Report - COP Prototype

2022 Communication on Progress

Snam S.p.A.

Published date

July 20, 2022

No. of questions

Supplemental files

Settala certificate.pdf

CEO Statement

Signed

Governance

Policies and Responsibilities

1. Does the Board / highest governance body or most senior executive of the company:

Issue an annual statement about the relevance of sustainable development to the company

Issue an annual statement that addresses impacts on both people and the environment

Issue an annual statement highlighting a zero tolerance for corruption

Sign off on organizational sustainability targets

Supervise Environmental, Social, and Governance reporting

Regularly review potential risks related to the business model

None of the above

Optional comment

According Italian dlgs. 254 , transposition of the EU directive about reporting, the Board of Directors is responsible for the policies regarding Environment, People, Anticorruption, Human Rights and Health and Safety which every year need to be published in the NFS under the direct responsibility of the Board of Directors itself.

2. Does the company have a publicly stated commitment regarding the following sustainability topics?

	No, this is not a current priority	No, but we plan to have a commitment within 2 years	Yes, and the commitment is focused on our own operations	Yes, and the commitment includes our own operations and the value chain	Yes, and the commitment includes our own operations and the value chain along with communities and society
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Optional comment

All the policies are available on Snam's website. Policy on Labour rights/Decent work is included in the Human Rights policy with specific separate policy for Inclusion & Diversity (including appendices about gender equality, recruiting and harassment). https://www.snam.it/export/sites/snam-rp/repository/ENG_file/Sustainability/Sustainable_development/Policy_human_rights.pdf https://www.snam.it/export/sites/snam-rp/repository/ENG_file/Sustainability/Sustainable_development/Policy_Diversity_inclusion_eng.pdf https://www.snam.it/export/sites/snam-rp/repository/file/Sostenibilita/sviluppo-sostenibile/Policy_Diversity_inclusion_parita_genere_eng.pdf https://www.snam.it/export/sites/snam-rp/repository/file/Sostenibilita/sviluppo-sostenibile/Policy_Diversity_inclusion_recruiting_eng.pdf https://www.snam.it/export/sites/snam-rp/repository/file/Sostenibilita/sviluppo-sostenibile/Policy_DI_Harassment_eng.pdf https://www.snam.it/export/sites/snam-rp/repository/ENG_file/Sustainability/Sustainable_development/Politica_HSE_Snam__eng.pdf https://www.snam.it/export/sites/snam-rp/repository/file/Governance/procedure/anticorruzione/snam_anticorruzione_01.pdf

3. Does the company have in place a code of conduct regarding each of the following sustainability topics?

	No, this is not a current priority	No, but we plan to have a code of conduct within two years	Yes, focused on employee conduct	Yes, focused on employees and suppliers	Yes, focused on employees, suppliers, and other business relationships
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Optional comment

Snam's code of conduct is available on the website: https://www.snam.it/export/sites/snam-rp/repository/file/Governance/codice-etico/Codice_Etico.pdf

4. Has the company appointed an individual or group responsible for each of the following sustainability topics?

	No one is specifically responsible for this topic	Yes, with limited influence on outcomes (e.g., limited access to internal information, limited decision-making authority)	Yes, with moderate influence on outcomes (e.g., has access to relevant information, reports to senior manager)	Yes, with direct influence of some outcomes (e.g., has access to relevant information, includes one or more senior manager with decision making rights	Yes, with direct influence at the highest levels of the organization (e.g., has access to relevant information, includes most senior members of organization)
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Optional comment

Human Rights is a very wide definition which entails different topics which have specific managers appointed separately (for example the discrimination topic is responsibility of the HR manager, decent labour has the HSE manager appointed for environmental aspects and the HR manager for aspects regarding employees behaviour and rights and so forth).

5. Does the company have a formal structure(s) (such as a cross-functional committee) to address each of the following sustainability topics?

	No formal structure	Yes, and with limited influence on outcomes (e.g., limited access to internal information necessary to understand risks, poor representation from relevant departments or functions)	Yes, with moderate influence on outcomes (e.g., it includes representatives of some functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, reports to senior manager)	Yes, with direct influence on some outcomes (e.g., it includes representatives of functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, it involves one or more members of senior management)	Yes, and with direct influence at the highest level of the organization (e.g., full access to relevant information, it involves members at highest level of organization)
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Optional comment

The company has a specific ESG Committee (whose members belong to the Board of Directors) with the highest responsibility for all sustainability issues. Besides internal interfunctional groups are organised to implement ESG projects. For example an internal interfunctional group was established to implement, monitor and update the ESG Scorecard. More precisely, the ESG Scorecard is a tool designed to provide disclosure on the main environmental, social and governance aspects and to assess the performance of the group with respect to targets definedinside the interfuncional group for the coming years.The ESG Scorecard identifies specific annual KPIs and targets in the environmental sphere (natural gas emissions, energy savings, green innovation, land protection and biodiversity), the social sphere (welfare, employee engagement, safety, gender diversity, responsible and sustainable supply chain, local communities) and the governance sphere (governance structure and its functioning, infrastructure reliability, anti-corruption, sustainable finance), with targets covering both next year and the 2025 planning horizon. The ESG Scorecard into action process is annual. Led by the ESG Officer, the process of publishing involves all the competent functions of the Company and its subsidiaries, aimed at revisiting and updating the ESG areas and the reference KPIs, with an aim of demonstrating continuous improvement and maintaining a constant dialogue with stakeholders and the market. Another interfunctional group is the Inclusion Team, a team of 40 people representing all diversities in the Group, this group is managed also with the help of a steering committee of managers belonging to the Leadership Team in order to share the initiatives and collects suggestions from the executives.

Prevention

6. Does the company have a process or processes to assess risk?

	No, this is not a current priority	No, but we are planning to develop one in the next two years	Yes, related to our own operations	Yes, related to our own operations and entire value chain and other business relationships
Human rights risks
Labour rights risks
Environmental risks
Corruption risks

Optional comment

The Enterprise Risk Management (ERM) unit, located at the second level of the ICRMS, reports directly to the General Counsel and plays a key role in the integrated management of enterprise risks for all Group companies, using an ERM Model. This Model, which operates in line with the indications of the CoSO Framework and of the Corporate Governance Code, as well as with international best practices, enables the identification, assessment and monitoring of risks and opportunities, both current and prospective, associated with Snam’s corporate strategy. In actual fact, the risk is defined as an effect of the uncertainty on the targets of the StrategicPlan and can be negative or positive in scope. The results of the risk and opportunity assessment and monitoring activities and the related mitigation measures are presented regularly to the Control, Risk and Related-Party Transactions Committee, the Board of Statutory Auditors, the Supervisory Body and the Board of Directors of Snam. In this context, the ERM unit also carries out awareness-raising and training activities for executive and non-executive directors with regard to the applied risk management methodologies and the evolution of Snam’s ERM model. The results are also shared with the Internal Audit department, which uses them when preparing audit plans; the Strategic Planning department, which assesses coherence with the risk assessments and analyses of the Strategic Plan; the Sustainability department, to support planning activities and to define strategies for managing ESG topics that are relevant to the Group.

6.1. During the assessment of risk, which business relationships are reviewed?

	A few suppliers or business relationships [approximately less than 25 %]	Several suppliers / business relationships (i.e., first tier or other high priority) [approx. 25 - 50 %]	Most suppliers / relevant business relationships [approx. 51 - 99 %]	All suppliers / relevant business relationships outside the supply chain
Human rights risks
Labour rights risks
Environmental risks
Corruption risks

Optional comment

Identification of risky events related to corporate process and of external risk factors that may affect the achievement of corporate objectives, both through interviews with Staff and Business Managers, responsible for the implementation of the plans aimed at an effective risk monitoring, and specific analyses of the operating processes of each Company and of the corporate Strategic Plan.

7. Does the company have a due diligence process through which it identifies, prevents, mitigates, and accounts for actual and potential negative impacts on sustainability topics?

	No, this is not a current priority	No, but we are planning to develop one in the next two years	Yes, related to our own operations	Yes, related to our own operations and entire value chain and other business relationships
Human rights risks
Labour rights risks
Environmental risks
Corruption risks

Optional comment

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. 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: - Employees - Women who work for Snam - Children - Subcontractors - 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’. 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.

