Legal and non-compliance risk

The legal and non-compliance risk concerns the failure to comply, in full or in part, with the European, national, regional and local laws and regulations with which Snam must comply in relation to the activities it carries out. The violation of such rules and regulations may result in criminal, civil and/or administrative sanctions, as well as damage to Snam’s balance sheet, financial position and/or reputation.

As regards specific cases, the infringement of regulations on the protection of workers’ health and safety and of the environment, and the infringement of anti-corruption rules, inter alia, may also result in (possibly significant) sanctions on the Company based on the administrative responsibility of entities (Legislative Decree 231 of 8 June 2001). Snam has, therefore, adopted and undertakes to promote and maintain an adequate internal control and risk management system aimed at allowing for the identification, measurement, management and monitoring of the main risks related to the activities carried out. With regard to the Risk of Fraud and Corruption, Snam believes it is of vital importance to ensure a climate of fairness and transparency in corporate operations and repudiates corruption in all its forms in the widest context of its commitment to abiding by ethical principles. Snam’s top management is strongly committed to pursuing an anti-corruption policy, trying to identify possible areas of vulnerability and eliminating them, strengthening its controls and constantly working to increase employees’ awareness of how to identify and prevent corruption in various business situations.

Reputational checks as well as accepting and signing the Ethics and Integrity Agreement are pillars of the control system designed to prevent the risks associated with illegal behaviour and criminal infiltration of our suppliers and sub-contractors, with the goal of guaranteeing transparent relations and professional morality requirements throughout the supply chain and for the entire duration of the association.

Snam is a member of the United Nations “Global Compact” and operates within the framework of the principles set forth by this global initiative, which are an integral part of its strategies, policies and rules, including the tenth principle of “zero tolerance” towards all forms of corruption, which is the foundation for a consolidated culture of integrity and business ethics.

Since 2014, Snam has collaborated with Transparency International Italia, as a member of the Business Integrity Forum (BIF), and in 2018 Snam signed a Memorandum of Understanding with the Berlin Secretariat of Transparency International.

In 2017, Snam began a collaboration with the OECD, becoming part of the Business at the OECD Committee (BIAC), and in October 2019 – as the first Italian company – joined the Leadership team as Vice-Chair of the Anti-corruption Committee.

In September 2019, Snam was also involved in the Partnering Against Corruption (PACI) initiatives of the World Economic Forum. Furthermore, thanks to its commitment to the issues of Business Ethics and Anti-Corruption, Snam was referenced in the document presented at the B20 Summit under the Japanese Presidency held in Tokyo (2019) as a “tangible example” of a company that has distinguished itself in the fight against corruption with its concrete actions.

In 2020, in addition to its role as Vice-Chair of the Anti-corruption Committee mentioned above, for the purposes of the progressive enhancement of ESG issues at a multilateral level also, Snam was also selected as a permanent member of the BIAC Corporate Governance Committee and, to the same end, the company’s efforts were also increased in the working tables promoted by the World Economic Forum in the area of “ESG and Corporate Governance”.

Within the OECD, Snam has participated in several events, among which we should mention the “Safeguards for a resilient Covid-19 response and recovery”, the first event of the year organised by the organisation since the beginning of the international health emergency, which replaced the annual Global Integrity Forum.

Lastly, during the B20 Saudi Presidency (2020), Snam was also one of the very few Italian companies to take an active part in the work of the Integrity & Compliance Taskforce, whose contributions were incorporated within the Policy Paper that was distributed to G20 members in view of the handover to the Italian Presidency (2021).