7.3 Antitrust Code of Conduct

The Company has adopted the “Antitrust Code of Conduct” (the “Antitrust Code”) procedure to ensure compliance by Snam and its Subsidiaries with the principles set out by the applicable antitrust legislation. The Antitrust Code applies to Snam and its Subsidiaries as part of Snam’s management and coordination activities, and is one of Snam’s initiatives aimed both at protecting competition as part of the business culture regarding market competion and at implementing suitable procedures and systems for minimising the risk of violations of antitrust laws, under the broader umbrella of compliance initiatives (Model 231, anti-corruption, business ethics, etc.).

In particular, bearing in mind that the main risks that a business may incur as a result of conduct in violation of the antitrust rules include inter alia the following:

1. administrative financial penalties;
2. liability for compensation in respect of damages caused to third parties by antitrust offences;
3. damage to the company’s image; and
4. possible negative impact on the prices of shares traded on regulated markets; following an analysis of international antitrust best practices, an antitrust compliance programme was drawn up. This is implemented by means of:
   • the adoption of the Antitrust Code;
   • dedicated communication and training initiatives for all employees that aim to ensure familiarity with the Code, as well as its effectiveness and correct implementation;
   • the establishment, within Snam’s Legal & Corporate Affairs and Compliance department, of an Antitrust Supervisor who will provide the necessary support and assistance concerning application of the Antitrust Code;
   • a monitoring programme in order to verify the effectiveness of the rules set out in the Antitrust Code and the suitability of amending and updating it in order to ensure more effective implementation of its rules in the light of regulatory and business developments.

The Antitrust Code is implemented at Snam and its Subsidiaries, and is aimed in particular at all:

• members of corporate bodies;
• executives;
• employees;
• representatives of Snam and/or its Subsidiaries.