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 Guideline, 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, U.S Foreign Corrupt Practices 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 Guideline 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.
The Anti-Corruption Guideline applies to Snam and its Subsidiaries and is brought to the attention of the other stakeholders.
The Anti-corruption Guideline extend to public officers, private individuals
The Anti-Corruption Guideline, is the reference document ofSnam’s Anti-Corruption Compliance
Programme, and is aimed to provide a systematic 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.
Key developments in the Anti-Corruption Guideline 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 and Subsidiaries relations with, relating to or involving a Business Associate must be conducted in accordance with the provisions of the Guideline and the related Anti-Corruption instruments.
Snam in 2014 received the highest score possible from Transparency International Italy for the communication of its Anti-corruption programmes and activities. In 2016, Snam and Transparency International signed an agreement to develop a partnership within the Global Corporate Supporters Forum promoted by the same non-governmental organisation. By virtue of the agreement, Snam has thus become the first Italian company to join the international partners of the Forum, which was created with the aim of bringing together companies that stand out for integrity in business management, in accordance with the standards of good governance, transparency and accountability promoted by Transparency International, as part of the global commitment against corruption and in favour of ethical business conduct.
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Anti-corruption compliance in action
Since 2010, at the behest of the Snam Board of Directors, the company's organisational structure
has been adjusted with the creation, within the Legal, Corporate Affairs, Compliance and ERM
Department, of a function dedicated to combating corruption and spreading a culture of business
ethics and integrity, namely the Business Integrity Unit.
The Business Integrity Unit:
- provides legal assistance to the business units of Snam and subsidiaries;
- identifies and assesses the risks of corrupt offences being committed, based on the results of integrity due diligence conducted on all Business Associates;
- ensures constant monitoring of developments of legislation and jurisprudence;
- elaborates and updates Snam Anti-Corruption instruments, and monitors their respect, in order to ensure effectiveness and real implementation of the relating Compliance Programme;
- 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 guideline. They must clearly understand and be aware of the
crimes, risks, personal and administrative responsibilities for individuals and the group, the
actions to be taken to combat corruption, and the penalties in the event of violation of the law,
including corporate rules on Anti-Corruption (both for individuals and for Snam).
Snam's commitment to raising employee awareness of anti-corruption issues was structured as follows:
- training course on anticorruption provided to all employees
- Anti-Corruption integrity due diligence carried out to all Business Associate (about 7,400 per year in 2021)
- adoption of the Anticorruption Guideline and updating of the regulatory instruments concerning the Anticorruption Compliance Programme, in line with the company regulatory framework and with the existing laws and best practices in the field (national and international).
From 2013, 16.350 hours of training were provided to all employees.
Anti-corruption Compliance Programme monitoring
From 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, has always been managed in collaboration with a leading external law firm, which carried out a review of the state of implementation and of the regulatory framework of the Anti-Corruption Compliance Programme and the level of employee awareness of the relevant safeguards. This analysis has always confirmed 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.
The Charter of Ethical Principles of Transparency International Italia
Snam has always tried to encourage virtuous behavior to foster the integrity of its organization and, by virtue of this commitment, collaborated in updating with Transparency International Italy and other companies such as Enel, Edison, Ferrovie dello Stato and Marsh.
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 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 theRreporting of Programme 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 "Organizational Transparency"). Transparency International Italia indicated that the Anti-Corruption regulatory framework was an example of "absolute excellence".
Since 2016 Snam has been a Top Partner of Transparency International, Italian Chapter.
28 October 2022 - 12:03 CEST