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 (regulatory level 1), (ii) procedures (regulatory level 2) and (iii) operating instructions (regulatory 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 to govern specific issues (sometimes with temporary validity).
These regulatory instruments are part of the efforts made by Snam and its Subsidiaries to run their management and coordination activities efficiently, and they are periodically sent to the Subsidiaries’ Boards of Directors. For the purposes of sufficiently considering the legal autonomy and principles of proper corporate and business management that govern their activities, the Subsidiaries are required to assess the need to supplement the content of the regulatory instruments issued by Snam, issuing (within a period of time specified by Snam’s regulations) 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 Snam’s regulation. If no supplementary document is issued within the allocated timeframe, Snam’s regulations are applied.
Subsidiaries 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 Subsidiaries) where they hold direct and specific responsibility, in accordance with applicable laws.