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7.2 Anti-Corruption Procedure

On 4 October 2013 – following the promulgation of Law No. 190 of 6 November 2012 (“Anti-Corruption Law”), which introduced, inter alia, 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 ten universal principles relating to human rights, labour, the environment and anti-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 work of Italy’s Global Compact Network.

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

The Procedure is available on the Company’s website (http://www.snam.it (PDF)).

Snam, from January to December 2014, developed a monitoring activity of Anti-Corruption Group “compliance program”. The implementation of this initiative, which is part of the “compliance program” corruption was developed, with the support of an independent advisor, through a direct and continuous check of the implementation and enforcement of anti-corruption procedures specified by the “compliance program”.

On June 2014, Snam has obtained by Transparency International Italy the highest score for its proactivity and transparency in the management and communication of anti-corruption programs and activities. The score follows the assessment on Transparency in Reporting on Anti-Corruption (TRAC) promoted by the renown non-governmental organization fighting corruption worldwide. The TRAC project stems from the need to raise the level of transparency of corporate communications and demonstrate the firms’ effective commitment to actively fight against corruption.

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