Compliance Committee and Model 231

The Compliance Committee of Saipem S.p.A. includes two external members, one of them appointed as Chairman of the Compliance Committee, and three internal members of the following functions of Legal Affairs, Human Resources and Internal Audit or their direct reports. On 27th July 2011 the Board of Directors has appointed as members of theCompliance Committeee Mr. Luigi Rinaldi (Chairman), Mr. Marco Elefanti (external member), Mr. Francesco Del Giudice, Mr. Roberto d’Onofrio and Mr. Alessandro Riva. The main purpose of the Compliance Committee is to check the effectiveness of the Saipem S.p.A. Organization, Management and Control Model ("Model 231 (includes the Code of Ethics") and to be the guarantor of the Saipem Code of Ethics. Saipem employees and stakeholders must report violations (or presumed violations) of the Model 231 to their line manager and/or the Compliance Committee. The Compliance Committee of Saipem S.p.A. can be contacted by e-mail at the following address:

ComplianceCommitteeSaipemSPA@saipem.com  
or
organismodivigilanza@saipem.com 

Bona fide individuals who report a non-compliance are protected against retaliation, discrimination and/or any type of penalty; their anonymity will be safeguarded, barring the legal requirements and the rights of the company and those of the person(s) wrongly or unlawfully accused.
On 27th October 2010 the Board of Directors of Saipem S.p.A. approved the updating of Model 231 which mainly concerned the extension of its application to data processing crimes as under art. 24-bis of the Italian Legislative Decree n. 231/2001.

The English text is a translation of the Italian official "Modello 231 (include il Codice Etico)".
In case of any conflict or discrepancies between the two texts the Italian text shall prevail.

Documentation of Compliance Committee and Model 231

• 
  Model 231
• 
  Code of Ethics