Operational risks

Ownership of storage concessions

The risk linked to maintaining storage concessions is associated for Snam to the business in which the subsidiary Stogit operates on the basis of concessions provided by the Ministry of Economic Development. Eight of the ten concessions (Alfonsine, Brugherio, Cortemaggiore, Minerbio, Ripalta, Sabbioncello, Sergnano and Settala) expired on 31 December 2016 and can be renewed no more than twice for a duration of ten years each time. With regard to these concessions, Stogit has submitted – within the statutory terms -– the extension request to the Ministry of Economic Development. The extensions of the concessions in Brugherio, Ripalta, Sergnano, Settala and Sabbioncello were granted until the end of 2020. For Alfonsine, Cortemaggiore and Minerbio, the related proceedings are still pending before the aforementioned Ministry. For the pending extensions, the Company’s activities, as provided for by the reference regulations, will continue until the completion of the authorisation procedures that are in progress, as envisaged by the original authorisation, which will be extended automatically on expiry until said completion. One concession (Fiume Treste) will expire in June 2022 and has already been renewed for the first ten-year extension period in 2011 and an application was submitted for the second extension on 18 May 2020. Lastly, another concession (Bordolano) will expire in November 2031 and can be extended for a further ten years20. If Snam is unable to retain ownership of one or more of its concessions or if, at the time of the renewal, the concessions are awarded under terms less favourable than the current ones, there may be negative effects on the Company’s operations, results, balance sheet and cash flow.

Malfunction and unexpected service interruption

The risk of the malfunctioning and unforeseen interruption of the service is determined by accidental events, including accidents or malfunctions of equipment or control systems, reduced output of plants, and extraordinary events such as explosions, fires, landslides or other similar events, third-party interference and corrosion, outside of Snam’s control. Such events could result in a reduction in revenue and could also cause significant damage to people and property, with potential compensation obligations. Although Snam has taken out specific insurance policies to cover some of these risks according to industry best practices, the related insurance cover could be insufficient to meet all the losses incurred, compensation obligations or cost increases.

Delays in the progress of infrastructure implementation programs

There is also the possibility that Snam could incur delays in the progress of infrastructure construction programmes as a result of several unknowns linked to operating, economic, regulatory, authorisation, competition and social factors or health emergency situations, regardless of its intentions. Snam is therefore unable to guarantee in absolute terms that the projects for upgrading, maintaining and extending its network will be started, be completed or lead to the expected benefits in terms of tariffs. Additionally, the development projects may require greater investments or longer time frames than those originally planned, affecting Snam’s financial position and economic results.

Investment projects may be stopped or delayed due to difficulties in obtaining environmental and/or administrative authorisations or to opposition from political forces or other organisations, or may be influenced by changes in the price of equipment, materials and workforce, by changes in the political or regulatory framework during construction, or by the inability to obtain financing at an acceptable interest rate. Such delays could have negative effects on the Snam Group’s operations, results, balance sheet and cash flow. In addition, changes in the prices of goods, equipment, materials and workforce could have an impact on Snam’s financial results.

Environmental risks

Snam and the sites in which it operates are subject to laws and regulation relating to pollution, environmental protection, the use of hazardous substances and waste disposal. These laws and regulations expose Snam to potential costs and liabilities related to the operation and its assets. The costs of possible environmental remediation obligations are subject to uncertainty regarding the extent of contamination, appropriate corrective actions and shared responsibility are therefore difficult to estimate.

Snam cannot predict if and how environmental regulations and laws may over time become more binding and cannot provide assurance that future costs to ensure compliance with environmental legislation will not increase or that these costs can be recovered within the mechanism’s tariffs or the applicable regulation. Although Snam has also taken out specific insurance contracts to cover some of the environmental risks, according to industry best practices, substantial increases in costs relating to environmental compliance and other related aspects and the costs of possible sanctions could have a negative impact on the business, operating results and financial and reputational aspects.