7.1. During the due diligence process, which business relationships are reviewed?

	A few suppliers or business relationships [approximately less than 25 %]	Several suppliers / business relationships (i.e., first tier or other high priority) [approx. 25 - 50 %]	Most suppliers / relevant business relationships [approx. 51 - 99 %]	All suppliers / relevant business relationships outside the supply chain
Human rights risks
Labour rights risks
Environmental risks
Corruption risks

Optional comment

Within the Snam Anti-Corruption Guidelines, for preventive purposes, Snam has identified three levels of action to be taken in respect of any Business Associate (among which suppliers) that has or intends to have a relationship with the Company: 1) ANTICORRUPTION DUE DILIGENCE - Prior to establishing any relationship with a Business Associate, every Department concerned must consult the Ethics & Antibribery Unit and, if applicable, request the necessary due diligence to the competent function; 2) ETHICAL AND INTEGRITY PACT - When the Business Associates are suppliers or subcontractors, they are asked to share and comply with the Company’s essential principles in terms of legality, responsibility and business ethics (including human and labour rights), in conducting their activities; 3) CONTRACTUAL CLAUSES - Contractual clauses bind Business Associates to comply with the principles of the Code of Ethics, Organizational and Management Model, Guidelines and Rules and establish that the Company has the right to terminate the contract in the event of breach of the obligations accepted and applicable regulations. In order to intercept any potential red flags (in terms of “criminal infiltration” or “inadequacy of the safeguards from a HSE point of view (or undue savings towards personal protective equipment)” such due diligence processes is supported by additional documentation required to all suppliers which are also assessed on Health Safety and Environment Issues and financial stability matters. The Anti-Corruption Guideline applies to Snam and its Subsidiaries and to all the Persons of Snam (which include all the persons who act on behalf of the Company, within their own responsibilities and activities)

Concerns and grievance mechanisms

8. Are there any processes through which members of the company’s workforce can raise concerns about the company’s conduct related to human rights, labour rights, environment, or anti-corruption?

No, this is not a current priority

No, but we plan to within two years

Yes, we have an informal process (e.g., through supervisors, others)

Yes, we have a formal process

Optional comment

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 available to the public in our website. 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.

8.1. Please provide additional detail regarding the process(es) the company has through which members of the company’s workforce can raise concerns about the company’s conduct.

	No	Yes
Is the process communicated to all employees/workers in local languages?
Is the process available to non-employees (e.g., contractors, vendors, suppliers)?
Is the process confidential (e.g., whistleblowing process)?
Are there processes in place to avoid retaliation?
Can concerns be raised about suppliers or other business relationships (e.g., clients, partners, etc.)
Other (Please provide additional information)

Optional comment

Everyone, included Snam's workforce, can send reports through three channels (vocal box, email and mail box for the Ombudsman) available on Snam's website. Employees are also trained about it in the compliance programme training. 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. 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. 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.

9. Does the company provide or enable access to effective remedy to right holders / stakeholders where it has caused or contributed to the adverse impact?

	No process to enable remedy to stakeholders	Remedy available to some stakeholders (i.e., some geographies, employees only)	Remedy is available to all affected stakeholders	Remedy is available to all stakeholders, and suppliers are expected to have similar policies
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Optional comment

Snam set a whistleblowing procedure, available to all stakeholders, wich defines the process for receiving reports about presumed irregularities, analysing this information and determining any corrective action to take. Snam's suppliers are expected to have a remedy policies but it is not a mandatory requirement for them to have it.

Lessons

10. How does the company capture lessons regarding each of the following sustainability topics?

	No lessons are regularly captured	Conducts root cause analyses/investigation of major incidents	Conducts root cause analyses/investigation and changes organizational policies, processes, and practices accordingly	Systematically conducts root cause analyses/investigation and leverages learnings to influence both internal and external affairs
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Optional comment

Here some example of how Snam captures lessons: 1) Regarding Decent Work, Snam is certified according ISO 45001 (the occupational health and safety standard) and in the management system are foreseen near miss collection, accident risk analysis, audit and periodical HSE meeting with every direction aimed to present news in the regulations, learned lessons and accident debriefing if any should occur. 2) Regarding Environment, Snam is certified according ISO 14001 and in the management system are foreseen audit, analysis of possible problems and non-compliances with the preparation of improvement plans shared with the interested functions. Besides, Snam with its committment towards decarbonization, energy transition and with its fight to climate change and methane leakege participates to peers groups and initiatives such as Marcogaz or OMGP of ONU in which shares its experiences and lesson learned. Similar partnerships are organised also with suppliers in order to help them decarbonize their business. 3) Regarding Corruption, Snam participates to international roundtables and associations on the Anti Corruption topic sharing its experiences, in particular: . Business at OECD, an international association representing more than seven million organisations worldwide, in which Snam participated as a member in the anti-corruption, integrity and transparency events. • Transparency International Italia, an anti-corruption association that organises forums and events to raise awareness and fight corruption. In 2021, Snam participated in the Business Integrity Forum and the Annual Event 2021 through speeches and round tables. • Partnering Against Corruption Initiative (PACI), an initiative focused on the fight against corruption promoted by the World Economic Forum, of which Snam is a member. • Business Forum 20, as part of the work of the Integrity & Compliance Task Force, which brings together companies and organizations engaged in anticorruption, compliance, integrity and transparency issues, with increasing attention to ESG issues. In 2021 Snam was an active member of this Task Force during the B20 Italian Presidency (as well as in 2020 under the Saudi Presidency).

Executive Pay

11. Is executive pay linked to performance on one or more of the following sustainability topics?

Optional comment

The 2021 Remuneration Policy of CEO and strategic managers is linked to ESG (Environmental, Social & Governance) objectives and, specifically, provides for the following, in line with the Company’s sustainable strategy: ■ for the short-term incentive, with a total weight of 20%, there are three specific KPIs linked to sustainability issues: the weighted index of frequency and severity (IpFG) of employee and contractor accidents; the confirmation of the inclusion with respect to a basket of sustainability indices which, from 2021, included Sustainalytics, in addition to Dow Jones Sustainability Index, FTSE4GOOD and CDP climate change; the increase in the value of sustainable financing. ■ for the long-term equity incentive plan, with a total weight of 20% , there are two KPIs related to sustainability issues: reduction of natural gas emissions and representation in terms of gender diversity in the Snam management team. There is a zero tolerance approach about Anti-corruption and an extensive compliance programme applied transversally on the group and business partners and, up to this moment, there wasn't any need to link remuneration to this issue.

Board Composition

12. Percentage of individuals within the company’s Board / highest governance body by:

	Number/Percentage	Not applicable (Please provide additional information)
Total number of board members (#)	9
Male (%)	67
Female (%)	33
Non-binary (%)
In Italy is not possible to collect data regarding sexual preferences.
Under 30 years old (%)	0
30-50 years old (%)	67
Above 50 years old (%)	33
From minority or vulnerable groups (%)
With the exception of non-binary minorities (a data not possible to collect in Italy) there aren't any minorities from vulnerable groups in the board
Executive (%)	11
Independent (%)	67

Data Assurance

14. Is the information disclosed in this questionnaire assured by a third-party?

No assurance for any metrics

Limited assurance for minority of metrics (e.g., GHG emissions only)

Limited assurance for majority of metrics

NFS and Sustainability Report are assured with a limited assurance according ISAEE 3000 criteria issued by IAASB by a third party (Deloitte).

Reasonable assurance for minority of metrics

GHG emissions associated to implants included in the ETS scheme are assured with a reasonable assurance by a third party (DNV GL).

Reasonable assurance for majority of metrics

Other (Please provide additional information)

Optional comment

In the links below are reported our reports and the pages in which is possible to read the Assurance letter. Annual Report (Assurance pages 489- 494): https://www.snam.it/export/sites/snam-rp/repository/ENG_file/investor_relations/reports/annual_reports/2021/SNAM_2021_Annual_Report.pdf Sustainability Report (Assurance pages 246- 248): https://www.snam.it/export/sites/snam-rp/repository/ENG_file/investor_relations/reports/annual_reports/2021/2021_sustainability_report.pdf Regarding the reasonable assurance of GHG emissions associated to implants included in ETS scheme we have 22 certificates issued by DNV business assurance (one for each implant). We uploaded one of them as an example (Settala gas storage implant).

Human Rights

Commitment

2. Does the company have a policy commitment in relation to the following human rights issues?

	No, and we have no plans to develop a policy	No, but we plan to in the next two years	Yes, included within a broader policy	Yes, articulated as a stand-alone policy
Rights of women and/or girls
2019
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
2021
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

Optional comment

On 8 May 2018, the Snam Board of Directors approved the Privacy Guidelines, a document containing the principles governing the proper management of privacy and the internal rules relating to the processing of personal data. The Guideline specifies the actions that must be implemented in accordance with both national and Community legislation on the processing and protection of personal data, as well as the provisions of the Authority and the guidelines of the relevant literature and law, so that the processing of personal data is carried out in accordance with the rights and fundamental freedoms of natural persons and in particular the right to protection of personal data. The Guideline applies to Snam and to its subsidiaries subject to management and coordination activities and is also brought to the attention of other investee companies in order to promote principles and conduct consistent with those expressed by Snam. The Guideline is not public, but the committmente to this right is also reported in the Human rights policy available on the website, https://www.snam.it/export/sites/snam-rp/repository/ENG_file/Sustainability/Sustainable_development/Policy_human_rights.pdf. Here it is possible to know more about the Guideline https://www.snam.it/en/governance-conduct/internal-control-and-compliance/privacy_protection/index.html Here it is possible to read Snam's policy about diversity and inclusion, https://www.snam.it/export/sites/snam-rp/repository/ENG_file/Sustainability/Sustainable_development/Policy_Diversity_inclusion_eng.pdf , this policy has also an appendix dedicated to gender equality, https://www.snam.it/export/sites/snam-rp/repository/file/Sostenibilita/sviluppo-sostenibile/Policy_Diversity_inclusion_parita_genere_eng.pdf

2.1. For each human rights policy, is it:

	Aligned with international human rights standards?	Publicly available?	Approved at most senior level of the company?	Applied to the company’s own operations?	Applied to the company’s supply chain and/or other business relationships?	Developed involving human rights expertise from inside and outside the company?	Other (Please provide additional information)
Freedom of expression
Digital security / privacy
Rights of women and/or girls
Access to culture
Rights of indigenous peoples
Free, prior and informed consent
Rights of refugees and migrants
Access to water and sanitation

Prevention

3. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following human rights issues?

