Snam prohibits corruption in any form as part of its wider business ethics control system. The company has strengthened its Anti-corruption safeguards and worked to raise employee awareness of how to identify and prevent corruption in the business contexts.
Anti-corruption efforts aim to avoid sanctions and business disruption as well as safeguard reputation
Snam prohibits corruption in any form of any Italian or foreign, public or private entity. Its Anti-corruption Procedure, an integral part of Snam’s broader business ethics control system, ensures compliance with national and international Anti-corruption laws, including the UK’s Bribery Act, and with the best international Anti-corruption standards. This is done not only to avoid considerable sanctions and business disruption but also to protect Snam’s reputation.
X° Global Compact principle
Snam’s Anti-Corruption Procedure has also been adopted in accordance with Principle 10 of the Global Compact, a United Nations initiative launched in 2000 to promote 10 universal principles relating to human rights, labour, the environment and the fight against corruption. The Global Compact brings together governments, businesses, United Nations agencies, labour organisations and civil society with the aim of creating "a more inclusive and sustainable global economy" by incorporating compliance with, and application of, shared values. Snam’s adherence to the Global Compact demonstrates and strengthens its status as a socially responsible business and the company participates actively in the work of Italy’s Global Compact Network.
Adoption and implementation of the Anti-corruption Procedure, approved by the board of directors, is mandatory for Snam and its subsidiaries
The Anti-corruption procedure extend to public officers, private individuals
The Anti-corruption Procedure, in Snam’s Anti-corruption compliance programme, provide a systemic reference framework of the Anti-corruption regulations that Snam has planned and implemented. It drew inspiration from the rules of conduct provided in the Code of Ethics and makes a clear distinction between acceptable and prohibited behaviour.
Compared to the previous Anti-corruption Management System Guidelines, key developments in the Anti-Corruption Procedure include:
- The prohibition of all forms of bribery and corruption in relations with public officials and private individuals
- Greater attention to supplier selection and qualification, contract awards, management of contracts, standard protective clauses, including those relating to the commitment to comply with Anti-corruption laws, and monitoring suppliers to ensure they meet requisite ethical standards
- The stipulation that all Snam group relations with, relating to or involving a public official must be conducted in accordance with the provisions of the Procedure and the related Anti-corruption instruments (Ancillary Procedures)
Snam in 2014 received the highest score possible from Transparency International Italy for the communication of its Anti-corruption programmes and activities. Read more about this important recognition from a global NGO focused on increasing transparency and reducing corruption.
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Anti-corruption compliance in action
At its meeting on 10 February 2010, Snam’s Board of Directors has also changed its organisational structure with the establishment of the Anti-Corruption Unit, within the Legal and Corporate Affairs and Compliance Department.
The Anti-corruption Unit:
- provides legal assistance to the business units of Snam and subsidiaries;
- ensures constant monitoring of developments of legislation and jurisprudence;
- identifies and evaluate the risks of commission of crimes of corruption by due diligence on business partners;
- elaborates, monitors and updates the Snam Anti-corruption policy in order to ensure its effectiveness and real implementation;
- oversees the training of Snam Personnel.
Snam employees must be informed about applicable Anti-corruption laws and the importance of complying with these laws and Snam’s guidelines. They must clearly understand and be aware of the crimes, risks, personal and administrative responsibilities for individuals and the group. They must know actions to undertake to fight corruption, and understand sanctions (for the individuals involved and for Snam for violation of the Procedure and Anti-corruption laws).
Snam’s commitment to greater employee awareness encompasses:
- for new employees “Fight against corruption in Snam
- 1130 Anti-corruption due diligence reviews were completed in 2014/2015 on business partners
- 15 Anti-corruption regulatory instruments were updated in 2014 and issued a new ancillary procedure.
A two-year training period dedicated to the code of ethics, model 231 and Anti-corruption issues - addressed to the entire population equipped with personal computers – was completed in 2014. Overall, 11,751 hours of training were provided with the attendance of 3,917 people.
From January to December 2014 Snam monitored the Group’s Anti-corruption compliance programme. The implementation of this initiative, which is an integral part of the Anti-corruption compliance programme, was managed in collaboration with a leading law firm which carried out a direct, ongoing audit of the implementation and application of the Anti-corruption procedures required by the compliance programme including through meetings with the key officers of Snam and its subsidiaries. This analysis confirms that the Anti-corruption compliance programme is highly "effective" and "appropriate", reflects the provisions of applicable regulations and international guidelines and best practices, and is one of the most sophisticated compliance programme adopted by major Italian and international companies.
TRAC "Assessment on Transparency in Reporting on Anti-corruption"
In June 2014 Snam voluntarily submitted to the Assessment on Transparency in Reporting in Anti-corruption ("TRAC") by Transparency International Italia, an international non-governmental organization engaged in the fight against corruption. This assessment led to an analysis that covered, among other, the information Snam makes available to the public through the website www.snam.it , including the Code of Ethics, Anti-Corruption Policy, financial reports and the Sustainability Report. Transparency International Italy assigned the maximum score to Snam for its proactive approach and transparency in the reporting of programmes and Anti-corruption activities. In fact, Snam achieved a score of 100% on both sections of the evaluation applicable to it ("Anti-corruption Programme" and "Organisational Transparency"). Transparency International Italia indicated that the Anti-corruption Procedure was an example of "absolute excellence".
29 August 2016 - 19:20 CEST