Code of ethics

Code of ethics

Snam code of ethics visual

Snam’s Code of Ethics sets out the expectations for business conduct that the company and its employees recognise, accept and promote.
It is the articulation of Snam’s values; it guides the performance of corporate activities and inspires decision-making and strategic thinking.

Code of Ethics as the articulation of Snam’s values

The Code of Ethics defines how Snam and its people interact with many suppliers, customers, fellow employees, communities and diverse stakeholders. These interactions must be carried out in a transparent, honest and fair way, in good faith, and in full compliance with antitrust and Anti-corruption rules and regulations. The Code of Ethics requires that all Snam employees respect its principles and details in their actions and behaviour while performing their functions according to their responsibilities.

Compliance with the code is a fundamental component of work quality and professional performance.

Top-level commitment for business conduct

The Code of Ethics was most recently approved by the Snam Board of Directors in 2013. The text, subject to periodic review, albeit in continuity with the provisions of the previous version (approved in 2001), presents some significant changes of innovation, including:

  • The Code of Ethics is at the heart of the internal control and risk management system and thus a central part of Snam’s corporate governance
  • The document emphasises Snam’s culture and the peculiarities of the regulated sector in which it operates, particularly concerning relations with authorities and European natural gas regulations.

What is the purpose of Snam’s Code of Ethics?

The Code of Ethics is a central corporate document for how Snam operates because:

  • It sets out the principles that inspire and guide Snam’s activities, such as respect for the law, fair competition, honesty, integrity, propriety and good faith, in respect of the lawful interests of customers, employees, shareholders, commercial and financial partners and the communities where the company has a business presence
  • It sets out the general principles of sustainability and corporate responsibility
  • It governs, among other things, Snam’s workplace, relations with stakeholders and suppliers, and the protection of personal data

The Code of Ethics is also at the heart of the internal control and risk management system, including:

  • Segregation of duties among those responsible for authorisation, execution or control
  • Corporate determinations capable of providing the general standards of reference to govern corporate activities and processes
  • Formal rules for the exercise of signatory powers and internal powers of authorisation
  • Traceability made possible with information systems that identify and reconstruct the sources, information and controls carried out to support the formation and implementation of the decisions of the company and how to manage the financial resources

The Code of Ethics reflects, among other things, a compulsory general principle of the Organisation, Management and Control Model adopted by Snam pursuant to the Italian regulations on the “ Administrative liability of legal entities deriving from criminal offences" contained in Legislative Decree No. 231 of 8 June 2001.

The Code of Ethics in practice

A two-year training programme on the code of ethics, model 231 and Anti-corruption was provided to all employees equipped with personal computers. Completed in 2014, 3,917 people participated in the training for a total of 11,751 hours.
To oversee the Code of Ethics and ensure it is followed, Snam has a Watch Structure as required by Law 231. In its role as Code of Ethics Supervisor, the Watch Structure responds to:

  • requests for clarification and interpretation of the code’s principles
  • suggestions for applying the code
  • reports of Code of Ethics violations whether discovered directly or indirectly.

Violations of the code of ethics, along with any other kinds of irregularities, should be reported following the established process of whistleblowing.

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27 October 2022 - 17:25 CEST