Business ethics and governance
In 2020 Snam has been selected as an active member of the Corporate Governance Committee of BIAC (Business at OECD) and participated in the World Economic Forum's "ESG and Corporate Governance" round table
Snam keeps on to collaborate with Transparency International : in 2020 the Company took part in the Business Integrity Forum of Transparency International Italia, where Snam shared its experience in several panels and in the institutional round table "Toward G20/b20 Italian Presidency"
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.
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.
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 2020. As at the end of 2020, 144 enterprise risks and 31 opportunities had been mapped.
The Sustainability Committee was established on 11 May 2016 and renamed as ESG Committee in 2018.
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.
16 April 2021 - 10:03 CEST