	No engagement on this topic	To better understand the risks/ impacts in question	To discuss potential ways to prevent or mitigate the risks/ impacts in question	To agree on a way to prevent/ mitigate the risks/ impacts in question	To assess progress in preventing /mitigating the risks/impacts in question	To collaborate in the prevention/ mitigation of the risks/ impacts in question
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

Optional comment

Regarding Digital Security, which is also a material topic (see Snam's materiality matrix at page 70 of the Snam Sustainability Report - Infrastructure reliability and resilience, business continuity and cyber security issue) Snam has developed its own cybersecurity strategy based on a framework defined in accordance with standard principles on the subject and has had a dedicated department for a few years now which, comprehensively, deals with addressing and implementing what has been planned at the strategic level, ranging from governance aspects to those that are more predominately technological. More specifically, in order to adequately counter the most modern yber threats, Snam has defined a cybersecurity incident management model intended to prevent, monitor and, when necessary, implement prompt remediation against events potentially capable of harming the confidentiality, integrity and availability of information processed and the I T systems used. At the basis of these activities is a Security Incident Response Team which, by relying on solutions that make it possible to collect and correlate all security events recorded throughout the company’s IT infrastructure, has the task of monitoring all anomalous situations that could have negative impacts for the company and activate, when necessary, suitable containment and remediation actions via the involvement of the technical and business structures concerned. Furthermore, regarding the rights of women, which is a material topic (see Snam's materiality matrix at page 70 of the Snam Sustainability Report - Diversity and Inclusion issue) the Snam Foundation in 2021 has implemented tutoring programmes in 5 high schools in 4 different italian cities involving 100 girls on STEM topics for a total amont of more than 700 hours. Also Snam is very committed on the Diversity&Inclusion as it set company targets and long term variable incentives on this topics and implemented several initiatives and projects such as the "Inclusion week", promoting the study of STEM disciplines (science, technology, engineering and mathematics) among young female students (donating six scholarships for three-year degrees and Master’s degrees to the Polytechnic Institute of Bari to be awarded to female students enrolled in the university’s Faculty of Engineering in the 2020/21 academic year). Snam has also internally created the ad hoc Inclusion Team is an inter-functional group of 40 people representative of the many corporate diversities which promotes a culture of diversity and equal opportunities in order to create an environment that enhances all the peculiarities of which it is composed as much as possible. The Inclusion team has drawn up an action plan “#Snam4Diversity, energia che include” , which includes a series of initiatives aimed at spreading the culture of diversity. Also Snam monitors the gender pay gap since ten years in order to reduce the remuneration differences between women and men until they no longer exist, thus promoting effective gender equality.

4. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this human rights issue?

	Provided internal training/ capacity building for the direct workforce	Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)	Conducting an audit process and/or corrective action plan	Collective Action with peers or other stakeholders to address the issue	Collaboration with governmental or regulatory bodies	Other (Please provide additional information)	No action within reporting period
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

Optional comment

In 2021, regarding digital security, the Security Incident Response Team was able to work without interruption and guarantee its support activities 24 hours a day, seven days a week. With regard to technological development, as mentioned previously, Snam has set in motion an ambitious digitalisation programme that will radically change business processes in the years to come and within which a strong focus on cybersecurity will always be guaranteed. In particular, starting 2020, the foundations were laid and the necessary processes implemented for the safe development of all the nascent Internet of Things initiatives. Firstly, a precise Security by Design process has been introduced, which puts in place compliance for precise requirements and checks for each application and infrastructural development. Additionally, more appropriate security technologies have been defined to support the new capabilities that Snam has acquired and will acquire in the years to come. Snam is very committed on the Diversity&Inclusion as it set company targets and long term variable incentives on this topics and implemented several initiatives and projects such as the "Inclusion week", promoting the study of STEM disciplines (science, technology, engineering and mathematics) among young female students (donating six scholarships for three-year degrees and Master’s degrees to the Polytechnic Institute of Bari to be awarded to female students enrolled in the university’s Faculty of Engineering in the 2020/21 academic year). Regarding the rights of women, the Snam Foundation in 2021 has implemented tutoring programmes in 5 high schools in 4 different italian cities involving 100 girls on STEM topics for a total amont of more than 700 hours. For the empowerment of Women, the Snam Foundation in 2021 launched the "Motivo donna" project based on a small company working on fabrics with the goal of creating a job and income opportunity for women with a fragile background, ensuring a professional development path with a good work life balance. The project involved 4 young women. The micro-company has been started through the installation of a fabrics lab in San Donato Milanese in a space made freely available by Snam and which will host the project for the first 3 years.

5. Who receives training for the following human rights issues?

	No training provided	Select employees	All employees	Contractors	Direct suppliers of the organization	Indirect suppliers of the organization	Other – such as partners, clients, etc.
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

Optional comment

On Digital Security, Snam provides training to all employees through online courses and live sessions or event according to the Company's standards (such as the so called "virtual coffees with.."). Also specific email with learning content on cyber security are feeded to all employees. Regarding the rights of women and girls, Snam in 2021 offered to all the company's employees a course on Diversity and Inclusion within its course catalogue and organized webinar open to all the company population on this topic. In addition to that Snam further enriched its portfolio of external initiatives on the topic by joining the YEP - Young Women Empowerment Program of the Ortygia Business School, aimed at mentoring female students in business and STEM faculties enrolled in a Master’s degree course at the main universities in Southern Italy, with the aim of supporting them. In 2021 Snam also joined the Rock your Mind event organised by Employerland in 2021 as a technical partner. The event combines music and recruiting, mainly targeting girls studying STEM disciplines, with the aim of fostering gender equality and contributing to a culture of diversity and inclusion. (see Snam'sSustainability Report page 142 : https://www.snam.it/export/sites/snam-rp/repository/ENG_file/investor_relations/reports/annual_reports/2021/2021_sustainability_report.pdf)

6. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following human rights issues?

	No monitoring of progress	Review issues on ad-hoc basis	Set annual targets/ goals, track progress over time (internal programs only)	Set annual targets/ goals, track progress over time (internal and external programs)	Other (Please provide additional information)
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

Optional comment

According to the Snam's ERM model each risk is evaluated with respect to different types of impact, operational and cross functional (such as financial, environmental, social etc). Among these cross functional impact types, there is the "social impact" which is measured by the appointed company's department and it takes into consideration the potential impact of the risk event on the human and labour rights and also on the community and territory. In particular, the topics analyzed are those relating to working conditions, the workers'sense of belonging to the company and the diversity and inclusion topic. The Social Impact is evaluated on a yearly based as it is part of the prioritiziation of each corporate risk evaluated within the ERM RIsk Assessment process. The Security Incident Response Team set its annual targets based on company ones and with particular care about the protection and the resilience of technological systems that in case of problems could have an impact on persons. The company maintains a strong partnership both with the Italian Agency for Cyber Security and with peer companies, in particular for matters related the compliance with the national and the European cyber security laws. In the agreements with suppliers, the cyber security goals are disclosed and it is expected that the suppliers get aligned to the Snam's cyber security baseline. Regarding the rights of women and girls, Snam's set its annual targets both within its ESG scorecard process ( which is a tool designed to provide maximum disclosure on the main environmental, social and governance aspects and to assess the performance of the group with respect to certain targets defined for the coming years) and within its remuneration policy. In particular, within the ESG scorecard Snam includes a couple of KPI regarding the SDG 5 (gender equality) and in particular the % of women in executive and middle-management roles and the % of women in succession planning (first and second reporting line); in addition to those KPI the Snam remuneration policy for the long-term equity incentive plan, a weight of 10% for a KPI regarding representation in terms of gender diversity in the Snam management team.

Response

7. During the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to adverse impact associated with the following human rights issue(s)?

	Yes	No	Choose to not disclose	Not applicable (Please provide additional information)
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

Optional comment

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. Snam whistleblowing procedure defines a process for receiving reports about presumed irregularities, analysing this information and determining any action to take. In order to guarantee the most excellent levels of independence, in 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. 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. 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. In 2021, Snam didn't find violations regarding human rights, thus there was no required implementation of mitigation plans and related corrective actions. https://www.snam.it/en/Sustainability/snam_commitments/human_rights.html

8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the human rights principles, including any challenges faced and actions taken towards prevention and/or remediation.

