Snam is aware to be a relevant player in the industrial sector and in the market in which it operates and that it assumes a role of responsibility in respecting human rights and in safeguarding the well-being of the people who work for the company (employees), and who collaborate with it (suppliers and business partners), as well as the communities in which it operates
Snam promotes a policy aimed at the concrete implementation of the United Nations Universal Declaration of Human Rights, the Fundamental Conventions of the ILO, the OECD Guidelines for Multinational Enterprises and the principles enshrined in the United Nations Global Compact, which it joined in 2009
In developing both its international business activities and those in which it participates with partners, Snam is inspired by protecting and promoting human rights. These rights are the inalienable and inescapable prerogatives of human beings and the basis for building societies based on the principles of equality, solidarity, repudiation of war and the protection of civil and political rights, social, economic and cultural rights and so-called third-generation rights (the right to self-determination, peace, development and environmental protection).
Snam protects individual freedom, in all its forms, and rejects any kind of discrimination, violence, forced or child labour. Particular consideration is given to recognising and protecting the dignity, freedom and equality of human beings, protecting labour and trade union freedoms, health and safety, as well as the system of values and principles in relation to transparency and sustainable development, as affirmed by international institutions and conventions.
In this regard Snam promotes a policy aimed at the concrete implementation of the United Nations Universal Declaration of Human Rights, which has direct applicability to the world of business today and is the foundation of the Human Rights Principles of the UN Global Compact, the Fundamental Conventions of the ILO, the OECD Guidelines for Multinational Enterprises and the principles enshrined in the United Nations Global Compact, which it joined in 2009. Snam adheres to the UN Guiding Principles on Business and Human Rights, which is the key normative framework for engagement and provide conceptual and operational clarity on the policies and processes companies should develop and implement in order to ensure that they meet their responsibility to respect human rights. In addition, the protection of Human Rights is part of Snam's procurement processes, and given the relevance that such topic has for the Company, corporate due diligences are also aimed at verifying the Health, Safety and Quality conditions of our third parties, as well as their related policies.
Therefore Snam adopted an approach to the issue of human rights based on principles and criteria defined in the human rights policy, in line with the principles and guidelines mentioned above.
In 2021, Snam didn't find violations regarding human rights, thus there was no required implementation of mitigation plans and related corrective actions.
RESPECT FOR FUNDAMENTAL RIGHTS AND ACTIONS TAKEN TO PROTECT THEM
Snam is committed to constant dialogue and exchange with its stakeholders in order to identify the main areas of protection and monitoring of human rights. Having also assessed the type of business and the geographical area in which the company operates, Snam considers the issue of the protection of human rights connected in particular to the following aspects:
Snam protects the right to decent work, explicitly prohibiting all forms of forced labour, child labour and human trafficking, pursuing a zero-tolerance strategy. Snam ensures stable and continuous employment in a safe and secure environment. 92.2% of the company’s contracts are permanent and several management systems certified in accordance with ISO 45001/OHSAS 18001 (the occupational health and safety standard) are in place. Initiatives have been introduced to encourage safe and responsible behaviour by all workers, such as the Zero Accident Award. Read more about the safety culture in Snam
Staff exposed to specific risk factors are subject to health monitoring by company physicians. Occupational health and safety measures extend not only to employees, but also to suppliers. Read about initiatives as the Contractors' safety prize in the role of suppliers and contractors
Snam implements various initiatives aimed at improving the quality of life of employees and their families with the aim of facilitating work/life balance. Some of the measures put in place by Snam are: the availability of different types of flexible working patterns, the expansion of the Smart Working programme, the flexibility of incoming and outgoing working hours by introducing the ‘short Friday’, whereby employees can end their working day from 1 p.m. onwards. Read about the welfare system in Snam
Snam also believes it is of fundamental importance to protect and support parenthood. An Employee Resource Group (ERG) has thus been set up to focus on this issue, in order to create a community of relatives, caregivers or people who are curious about the subject, with the aim of providing support and awareness to solve the challenges of achieving work/life balance, and to transfer the many skills that can be learned while raising a child to work, and vice versa. Read about the Snam's support to maternity in the importance of diversity
Snam prevents and rejects any form of discrimination in individuals’ personal, cultural and professional sphere, violence and corruption, whether direct or indirect, and any form of harassment, intimidation and/or sexual, psychological, physical or verbal abuse.
