In its business relations, no matter how significant they are, Saipem is inspired by and complies with the principles of loyalty, fairness, transparency, efficiency and openness to the market.
To this end, Saipem undertakes to maintain and strengthen a governance system in line with international best practice standards, able to deal with the complex situations in which Saipem operates, and with the challenges it faces for sustainable development. To Saipem, sustainability means working with the awareness of the responsibility it has towards all it stakeholders. Guaranteeing collaborative relationships based on fairness with each stakeholder is essential to the success of the projects that the Company is involved in. Saipem’s sustainability model guides all business processes. It is oriented towards excellence and the achievement of long-term objectives to prevent, reduce and manage possible risks.
Saipem operates in the reference framework of the Universal Declaration of human rights adopted by the United Nations, the fundamental conventions of the ILO (International Labour Organisation) and the OECD Guidelines for multinational enterprises. The company repudiates any form of discrimination, corruption, forced labour or child labour.
In particular, Saipem pays attention to the acknowledgement and safeguarding of the dignity, freedom and equality of human beings, to the protection of labour and the freedom of trade unions, to health, safety, the environment and biodiversity, as well as to values and principles relating to transparency, energy efficiency and sustainable development, in accordance with international institutions and conventions. Respect for human rights is the foundation for an inclusive growth of populations and regions, and consequently of the companies that develop in them. Saipem contributes to the creation of the socio-economic conditions required for the effective enjoyment of fundamental rights and promotes the professional growth and well-being of its own local human resources. In 2017, as part of Saipem's commitment to promoting human and labour rights in its activities, the Company published its first Human Rights Policy.
Additionally, the Sustainability, Scenarios and Governance Committee has been set up (comprised of the Chairman of Saipem S.p.A. and three non-executive directors the majority of whom are independent) and is responsible for assisting the Board of Directors by fulfilling a preparatory, consultative and advisory role in assessments and decision-making processes with regard to the Sustainability, Corporate Governance, Saipem’s Corporate Social Responsibility and the review of scenarios envisaged in the preparation of the Strategic Plan.
Code of Ethics
The Code of Ethics forms an integral and substantial part of Model 231 and is, among other things, a general, mandatory principle.
Saipem’s Code of Ethics is the same for all Saipem Personnel.
It defines quite clearly, in compliance with the law, the values that the Company recognises, accepts and shares, as well as the responsibilities that it assumes both internally and externally. It enforces correctness, loyalty, integrity and transparency in operations, behaviour, working methods and relations with other parties inside and outside the Group.
Compliance with the Code of Ethics by Saipem’s directors, statutory auditors, management and employees as well as by all those who operate in Italy and abroad to achieve Saipem’s objectives (“Saipem’s People”), each within their own functions and responsibilities, is of paramount importance – also pursuant to and for the effects of legal and contractual provisions governing the relationship with Saipem – for Saipem’s efficiency, reliability and reputation, which are all crucial factors for its success and for improving the social situation in which Saipem operates.
Everyone at Saipem is required to have knowledge of the principles and contents of the Code of Ethics, as well as of the reference procedures that regulate the functions and responsibilities covered.
The Code of Ethics provides for the appointing of the Guarantor of the Code of Ethics, the functions of which are assigned to the Compliance Committee, a corporate body which is endowed with “autonomous powers of initiative and control” pursuant to art. 6, paragraph 1, letter b) of Legislative Decree no. 231 of 2001 on the liability of entities for administrative offences deriving from crime.
The tasks assigned to the Guarantor concern, among other things, the promotion of dissemination activities and the training of Saipem employees, the examination of news relating to any possible violations of the Code and communication to the competent structures of the results of the relevant inspections so that appropriate measures can be taken.
Still with a view to disseminating the principles laid down in the Code of Ethics and in Model 231 in the best and most effective way, Saipem has also published on its intranet, the “Saipem Business Integrity Guide”, the aim of which is to provide Saipem employees with yet another tool that is easy to read and consult in order to better understand and share the ethical values of Saipem. This Guide provides an overview of the principles and reference policies, as well as some explanations and a description of some practical cases in the “What to do if” section. The Guide does not replace the Code of Ethics, Model 231 or the procedures, but it facilitates their comprehension.
Saipem has put in place a solid and effective system for discouraging, detecting, investigating and reporting any illegal behaviour in the company and the whistleblowing process is a part of this.
