Prevention of active and passive corruption

Future objectives and results achieved





2020 performance






Percentage of third party counterparts on which reputational due diligence checks have been performed

ESG scorecard

100% up to 2023







Percentage of BoD time dedicated to ESG matters in strategy meetings and induction sessions

ESG scorecard

at least 40% up to 2023

41% (*)

(*) Data extracted from the minutes of Board meetings from January 2020 to December 2020 and from the Corporate Governance Report and including Board Induction sessions.

ESG scorecard KPI entered in the ESG Scorecard

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.

Risks and material topics associated with aspects concerning the prevention of active and passive corruption



Material topics


Risk of possible breach of laws and regulations and of an inadequate reputational profile for suppliers and subcontractors

  • Business integrity
  • Fighting corruption

For a complete description of the risks, please refer to “Risks factors and uncertainties” contained in the “Risk management” section in the Integrated Management Report.

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.

 Anti-corruption Compliance Programme Highlights

  • Zero Tolerance Policy towards any form of corruption
  • Specific rules and controls in relation to the activities identified as potentially “at risk” and to the activities concerning the effective implementation of anti-corruption compliance
  • Clear distinction between permitted conduct and prohibited conduct
  • Special attention to relations with public officials and with suppliers and sub-contractors and, in general, with all associated businesses
  • Establishment of the Ethics & Anti-bribery dedicated function
  • Annual monitoring of activities with the involvement of managers
  • Specific training launched in 2016 for over 1,442 participants, which continued in 2017 and 2018 for all new hires, renovated in 2019 for all the concerned company workforce (2,906 people) and further conveyed to new hires in 2020
  • Preparation of the “Anti-corruption Mini Guide”, distributed to all Snam staff as a document that can easily be consulted, designed to reinforce our anti-corruption culture
  • Example of “absolute excellence” from Transparency International Italy following its “Assessment on Transparency in Reporting on Anti-Corruption”
  • 7,453 reputation audits were carried out on business partners in 2020 (2,758 of which were suppliers and sub-contractors)

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.

 Download XLS (12 kB)


GRI Standard

Measure­ment unit




Cases of proven corruption






Reports received on corruption and under examination




Reports received on corruption and archived because unfounded




Hours of training on anti-corruption, code of ethics and model 231





Participations in training on anti-corruption, code of ethics and model 231 (*)





Instead of the participants, the number of participations is reported as recorded in the attendance recording system for training purposes.

56 In this regard, the Code of Ethics provides, inter alia, that Snam rejects any kind of corruption (in all its forms with reference to any public or private entity) and that practices of corruption, unlawful favours, collusive behaviour, solicitations, direct and/or through third parties, personal and career advantages for themselves or others, are without exception prohibited.
57 The Anti-corruption Guidelines are available on the Company website at:

to pagetop