The fight against corruption and illegality

The main internal reference for the fight against corruption is the Anti-corruption policy, adopted by all Group companies. The policy is inspired by the principles of conduct established by the Code of Ethics and makes a clear distinction between the allowed and the prohibited conducts. In particular, it:

• prohibits the offering, promising, giving, paying, or allowing anyone to give or pay, directly or indirectly, an economic advantage or other benefits to a public official or to a private person (Active Corruption); prohibits accepting the request from, or solicitations from, or allowing someone to accept or solicit, directly or indirectly, an economic advantage or other benefits from anyone (Passive Corruption);
• pays particular attention to the selection of suppliers and the qualification process, to the awarding of contracts, the management of contracts, the standard terms of protection, including those of commitment to respect Anti-Corruption Laws and to verify the ethical requirements of suppliers;
• establishes that all of Snam’s relations with, or related to, or involving a public official must be conducted in accordance with the Anti-Corruption Procedures and instruments (the so-called Ancillary Procedures), including, in particular, the procedure for managing sponsorships and free donations.

The Anti-Corruption policy is part of a broader business ethics control system adopted by Snam aiming to ensure the company’s compliance with national and international laws and best standards. In this context, the hours of awareness training are provided to the staff and monitoring activities are also performed to analyse the degree of dissemination and knowledge.

To prevent the risk of corruption in the supply chain, all suppliers and subcontractors are required to sign the Ethics and Integrity Agreement that allows the performance of reputational analysis aimed at identifying – based on public information – indicators of irregularities or possible risks of infiltration by organised crime.

In 2017, Snam collaborated with the OECD, participating, as the first Italian private sector company, to the Business and Industry Advisory Committee (BIAC). Snam has also collaborated with the Ministry of Foreign Affairs attending to:

(i) the “VIII Conferenza Italia – America Latina e Caraibi”, in which Latin American Ministers of Justice and Italian Authorities participated; (ii) to the “Italian Business Integrity Day” held at the Italian Embassy in Washington within the scope of the Business Integrity Day promoted by the Ministry of Foreign Affairs. Snam was invited, together with other companies to participate to the Business Integrity Forum of Transparency International IT.

During these events, the company illustrated the instruments established in the area of transparency and anti-corruption. On the matters of business ethics, legality and anti-corruption, approximately 327 hours of training were provided.

Ethical principles and business values

Transparency, honesty, fairness, good faith in full compliance with competition protection rules;

Stakeholder engagement, extending the dialogue on the topics of sustainability and corporate responsibility;

Creating competitive value for the company, its Stakeholders and the territories in which it operates;

Protecting and promoting human rights;

Protecting all forms of individual freedom and repudiating any type of discrimination, violence, corruption (in any form thereof with reference to any public or private persons), and forced or child labour;

Recognising and safeguarding the dignity, freedom and equality of human beings;

Protecting jobs and trade-union freedom, health, safety, the environment and biodiversity.