6. Code of Ethics

The Code of Ethics defines a shared value system and expresses Snam’s business ethics culture. It forms the basis for the Company’s strategic line of thought and the conduct of its corporate activities¹³.

The Code of Ethics

1. states the values which identify Snam, such as compliance with the law, transparency, honesty, correctness, good faith, full respect of the provisions which protect competition;
2. contains the behavioral standards in the relations with stakeholders (employees, clients, shareholders, commercial and financial partners, as well as the community in which the Company is present through its activities); and
3. forbids, without exemption, any form of bribery, illegitimate favors, collusive behaviors, requests, direct or through third parties, of personal or career advantages in favor of oneself or other people.

The Code of Ethics represents, inter alia, an irrevocable general principle of the Organisation, Management and Control Model adopted by Snam pursuant to the Italian regulations on the “liability of entities for regulatory offences connected to criminal acts” set out in Legislative Decree 231/2001. The Board of Directors has appointed the Watch Structure, set up pursuant to Legislative Decree 231/2001, to the role of Code of Ethics Supervisor, to which the following may be presented:

• requests for clarification and interpretation of the principles and content of the Code of Ethics;
• suggestions relating to the application of the Code of Ethics;
• reports of violations of the Code.