7.1 Notifications Procedure, anonymous or otherwise, received by Snam and ist Controlled Companies
The Company has approved a procedure for when Snam and its Controlled Companies receive information from known and unknown sources (the “Notification Procedure”).
The Notification Procedure establishes the criteria and methods for setting up information channels that are suited to receiving, analysing and processing notifications relating to problems with the internal control system, company reporting, corporate administrative liability, fraud, corruption or other matters (violations of the Code of Ethics, mobbing, theft, security breaches, etc.), sent by the employees (including top managers), members of the corporate bodies or third parties, also in confidentially or anonymously form.
The Notification Procedure fulfils the requirements set forth in the Organisation, Management and Control Model pursuant to Legislative Decree No. 231 of 2001, Snam’s Anti-Corruption Procedure and the Corporate Reporting Control System Procedure.
It applies to Snam and its Controlled Companies as part of Snam’s own management and coordination activities. In compliance with the principles of proper business management of subsidiaries, Snam also manages the notifications and processes the related data pursuant to privacy regulations in the interest of its Controlled Companies, in accordance with their decision-making autonomy and in line with current legislation and internal rules on privacy, also ensuring compliance with the confidentiality requirements of investigative activity.
In order to facilitate the notification process, Snam has set up different notifications channels. These communication channels are used by Snam and its Controlled Companies. They are prepared and maintained by the Internal Audit department.
The Internal Audit department prepares a quarterly report on the notifications received, which is sent to:
- the Chairman;
- the CEO;
- Board of Statutory Auditors;
- Control and Risk Committee;
- External Auditors;
- Anti-Corruption department;
- Supervisory Body;
- Director of Planning, Administration, Finance and Control.
For notifications regarding the Controlled Companies, the relevant part of the report is sent to the Chief Executive Officers of the Controlled Companies in question, as well as to their audit and supervisory bodies.