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7.2 Anti-Corruption Procedure

On 4 October 2013 - following the proclamation of Law No. 190 of 6 November 2012 (“Anti-Corruption Law” Provisions for the Prevention and Repression of Corruption and Illegality in Public Office), which introduced, among other things, the crime of private corruption (Article 2635 of the Italian Civil Code), and after approval from the Board of Directors - the new Anti-Corruption Procedure (replacing the previously adopted Anti-Corruption Management System Guidelines, or MSGs) was issued.

In accordance with Snam’s Code of Ethics, the Anti-Corruption Procedure prohibits the corruption in any form of any Italian or foreign public or private entities and is an integral part of a broader business ethics control system adopted by Snam that aims to ensure the Company’s compliance with national and international anti-corruption laws, including the UK’s Bribery Act, and with the best international anti-corruption standards, helping to protect Snam’s reputation.

The Anti-Corruption Procedure has also been adopted in accordance with Principle 10 of the Global Compact, a United Nations initiative launched in 2000 to promote 10 universal principles relating to human rights, labour, the environment and the fight against corruption. Snam’s adherence to the Global Compact demonstrates and strengthens its status as a socially responsible business committed to supporting and actively participating in the works of Italy’s Global Compact Network.

Adoption and implementation of the Anti-Corruption Procedure is mandatory for Snam and its Controlled Companies, which have transposed it by resolution of the Board of Directors.

The Procedure is available on the Company’s website (http://www.snam.it/en/Governance/Procedures/Anti-corruption_procedures/).

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