7. Snam’s Regulatory System
In accordance with the evolving process aimed at continually improving the effectiveness and efficiency of its internal control and risk management system, Snam has adopted its own Regulatory System comprising the following levels: (i) Corporate System Framework (Level 1), (ii) Procedures (Level 2) and (iii) Operating Instructions (Level 3).
Certified management system documents (in accordance with ISO standards) on Health, Safety, Environment and Quality (policies, manuals, procedures and operating instructions) are also an integral part of the Regulatory System. Lastly, regulatory circulars are required solely to govern specific issues (sometimes with temporary validity).
These regulatory instruments are part of the efforts made by Snam to run their management and coordination activities efficiently over its Controlled Companies, and they are periodically sent to the Controlled Companies’ boards of directors. For the purposes of sufficiently considering the legal autonomy and principles of good corporate and business management that govern their activities, the Controlled Companies are required to assess the need to supplement the content of the regulation issued by Snam, issuing (within a period of time specified by the Snam regulation) a dedicated supplementary document of their own: (i) relating to their own specifications; (ii) referring exclusively to organisational aspects; and (iii) without prejudice to principles, rules and guidelines defined by the Snam regulation. If no supplementary document is issued within the allocated timeframe, the Snam regulation is applied.
Controlled Companies are required to formally adopt measures on specific subjects (e.g. relating to health, safety and the environment and/or pertaining to the boards of directors of Snam and its Controlled Companies) where they hold direct and specific responsibility, in accordance with applicable laws.