Snam S p A : Tax transparency report 2024

TAX TRANSPARENCY

REPORT 2024

APRIL 2025

Energy infrastructure for a sustainable future

1. HIGHLIGHTS

2. SNAM

3. SUSTAINABILITY

4. TAX STRATEGY

5. TAX RISK CONTROLS

6. TAX REPORTING

7. APPENDIX

COMPANY PROFILE

Snam, with its purpose "energy to inspire the world", is committed to transporting what the world needs most to improve itself: energy. A profound, fundamental raison d'être that has had to be reconciled with the current geopolitical situation, in which rising uncertainty and price volatility require resilient systems able to withstand geopolitical shocks. Snam has thus chosen to direct its commitment towards a system of "energy infrastructures for a sustainable future", thanks to which the great challenge of the energy trilemma - to guarantee secure, competitive and environmentally friendly supplies - can be tackled with confidence, fostering the resilience, adaptability and transition of the territories served. In this perspective, the Group's engineering tradition and its ability to lead the country with competence and responsibility are further enhanced by innovation and the central role of people, becoming the drivers of a harmonious path that, by preserving the balance of the energy system, concurrently leads to the goal of Carbon Neutrality and the subsequent goal of Net Zero. All in the name of unwavering values.

Together with the Group's vision, which intends to guide the sector through an increasingly innovative sustainable energy network, purpose and ambition will help Snam to face the many challenges of the future: an environmental impact that wants to become positive, increasing digitalisation, a real connection with local communities and the development of energy transition businesses. This is how Snam intends to realise its ambition by creating value for all stakeholders, through two strategic levers: sustainability and innovation, which continue to be the strategic levers to support Snam's ambition to become a leading pan-European multi- molecule energy operator.

www.snam.it

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1. HIGHLIGHTS

2. SNAM

3. SUSTAINABILITY

4. TAX STRATEGY

5. TAX RISK CONTROLS

6. TAX REPORTING

7. APPENDIX

MESSAGE FROM SNAM GROUP'S CFO AND TAX DIRECTOR

The Tax Transparency Report represents Snam's commitment to constantly improve

tax transparency,

it is a fundamental value

in which we believe, an intregral part of the Group's sustainable growth strategy.

Luca Passa

Chief Financial Officer, Snam Group

The third Tax Transparency Report marks a further stage in our journey towards tax transparency, allowing us to look into taxes, around taxes and beyond taxes. Thus, we present our taxes paid, tax governance and the effects on ESG matters.

Giuseppe Nicosia

Tax Director, Snam Group

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1. HIGHLIGHTS

2. SNAM

3. SUSTAINABILITY

4. TAX STRATEGY

WHAT'S NEW IN THE REPORT

New info icon.

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5. TAX RISK CONTROLS

6. TAX REPORTING

7. APPENDIX

Tax and the environment

Business ethics

Integration of the TCF model

Global Minimum Tax

Transfer pricing

ETR reconciliation

1. HIGHLIGHTS

2. SNAM

3. SUSTAINABILITY

4. TAX STRATEGY

5. TAX RISK CONTROLS

6. TAX REPORTING

7. APPENDIX

CONTENTS

COMPANY PROFILE

MESSAGE FROM SNAM GROUP'S CFO AND TAX DIRECTOR

WHAT'S NEW IN THE REPORT

1. HIGHLIGHTS

1. Snam's journey to Transparency
2. Strengthening the tax infrastructure
3. Tax contribution to ESG topics

2. SNAM

1. Business
2. Snam's global footprint

3. SUSTAINABILITY

3.1 Snam and sustainability

3.2 Snam's sustainability strategy

1. Sustainability scorecard
2. Sustainable finance

3.5 Tax and the environment

4. TAX STRATEGY

1. The control environment
2. Tax strategy fundamentals
3. Tax strategy

4.4 Business ethics

4.5 Tax reform

5. TAX RISK CONTROLS

1. The control system's architecture
2. Tax control tools as part of the TCF 5.3 Integration of the TCF model

1. Relations with the tax authorities
2. Snam stakeholders

5.6 Global Minimum Tax

5.7 Transfer pricing

6. TAX REPORTING 2024

1. Key figures
2. Group indicators
3. Tax contribution by country
4. Trend analysis
5. Tax contribution by business
   6.6 ETR reconciliation

7. APPENDIX

1. Tax contribution by country
2. Total tax contribution
3. Glossary
4. Sustainable Development Goals (SDGs)
5. KPMG methodological assistance
6. PwC TLS assistance

