6.5 Departments with specific control functions

With a view to continually improving the efficiency and effectiveness of the internal control and risk management system of Snam and its Subsidiaries, and to better integrating this system, in addition to the departments mentioned previously, the following organisational structures play an important role in identifying, measuring and monitoring operational risks, doing so in a coordinated manner and using constant information flows.

Legal & Corporate Affairs and Compliance, the duties of which include:

• ensuring the proper operation of management and coordination activities;
• overseeing the updating of corporate standards and principles and their compliance with applicable laws, regulations and provisions, as well as connecting, coordinating and controlling compliance activities;
• overseeing the definition of governance rules and systems;
• ensuring that the business units of Snam and its Subsidiaries have the necessary support and advice in terms of legal compliance, and that suitable solutions are put forward;
• performing the necessary activities and analysis to coordinate, monitor and control risk as part of the optimisation of operating processes.

Legal & Corporate Affairs and Compliance contains the Legal Compliance team, which is responsible for:

• promoting the simplification/streamlining of the compliance models and of the system of associated rules and procedures, quantifying the real risk in specific areas, in line with international best practice, and monitoring their application;
• disseminating a culture of compliance, working with the relevant departments to promote and ensure communication and training on key topics;
• ensuring that the business units of Snam and its Subsidiaries have the necessary support and advice in terms of legal compliance, and that suitable solutions are put forward.

The Legal Compliance team contains an Anti-Corruption Unit, whose role is to provide specialist legal advice and support on anti-corruption issues to the business units of Snam and its Subsidiaries. The main functions of this unit are: (i) to adjust existing procedures as necessary and promote the adoption of new regulations by the Subsidiaries; (ii) to train and raise awareness among staff with regard to familiarity and compliance with anti-corruption regulations; (iii) to promote the adoption of new legislation and periodically review the Anti-Corruption Procedure to optimise its effectiveness; (iv) to submit a half-yearly report on its monitoring activities to: (a) the Watch Structure; (b) the Board of Statutory Auditors; (c) the Control and Risk Committee; and (d) the Director of Planning, Administration, Finance and Control.

Planning, Administration, Finance and Control, the duties of which include:

• overseeing activities pertaining to budgeting, treasury and insurance against financial and business risks, as well as relationships with banking, financial and insurance counterparties;
• defining strategies for the management of financial risks and drawing up the Group’s insurance programme;
• insuring against financial risks through the purchase and sale of derivatives, in accordance with established risk limits and guidelines;
• helping to define the target financial structure in accordance with the Company’s business and risk profile;
• identifying and analysing the main financial risks pertaining to the Group’s business, defining methods and tools to measure, control and monitor the identified risks, and ensuring the consistency of these methods with those defined by the relevant Risk Management team;
• working with the relevant departments to suggest updates to risk evaluation and credit management methods.

Planning, Administration, Finance and Control includes the Corporate Reporting Control System department, the duties of which include:

• drawing up rules and methodologies related to the establishment and maintenance of the Corporate Reporting Control System;
• managing the risk assessment process relating to corporate reporting and the implementation of controls;
• managing information flows, control assessments, statements and reports on the state of the Corporate Reporting Control System and providing methodological and operational support to the departments involved in implementing it;
• performing activities related to the definition of scope, examination and assessment of the Corporate Reporting Control System, as well as drawing up reports on assessment results and preparing reports on the System for the Executive Responsible for preparing corporate accounting document and the supervisory bodies.