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7.1 Procedure for notifications, anonymous or otherwise, received by Snam and its Subsidiaries

The Company has approved a procedure for when Snam and its Subsidiaries receive information from known and unknown sources (the “Notification Procedure”). The Notification Procedure establishes the criteria and methods for setting up information channels that are suited to receiving, analysing and processing notifications relating to problems with the internal control system, company reporting, corporate administrative responsibility, fraud, corruption or other matters (violations of the Code of Ethics, mobbing, theft, security breaches, etc.). These can be received openly, confidentially or anonymously from employees (including senior management), members of corporate bodies or third parties.

The Notification Procedure complies with the provisions of Model 231, the Anti-Corruption Procedure and the Corporate Reporting Control System.

It applies to Snam and its Subsidiaries as part of Snam’s own management and coordination activities. The report management and related data processing is carried out by Snam, including in the interest of its Subsidiaries, in compliance with the principles of proper business management of the same Subsidiaries whilst respecting their decision-making independence and in observance of the regulations in force and the internal privacy policy, thereby also fulfilling the confidentiality requirements underlying the performance of preliminary investigation activities.

Snam has prepared various communication channels to make it easier to receive notifications. These communication channels are used by Snam and its Subsidiaries. They are prepared and maintained by the Internal Audit department.

The Internal Audit department draws up a quarterly report on notifications received, which is submitted to the following Company bodies and departments:

  • Chairman;
  • CEO;
  • Board of Statutory Auditors;
  • Control and Risk Committee
  • External Auditors;
  • Anti-Corruption Lawyer;
  • Watch Structure;
  • Director of Planning, Administration, Finance and Control.

With reference to the notifications relating to the Subsidiaries, the reports, insofar as relevant, are sent to the Chief Executive Officers of each Subsidiary concerned, as well as to the related Control and Supervisory Bodies.

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

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