Employees and staff in key roles

Snam’s ability to operate its business effectively depends on the skills and performance of its personnel. The loss of “key” personnel or the inability to attract, train or retain qualified personnel (particularly for technical positions in which the availability of appropriately qualified personnel may be limited) or situations in which the capacity to implement the long-term business strategy is influenced negatively due to significant disputes with employees could trigger an adverse effect on the business, financial conditions and operating results.

The events related to this risk category may also refer to the theme of Diversity and Inclusion.

Risk linked to foreign equity investments

Snam’s investee companies abroad may be subject to regulatory/legislative risk, conditions of political, social and economic instability, market risks, and the cyber security, credit and financial and other risks typical of the natural gas transportation and storage segments identified for Snam such to negatively influence their operations, economic results, balance sheet and cash flows. For Snam, this could have negative impacts on the contribution to profit generated by such investments.

Risks associated with future acquisitions/equity investments

Every investment made under the scope of joint venture agreements and any future investment in Italian or foreign companies could involve an increase in the complexity of the Snam Group’s operations and it may not be possible to ensure that these investments generate the anticipated income under the scope of the acquisition or investment decision and are correctly integrated in terms of quality standards, policies and procedures consistent with the rest of Snam’s operations. The integration process could require additional costs and investments. Improper management or supervision of the investment made may adversely affect the business, operating results and financial aspects.

Operating risks

Description

Related material topics

Mitigation actions

Impact on capital

Maintaining gas storage concessions

  • Economic performance and value creation

Development of storage in accordance with the most current technical and economic criteria and science and technology best practices

Delays in the progress of infrastructure implementation programs

  • Protecting the local area and biodiversity
  • Relations with local communities

Application of the strictest national and international environmental and safety standards during the design process with particular attention to protecting the natural value of the territories and biodiversity


 

Communication policy concerning the work to be carried out in order to share projects with the territory and stakeholders from the beginning

 

Structured and meticulous performance qualification and monitoring system for contractors

Breakage or damage to pipelines/plants, also as a result of extraordinary events, which could cause malfunction and unexpected service interruption

  • Health and safety
  • Reliability of infrastructures, business continuity and cyber security

Application of management systems and procedures that take the specific nature of Snam’s activities into account




Implementation of a recovery plan and business continuity management system

Communication initiatives aimed at providing information regarding the presence of infrastructure and the behaviours to be avoided/implemented by third parties in order to prevent damage occurring to them

Technologically-advanced tools for monitoring/controlling the state of the infrastructure/plants and the territories concerned

Continuous verification of insurance coverage in relation to the type of business and related risks

Systematic and continuous maintenance and control

Acquisition of equity investments

  • Economic performance and value creation

Due diligence for investment assessment, also with the support of external advisers

 

Overall planning in terms of the time, actions and resources required to ensure efficiency/effectiveness in the management of activities

 

Elaboration and continuous monitoring of the acquisition business plan

Asset Management

  • Economic performance and value creation

Support for affiliates, as a business partner, in the regulatory, operational and financial structure optimisation fields

 

Cyber threats (Cyber security)

  • Reliability of infrastructures, business continuity and cyber security

Adaptation of IT and business continuity systems to the ISO/IEC 27001 and ISO22013 standards respectively, with the provision of the relative certifications

Definition of a security incident management team model to promptly respond to events that could potentially damage the integrity of information and computer systems used

 

 

 

 

Human capital

Relational capital

Intellectual capital

Financial capital

Infrastructure capital

Natural capital

20 The Stogit concessions issued prior to the entry into force of Legislative Decree 164/2000 can be extended by the Ministry of Economic Development a maximum of twice, for ten years at a time, pursuant to Article 1, paragraph 61 of Law 239/2004. Pursuant to Article 34, paragraph 18 of Decree-Law 179/2012, converted by Law 221/2012, the duration of the single Stogit concession issued after the entry into force of Legislative Decree 164/2000 (Bordolano) is for thirty years with the possibility of extension for a further ten years.

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