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. The main topics addressed in the last years are welfare, safety at work, considering also the impact of the pandemic, the diversity&inclusion and suppliers. During the reporting period (2021) Snam has taken action to implement the human rights principles as follows: 1) welfare: Snam’s Welfare Plan, created in 2018, continued to evolve year after year, providing to employees services capable of effectively responding to their needs. The “Snammy” platform encompasses all the initiatives of the Welfare Plan and it is organised into five main areas: Family and Education, Health and Care, Well-being and Work-Life Balance, Finance and Savings, Social Commitment. In total, there are 30 services (both corporate and contractual) offered to meet people’s current needs and requirements. Snam is also actively dedicated to supporting employees in the area of parenthood, offering a concrete contribution to encouraging work-life balance through incentives and benefits that go beyond the law requirements. Infact in 2021 paternity leave has been extended by an additional five days in 2021 compared to the legal provisions, in order to provide greater support to families and Snam lead a group of peers in the Generazione Donna initiative aimed to share best pactice about parenting. 2) diversity: Considering Snam’s business characterised by specialised technical skills difficult to find between female graduates gender diversity is a point of attention for Snam to which many initiatives and projects are dedicated. Actually, by 2021, there were 569 women in the company (+12% compared to 2020), representing 16.6% of the company population (+1 percentage point compared to the previous year). Snam has been promoting the study of STEM disciplines (science, technology, engineering and mathematics) among young female students for years. In this regard, in February 2021, Snam donated six scholarships for three-year degrees and Master’s degrees to the Polytechnic Institute of Bari to be awarded to female students enrolled in the university’s Faculty of Engineering in the 2020/21 academic year. In addition to that, in 2021 Snam joined SheTech, the non-profit association created with the aim of bridging the gender gap in the world of technology, digital and entrepreneurship through networking, empowerment and training activities. Snam also joined the Rock your Mind event organised by Employerland in 2021 as a technical partner. The event combines music and recruiting, mainly targeting girls studying STEM disciplines. Also in 2021, Snam further enriched its portfolio of initiatives by joining the YEP - Young Women Empowerment Program of the Ortygia Business School, aimed at mentoring female students in business and STEM faculties enrolled in a Master’s degree course at the main universities in Southern Italy. To celebrate and share inclusion best practice, in 2021 Snam organised “#Snam4Diversity, energy that includes” Inclusion Week for the first time: a week of events dedicated to creating awareness of the diversity present and making the most of it. The week will be held annually. In its first edition, it involved more than 800 employees through a programme of five appointments where important topics such as Inclusive Leadership, Cultures of Respect, LGBTQ+ Inclusion and Disability were discussed with speakers from inside and outside the company. The Inclusion Team created ad hoc by Snam is an inter-functional group of 40 people representative with the aim to create a series of initiatives aimed at spreading the culture of diversity. During 2021, the Inclusion Team promoted 11 new initiatives to spread the culture of inclusion in the company, involving more than 1,800 colleagues in various activities. 3) Safety at work: Snam4Safety is a project aimed at strengthening the safety culture and awareness of employees and contractors. In spite of the difficulties caused by the Covid-19 pandemic, the project continued in 2021, with the completion of a coaching activity for Operations Managers and Prevention and Protection Service Managers (ASPPs), with the support of DSS Sustainable Solutions Italy. The project will continue in 2022, also extending its activities to the nonregulated business companies. As part of the Snam4Safety initiative, a series of awards and trophies have been defined to be awarded based on the achievement of particular safety performances. These include the Zero Injury Award, whereby site employees commit to achieving 365 consecutive days without an injury - both at work and commuting (zero injury target). A tangible award is given to the winning staff each year, in the form of welfare credits. In 2021, 10 teams, amounting to 1,296 employees, received the award. Since the start of the health emergency due to the spread of the Covid-19 virus, an interfunctional team named Crisis Management has been in place The team had the fundamental task of assessing the level of risk to which Snam workers could be exposed and defining the appropriate precautionary and containment measures to ensure not only the protection of workers’ health in all operating conditions, but also the continuity of the service. 4) Suppliers: As part of its procurement activities, Snam actively promotes safe working conditions and the protection of human rights, as set out in its “Human Rights Policy” which contains the principles and criteria that suppliers must adhere to in all phases of their collaboration with the company. The required standards of behaviour and scope of application are checked and controlled during the qualification/accreditation process, at the conclusion of the contract and during audit activities. Besides Snam, when selecting and qualifying suppliers, in line with the Social Supply Chain Policy, promotes the participation of companies belonging to the Third Sector, such as cooperatives, associations and non-profit businesses, providing incentives for its suppliers to adopt similar behaviour in turnand thus generate a multiplier effect. At the end of 2021, there were 83 suppliers belonging to the Third Sector in the Supplier Registry, reaching the target set out in the ESG Scorecard ahead of schedule. Snam has provided work worth 2.5 million euros to these companies, mainly in the areas of providing research services and green maintenance.

Labour

Commitment

1. Does the company have a policy commitment in relation to the following labour rights principles?

	No, and we have no plans to develop a policy	No, but we plan to in the next two years	Yes, included within a broader policy	Yes, articulated as a stand-alone policy	Not applicable (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Reviewed in 2021
Forced labour
Reviewed in 2021
Child labour
Reviewed in 2021
Non-discrimination in respect of employment and occupation
Reviewed in 2021
Occupational safety and health
2019
Working conditions (wages, working hours)
Reviewed in 2021

Optional comment

See HSE policy about Occupational safety and health and the Policy on Human rights for all the other issues. https://www.snam.it/export/sites/snam-rp/repository/ENG_file/Sustainability/Sustainable_development/Politica_HSE_Snam__eng.pdf https://www.snam.it/export/sites/snam-rp/repository/ENG_file/Sustainability/Sustainable_development/Policy_human_rights.pdf

1.1. For each labour rights policy, is it:

	Aligned with international labour standards?	Publicly available?	Approved at most senior level of the company?	Applied to the company’s own operations?	Applied to the company’s supply chain and/or other business relationships?	Developed involving labour rights expertise from inside and outside the company?	Other (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

Optional comment

The HSE policy applies to all the Snam Group's companies and the Human Rights policy applies to all the Snam Group's companies and it is communicated to all people who have a business relationship with Snam. In addition to that, the Company's suppliers have to be aware of the Code of Conduct and of the 231 Model's principles before starting working with Snam, these are all documents where these aspects related to labour rights are addressed.

Prevention

2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following labour rights issues?

	No engagement on this topic	To better understand the risks/ impacts in question	To discuss potential ways to prevent or mitigate the risks/ impacts in question	To agree on a way to prevent/ mitigate the risks/ impacts in question	To assess progress in preventing/ mitigating the risks /impacts in question	To collaborate in the prevention/ mitigation of the risks/ impacts in question	Other (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

Optional comment

Snam engages with its stakeholders periodically to assess the materiality process with workshops, one to one interview and surveys. In doing so Snam discusses with them about each material issue in the social area taking note of problems, risks perceived and suggestions. In 2021 Snam contacted with surveys more than 6,000 stakeholders with a response ratio of 28%, realized 5 workshops with media, employees, suppliers, clients and institutional stakeholders and interviewed 4 environmental associations. The most relevant issue arisen in the social area is health and safety. The first and the last topics (Freedom of association and working conditions) are engaged only with employees. Freedom of association is fully guaranteed by Snam and it is a right not considered at risk. Actually in 2021, Snam held 162 virtual meetings with local and national trade unions in compliance with government regulations and specific company policies aimed at limiting contagion from Covid-19, during which the parties discussed various projects to develop already consolidated businesses and those recently launched, as well as issues of organisational importance arising from the crisis situation that occurred this year. Forced and child labour issues are reported in the ethic code and shared consequently also with suppliers, but are considered low risk in Italy. Forced labour and child labour are not issues at risk for the internal workforce but are taken into account in code of ethics and suppliers are required to sign the Ethics and Integrity agreement.

3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this labour rights issue?

	Provided internal training/ capacity building for the direct workforce	Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)	Conducting an audit process and/or corrective action plan	Collective Action with peers or other stakeholders, in particular workers' organizations, to address the issue	Collaboration with governmental or regulatory bodies	Other (Please provide additional information)	No action within reporting period
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

Optional comment

ll the issues with the exception of child labour and force labour are discussed with trade union organisations. Snam respect the italian law (being possible for employees to freely subscribe to labour unions), and actually during 2021, Snam held 162 virtual meetings with local and national trade unions in compliance with government regulations and specific company policies aimed at limiting contagion from Covid-19, during which the parties discussed various projects to develop already consolidated businesses and those recently launched, as well as issues of organisational importance arising from the crisis situation that occurred this year . Besides, regarding the Freedom of Expression right, Snam provides selected employees (executives) with an informative "new hires package" on labour union associations, for all the other employees , information/training on labour union is provided on demand. Regarding working conditions are availbale information package on intranet and introduction in new hires training courses. Regarding the topic of "forced labour", new hires at Snam are provided with the Code of Ethics and with specific training on it (where the topics of child and forced labour, among others, are addressed) and new suppliers at Snam are required to subscribed the so called "Patto Etico di Integrità" ( in english, Ethical Pact of Integrity) which deals also with this kind of issue. The Safety and Health issues are covered by a management system according ISO 45001, so all the types of engagement are foreseen with the exception of the collaboration with the government.