In order to create a working environment free of discrimination, in 2019 Snam set up a specific corporate Diversity & Inclusion policy. In early 2020, it also launched the Inclusion Team, a group aimed at representing diversity and introducing initiatives to support a culture of inclusion, and in 2021 it published its Harassment Policy. To encourage diversity and inclusion within the company, Snam has also enhanced the presence of women and encouraged the integration into company processes of people with a disability (117 people). Read more about the numbers on the Diversity page
In order to promote diversity and inclusion, Snam has created four Employee Resource Groups (ERG) of which one is dedicated to increase the awareness and knowledge of LGBTQ+ (Lesbian, Gay, Bisexual, Trans, Queer and others) issues and one dedicated to disability, thus nurturing a culture that can help break down limiting stereotypes. Within these ERGs, company initiatives can be proposed, issues and concerns can be discussed, and a space for dialogue, growth and support is created. It is also possible to participate in exchange and comparison meetings with other companies and to listen to external speakers in order to give the people in the community all the tools they need to discuss these issues (with children, friends, relatives and acquaintances) outside the community.
Finally, as proof of the company’s commitment in this area, Snam joined Valore D, an association of companies that promotes female leadership, talent and diversity. Learn more about Snam’s partnership with Valore D and the Diversity&Inclusion issue in the page about Diversity
Snam is committed to ensuring equal opportunities for all employees and colleagues, at all stages of employment and professional growth, based solely on merit and skills.
The Diversity & Inclusion policy was enhanced with two new appendices: the first on gender equality, the second on recruitment (both introduced in 2020) and the third on harassment at work (introduced in 2021).
With the aim of developing a community in which employees can use their talents to improve, innovate and contribute to their professional success, Snam has created 4 Employee Resource Groups (ERG) of which one is focused on STEM subjects, generating networking opportunities and helping the next generation to approach STEM subjects, with the aim of creating a balanced pipeline of new talent in the energy sector.
With regard to the gap between women and men, Snam is constantly working to ensure equal opportunities by improving the gender pay gap in line with trends in recent years, thanks to the consolidation of actions aimed at improving the gender balance within the company. Read more about all the initiatives in the page about Diversity
Confirming its growing commitment in this area, for the second year in a row Snam is among the 418 companies at global level included in Bloomberg’s 2022 Gender-Equality Index (GEI). Read more about the remuneration system on the Workers at the Core page
Snam guarantees the right to freedom of association through the freedom to belong to a trade union, promoting and protecting the social and economic interests of all employees. At the same time, Snam promotes freedom of opinion and education by involving employees in various discussion activities in order to identify improvement actions, such as a workshop dedicated to materiality analysis. Learn more about materiality analysis
Snam undertakes to protect the right to collective bargaining by taking part in collective negotiations and holding periodic consultations with employees’ trade union representatives on working conditions, remuneration and dispute resolution. Read about this issue in the Trade Union activities
Snam believes that in order to construct energy infrastructure, it needs to listen carefully to the local community and directly engage with them. Snam’s approach is to understand the needs of the socio-economic and environmental context in which the project is to be incorporated. Listening and comparing with the region leads to identification of shared value projects to be implemented in the region in question. For example, for the projects that Snam has conducted in Minerbio and plans to conduct in Abruzzo and Puglia, a special information area has been created. Read about it in the mini-websites Progetto Puglia, Snam for Minerbio and Snam for Abruzzo (available in Italian only)
Assessments of the effects on the environment cover all the phases of the work, location, design, construction, operation and decommissioning life cycle. These assessments are completed as part of the Environmental Impact Assessment (EIA) procedure, at the end of which the competent administrations, both at central and local level, issue the authorisations required by current legislation. Read about the Environmental Impact Assessment in the page dedicated to Biodiversity
Snam, in the development of projects for the construction of its energy infrastructures, compensates for the laying of the gas pipeline on land owned by private individuals or communities / public entities, with specific compensation according the methane pipeline easement dimensions and with compensation for the tenants of the funds (both private / public entities or communities that have rights of use of the land concerned). In many cases, agreements are entered into with the professional organizations of farmers present in the area which ensure further protection for their members.
