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Anti-corruption and ethical business practices

2017 Results

+6,200

Training man-hours delivered on the OM&C Model (Organisation, Management and Control Model adopted by Saipem subsidiaries and Model 231 adopted by Saipem SpA), Code of Ethics and Anti-corruption.

79%

of subsidiaries covered by the OM&C Model, Code of Ethics and Anti-corruption training.

100%

of JVs covered by the OM&C Model, Code of Ethics and Anti-corruption training.
SUSTAINABLE DEVELOPMENT GOALS
2018 Objectives
Continue to deliver periodic refresher training of employee awareness promotion.
Maintain an adequate system of internal control and risk management.
Periodically review the OM&C Model.
Reinforce transparency in communication and relations with stakeholders.
Business ethics is the only acceptable option

We undertake to maintain and strengthen our corporate governance system in line with international best practice standards that can withstand both the complex situations in which our Company operates and the challenges it faces in the effort to foster sustainable development. It is the duty of all Saipem people to comply with the law, regulations, statutory provisions, self-regulatory codes and to embody ethical integrity and fairness; we strive with alacrity and determination to ensure that these principles and values characterise the conduct of the whole organization.

As a multinational organisation, Saipem and its personnel are subject to the laws of different countries, including any laws that ratify international conventions and prohibit the corruption of Public Officials and private parties. Furthermore, since Saipem SpA has its headquarters in Italy, both the Company and its personnel are subject to Italian law and, in particular, to the provisions of Legislative Decree No. 231/2001 and its subsequent amendments, which regulates the administrative liability of legal entities deriving from offences, such as internal and international bribery, committed by their directors, employees or associates, in Italy or abroad, in the interest or to the advantage of said legal entities.

As an official member of the UN Global Compact from whose Ten Principles we draw inspiration, our commitment also falls within our adherence to the 10th principle, which concerns the fight against corruption. In accordance with the principle of ‘zero tolerance’ for corruption expressed in the Code of Ethics, we implemented the Anti-Corruption Compliance Programme to face other risks head-on which may be encountered by our Company in our business activities. The programme is a detailed system of rules and controls to prevent corruption-related crimes, characterised by its dynamism and constant attention to evolving national and international legislation and best practices. We updated this Compliance Programme by approving the ‘Anti-Corruption’ Management System Guideline (MSG), with the objective of prohibiting any form of active or passive bribery involving not only Public Officials but also private parties. The ‘Anti-Corruption’ MSG provides a systematic framework to the long-established Anti-Corruption Regulations that our Company has designed and implemented over time and is reviewed and approved by the Board of Directors of Saipem SpA. Its adoption and enforcement is mandatory for Saipem SpA and all its subsidiaries.

CORPORATE GOVERNANCE

The integration of an advanced Corporate Governance system with a structured Risk Management System is a cornerstone for managing  a sustainable business. Integrity and transparency are the principles that inspire us in defining our Corporate Governance system, a founding element of the Company’s business model. Our  organizational structure is characterised by the presence of a Board of Directors, a pivotal body in the governance system, to which our management is exclusively entrusted. The Board of Statutory Auditors has supervisory functions, whereas external auditors are in charge of the legal auditing of accounts. Three committees with advisory and consulting functions have been set up within the Board of Directors, one of them appointed since 2015 with specific Corporate Governance and Scenario functions, updated in 2018 with advisory and consulting functions in Sustainability matter.

WHISTLEBLOWING

All Saipem employees and stakeholders must report any violations (or alleged violations) of the OM&C Model. We have a Corporate standard that describes the process for managing reports. The term ‘report’ refers to any information regarding possible violations, behaviours and practices not in line with the Code of Ethics and/or which may cause damage or injury to Saipem SpA (even if only to its reputation) or any of its subsidiaries. Whistleblowers are guaranteed against any form, direct or indirect, of retaliation, discrimination or penalisation, for reasons connected directly or indirectly to the report, without prejudice to the legal obligations and the protection of the rights of the Company or of the people accused owing to wilful misconduct or gross negligence. We have prepared various channels of communication in order to facilitate sending reports, including, but not necessarily limited to, regular post, fax numbers, e-mail, yellow boxes and communication tools on the Intranet/Internet sites of Saipem SpA and its subsidiaries.

BUSINESS ETHICS TRAINING PROGRAMMES

Our personnel are regularly informed of and trained in the Company’s Compliance and Governance systems, as well as in the importance of compliance with legislation and related procedures, so that they clearly understand the different duties, crimes, risks, the relevant personal and corporate responsibilities, and how to recognize which actions to implement in order to avoid committing any violations. Given the criticality of these issues, a training matrix on Compliance and Governance topics has been defined. Within the framework of the matrix, Anti-Corruption themes play a central role by offering: courses on the ‘Legal, contractual and insurance aspects of projects’ for employees with a more advanced level of seniority and expertise; specific training sessions for at-risk personnel working in the countries where we operate; a specific e-learning module on the ‘Internal Control System over Corporate Reporting’ delivered to our personnel in Italy and abroad.

+1,900 employees have been trained in the OM&C Model, Code of Ethics and Anti-corruption

DISSEMINATING A CULTURE OF BUSINESS INTEGRITY IN NIGERIA

We have been working to disseminate a culture of business ethics and integrity in Nigeria by launching the Leading by ethics campaign. This initiative initially targeted  200 Saipem employees and then was extended, together with the UN Global Compact, to involve 50 local Saipem vendors and local NGOs. As part of this campaign, attendees participated in the Leading by ethics training session and watched the Leading by ethics movie.

To watch the Leading by Ethics Movie click here

RESPONSIBLE BUSINESS

Human and labour rights

Saipem is a responsible employer promoting positive behaviour also outside its own operative boundaries.