4. Who receives training for the following labour rights issues?

	No training provided	Select employees	All employees	Contractors	Direct suppliers of the organization	Indirect suppliers of the organization	Other – such as partners, clients, etc.
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

Optional comment

Regarding the Freedom of Expression right, Snam provides selected employees (executives) with an informative "new hires package" on labour union associations, for all the other employees , information/training on labour union is provided on demand. On the Freedom of Expression right, Snam provided in 2021 also to all employees training about inclusive language during the "Inclusion Week" through a specific webinar. On this topic in 2021 Snam organized also the “Leadership School” training course involving the approximately 470 People Managers, the participants were involved in five meetings during which they addressed relevant topics, including strategic relationship management, valuing differences between people in communication and relationships (see Snam's Sustainability Report page 133: https://www.snam.it/export/sites/snam-rp/repository/ENG_file/investor_relations/reports/annual_reports/2021/2021_sustainability_report.pdf). Regarding Forced Labour and Child Labour, training is provided to all employees on the Code of Ethics where the ILO principles are taken into consideration and Snam provides information on these topics to its contractors and suppliers always through the application of its Code of Ethics to these categories of stakeholders. Regarding the occupational safety and health, training is provided to all the employees through courses supplied by the internal HSEQ department with specific courses for selected employees; contractors and direct suppliers are provided with a Portal where they can find dedicated business oriented communications as knowledge sharing on sustainabiity and HSE topics (such as ISO 45001 management system and best practices about HSE). here the link to the Supplier Portal: https://fornitori.snam.it/tamtamy/home.action?lang=ti_en In addition to that, meetings are organized with direct suppliers and contractors to discuss and share with them knowledge on several topics among which the above mentioned ones.

5. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following labour rights issues?

	No monitoring of progress	Review issues on ad-hoc basis	Set annual targets/ goals, track progress over time (internal programs only)	Set annual targets/ goals, track progress over time (internal and external programs)	Other (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

Optional comment

Snam has external targets on its ESG Scorecard regarding the Health and Safety topic, in particular the following target: the IpFG (Combined Frequency and Severity Index). In the Scorecard there are also two targets on the diversity topics such as the % of women in executive and management positions and the % of women in the succession plans (first and second lines). Regarding the freedom of association, it relates to the right to join labour unions and the percentage of people who joins is monitored through the industrial relations department. On the "Forced/Child labour" topic, it is not a risky issue in Italy, therefore Snam addresses the topic providing training and awareness through the Code of Ethics. On the "Working conditions" topic, the Snam's HR department has internal KPI and targets for monitoring.

Performance

6. What is the percentage of employees covered under collective bargaining agreements?

	Percent of employees (%)	Unknown
Employees covered under collective bargaining (%)	100

7. What is the percentage of employees in a trade union or other workers' organization?

	Percent of employees (%)	Unknown	Not applicable (Please provide additional information)
Employees in a trade union or on a worker committee (%)	21.4

8. In the course of the reporting period, what was the percentage of women in:

	Percent of women (%)	Unknown
Senior leadership level position	21.3
Non-executive board	33

Optional comment

The female percentage of all Snam's executives is equal to 21.3%, while considering only the leadership team (C-suites) rises up to 40%.

9. What was the average ratio of the basic salary and remuneration of women to men (comparing jobs of equal value) during the reporting period?

	Salary ratio (%)	Unknown	Choose to not disclose
Women / Men (%)	95

Optional comment

Beside salary ratio, Snam calculated different gender pay gap by cash, by role and by base salary each according three categories (executive, managers and office workers) , for details see pag 141 of 2021 Sustainability Report, https://www.snam.it/export/sites/snam-rp/repository/ENG_file/investor_relations/reports/annual_reports/2021/2021_sustainability_report.pdf

10. In the course of the reporting period, how frequently were workers injured (injuries per hour worked)?

	Frequency of injury	Unknown	Choose to not disclose
Frequency of injury	2.11

Optional comment

Please see pag 144 of 2021 Sustainability Report, https://www.snam.it/export/sites/snam-rp/repository/ENG_file/investor_relations/reports/annual_reports/2021/2021_sustainability_report.pdf

11. In the course of the reporting period, what was the company’s incident rate?

	Incident rate	Unknown	Choose to not disclose
Incident rate	2.11

Optional comment

All the injuries involving employees and contractors occurred in Italy (for employees 8 in the North, 1 in the Centre, and 2 in the South, and for the contractors 1 in the Centre). The injuries involved only male staff. The rate of recordable work related accidents, which correspond to the total number of injuries, is 2.11 for employees, while it is 0.12 for contractors.

Response and Reporting

12. In the course of the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to the adverse impact associated with the following labour rights issues?

	Yes	No	Choose to not disclose	Not applicable (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

Optional comment

Snam didn't find violations regarding these issues. Of course, regarding health and safety, some incident happened but they were treated as required by ISO 45001 management system and italian law requirements.

13. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the labour rights principles, including any challenges faced and actions taken towards prevention and/or remediation.

The Snam's challenges and activities related to labour in 2021 regarded mainly health and safety in the workplace, the company welfare and wellness of employees also in relation to the effect of the covid 19 pandemics. Also non discrimination, gender equality and the promotion of an inclusive workplace have been topics on which Snam worked on in 2021, along with an important agreement on the smartworking reached with the labour unions, where the operational details were defined both for its implementation in emergencies and in normal situations. In particular in 2021 on the Health and Safety topic, the Snam4Safety project continued despite of the difficulties due to the pandemic, aimed at strenghtening the culture and awareness on the safety topics both for employees and contractors and in 2022 it will be extended to the non regulated businesses. The attention towards the covid 19 pandemics continued with the drafting of a shared Health Protocol, defined between the Government and the social players, the integration of Risk Evaluation documents and the organization of an awareness campaign constant and widespread to all employees. Regarding the Corporate Welfare, many initiatives were launched with a participation rate equal to 50%, increased compared to the 39% in 2020. The initiatives were implemented on "Snammy", the platform which encompasses all the Welfare Plan and it is organized in 5 main areas of intervention for 30 services (corporate and bargaining agreements): Family and Instruction, Health and Care, Wellness and Work Life Balance, Finance and Saving, Social Committment. An initiative worth mentioning is the extension of the paternity leave to 15 paid days compared to the 10 according to the Italian law. Last but not least, the continuous attention towards diversity and the creation of an inclusive working environment which in 2021 resulted in the publishing of the third appendix to the diversity and inclusion policy regarding harrassment and the implementation by the Inclusion Team of 11 initiatives involving more than 1800 employees among which, along with the others, the first Snam Inclusion Week and the institution of 3 Employees Resource Group on the Parenting, STEM and LBGTQ+ topics.

Environment

Commitment

1. Does the company have a formal policy on the following environmental topics?

	No, and we have no plans to develop a policy	No, but we plan to in the next two years	Yes, included within a broader policy	Yes, articulated as a stand-alone policy	Not applicable (Please provide additional information)
Climate Action
2019
Water
Oceans
Forests / Biodiversity / Land Use
2019
Air Pollution
2019
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
2019
Energy & Resource Use
2019

Optional comment

https://www.snam.it/export/sites/snam-rp/repository/ENG_file/Sustainability/Sustainable_development/Politica_HSE_Snam__eng.pdf Snam has an HSEQ policy available on its website (see the link above), covering all these aspects especially with regard to climate change and energy, our most material issues. Water and oceans are not directly mentioned, being non material for our business. They are referred to as "the efficient use of natural resources and ensuring the protection of biodiversity and ecosystems", however since Snam acquired some new business in different business sector the water materiality is to be evaluated and consequently there will be tha chance to include this issue in the policy, if material.

1.1. For each environmental policy, is it:

	Aligned with international environmental standards?	Publicly available?	Approved at most senior level of the company?	Applied to the company’s own operations?	Applied to the company’s supply chain and/or other business relationships?	Developed involving environmental expertise from inside and outside the company?	Other (Please provide additional information)
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

Optional comment

Snam environmental policy is public, high level and signed by Snam'CEO. Snam’s environmental policy extends to the entire value chain and applies: to all the production phases of every product (e.g. production of natural gas compressors) and services (e.g. transportation of natural gas), including distribution and logistics phases, in addition to related waste management; to each site and building; all the relationships with external stakeholders; all mergers and acquisitions; every key business partner (including partners related to non-managed operations, joint ventures, outsourcing or third-party producers); every supplier, including service and contractor suppliers; all due diligence processes as well as Merger and Acquisition processes. All the issues reported are addressed in the policy with the exception of oceans an water: these issues are not material for Snam's business which doesn't involve ocean and is characterised by low water withdrawals (for office use and premises irrigation). However water is indirectly addressed in the sentence "to promote...the efficient use of natural resources".

Prevention

2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following environmental issues?

