Whistleblowing
Snam has adopted a Procedure 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 whistleblowing procedure defines a process for receiving reports about presumed irregularities, analysing this information and determining any action to take
Since long time, Snam – in the context of the process aimed at managing the reports received (so called whistleblowing procedure) set up specific channels of communication, as specified in the Policy. In addition to Snam, the Subsidiaries also make reference to such channels.In order to guarantee the most excellent levels of independence, last July 2016 Snam modified the Policy to entrust an external person (Ombudsman) with the management of the said channels of communication and the specific task of guaranteeing that the receipt and analysis of every report received is performed applying the utmost confidentiality criteria necessary to protect the integrity of any reported persons and the effectiveness of the investigations.Anyone who receives a report coming from outside the required channels must promptly send the original copy of the same to the Ombudsman who must also receive the documentation, if any, pertaining to the reported events, as well as the outcome of any investigations already conducted on the matter.
The Report may concern any information relating to possible violations, conduct and practices that are not compliant with that established by the Snam Code of Ethics and/or which can cause damage or prejudice, even if only to image, to Snam or to Subsidiaries, relating to the Snam Staff or Third parties, and relating to any of the following matters:
- Internal Control System;
- other matters (such as, for example: violation of the Snam Code of Ethics, corporate administrative liability pursuant to Legislative Decree no. 231/2001, HSE matters, mobbing, security, anti-corruption, violation of business ethics, etc.).
Anonymity guarantee
All organisational units/positions of Snam S.p.A. and of the related subsidiaries concerned with the receipt and processing of reports are required to guarantee the utmost confidentiality and anonymity of the reporting parties, and to this end, they must use suitable communication criteria and methods to ensure the integrity of the people mentioned in the reports, as well as the anonymity of the reporting parties, so as to prevent the latter from being subject to any form of retaliation.
Investigation
The Ombudsman is supported by the Internal Audit function in performing the necessary
investigations with regard to the reported events through one or more of the following activities,
ensuring that such stages are carried out as quickly as possible, whilst guaranteeing the
completeness and accuracy of the investigation activities:
1. Preliminary investigation;
2. Investigation;
3. Audit;
4. Corrective action monitoring.
The channels of communication provided are as follows
- OMBUDSMAN SNAM – Piazza S. Barbara, 7 (20097) San Donato Milanese (MI)
- vocal box: +39 02/37039230;
- email: segnalazioni@snam.it.
| Reports received | 2019 | 2020 | 2021 | |
|---|---|---|---|---|
| Reports received and processed | 11 | 10 | 6 | |
| relating to the Internal Control System | 1 | 5 | 4 1 | |
| relating to accounting, auditing, fraud, etc. | - | - | - | |
| relating to other matters (breaches of the Code of Ethics, administrative liability pursuant to Legislative Decree no. 231/2001, HSE, mobbing, security, anti-corruption law, etc.) | 10 2 | 5 | 5 3 | |
| Reports dismissed due to lack of evidence or because untrue (n°) | 6 | 3 | 2 4 | |
| Reports resulting in corporate disciplinary or managerial action and/or referral to a legal authority | 5 | 5 | 0 | |
| Reports in the process of examination (n°) | 0 | 2 | 6 6 | |
1 Of which 3 also related to other matters.
2 Includes management of 4 additions relating to 3 reports received during 2019.
3 Of which 3 also related to Internal Control System.
4 Referring to reports received in 2020.
5 By "management", we also mean organisational/procedural interventions relating to actions
to improve the Internal Control and Risk Management System (SCIGR).
6 The INTAU analyses have been completed. 4 reports are in the process of being filed by the
competent Supervisory Bodies; the remaining 2 reports are being examined by other corporate
functions.
03 March 2023 - 09:47 CET