Anti-Corruption Procedures

In the past years Saipem has actively taken part in the fight against corruption by expressly prohibiting in its Code of Ethics "practices of corruption, unlawful favours, collusive behaviours, direct or indirect solicitations for personal benefits and career gains for oneself or for others." All Saipem  personnel are required to comply with the Code of Ethics, which must be expressly accepted by all suppliers during their qualification process.
Saipem has committed to respect the principles of the United Nations Convention Against Corruption (UNCAC), the principles of the OECD Convention on Combating Bribery of Foreign Officials in International Business Transactions and the Business Principles for Countering Bribery issued by Transparency International.
In 2010 Saipem’s commitment was also further strengthened by two initiatives:

• the issuance, after due approval by Saipem’s Board of Directors, of the Anti-Corruption Compliance Guidelines and first two Anti-Corruption Ancillary Procedures, relating respectively to joint venture agreements and intermediary agreements (which will be followed by additional Ancillary Procedures in specific risk areas, currently in the process of being finalised); and
• the creation, within the Saipem Legal Affairs Department, of a dedicated organizational structure denominated Anti-Corruption Legal Support Unit, in charge of providing the business units of Saipem and of its subsidiaries, both in Italy and abroad, with ad hoc legal advice and support on specific anti-corruption issues, promoting and co-ordinating the anti-corruption training and periodically reviewing and updating the Anti-Corruption Compliance Guidelines. The Anti-Corruption Legal Support Unit also submits an annual report on its monitoring activity to the Compliance Committee of Saipem S.p.A.

The Anti-Corruption Compliance Guidelines and the Anti-Corruption Ancillary Procedures are aimed at providing a framework of the anti-corruption rules and procedures implemented in order to maximise Saipem’s compliance with the Code of Ethics and the national and international laws applicable in Italy and abroad. Both the Anti-Corruption Compliance Guidelines and the Anti-Corruption Ancillary Procedures have been adopted by all controlled companies of Saipem Group, both in Italy and abroad.
Saipem requires compliance with the anti-corruption laws by all its intermediaries, its business partners as well as by its “covered business partners", who , in carrying out their activity in the interest of Eni, could have relevant contacts with public officials.
Saipem personnel have the duty to comply with the anti-corruption rules: to such end, all relevant documents are easily accessible through the Company’s intranet portal.
Moreover, in 2010 an internal event was organised to inform Saipem Top Mangement of the Company’s most recent anti-corruption initiatives. Such event was followed by the launch of a mandatory anti-corruption training programme for personnel "at risk" both in Italy and abroad, consisting  of courses aimed at providing a general framework of the anti-corruption rules and issues and of a series of interactive workshops to address and analyse specific cases and practical situations that may arise during the Company’s activity.
In such context, a role of primary importance is vested in the managers, who have the duty to promote their teams’ compliance with the Anti-Corruption Guidelines and Ancillary Procedures. In addition, Internal Audit examines and independently evaluates internal controls to ensure that the provisions of the Anti-Corruption Compliance Guidelines are complied with on the basis of their annual audit programme, as approved by the Board of Directors.
Any suspected or known breach of the anti-corruption laws or Anti-Corruption Compliance Guidelines must immediately be reported in accordance with the provisions set out in the Reports (Including Anonymous One) Received by Saipem and Its Subsidiaries.
Disciplinary measures may be taken against Saipem personnel found guilty of breaching the anti-corruption laws, who do not take part in the prescribed training programme, who omit to report violations they are aware of or who retaliate against others who report violations.
 

Documentation of

• 
  Anti-Corruption Compliance Guidelines
• 
  Reports (Including Anonymous One) Received by Saipem and Its Subsidiaries