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3. Code of Ethics

On 30 July 20137, the Board of Directors approved the new version of the Code of Ethics8 which defines a shared system of values and expresses the business ethics culture of Snam, as well as inspiring strategic thinking and guidance of business activities.

The Code of Ethics (i) sets out the principles inspiring and establishing Snam’s activities, such as respect for the law, fair competition, honesty, integrity, propriety and good faith, in respect of the lawful interests of customers, employees, shareholders, commercial and financial partners and the communities where the Company has a business presence; (ii) sets out the general principles of sustainability and corporate responsibility; and (iii) concerns, inter alia, the workplace, relations with stakeholders and suppliers, and the protection of personal data.

The Code of Ethics reflects, among other things, a compulsory general principle of the Organisation, Management and Control Model adopted by Snam pursuant to the Italian regulations on the “administrative liability of legal entities deriving from criminal offences” contained in Legislative Decree No. 231 of 8 June 2001. The Board of Directors assigned the Supervisory Body, which was set up pursuant to Legislative Decree No. 231 of 2001, the role of Code of Ethics Supervisor, meaning the following can be submitted to it: (i) requests for clarification and interpretation of the principles and content of the Code; (ii) suggestions on the application of the Code; and (iii) reports of violations of the Code, whether these have been discovered directly or indirectly.

The Code of Ethics is available on the Company’s website (http://www.snam.it/en/Governance/Code_of_ethics/index.html).

7 In June 2008, the Board of Directors adopted the Code of Ethics, which replaced the code of conduct approved in 2001.

8 The new version of the Code of Ethics is a continuation of the previous version, but also includes some significant changes, such as: (i) the revision and supplementation of the ethical principles and rules of conduct in relation to corruption, and (ii) the emphasis placed on Snam’s culture and the peculiarities of the regulated sector in which it operates, particularly with regard to relations with regulatory authorities and European regulations on natural gas (previously governed by a dedicated addendum to the Code of Ethics).

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