Snam has adopted a Procedure 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 whistleblowing procedure defines a process for receiving reports about presumed irregularities, analysing this information and determining any action to take
Since long time, Snam – in the context of the process aimed at managing the reports received (so called whistleblowing procedure) set up specific channels of communication, as specified in the Policy. In addition to Snam, the Subsidiaries also make reference to such channels.In order to guarantee the most excellent levels of independence, last July 2016 Snam modified the Policy to entrust an external person (Ombudsman) with the management of the said channels of communication and the specific task of guaranteeing that the receipt and analysis of every report received is performed applying the utmost confidentiality criteria necessary to protect the integrity of any reported persons and the effectiveness of the investigations.Anyone who receives a report coming from outside the required channels must promptly send the original copy of the same to the Ombudsman who must also receive the documentation, if any, pertaining to the reported events, as well as the outcome of any investigations already conducted on the matter.
All organisational units/positions of Snam S.p.A. and of the related subsidiaries concerned with the receipt and processing of reports are required to guarantee the utmost confidentiality and anonymity of the reporting parties, and to this end, they must use suitable communication criteria and methods to ensure the integrity of the people mentioned in the reports, as well as the anonymity of the reporting parties, so as to prevent the latter from being subject to any form of retaliation.
The Ombudsman is supported by the Internal Audit function in performing the necessary
investigations with regard to the reported events through one or more of the following activities,
ensuring that such stages are carried out as quickly as possible, whilst guaranteeing the
completeness and accuracy of the investigation activities:
1. Preliminary investigation;
4. Corrective action monitoring.
The channels of communication provided are as follows
- OMBUDSMAN SNAM – Piazza S. Barbara, 7 (20097) San Donato Milanese (MI)
- vocal box: +39 02/37039230;
- email: firstname.lastname@example.org.
|Total reports received||20||17||25|
|those involving the internal control system||2||2||14|
|&those involving accounting, auditing, fraud, etc.||0||0||0|
|those involving administrative liability pursuant to Legislative Decree no. 231/2001||0||0||1|
|those involving violations of Anti-corruption law||0||1||4|
|those involving other subjects (Code of Ethics, mobbing, theft, security, etc.)||18||14||6|
|Reports filed due to false or missing information||13||8||12|
|Reports that resulted in internal disciplinary or managerial action and/or submission to the judicial authorities||1||3||6|
|Reports currently being examined||7|
21 March 2017 - 09:35 CET