Business ethics and governance

Business ethics and governance


The collaboration with OECD continues: in 2021 the participation in the round table "Leading through the Crisis, Crisis Integrity and Anticorruption for a Resilient Recovery" stands out. The changes caused by the pandemic in the risk field were discussed, considering the point of view of a large company


Snam keeps on to collaborate with Transparency International : in 2021 it participated in the Business Integrity Forum and in the Annual Event of Transparency International Italy, where it brought its experience to numerous panels


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.

It must be noted that no incident on human rights violations and no provision for fines and settlement on ESG issues in audited accounts have been registered in Snam during 2021.


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.

Learn more about Snam's Code of Ethics

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.

Find out about Snam's anti-corruption efforts

Read about Snam's commitment to the UN Global Compact

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.

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 Audits", 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.

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.

See full details of Snam's whistle-blowing process and data

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 2021. As at the end of 2021, 175 enterprise risks and 56 opportunities had been mapped.

In light of the most recent trends in this area, starting from 2021, Snam has also launched a series of initiatives aimed at integrating ESG issues into the ERM framework, drawing inspiration from leading practices on the subject, such as CoSO ERM, CoSO ERM WBCSD (World Business Council for Sustainable Development) and TCFD. In particular, two activities were carried out: the Diagnostic Assessment of the ESG risk areas and the ESG Risk Assessment.
The Diagnostic Assessment was conducted with the aim of identifying the ESG risk areas, based on the sustainability issues identified in the materiality analysis, and assessing the level of maturity of the control measures relating to the identified ESG risk areas.
After this phase, and starting from the results of the study carried out, the Group intensified its activities by launching, for the first time, an extraordinary Risk Assessment campaign with an ESG focus. Preliminarily to this campaign, which involved the entire company perimeter and Top Management, the Group strengthened its ERM methodology from an "ESG" perspective by applying the definition of ESG-related and Climate-related risks within its own model in a completely transversal way to one's own risk portfolio: the link to ESG factors is therefore not reserved for a specific risk category created specifically for this purpose, but is expressed horizontally to all the risk categories through an ERM risk mapping activity on material issues.


Read more about how Snam manages risk

Read an overview of Snam's internal control system and approach to compliance

Discover Snam's Control and Risk Committee


The Sustainability Committee was established on 11 May 2016 and renamed as ESG Committee in 2018. Since 2022 it also oversees the topic of energy transition scenarios.

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 Environmental, Social & Governance Committee (ESG) which, from May 2019, replaced and supplemented the Sustainability Committee, in the company since 2016.

Discover Snam's Committees


Discover Snam’s Corporate Governance system


Read about the main risks managed Snam has identified


Read the 2021 Report on Corporate Governance and Ownership Structure

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20 May 2022 - 17:30 CEST