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1. HIGHLIGHTS

2. SNAM

3. SUSTAINABILITY

4. TAX STRATEGY

5. TAX RISK CONTROLS

6. TAX REPORTING

7. APPENDIX

1. HIGHLIGHTS

Energy infrastructure for a sustainable future

6

1. HIGHLIGHTS

2. SNAM

3. SUSTAINABILITY

4. TAX STRATEGY

5. TAX RISK CONTROLS

6. TAX REPORTING

7. APPENDIX

1.1 SNAM'S JOURNEY TO TRANSPARENCY

					2025
				2024
			2023		Publication
		2021-2022
				of the third Tax
			Publication of	Transparency Report
	2019-2020		Publication of the	the second Tax	which has been
		Transparency Report	the following
				expanded to include
2018			first Tax Transparency	Submission of the	information:
		Report which	application for the
	Ongoing dialogue	represented a	inclusion of Snam	· Global Minimum Tax;
		with the tax	decisive step forward	FSRU Italia S.r.l. in
	Snam and Snam	authorities (requests)	in the Group's tax	the collaborative	· Transfer pricing;
	Rete Gas join the	with a view to	transparency	compliance regime
	collaborative	clarifying uncertain			· Integration of the
	compliance regime	tax positions, also	Implementation	Signing of the code of	TCF model with
Approval of the Tax	which was voluntarily	for other group	of requests for	conduct	the other risk
Strategy by Snam's	joined by another	companies	clarification about new		management models
Board of Directors	seven group companies		investments for Snam		adopted by Snam
			FSRU Italia

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1. HIGHLIGHTS

2. SNAM

3. SUSTAINABILITY

4. TAX STRATEGY

5. TAX RISK CONTROLS

6. TAX REPORTING

7. APPENDIX

1.2 STRENGTHENING THE TAX INFRASTRUCTURE

Snam's tax infrastructure, with the company's people at its centre, has been strengthened through specific initiatives implemented during 2024

TAX INFRASTRUCTURE

Tax strategy	Tax Control
	Framework (TCF)
Risk Assurance &	Cooperative
Compliance Integrated	compliance regime
(RACI)
Tax reporting	Update mechanism

STRENGTHENING

1 TCF SCOPE

Snam FSRU applied to join the cooperative compliance regime.

In addition, two other companies joined the voluntary TCF.

2 INTERNAL REGULATIONS

The companies that are part of the collaborative compliance regime have signed the code of conduct. As part of its ongoing updating of internal regulations, the Snam Group

adopted three new tax procedures.

3 TRAINING

In order to further spread the tax culture, a meeting was organised with the Snam Foundation

aimed at other third sector organisations. In addition, courses on taxation were held for Snam people, including an internal course with the Legal Department.

4 DIGITALISATION

Snam launched a project to digitise the calculation of direct taxes, developing

a specific application that also simplifies the collection of data from companies in the tax consolidation scope, to ensure greater certainty in the determination of taxes.

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1. HIGHLIGHTS

2. SNAM

3. SUSTAINABILITY

1.3 TAX CONTRIBUTION TO ESG TOPICS

AREA

v	on
	m
n	ir			e
						n
E									t
									• Tax incentives linked to emissions reduction
									• Taxes: to discourage the use of polluting goods
									• Higher excise taxes on activities with higher
									environmental impacts
				c
			o ia
	S			l
									• Snam's contribution through its taxes
									• Tax benefits for social investments and adequate level
									of global taxation
									• Tax training courses
				rn
			e	a
	v			n
o					c
G								e

• Transparent and cooperative relationship with the tax authorities

• Tax strategy & governance

• Tax risk management

4. TAX STRATEGY

5. TAX RISK CONTROLS

6. TAX REPORTING

7. APPENDIX

ACTIONS

• Setting emission reduction targets to contribute to climate change mitigation

• Contribution to the achievement of carbon neutrality through energy requalification assistance through Renovit and the development of the biogasssector with Bioenerys

• Utilisation of Bionerys' biogass for the transport business

• Joint venture project for CO2 capture and storage (Ravenna CCS)

• Arbolia reforestation activities for CO2 and PM10 absorption

• No CBAM goods were imported in 2024

• The Group's workforce reached 3,901, an increase of 2.7% on 2023

• Snam supports the domestic economy through its tax contribution as both a taxpayer and a withholding agent

• Solidarity campaigns with the Snam Foundation to strengthen local relations

In 2024, Snam employees donated 6,377 hours to volunteering initiatives (up on the previous year).

• Continuous expansion of corporate health benefits, with extension of supplementary healthcare to all employees and regular updates on how to use the benefits
• Ongoing training and awareness-raising activities of personnel aimed at increasing their skills and familiarity with tax aspects
• The Snam Group companies generally pay higher taxes than the Global Minimum Tax

• The Board of Directors has approved the Group's Tax Strategy

• Snam and Snam Rete Gas joined the cooperative compliance regime in 2018

• Tax Control Framework rolled out (extended to nine other group companies on a voluntary basis)

• Snam and San Rete Gas signed the Code of Conduct

• Snam FSRU Italia has applied for admission to the collaborative compliance regime

Snam requires sustainability due diligences to be performed when acquiring majority equity investments

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1. HIGHLIGHTS

2. SNAM

3. SUSTAINABILITY

4. TAX STRATEGY

5. TAX RISK CONTROLS

6. TAX REPORTING

7. APPENDIX

2. SNAM

Energy infrastructure for a sustainable future

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