Prevention of active and passive corruption

Material topics and risks related to the prevention of active and passive corruption

Business integrity: Snam considers maintaining business integrity essential for its economic and social relations, promoting honesty, transparency and fairness in its business processes, in compliance with the principles and values on which the Group is based.

Fighting corruption: Snam recognises corruption as a serious threat to its development. For this reason, The Group conducts its business in full compliance with the rules and pledges to fight against corruption nationally and internationally, in relations with both public and private officials.

Policies, commitments and management model

Anti-corruption Compliance Programme

Snam has defined an Anti-corruption Compliance Programme designed to identify and assess corruption risks related to its business activities and to prevent the violation of both internal and external rules. This programme does not only adopt the 231 Model (aimed at preventing offences from which administrative liability for offences by the company arises, including corruption offences) but, consistent with the provisions of international guidelines and best practices, has also implemented the following instruments⁵⁶:

Anti-Corruption Guidelines

The Anti-corruption Guidelines are an integral part of a broader corporate ethics control system, aimed at ensuring Snam’s compliance with national and international Anti-corruption Laws and with the best international standards in the fight against corruption, also with the goal of protecting Snam’s reputation, with particular regard to the selection of suppliers and business partners, the management of relations with such parties and the relevant protective contractual clauses. Furthermore, the Guidelines comply with the tenth principle of the Global Compact, which repudiates corruption “in all its forms, including extortion and bribery” and clearly outline permissible and prohibited conduct.

The Anti-Corruption Guidelines apply to Snam and its subsidiaries and have also been brought to the attention of investee companies, with the aim of promoting conduct and information flows consistent with those expressed by Snam. Furthermore, Snam uses its influence, as far as the circumstances reasonably permit so, to encourage the companies and the entities in which Snam owns a non-controlling shareholding and associated businesses to meet the standards specified in the Anti-corruption Guidelines⁵⁷.

Collaboration with Transparency International and other initiatives

Since 2016, Snam has been working alongside Transparency International to develop a partnership under the scope of the Global Corporate Supporters Forum. As part of the agreement, Snam is one of the international partners of the Forum as the first Italian company to be in conformity with the standards of good governance, transparency and accountability promoted by Transparency International, in the context of the global commitment against corruption and promoting ethical business conduct.

In 2020, thanks to Snam’s constant commitment to the issues of anti-corruption, business ethics, integrity and transparency, and despite the challenges caused by the Covid-19 emergency, the company was involved in various multilateral initiatives, including:

• Safeguards for a resilient Covid-19 response and recovery, first event of the year organised by the OECD since the start of the pandemic;
• participation in the Business Integrity Forum organised by Transparency International Italia where Snam took part in several panels and in the institutional round table “Toward G20/b20 Italian Presidency”;
• B20 Saudi Arabia:
  • summit held in October, celebrating the official handover of the presidency of the International Business Forum to Italy;
  • Saudi Presidency: (i) Pursue a Culture of High Integrity in the Public and Private Sectors; (ii) Leverage Emerging Technologies to Manage Risks relating to Corruption and Fraud; (iii) Enhance Integrity and Transparency in Public Procurement;
  • side events: (i) Reviving Business for a New Normal, (ii) Enhancing Integrity for Responsible and Inclusive Growth; (iii) Pre-summit Shaping a More Inclusive World Reviving Business for a New Normal;
• Compliance in times of crisis organised by the Partnering Against Corruption Initiative of the World Economic Forum;
• OECD events: (i) Asia Network on Corporate Governance of State-Owned Enterprises; (ii) Working Party on Responsible Business Conduct; (iii) OECD Working Group on Bribery; (iv) Working Party on State Ownership and Privatisation Practices.

In addition to the role of Vice Chair within the Anti-Corruption Committee acquired in 2019, in order to better address ESG issues at a multilateral level, Snam has also been selected as an active member of the Corporate Governance Committee of BIAC (Business at OECD). With the same purpose, the company participated in the World Economic Forum’s “ESG and Corporate Governance” round table.

In addition, Snam has eliminated all manual data procedures and has improved the traceability, transparency and security of all its operations by digitising its information flows to the National Anti-Corruption Authority through a direct interface between their respective computer systems and the assignment of a tender identification code (CIG).

Key performance indicators

The indicators below show the results of the management of the aspects related to the prevention of corruption, with an indication of the reference GRI standard.

In 2020, the training cycle launched in 2016 continued with the aim of applying the concepts of business ethics, legality and anti-corruption in our daily operations, enabling the participants to recognise potential Red Flags and manage them. The training on these issues has a cyclical nature, designed to follow the evolution of the regulations applicable to the Company and the related amendments to the internal regulatory system. The figures for training on the code of ethics and anti-corruption are decreasing, because the ‘compliance path’, which started in 2019, was mostly provided to new employees in 2020. With regard to reports, it should be noted that the one received refers to an anonymous report alleging corruption in the management of certain suppliers.