5. 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 activities⁹. In particular, 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 behavioural 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 favours, collusive behaviours, requests, direct or through third parties, of personal or career advantages in favour of oneself or other people.

Amongst other things, the Code of Ethics represents a general binding principle of the 231 Model. The Board of Directors has assigned the Supervisory Body, established pursuant to Legislative Decree No. 231 of 2001, the role of Code of Ethics Supervisor, to which the following may be submitted:

• 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; and
• notifications of breaches of the Code of Ethics.