Business ethics and governance
In march 2018 Snam collaborated with OCSE taking part in the Anti-Corruption and Integrity Forum in Paris in March. Snam was the only Italian private company to take part in a discussion comparing the various national approaches to the fight against corruption and the promotion of integrity in businesses.
At the presentation of the Business Index on Transparency at the Business Integrity Forum held in November. On this occasion, the Snam took part in a discussion comparing good practices for fighting corruption and, as the representative of the Energy sector, it stood out for its own best practices and for the extent of its culture of business ethics and preventive measures adopted.
Snam’s anti-corruption guideline constitutes a key element in the company’s commitment to proper business conduct.
Snam is keenly aware of the social impact of its activities and aims to develop its business in a sustainable fashion, both in Italy and increasingly abroad.
The company understands that the sustainability of its business must come from within and be based on a solid bedrock of good corporate governance and on policies and systems that underpin its standards of responsible business conduct in all corporate spheres.
Maintaining an efficient governance system, in line with international best practice, is therefore an integral part of Snam’s sustainability strategy and the basis for effectively creating shared value with stakeholders.
Thanks to this approach, Snam manages to uphold its commitments towards environmental protection, the health and safety of its people, employee rights and a respect for diversity, as well as co-operation with the communities where it operates.
The Code of Ethics has been updated to reflect organisational and regulatory changes.
Snam’s Code of Ethics sets the expectations for business conduct and guides relationships with all stakeholders – both internally and externally – according to the principles of transparency, correct behaviour, good faith, honesty and competition.
Countering corruption is a critical factor for Snam’s success; in line with its Code of Ethics, the company prohibits corruption in all its forms.
A key factor of Snam’s commitment to sustainability is its ability to perform its business activities with honesty and integrity, complying with laws and standards nationally and internationally.
From this perspective, Snam considers the fight against corruption to be a priority and has chosen to adopt its Anti-corruption Guideline.
This commitment is backed up by Snam’s adherence to the United Nations Global Compact, which puts the fight against corruption as its 10th principle.
Suppliers Ethic and Integrity Agreement
In order to formalise this reciprocity, Snam asks its suppliers to sign up to an Ethics and Integrity Agreement that aims to ensure transparent relations, professional morality throughout the supply chain (including subcontractors) and for the entire duration of the relationship, and powers to intervene in the event of non-compliance or breaches, under the terms and conditions established in Group procedures.
- Fighting public and private corruption.
- Rejecting all direct and indirect crimes against government, however they are committed.
- Fighting mafia infiltration into the legal economy.
- Protecting and safeguarding the environment to ensure sustainable development for future generations.
- Safeguarding workplace and construction site health and safety.
- Upholding the freedom of association and collective contracts, and preventing forced labour and the economic exploitation of minors.
- Complying with the principles of proper competition.
Snam has adopted a Guideline for receiving information (either anonymous or by a named individual) about presumed irregularities. The company publishes annualy data on the number of reports received, closed and under examination.
Snam has long established specific communication channels, indicated in the Guideline, as part of the reporting process (c.d. whistleblowing), to which the subsidiary companies also refer, in addition to Snam. Snam had already entrusted the management of the aforementioned communication channels to an external party (Ombudsman) which ensures the receipt and analysis of each report by applying appropriate criteria of strict confidentiality, adequate moreover, to protect the good repute of the people reported and the effectiveness of the investigations; besides, in order to guarantee levels of excellence and independence, Snam modified its own legislation in March 2018 to implement the provisions of law n. 179/2017 on the subject of "whistleblowing".
Each year, the company publishes data on the number of reports received, resolved and under examination.
Managing risk involves defining a model for identifying the most important risks, drawing up mitigation actions and develop a reporting system.
Responsibility for the internal control system and risk management lies with Snam’s Board of Directors, supported by the Control and Risk Committee. Besides in the company,there is the Enterprise Risk Management unit which is charged with defining a corporate risk management model, extending to issues of health, safety and the environment.
The implementation of the control system is the primary responsibility of functional management while the Internal Audit function has an independent role and makes sure the internal control and risk management system is functioning and adequate.
The Board of Statutory Auditors monitors the effectiveness of the internal control and risk management system.
Using the ERM model (Enterprise Risk Management), risk assessment cycles were performed on the entire Snam Group in 2018. As at the end of 2018, 138 enterprise risks had been mapped and broken down between all corporate processes. Moreover, the 2018 mapping of risks and opportunities considered the new activities under the scope of new unregulated businesses, as a result of acquisitions made during the year.
The Sustainability Committee was established on 11 May 2016.
The Board of Directors plays a central role in overseeing the company’s commitment to sustainable development along the chain of value which is later presented to the Shareholders’ Meeting. It is assisted with these tasks by the Sustainability Committee, established on 11 May 2016, which makes proposals and provides advice.
18 April 2019 - 14:56 CEST