7.2 Anti-Corruption Procedure

Snam has adopted an Anti-Corruption Procedure, based on the principles of conduct set out in Snam’s Code of Ethics, which aims to provide all personnel with rules to be followed in order to ensure compliance with the Anti-Corruption Laws.

In accordance with Snam’s Code of Ethics, the Anti-Corruption Procedure prohibits corruption in any form in relation to any Italian or foreign public or private entity 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 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 related 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 means of a resolution of the Board of Directors.

Since January 2014, Snam has undertaken an activity of monitoring the Group’s anti-corruption “compliance programme”. The implementation of this initiative, which forms an integral part of the anti-corruption compliance programme, is based, with the support of an independent advisor, on direct and continuous verification of the implementation and enforcement of the anti-corruption procedures provided for by the compliance programme. The “anti-corruption compliance programme” monitoring activities carried out in 2015 were focused not only on an assessment of the suitability and effectiveness of this programme with respect to the criteria resulting from guidance and international best practices in this field, but were structured in a more dynamic manner through the distribution of self-assessment questionnaires addressed at Key Officers and their closest collaborators within Snam and its Subsidiaries, in order to collect and analyse information about:

• the dissemination of anti-corruption procedures;
• the awareness of corruption risks on the part of each person in their area of responsibility;
• improvement suggestions for ensuring that the “anti-corruption compliance programme” is always updated.

In June 2014, Transparency International Italy awarded Snam the maximum score for proactivity and transparency in the management and communication of anti-corruption programmes and activities. This is the result of the assessment on Transparency in Reporting on Anti-Corruption (TRAC) promoted by the authoritative non-governmental organisation that fights corruption at a global level. The TRAC project was born out of the need to increase the transparency of corporate reporting and to demonstrate a concrete commitment by companies in the fight against corruption.