In relation to the construction of major works (compression plants or large methane pipelines), Snam assesses the direct and indirect economic and social impact on the region and local communities using Social Impact Assessment tools and methods.
Snam has created Fondazione Snam in order to make available to the region and communities the skills and abilities that throughout the company’s history have contributed to the innovation, progress and social growth of the country through the construction and management of complex infrastructure. Read more about Fondazione Snam
Snam undertakes to protect information relating to its employees and, more generally, to its stakeholders, generated or acquired internally and in business relations, and to avoid any improper use of such information. Snam intends to ensure that the processing of personal data is completed in full respect of the rights and fundamental freedoms, as well as the dignity of the data subjects, as set out in current legislation.
Learn more about privacy protection
SNAM’S COMMITMENT TO HUMAN RIGHTS PROTECTION
In compliance with the principles of the Code of Ethics, the provisions of the Organisation, Management and Control Model adopted by Snam and the rules contained in corporate policies, Snam adopts a dynamic approach to risk assessment through periodic assessment and monitoring of relevant indicators, also supported by an integrated risk assurance and compliance system, with a view to continuous improvement and review of corporate risk mapping.
With the aim of promoting virtuous behaviour along the entire value chain, as well as to better ensure its own control in this area, Snam has developed structured processes in terms of both risk management and compliance.
With regard to the enterprise risk management process, metrics have been introduced to assess events and map their impact in relation to human and labour rights. These assessments are conducted across all risks and opportunities identified as part of the risk management process, and complement other business impact assessments. Learn more about the ERM process
With regard to compliance aspects, Snam has introduced a process for monitoring the compliance of its suppliers, aimed at extending the due diligence activities completed on third parties to aspects more closely related to the health and safety of workers and financial stability, as well as reputational and technical aspects (Learn more on Suppliers' portal).
Snam also has a supply chain qualification system that aims to verify not only the supplier’s current capabilities, but also its future potential, according to criteria of objectivity, transparency and traceability. There are additional requirements for more critical product categories, such as the possession of certified management systems in accordance with international standards (e.g. ISO 9001, OHSAS 18001/ISO 45001, ISO 14001).
Once the qualification process has been successfully completed, following a tendering process, the contract is concluded. In this phase, the issue of rights is taken into account by means of a series of contractual clauses detailing the requirements and obligations that the supplier must fulfil with regard to regulatory, remuneration and contractual conditions for its employees, as well as occupational health and safety.
Thanks to this process, assessments of the establishment and/or continuation of a business relationship with a Snam business partner can never be made without passing this preliminary due diligence phase, i.e. the absence of critical indicators relating to working conditions, the protection of workers’ health and safety, the correct and complete payment of salary, insurance and social security payments and, lastly, financial solidity.
Snam conducts reputational due diligence on all its third parties, at the various stages of the relationship, and the aspects related to the protection of human rights that may arise from such analyses are always taken into due consideration, even when assessing new business relationships, such as joint ventures, acquisitions or mergers.
The extended due diligence process aims to ensure respect for the human rights of greatest importance given the activity and geographical context in which the Group operates, such as those related to working conditions (discrimination, forced and child labour, restrictions on freedom of association and collective bargaining, fair remuneration and health and safety), as well as those related to the freedom of the individual, such as the right to privacy and the processing of personal data of all those who work to achieve Snam’s objectives.
