Snam is required to comply with rules and regulations at EU, national, regional and local level.
The expenses associated with the actions required to fulfil its obligations constitute a significant cost item now and for the years ahead.
In addition to minimising the risks from its activities, compliance with rules and regulations is required in order to obtain authorisations and/or permits relating to health, safety and the environment. Violation of current regulations may result in criminal and/or civil sanctions and, in specific cases where safety and environmental rules are violated, companies may be liable on the basis of a European model of corporate social responsibility adopted in Italy by Legislative Decree 231/01. The possibility of Snam incurring significant costs or liability cannot be entirely ruled out.
Current regulations highlight the value of organisational models aimed at preventing offences in the event of violation of environmental and workplace health and safety laws, specifying corporate liability.
Snam uses organisational instruments and internal regulations to establish the responsibilities and procedures to be adopted with the Group when designing, constructing, operating and disposing of all corporate assets, thereby ensuring compliance with laws and internal regulations on health, safety and the environment.
Snam and the companies it controls have implemented environmental and workplace health and safety management systems based on the principles of its own Health, Safety, Environment and Quality Policy, which has been consolidated in the Company for several years.
The documentation and application of the Snam Management Systems are certified according to international regulations.
2013 is the first year in which all the Group companies are operating with OHSAS 18001 certification, which certifies corporate risk control and reduction, accident prevention and compliance with legislation in force.
In 2013, Snam Rete Gas extended the certification of its Environmental Management System to all companies, in accordance with the UN EN ISO 14001 standard. The “Gas pipeline management” and “Stations” processes had been certified previously.
By adopting management systems and procedures that take into account the specific characteristics of its business, and by continually improving and modernising its facilities, Snam ensures that it can identify, assess and mitigate risks as part of a cycle of continual improvement.
Snam pays the utmost attention to all its operational processes: from designing and constructing plants to operating and maintaining them. For the purposes of business management and operational control, the Company uses specific techniques that are continually being updated and are developed in compliance with international best practices.
Snam develops and maintains technical regulations and management systems for the environment and workplace health and safety based on an annual cycle of planning, implementation, control, reviewing results and setting new objectives.
Management system control is conducted by monitoring health, safety and environmental indicators, periodic reporting and inspections of operating sites and the registered office, which involve:
- a technical audit, designed to ensure that the management systems are applied correctly in compliance with the Code of Ethics and Organisational Model 231;
- management system checks on certification, maintenance and renovation (conducted at least annually by an external certifying body);
- health, safety and environment checks on outsourced activities.
The findings are examined together with the results of the operating checks, providing basic information for planning future activities and setting new objectives, in accordance with Snam principles.
Snam has adopted organisational and regulatory measures for the prevention (availability, goods and services contracts, training, etc.) and management of any operational crises which may impact assets, people and the environment, identifying the actions required to limit damage.
Snam participates in international working groups which conduct benchmarking activities, draw up guidelines and carry out studies aimed at identifying ways in which gas transportation processes can be improved.
In addition to the risk response, monitoring and management system and the HSE measures adopted across the Group, Snam has taken out insurance to limit the possible negative effects on its assets of damage caused to third parties and to industrial property, whether onshore or offshore (Messina strait, Offshore LNG Toscana (OLT) connection at Livorno), that could occur during operations and/or investment works. The insured amount varies according to the type of event and is determined by current market best practice in risk assessment.
Risks connected with failing to meet infrastructure development objectives
Snam’s effective ability to develop its infrastructure is subject to many unforeseeable events linked to operating, economic, regulatory, authorisation and competition factors which are outside of its control. Snam is therefore unable to guarantee that the projects to upgrade and extend its network will be started, be completed or lead to the expected benefits in terms of tariffs. Additionally, the development projects may require greater investments or longer timeframes than those originally planned, affecting Snam’s financial position and results.
Risks deriving from malfunctioning of plants
Managing regulated gas activities involves a number of risks of malfunctioning and unforeseeable service disruptions due to factors which are outside of Snam’s control, such as accidents, breakdowns or malfunctioning of equipment or control systems; the underperformance of plants; and extraordinary events such as explosions, fires, earthquakes, landslides or other similar events beyond Snam’s control. These events could also cause significant damage to people, property or the environment.
Any service interruptions and subsequent compensation obligations could lead to a decrease in revenue and/or an increase in costs. Although Snam has taken out specific insurance policies to cover some of these risks, the related insurance cover could be insufficient to meet all the losses incurred, compensation obligations or cost increases.
Risks deriving from the need to manage a significant flow of information to operate regulated services
The regulatory framework in which Snam operates involves continually collecting and processing a significant flow of information from its service clients. The information received by Snam includes, inter alia, capacity bookings, details of where gas is coming from and going to each day, physical and commercial balancing mechanisms and forecasts on demand and transportation capacity usage. This flow of information, partly managed by extensive use of IT systems, is broad and complex. Therefore, Snam cannot guarantee that its management will not lead to operating and planning difficulties which could affect its business.
Risks deriving from the seasonal nature of the business
Based on the current regulatory framework, Snam’s overall business is not affected by seasonal or cyclical factors which could have a significant impact on its annual or interim financial position and results.