Snam has adopted its own system of regulations that can be broken down into the following levels:
- Corporate System Framework (Level 1);
- Procedures (Level 2); and
- Operating Instructions (Level 3).
Moreover, certified management system documents (pursuant to ISO standards) on Health, Safety, Environment and Quality (Policies, Manuals, Procedures and Operating Instructions) are also an integral part of the regulatory system. Lastly, regulatory circulars are required to govern specific issues (sometimes with temporary validity).
Snam’s Regulatory System is designed to:
- monitor and support the effectiveness of the internal control and risk management system; and
- govern certain aspects of the management and coordination exercised by Snam over the Subsidiaries, to whose respective Boards of Directors the regulatory instruments adopted by Snam are sent periodically for information purposes.
Subsidiaries are required to assess the need to supplement the content of the regulatory instruments issued by Snam, issuing a dedicated supplementary document of their own: (i) that relates to their own specific requirements, and (ii) exclusively referring to organisational aspects. If no supplementary document is issued by the Subsidiaries within the allocated timeframe, Snam’s regulations are applied.
Subsidiaries are required to formally adopt measures on certain specific subjects (e.g., relating to health, safety and the environment and/or pertaining to the Boards of Directors of Snam and its Subsidiaries) where they hold direct and specific responsibility or, as the case may be, are required to adopt the measures adopted by Snam.