	No engagement on this topic	To better understand the risks/ impacts in question	To discuss potential ways to prevent or mitigate the risks/ impacts in question	To agree on a way to prevent/ mitigate the risks/ impacts in question	To assess progress in preventing/ mitigating the risks/ impacts in question	To collaborate in the prevention/ mitigation of the risks/ impacts in question	Other (Please provide additional information)
Climate Action
Water
Snam engages with its stakeholders periodically to assess the materiality process with workshops, "one to one" interview and surveys. In doing so Snam discusses with them about each material issue in the environmental area taking note of problems, risks perceived and suggestions.
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Snam engages with its stakeholders periodically to assess the materiality process with workshops, "one to one" interview and surveys. In doing so Snam discusses with them about each material issue in the environmental area taking note of problems, risks perceived and suggestions.
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Snam engages with its stakeholders periodically to assess the materiality process with workshops, "one to one" interview and surveys. In doing so Snam discusses with them about each material issue in the environmental area taking note of problems, risks perceived and suggestions.
Energy & Resource Use

Optional comment

Snam engages with its stakeholders periodically to assess the materiality process with workshops, "one to one" interview and surveys. In doing so Snam discusses with them about each material issue in the environmental area taking note of problems, risks perceived and suggestions. In 2021 Snam contacted with surveys more than 6,000 stakeholders with a response ratio of 28%, realized 5 workshops with media, employees, suppliers, clients and institutional stakeholders and interviewed 4 environmental associations. The most relevant issue arisen in the environmental area was climate change. Therefore Snam organised several initiatives and meeting to involve its value chain (suppliers and associates) to involve them in business decarbonization and energy savings projects. With regard to biodiversity Snam collaborates with government and universities in order to minimise the impact of its projects.

3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with these environmental topics?

	Provided internal training/ capacity building for the direct workforce	Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)	Conducting an audit process and/or corrective action plan	Collective Action with peers or other stakeholders to address the issue	Collaboration with governmental or regulatory bodies	Other (Please provide additional information)	No action within reporting period
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

Optional comment

Snam has an extensive plan to involve employees, suppliers and business partners in its Towards net zero strategy. Employees are involved in webinars and ideas' challenges to decarbonize business and save energy, suppliers are involved in specific webinars, in CDP suppliers initiative and in collaborations helping to decarbonize their business, business partners are involved in Snam's strategy by means of meetings, webinars and sharing of best practices. Besides Snam, in collaboration with the government, plays an important role in the Country decarbonisation with its new businesses dealing with hydrogen, biomethane, mobility and energy efficiency. Snam sponsored the project PlasticLess with Lifegate to clean the sea in the docks and constituted with CDP equity a benefit company Arbolia to address reforestation and plant new trees. Regarding waste, besides the Lifegate plasticless project, Snam collaborates with suppliers to reduce plastic packaging. With respect to air pollution we collaborate with Marcogaz a technical association of gas transport companies. Selected staff employees are trained on environmental issues in order to prepare specific procedures to be followed by technical workforce, besides, management systems verify through internal audits that all processes are in compliance with procedures. Often we collaborate on environmental issues including biodiversity with government and regulatory bodies to answer requirements and prescriptions. With regards to biodiversity we built capacity with our employees in relation to Snam's target about biodiversity in our ESG webinars and we addessed the schools with our initiative Young Energy which involved more than 800 students on specific issues as biodiversity and inclusion&diversity.

4. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following environmental topics?

	No monitoring of progress	Review issues on ad-hoc basis	Set annual targets/ goals, track progress over time (internal programs only)	Set annual targets/ goals, track progress over time (internal and external programs)	Other (Please provide additional information)
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

Optional comment

Snam set annual targets, periodically monitored and controlled, related to its main material issues. Ocean is completely unrelated to our business. Water and air pollution are not material for our business, but only relevant. We manage these last issues monitoring them, also by means of our environmental management system (ISO 14001). With regard to air pollution there are also internal target to extend the use of DLE turbines to all Snam's implant, a target almost reached. Regarding waste Snam set the target of eliminating plastic in industrial packaging (without prejudice to safety) by 2023.

4.1. For each environmental topic in which the company sets timebound goals / targets, what kind of targets has the company set?

	Description of targets (e.g., what is the target, absolute vs. intensity, externally verified, on track, etc.)
Climate Action	28% of Scope 1 and 2 emissions by 2025 compared to 2018 values, absolute, on track; 40% of Scope 1 and 2 emissions by 2027 compared to 2018 values, absolute, on track; 50% of Scope 1 and 2 emissions by 2030 compared to 2018 values, absolute, on track; Net zero for Scope 1 and 2 emissions by 2040, absolute, on track; 55% of natural gas emissions by 2025 compared to 2015 values, absolute, on track; 46% of emissions from associates companies, fuel and electricity production, business travel and employee commuting by 2030 vis a vis 2019 values, absolute, on track;- 55% tCO2e/M€ capex for suppliers by 2030 vis a vis 2019 values, intensity, on track. The Scope 1, 2 and 3 targets to 2030 are aligned with the generic SBTi methodology to limit a global temperature rise to no more than 1.5°C, because a methodology for Snam's sector is not yet available.
Energy & Resource Use	Increase the share of green electricity purchased respect to the total to 55% by 2030. Intensity target in line for year 2021, equal to 41%
Water
Forests / Biodiversity / Land Use	% vegetation restoration of the natural and semi-natural areas involved in the construction of the pipeline routing > 99%, annually. The target in 2021 has been reached.
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)	Snam has the target to eliminate plastic in industrial packaging (without prejudice to safety) by 2023 and eliminate disposable plastic in beverage dispensers in all corporate headquarters from 2020. The first objective has reached 96% of reduction in 2021, while the second was postponed due to Covid.
Oceans

4.2. For each environmental topic in which the company sets timebound goals / targets, how is progress against target / goal tracked?

	Progress is reviewed against goals annually or more frequently	Progress is reported internally to the most senior level	Progress is reported externally	Other (Please provide additional information)
Climate Action
Energy & Resource Use
Water
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Oceans

Optional comment

All the targets are annually disclosed in the coporate reports, targets in the ESG scorecard are also disclosed during strategy presentation and all are monitored and discussed at senior level and in the board. Regarding the topics without a target, monitoring and progress are also assured by the environmental management system wich uses continuous improvement approach.

5. In the course of the reporting period, has the company been involved in providing or enabling remedy for any actual impacts associated with the following environmental issue(s)?

	Yes	No	Choose to not disclose	Not applicable (Please provide additional information)
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

Optional comment

Snam set a whistleblowing procedure wich defines the process for receiving reports about presumed irregularities, analysing this information and determining any corrective action to take. In 2021 no reports concerning Code of ethics and D.Lgs. 231 (covering also environmental harm) has been received and no significant administrative penalties (exceeding $ 10,000) was applied during 2021. Besides Snam, according the law 239/2004, provides regions, territory bodies and municipalities affected with construction or upgrading of storage or thrust stations for environmental compensations. These compensations are financings or collaborations with the interested bodies to realize projects aimed at improving the environment such as planting trees, energy saving or sustainable mobility.

Climate Action

6. What were the company’s gross global greenhouse gas emissions for the reporting period?

Scope 1 Emissions

Full

None

Emissions (tCO2e)

1397000

Scope 2 Emissions

Full

None

Emissions (tCO2e)

31000

Scope 3 Emissions

Full

Partial

None

Emissions (tCO2e)

995000

Optional comment

Snam’s value chain emissions relevant for its business can be classified into the following macrocategories: • Emissions from Snam’s Associate companies (GHG Protocol category: Investments); • Emissions from the supply chain, which include emissions from suppliers working for Snam (GHG Protocol categories: Purchased goods and services, Capital goods, Upstream transportation and distribution, Waste generated in operations and Upstream leased assets); • Emissions from fuel extraction and electricity generation and transport that are not included in Scope 1 and 2 (GHG Protocol category: Fuel-and-energy-related activities not included in Scope 1 or 2); • Other, which includes business travels and employee commuting (GHG Protocol categories: Business Travels; Employee commuting).

7. What percentage of the company's revenue was invested in R&D of low-carbon products/services during this reporting period?

Percent of revenue (%)

Unknown

Not applicable (Please provide additional information)

Optional comment

Actually the percent of revenue is 0.005%. Snam has initiatives of research and development about launching innovative start-ups in the hydrogen world and collaborations with Politecnico di Milano university. Snam has also limited research on methane reduction activities even if the greatest investments in this area aren't classifies as research and development but more as best technologies availabale.

8. Has the organization acted to support climate change adaptation and resilience?

We have taken action to increase organization-wide resilience to climate change

We have taken action to increase resilience in our supply chains

We have taken action to increase resilience in the communities in which we operate

We have provided funding for climate change adaptation and resilience initiatives and projects

We have not taken actions to build climate change resilience in the reporting period

Other (Please provide additional information)

Unknown

Optional comment

Snam's 2021-2025 Strategic Plan and the Long-Term Vision to 2030 contribute to supporting the great transformation underway in the energy sector, leveraging on the enabling role of infrastructure to achieve a fully decarbonised economy through a plan of increasing investments. In the firm belief that the business strategy cannot disregard the climate strategy, Snam has strengthened its decarbonisation objectives by setting short- to medium-term intermediate targets for reducing greenhouse gas emissions from its activities (Scope 1 and 2) and defining new targets for reducing emissions associated with its value chain (Scope 3). Snam thus becomes the first energy infrastructure company within the European Union to set Scope 3 emission reduction targets, also related to its suppliers, by 2030. Besides in 2021 Snam Foundation, in collaboration with Compagnia San Paolo, launched the national competition for Energia Inclusiva to identify, select and accompany innovative and creative solutions to reduce and combat the phenomenon of energy poverty. The call for proposals led to the selection of 13 finalist projects that benefited from an accompanying path lasting a total of over 300 hours to develop and make the project ideas more solid. At the end of the support period, 4 winning projects have been selected which will have access to a total contribution of € 185 thousand made available by promoters of the call and distributed over the years of implementation.