In carrying out the due diligence process, Snam considers interactions with all its main stakeholders, paying particular attention to the most vulnerable social groups, as set out in the Group’s Code of Ethics:
- Women who work for Snam
- People with disabilities
- Local communities.
Within the supply chain, Snam is also committed to promoting an occupational health and safety and environmental protection culture and good practice, as well as upholding international standards on labour law, ensuring that all its suppliers are familiar with the 231 Model and the principles of the Code of Ethics, and disseminating the ten principles set out in the Global Compact with a view to spreading the values contained therein.
In order to protect the integrity of supply chain sustainability and to involve and commit suppliers/subcontractors more closely to the principles and values considered indispensable and to the most stringent reputational requirements, Snam has drawn up an ‘Ethics and Integrity Pact’. Learn more about the ethics and integrity pact with suppliers
In addition, to further protect the integrity of its supply chain, Snam allocates all of its procurement through contracts that contain explicit sustainability-related clauses (ESG factors).
The requirements for suppliers are contained in the Code of Ethics. For more information, consult the Code of Ethics for Snam suppliers and the Group’s Supplier Portal.
The issue of human rights, as well as the "just transition" approach, are issues that the Sustainability and Social Impact department analyzes promptly and which it assesses in the light of the operating context, the evolution of current legislation, based on benchmarks and comparison with external realities. Many functions collaborate in the management of this issue, from Legal to HR, from Supply Chain to Security, based on the declination of the human rights aspect. The projects and initiatives connected to them are mainly developed through collaboration with the Snam Foundation.
Snam undertakes, following the due diligence process, to implement all corrective actions necessary to mitigate the potential impacts of risks on human rights and to implement a continuous internal and external monitoring system, in order to verify respect for fundamental rights and prevent any irregularities.
In order to manage any irregularities or breaches of the principles contained in its Code of Ethics and Human Rights Policy, there is a specific reporting system which, as indicated in the Guideline on ‘Anonymous reports received by Snam and its subsidiaries’, is accessible to all employees and colleagues, as well as to third parties (it is available on the website and through various channels). It defines a detailed process for managing, analysing and investigating any irregularities reported, as well as for taking measures and mitigating actions.
In order to protect against any violation of human rights, a disciplinary system is in place to sanction non-compliance with corporate principles and rules for all individuals within Snam. Snam’s Supervisory Board notifies the competent departments of any breach and, in conjunction with the Human Resources department, monitors the application of disciplinary sanctions.
Any corrective measures taken must be proportionate to the extent of the irregularity and the act challenged.
Snam also constantly monitors the performance of its suppliers in the execution phases of the contracts awarded, using various tools:
- Feedback: questionnaires filled in periodically by the contract manager
- Technical audits: random site visits to check the application of and compliance with legal and contractual requirements
- Rating Index (RI), an assessment that takes into account compliance with technical, environment, health and safety (EHS) contractual requirements, agreed delivery times and the establishment of a constant committee relationship throughout the contractual period (behaviour).
During 2021, 810 pieces of feedback were collected (151 suppliers), 389 contracts were analysed, 4,358 checks were conducted on the regularity of contributions of 1,811 suppliers and second tier suppliers (+2.4% respect to 2020), and the assessments from the RI showed an overall improvement, testifying to the effectiveness of sharing know-how and best practice in the way that Snam does along the entire supply chain.
If audits find any irregularities or breaches of contracts and agreed standards, this may result in reports of anomalies or critical issues, sometimes leading to Snam deciding to limit, suspend or even revoke the qualification of the non-compliant supplier. During 2021, 29 measures were adopted within this scope.
Ongoing supplier training is another tool used by the Group to promote respect for human rights throughout the supply chain and to prevent breaches and irregularities.
Finally, the Supplier Portal is also fundamental for accompanying suppliers on a path of continuous improvement. It is through the portal that Snam implements its procurement policy, with absolute transparency, traceability and completeness of the information published, while also sharing and disseminating sustainability issues, including respect for human rights.
20 October 2022 - 15:54 CEST