorizations for the exercise of the activities of undertaking and the destination that the Authorities will have to give those items of entry, UNIPORT believes It is essential that: any innovation on such delicate aspects in how much they contribute to determining the "cost of the port", do not change the conditions of competitiveness in a pejorative way of terminal operators and authorized companies already exposed to the competition from non-Italian airports and operators and, in addition, traffic segments, including non-European operators with cost structure not even comparable with that of Italy; the items on which to finalize those revenues are determined in a way that clear and appropriately detailed, to avoid that, because of interpretations or applications differing from one port to another, yes create situations of disparity between operators, ultimately altering the conditions of competitiveness; there is a effective supervision of the homogeneous application of the rule.