The importance of business integrity

The Code of Ethics forms an integral and substantive part of Model 231 and represents a general, mandatory principle. 

Saipem’s Code of Ethics is the only code for all Saipem People. 

It clearly establishes not only the values the Company recognises, accepts and shares in compliance with the law, but also its internal and external responsibilities. It enforces fairness, loyalty, integrity and transparency in its operations, conduct, working methods and internal and external Group relationships.    

Compliance with the Code of Ethics not only by Saipem’s directors, statutory auditors, managers and employees, but also by all those who operate in Italy and abroad to achieve Saipem’s objectives (“Saipem People”), each within their own remit and responsibilities, is of paramount importance.

The legal and contractual provisions governing the relationship with Saipem are of equal importance for Saipem’s efficiency, reliability and reputation, which are all crucial factors for its success and for improving the social context in which it operates.   

Each person in Saipem is actually required to know not only the principles and contents of the Code of Ethics, but also the reference procedures that govern the departments and the responsibilities held. 

The Code of Ethics establishes the appointment of the Guarantor of the Code of Ethics, whose functions are assigned to the Supervisory Board, a collegial body which is granted “autonomous powers of initiative and control” pursuant to Art. 6, paragraph 1, letter b), Italian Legislative Decree No. 231, 2001 on the administrative liability of legal entities for offences. 

The Guarantor is expected, among other things, to train and circulate information among Saipem employees, to assess any reports of possible breaches of the Code of Ethics and to notify the competent structures of the results of its investigations in order to take the necessary measures. 

Still with a view to improving a more effective circulation of the principles laid down in the Code of Ethics and in Model 231, Saipem has also issued the “Saipem Business Integrity Guide”, the aim of which is to provide employees with an additional, user friendly tool in order to better understand and share the Company's ethical values.

This Guide provides an overview of the principles and relevant policies, as well as clarifications and a description of some practical cases in the “What to do if” section.

The Guide is not intended to replace the Code of Ethics, Model 231 or the procedures, but to make them easier to understand. 

Saipem has adopted a Whistleblowing management system that ensures the management of whistleblowing reports received, including anonymously, in Italy and abroad for all the Group companies.

We ensure the receipt, management, analysis and handling of Whistleblowing reports, including the anonymously, received by Saipem SpA and its subsidiaries in Italy and abroad.

In compliance with the provision of the Directive (EU) 2019/1937 and the relevant transposition laws, the company’s Organisational, Management and Control Model, pursuant to Italian Legislative Decree. n. 231 of 2001, and internal anti-corruption regulations, we have adopted a system for the management of whistleblowing reports that enables us to manage whistleblowing reports received, including anonymously, by Saipem SpA and by its subsidiaries in Italy and abroad.

Whichever channel is used, we guarantee the receipt, analysis and management of whistleblowing reports that are sent by or transmitted from anyone, also anonymously:

• Saipem people (resources that independently from the contractual typology, work for the company, also for training purposes and without any compensation, employees of third parties that have direct relations with the company);
• Other third parties in relation with Saipem (e.g. Business Partners, clients, vendors, Saipem audit company, advisors, partners)
• All the stakeholders (included shareholders and people in charge of administration, direction and control Functions, supervision or representation).
  

The whistleblowing reports are related to behaviours in violation of the Code of Ethics, laws, rules and internal policies, Authority provisions, 231 Models.

The company guarantees the strict confidentiality on the persons and facts reported and on the identity of the reporting persons to ensure that they are not subject to any form of retaliation.

Whistleblowing reports may be sent using a dedicated Platform – suitable for ensuring, by IT tools, the confidentiality of the reporting person’s identity –  available at the following link:

https://www.saipem.com/en/about-us/business-integrity/reports
 

Please note that, alternatively, it is possible to send the report also through the following channels:

• Ordinary post: Saipem SpA, Spot Audit and Whistleblowing Function, Via Luigi Russolo 5, 20138 Milano (MI), Italy;
• Email address: WhistleBlowing@saipem.com;
• Voice mail: +39 02 442 53012 at disposal of Spot Audit and Whistleblowing Function;
• Direct meeting with Spot Audit and Whistleblowing Function.

Without prejudice to the preferential use of the reporting channels made available by Saipem, in the cases peremptorily indicated pursuant to Article 6 of Legislative Decree 24 of 10 March 2023, reports may also be submitted to the competent authority in the matter (ANAC).

The information and personal data provided in the context of whistleblowing reports are processed for the purpose of managing and following up the reports, as well as investigating any reported conduct and adopting the necessary measures in accordance with applicable laws, including data protection legislation. For more information on the modalities and purposes of the processing of personal data included in the reports and collected during the procedure, please consult the privacy information notices available on this page.

Saipem's business activities have always complied with the principles of loyalty, fairness, transparency, integrity and with the laws and regulations. 

Corruption is an intolerable obstacle to business efficiency and fair competition. 

Saipem's “Anti-corruption Compliance Programme” uses a detailed system of regulations and controls to prevent corruption, consistent with international best practices and with the principle of “zero tolerance” expressed in the Code of Ethics.   

More specifically, the Saipem Code of Ethics establishes that “Practices of corruption, unlawful favours, collusive conduct, direct or third party solicitations for personal benefits and career gains for oneself or for others, are, without exception, prohibited”. 

Saipem's “Anti-Corruption Compliance Programme” stands out for being dynamic and for paying constant attention to any changes in national and international legislation and best practices.   

Over the years, the “Anti-Corruption Compliance Programme” has continually improved  with constant updates in compliance with the applicable anti-corruption provisions and international conventions (including the 2003 United Nations Convention Against Corruption, the 1997 "Convention of the Organisation for Economic Cooperation and Development on Combating Bribery of Foreign Public Officials in International Business Transactions", the 1977 US Foreign Corrupt Practices Act, the 2010 UK Bribery Act, the Italian Legislative Decree No. 231 of 8 June 2001 and the French Law No. 1691 of 2016 (“Sapin II”).  

In 2019, Saipem SpA issued the latest revision of its “Anti-Corruption Management System Guideline” (MSG), which improved the regulations in its “Anti-Corruption Compliance Programme” and Saipem's Corporate Governance systems on anti-corruption issues. The adoption and implementation of the MSG on Anti-Corruption is mandatory for Saipem SpA and for all its subsidiaries. 

Saipem expects all its Business Partners to comply with all the applicable laws, including the anti-corruption laws during business conducted with Saipem, and to comply with the principles set out in the MSG on Anti-Corruption, published on Saipem's Internet website.   

Saipem is also one of the first Italian companies to have been awarded the international ISO 37001:2016 "Systems of anti-corruption management".

This certification, awarded by an independent third party organisation, identifies a management standard, establishes the requisites and provides guidelines to help an organisation prevent, identify and address corruption, and comply with the anti-corruption legislation and any other voluntary commitments applicable to their own activities. 

All Saipem People are responsible for complying with anti-corruption legislation: all these documents are made available via the appropriate company channels.

A major role is played by the managers, who are expected to encourage all their colleagues to comply with the anti-corruption procedures. 

Moreover, Saipem is aware that the main criteria to develop an effective strategy to combat the phenomenon of corruption lies in making people aware of the tools to prevent it and it considers training activities and awareness-raising activities to be of paramount importance.