The management, employees, consultants, collaborators and business partners must report to the Compliance Committee any behaviour that is not in line with the principles and contents of Model 231.
With a view to facilitating the reporting of Whistleblowing, it makes the following communication channels available to all Saipem employees and site users, particularly:
- ordinary postal service (address: Saipem SpA, Internal Audit Function, Via Martiri di Cefalonia 67, 20097 San Donato Milanese (MI), Italy);
- fax numbers (International toll-free telephone number - fax: +39 02 442 54088);
- email (email addresses): whistleBlowing@
- Compliance Committee of Saipem SpA email:
- communication tools on Saipem SpA intranet/internet sites;
- alternative tools for the collecting of the reports (e.g. dedicated post boxes, so-called Yellow-Boxes) made available by the human resources and/or competent HSEs, for corporate offices that do not permit widespread access to computerised work stations
Whistleblowers are guaranteed against any form, direct or indirect, of retaliation, discrimination or penalization, 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 by wilful misconduct or gross negligence, as well as the provision of disciplinary measures to be applied to those who make, with wilful misconduct or gross negligence, reports that prove to be groundless. In any case, the confidentiality of the whistleblower’s identity is assured; sanctions are also imposed on those who violate provisions adopted to guarantee safeguarding of the whistleblower.
Anti-Corruption Compliance Programme
Saipem has always conducted its business with loyalty, fairness, transparency, integrity and in full observance of laws and regulations. In this context corruption is an intolerable obstacle to the efficiency of business and fair competition.
Among the various initiatives, Saipem has designed an “Anti-corruption Compliance Programme”, a detailed system of regulations and controls for the purpose of preventing corruption, in line with international best practices and with the principle of “zero tolerance” expressed in the Code of Ethics.
In particular, Saipem’s Code of Ethics (included in Model 231) establishes that “practices of corruption, unlawful favours, collusive behaviours, direct or indirect 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 its dynamism and constant attention to developments in the national and international regulatory scenarios and best practices.
Over the course of the years, in a perspective of continuous improvement, the “Anti-Corruption Compliance Programme” has been constantly updated in line with the reference provisions (including among others the United Nations Convention against Corruption, the Organisation for Economic Co-operation and Development Convention on Combating the Bribery of Foreign Public Officials in International Business Transactions, Italian Legislative Decree no. 231 of 8 June 2001, the US Foreign Corrupt Practices Act, the UK Bribery Act and the French Sapin 2 law).
In 2015 Saipem SpA issued the latest revision of the “Anti-Corruption” Management System Guideline (MSG) which represents an improvement of the regulatory context of the “Anti-Corruption Compliance Programme” and of Saipem’s Corporate Governance systems on Anti-Corruption issues. The aforementioned MSG was examined and approved by the Board of Directors of Saipem SpA and its adoption and implementation is mandatory for Saipem SpA and for all its subsidiaries.
Saipem requests compliance by Business Partners with the applicable laws, including the anti-corruption laws pertinent to the business activities carried out with Saipem, and the commitment to follow the reference principles contained in the Anti-Corruption MSG.
Saipem is, moreover, one of the first Italian companies to obtain the international certification ISO 37001:2016 “Antibribery Management Systems” The certification, awarded by an independent third party, attests to a standard of management, specifies a series of measures and provides guidelines to help organizations prevent, detect and address bribery, and comply with the anti-bribery legislation and any other voluntary commitments applicable to their own activities.
All Saipem personnel are responsible for complying with the anti-corruption laws: for this reason all documents relating to this topic are easily accessible on the Company’s web site and intranet portal. In this context, a particularly important role is played by the managers, who are called upon to enforce observance of the anti-corruption procedures, also by their collaborators.
Aware, moreover, that the primary element for developing an effective strategy to combat the phenomenon of corruption lies in fostering thorough knowledge of the tools for its prevention, Saipem considers the training activities and awareness-raising activities of paramount importance.
Any violation, alleged or confirmed, of the anti-corruption laws or anti-corruption procedures must be reported immediately via one of the channels indicated in the procedure “Whistleblowing reports received (including anonymously) by Saipem and by its Subsidiaries in Italy and abroad”, available on the web site. The whistleblower’s report form is also available from the link below:
Disciplinary measures may be taken against any Saipem personnel found guilty of breaching the anti-corruption laws or who omit to report violations that have come to their knowledge.