Energy / Resource Use

9. Please report the company's renewable energy consumption as a percentage of total energy consumption in the reporting period.

% of total energy consumption

1.14

Unknown

Optional comment

The main energy source used by Snam is natural gas for the gas turbines in the compressor stations for transport and storage. In the Strategic plan are foreseen investments to replace this turbines with dual fuel turbines with the possibility to use green electricity. Actually the share of green electricity acquired in the total is 41% in 2021 with the target to reach 55% by 2030. Besides, the company launched energy efficiency programmes and measures years ago that include the installation of photovoltaic systems, high-efficiency heat generators, the commissioning of trigeneration plants and the installation of LED lighting systems.

Technology

10. What percent of the company's revenue came from environmentally friendly products / services during this reporting period?

Percent of total revenue (%)

12.1

Snam4Environment for biomethane infrastructure, Snam4mobility for green mobility solutions, H2BU for the introduction of hydrogen as energy vector and Renovit for energy efficiency

Unknown

Not applicable (Please provide additional information)

Optional comment

Thanks to the work of Snam4Mobility and Snam4Environment, Snam will contribute to achieving the decarbonisation of transport on the national territory, promoting renewable bio-mobility, which reduces or even eliminates CO2 emissions. Snam4Mobility, develops the biomethane and natural gas mobility sector for heavy and light vehicles and the construction of CNG / L (compressed and liquefied natural gas) and bio-CNG / L (compressed and liquefied natural bio gas) stations, cleaner and more efficient alternatives to fuels traditional. Snam4Environment, through the know-how of IES Biogas, is specialised in the development of biomethane infrastructure, promoting the spread and use of biomethane throughout Italy, contributing to the creation of value and promoting the energy transition of the country. The Hydrogen business unit (BU H2) is dedicated to the development of projects for the use of hydrogen both in industrial applications and in the field of sustainable mobility, taking advantage of important prospects that this vector will have with respect to the achievement of the decarbonisation objectives. In fact, hydrogen does not generate carbon dioxide or other emissions climate-altering gases, nor emissions harmful to humans and the environment and furthermore its versatility allows its use both in industrial applications (thermal, feedstock and fuel cell) and in sustainable mobility (trains, refueling stations for light vehicles and heavy, airports). About 100% of the Snam network is already H2-ready, that is, ready to welcome ever greater percentages of hydrogen and further studies are underway to promote its production, distribution and use.

Sector-specific: Water

12. Please provide details regarding the company's water withdrawal and consumption (own operations) during the reporting period.

Water withdrawal (volume of water in megaliters):

	Mega-liters	Unknown	Not applicable (Please provide additional information)
Total	392
Groundwater:
Snam doesn't use water in its productive process, therefore the withdrawals are very limited and the water is mainly used for offices and green premises irrigations. The withdrawals are only in Italy, in regions not characterised by high water stress and the breakdown is the following in megaliters: 108 from aqueduct, 137 from groundwater, 5 from surface water, 142 from other sources (wastewater, rainwater, etc.)..
Surface water:
Snam doesn't use water in its productive process, therefore the withdrawals are very limited and the water is mainly used for offices and green premises irrigations. The withdrawals are only in Italy, in regions not characterised by high water stress and the breakdown is the following in megaliters: 108 from aqueduct, 137 from groundwater, 5 from surface water, 142 from other sources (wastewater, rainwater, etc.)..
Rainwater:
Snam doesn't use water in its productive process, therefore the withdrawals are very limited and the water is mainly used for offices and green premises irrigations. The withdrawals are only in Italy, in regions not characterised by high water stress and the breakdown is the following in megaliters: 108 from aqueduct, 137 from groundwater, 5 from surface water, 142 from other sources (wastewater, rainwater, etc.)..
Wastewater:
Snam doesn't use water in its productive process, therefore the withdrawals are very limited and the water is mainly used for offices and green premises irrigations. The withdrawals are only in Italy, in regions not characterised by high water stress and the breakdown is the following in megaliters: 108 from aqueduct, 137 from groundwater, 5 from surface water, 142 from other sources (wastewater, rainwater, etc.)..
Percentage of water withdrawn in regions with high or extremely high water stress (%)	0

Water consumption (volume of water in megaliters):

	Mega-liters	Unknown	Not applicable (Please provide additional information)
Total	192
Groundwater:
The total water consumption is the total withdrawal (392) minus the total discharge (200) equal to 192 megaliters. Since the classification for withdrawals and discharges is different, it is not possible to have the breakdown for consumptions. The breakdown for the discharges is the following: 113 megaliters in the sewer and 87 megaliters in groundwater and surface water. The consumption in high water stress region is equal to zero as in the withdrawal question, since the withdrawals are only in Italy.
Surface water:
The total water consumption is the total withdrawal (392) minus the total discharge (200) equal to 192 megaliters. Since the classification for withdrawals and discharges is different, it is not possible to have the breakdown for consumptions. The breakdown for the discharges is the following: 113 megaliters in the sewer and 87 megaliters in groundwater and surface water. The consumption in high water stress region is equal to zero as in the withdrawal question, since the withdrawals are only in Italy.
Rainwater:
The total water consumption is the total withdrawal (392) minus the total discharge (200) equal to 192 megaliters. Since the classification for withdrawals and discharges is different, it is not possible to have the breakdown for consumptions. The breakdown for the discharges is the following: 113 megaliters in the sewer and 87 megaliters in groundwater and surface water. The consumption in high water stress region is equal to zero as in the withdrawal question, since the withdrawals are only in Italy.
Wastewater:
The total water consumption is the total withdrawal (392) minus the total discharge (200) equal to 192 megaliters. Since the classification for withdrawals and discharges is different, it is not possible to have the breakdown for consumptions. The breakdown for the discharges is the following: 113 megaliters in the sewer and 87 megaliters in groundwater and surface water. The consumption in high water stress region is equal to zero as in the withdrawal question, since the withdrawals are only in Italy.
Percentage of water consumed in regions with high or extremely high water stress (%)	0

13. Please provide details about the company’s water intensity of products in regions with high or extremely high water stress.

Water intensity of products (cubic meter/$):

Unknown

Not applicable (Please provide additional information)

Optional comment

Snam doesn't use water in its processes, and this issues is considered not material by Snam and its stakeholders. Actually the withdrawal of fresh water is mainly used for office activities, fire-combating systems and irrigation of green areas. Besides Snam uses sea water in the process of regasification of LNG, but this withdrawal is then put it again in the sea. Besides Snam operates in Italy and there aren't withdrawals in regions subjected to high water stress.

Sector-specific: Air pollution

17. Where applicable, please report the company's emissions of the following pollutants during the reporting period.

	Emissions (tCO2e)	Unknown	Not applicable (Please provide additional information)
NOx	558
SOx
Snam uses methane as a fuel for the 96,5%, therefore pollutants are Nox and CO (2021 value is 246 t) while the other categories reported are negligible.
Volatile Organic Compounds (VOC)
We don't account Methane as VOC, we account it separately as methane leakage, which in 2021 is equal to 22064 ton.
Hazardous air pollutants (HAP)
Snam uses methane as a fuel for the 96,5%, therefore pollutants are Nox and CO (2021 value is 246 t) while the other categories reported are negligible.
Particulate matter (PM10)
Snam uses methane as a fuel for the 96,5%, therefore pollutants are Nox and CO (2021 value is 246 t) while the other categories reported are negligible.
Persistent organic pollutants (POP)
Snam uses methane as a fuel for the 96,5%, therefore pollutants are Nox and CO (2021 value is 246 t) while the other categories reported are negligible.
Other (please specify in text box)	246

Sector-specific: Waste

18. Please report the company's total weight of waste generated in metric tonnes during the reporting period.

Waste Generated (t)

120776

Unknown

Not applicable (Please provide additional information)

19. Please report the percentage of the company's waste that was hazardous waste (i.e., hazardous waste ratio) during the reporting period.

Hazardous Waste Ratio (%)

4.93

Unknown

Not applicable (Please provide additional information)

20. Please report the company's estimated metric tonnes of single-use plastic consumed wherever material along the value chain during the reporting period.

Single-use plastics (tonnes)

0.225

Unknown

Not applicable (Please provide additional information)

Optional comment

Since 2019, Snam has been committed to reducing its use of plastic by setting a target for eliminating the plastic used in supply packaging by 2023 and also eliminating the plastic used to send materials to its sites, net of the amount needed for safety reasons. Together with suppliers, new supply specifications have been defined that include the elimination of non functional packaging and the replacement of essential plastic packaging with other more ecocompatible materials.These measures have reduced incoming plastic by 96% and completely eliminated plastic waste in central warehouses in 2021.

Overall Environment

21. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the environment principles, including any challenges faced and actions taken towards prevention and/or remediation.

