Combating corruption

Snam’s commitment to combating corruption in all its forms is managed within the broader context of business ethics. In recent years, the Company has continued to strengthen its anti-corruption safeguards and has worked to raise employee awareness of how to identify and prevent corruption in various business contexts, providing them with an internal regulatory reference on the subject.

The Anti-Corruption Guideline, applied to Snam and its subsidiaries and brought to the attention of other investee companies in order to promote principles and conduct consistent with as expressed by the parent company, is aligned with the tenth principle of the Global Compact, which repudiates corruption “in all its forms, including extortion and bribery” and clearly outlines permitted and prohibited conduct.

The Guideline is inspired by the principles of ethics, transparency, fairness and professionalism already referred to in the Code of Ethics and aims to strengthen the sensitivities of the Snam people in recognising corruption issues and other types of fraud, as well as their responsiveness in taking an active role in preventing, suppressing or reporting possible violations of the anti-corruption laws.

The Anti-Corruption Guideline is an integral part of a broader business ethics control system, aimed at ensuring compliance with both national and international Anti-Corruption Laws and the best international standards in the combat against corruption, also to protect Snam’s reputation. This commitment translates not only into careful monitoring of the Group’s activities, but also into constant attention to relations with counterparties, ensured, among other things, by the ‘Reputational Audits’.

Thanks to Snam’s ongoing commitment to anti-corruption, business ethics, integrity and transparency, and despite difficulties related to the Covid-19 health emergency, the Company has been involved in several multilateral initiatives, including:

• Safeguards for a resilient COVID-19 response and recovery, the first event of the year organised by the OECD since the pandemic began. On this occasion, Snam was invited to speak about possible new corruption risks in the context of the crisis due to the global pandemic and the new concrete challenges that companies may face in preventing such risks;
• Business Integrity Forum of Transparency International Italia, where Snam participated in several panels and in the institutional round table “Toward G20/b20 Italian Presidency”;
• B20 Saudi Arabia:
  • 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;
  • Summit held in October, where the handover of the International Business Forum to the Italian Presidency was made official;
  • 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;
• Compliance in times of crisis organised by 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 Deputy Chair within the Anti-Corruption Committee already acquired in 2019, for the purposes of a progressive enhancement of ESG issues also at multilateral level, Snam has been selected as an active member of the Corporate Governance Committee of BIAC (Business at OECD). With the same objective in mind, the company participated in the World Economic Forum’s “ESG and Corporate Governance” round table. On all these occasions, the Company highlighted its tools to protect transparency and the combat against corruption, including, among others, training sessions, many of which for new recruits, on business ethics, legality and anti-corruption, which will amount to 1,414 hours in 2020.

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

Relations with suppliers and business partners

The Anti-Corruption Guidelines pay particular attention to the selection of suppliers and business partners, the management of relations with them and the relevant contractual protection clauses: in order to prevent the risk of corruption and fraud in relations with the supply chain, all suppliers and subcontractors are required to sign the Ethics and Integrity Pact, which allows them to carry out reputational analyses aimed at identifying in advance, also on the basis of public information, the risk of possible infiltration by organised crime.

Already in 2019, the Group had carried out this type of verification on all counterparties, a result that was confirmed in 2020, with 100% of counterparties verified. In particular, during the year, 7,453 reputational audits were carried out on counterparties (of which 2,758 on suppliers and subcontractors), following which the Assessment Team, in the event of unlawful conduct, ordered 20 measures.

To reinforce this theme, Snam has implemented a new process aimed at having a deeper knowledge of its suppliers, not only from a “reputational” point of view, but also from a broader “compliance” point of view. It then introduced the new category of “Compliance Audits⁵”, which involve analyses of the financial soundness of suppliers as well as their suitability and adequacy, both from a technical and HSEQ point of view. The category of “Compliance Audit” will gradually replace the reputational audits carried out in the supplier engagement phases following “qualification”, ensuring regular monitoring of the supply chain 360 degrees.