Snam is determined to play a leading role in achieving the ambitious objectives set at national and European level, to make the decarbonisation and energy transition process a reality and to support a sustainable economic model. Building on its established capabilities in regulated businesses and its expertise in green gas and new energy transition trends, the company is evolving towards a concept of multi-commodity infrastructures, i.e., capable of transporting and storing different types of molecules, continuing at the same time to develop its hydrogen, biomethane, sustainable mobility and energy efficiency businesses. In 2021, Snam has strengthened its decarbonisation objectives by setting short- to medium-term intermediate targets for reducing greenhouse gas emissions from its activities (Scope 1 and 2) and defining new targets for reducing emissions associated with its value chain (Scope 3). Still related to the climate change issue there is all the work done to reduce Snam's methane emissions and to reach the challenging target to reduce them of 55% at 2025 implementing several initiatives: from LDAR techniques use, recompression in line of gas during maintenance activities and valves replacement. With its new business for energy transition, important results were obtained through Renovit energy efficiency activities and biomethane production from FORSU and agricultural waste through Snam4environment activities. Thanks to Renovit 14.5 kton of CO2 eq were avoided in 2021, while Snam4environment increase biomethane production aup to 7.2 mln m3 in 2021 contributing to circular economy. All the ESG factors are nevertheless integrated into the company’s strategy and management, and environmental, social and governance objectives are encapsulated in the ESG Scorecard, which was further strengthened in 2021 to provide stakeholders with an even more holistic view of the commitment to these issues. Therefore important work was done not only on climate change and energy transition related issues, but also on biodiversity and forestation with the km of environmental restorations performed in 2021 and the collaboration to the “Mosaico Verde” reforestation campaign promoted by Legambiente in cooperation with Arbolia S.p.A. which led to planting about 1,000 new trees of native species in Taranto and about 1,800 in Milan as part of the “Forestami” project. Other work has been done for plasticless and paperless activities to reduce plastic waste in the supply chain and use of paper in the staff activities and to install retrofit systems for the cars in Snam's corporate fleet reducing the environmental impact.

Anti-corruption

Commitment

1. Does the company have an anti-corruption compliance programme?

No, it is not an immediate business priority

No, but we plan to in the next two years

Yes

2021

Optional comment

2. Does your company have policies and recommendations for employees on how to act in case of doubt and/or in situations that may represent a conflict of interest, e.g. with regard to gifts and hospitality, donations, sponsorship, or interactions with public officials?

No, and we have no plans to develop a policy

No, but we plan to in the next two years

Yes, included within a broader policy

Yes, articulated as a stand-alone policy

Optional comment

You can find information on this topic in the Code of Conduct and in the Anti-corruption Guidelines https://www.snam.it/export/sites/snam-rp/repository/file/Governance/codice-etico/Codice_Etico.pdf https://www.snam.it/export/sites/snam-rp/repository/file/Governance/lineaguida/anticorruzione/snam_anticorruzione_01.pdf

Prevention

3. Who receives training on anti-corruption and integrity?

Optional comment

All employees receive training, but also contractors, suppliers and partners must declaire to know and be aware of the Code of Ethics, 231 Model and anti-corruption Guidelines, available on Snam website and made available to them in the qualification phase. Actually, in addition to compliance with the requirements of quality, price and reliability, suppliers are also required to make a formal commitment to comply with the contents of Snam’s Code of Ethics and the “Ethics and Integrity Pact” (including subcontractors).

3.1. How often is such training provided?

	One time only	Every year	Every two or more years	We do not collect this data
All employees
Select employees
Contractors
Direct suppliers of the organization
Other – such as partners, clients, etc.
Indirect suppliers of the organization

Optional comment

All employees receive training when they are hired, and also they get learning courses on specific topics on a regular basis.

4. Does the company monitor its anti-corruption compliance programme?

No, we do not monitor the anti-corruption compliance programme

Review issues on ad-hoc basis

Yes, through internal employee self-evaluations

Yes, through automated controls monitoring

Yes, through external independent monitoring

Yes, through other mechanisms

Optional comment

The internal monitoring is supported by an external advisor.

Response and Reporting

5. Please report the company's total number and nature of incidents of corruption during the reporting year.

	Number of incident(s)	Unknown	Choose to not disclose
Confirmed during the current year, but related to previous years	0
No incident founded
Confirmed during the current year, and related to this year	0
No incident founded

Optional comment

See pag 320 of 2021 Annual Report https://www.snam.it/export/sites/snam-rp/repository/ENG_file/investor_relations/reports/annual_reports/2021/SNAM_2021_Annual_Report.pdf

6. Within the reporting period, what measures has the company taken to address suspected incidents of corruption independently or in response to a dispute or investigation by a government regulator?

Initial case assessment

Internal investigation

Review by risk / ethics committee

Review by board of directors

External audit / review

Other (please provide additional information)

Supervisory Body receives internal audit reports and can provide the company with instructions and/or recommendations.

Not applicable/no incidents in the reporting period

Optional comment

The internal investigation is conducted by Internal audit that reports the results of its investigation to the Supervisory Body and at the end of each year also to the Board.

7. Does your company engage in Collective Action against corruption?

No, it is not an immediate business priority

No, but we plan to in the next two years

Yes (please explain)

Snam has the leadership of the anti corruption committee of BIAC and OECD, is an active member at the B20 integrity and compliance taskforce, is member of PACI at WEF, and top member of Transparency international.

8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the anti-corruption principle, including any challenges faced and actions taken towards prevention and/or remediation.

Snam, in establishing and maintaining an Anti-Corruption Compliance Programme, is not limited to adopting a 231 Model (aimed at preventing the predicate offences of administrative liability for corporate crime, including corruption offences) but, in accordance with international guidance and best practice, has also implemented the following tools: • “Top level commitment”, i.e. a commitment at the highest level to fight corruption; • the adoption of specific anti-corruption measures; • the establishment of a dedicated Anticorruption Unit • anti-corruption due diligence on contractual/commercial counterparties; • monitoring by an external and independent advisor to verify actual knowledge of and implementation of the procedures; • raising of awareness of employees through specific training and information activities; • disciplinary action in the event of breaches of the anti-corruption rules; • periodic risk assessment. Snam has also in place multilateral collaborations, being a member of the UN Global Forum and, as part of the Sustainable Development Goal No. 16 on Peace, justice and strong institutions, has strengthened its collaborations and partnerships with national and international organizations and institutions: • Since 2016, Snam has been a partner of the General Secretariat of Transparency International and, thanks to its active role within the Business Integrity Forum of the Italian Chapter, it is constantly involved in various working tables and institutional events, in which it is called upon to represent its best practices in terms of business integrity and anti-corruption; • Starting in 2017, Snam - as the first Italian company in the private sector - joined the Business and Industry Advisory Committee (BIAC), now renamed “Business at OECD” and, in 2019, joined the Leadership of the Anticorruption Committee, with the appointment of Vice-Chair. This active collaboration has allowed it to be invited to all public consultations at OECD, to provide its contribution and to share her experience, on the subject of prevention of unlawful acts and business integrity in the prepared documents •Thanks to the development of these partnerships, Snam participates annually in some recurring events, assuming a primary role in the panels. Among them, above all, the OECD: (i) Global Anti-Corruption & Integrity Forum; (ii) Global Fo[1]rum on Responsible Business Conduct; (iii) Working Party on State Ownership and Privatization Practices; (iv) Corporate Governance Committee meeting; (v) Public Integrity Indicators Portal and of the 2021 Recommendation for Further Combating Bribery of Foreign Public Officials in International Business Transactions. • In October 2019, Snam joined the World Economic Forum’s Partnering Against Corruption Initiative and participated in past editions of the Forum Business 20 (also called “B20”) as a full member of the Compliance & Integrity Taskforce, under the Saudi and Italian Presidency respectively in 2020 and in 2021, preparing for the third term in office under the Indonesian Presidency 2022. • During 2021, Snam continued to be active in the area of multilateral activities, participating in various institutional events and providing its contribution to various working tables, in addition to those mentioned above. In particular, the following should be mentioned: (i) Leading through the Crisis: Integrity and Anticorruption for a Resilient Recovery, as part of the OECD Global Anti-Corruption & Integrity Forum; (ii) Transparency Italia’s Business Integrity Forum in June, where – as part of the panel dedicated to the topic of “Intelligent Compliance” – the Snam Chief Executive Officer, Marco Alverà, intervened at the opening with a video message recalling the imperative of ethical principles related to integrity, anti-corruption and sustainability within a company. (iii) B20 Special Event “How to promote Sustainable Governance, increase transparency, fight corruption to enhance fair competition”; (iv) B20 Summit 2020, which formalized the transfer of the International Business Forum to the Indonesian Presidency; and, lastly, (v) Tranparency International Italia’s Business Integrity Forum, annual event held in November, in which Snam participated in two panels: “From B20 Italy 2021 to B20 Indonesia 2022 and beyond”, in which it reported on its experience within the Integrity & Compliance Task Force of past presidencies and future prospects, and “Ethical and Useful”, in which the EVP Institutional Affairs, ESG, Communication & Marketing was involved in a round table discussion on Italy’s possible role as a promoter of the energetic transition.