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Reporting on the 10th principle of Global Compact

Eni's reporting on the 10th principle according to the guidelines of the Global Compact
Commitment and Policy Internal levelExternal levelCollective level
B1 Publicly stated commitment to work against corruption in all its forms Diffusion of the Code of Ethics and Model 231, available on the company website, to all those with whom eni has relations. Update of the Anti-Corruption Guidelines in the new Anti-Corruption Management System Guideline.

B2 Commitment to be in compliance with all relevant laws, including anti-corruption laws Commitment to officially subscribe to the highest relevant international standards (GC Principles, UNCAC and OECD Conventions). Subscription to EITI and reinforcement of the role of promoter in Countries of operations which do not subscribe to the initiative in collaboration with the Foreign Ministry. Commitment to respect the Business Principles for Countering Bribery of Transparency International. Participation in the Working Group of the GC on the matter of anti-corruption (national and international scope). Statement on the occasion of the EITI Plenary Meeting (held in Paris). Scientific collaboration agreement with UNODC on anti-corruption.

D2 Statement of support for international and regional legal frameworks, such as the UN Convention against Corruption

D3 Carrying out risk assessment of potential area of corruption Divulgation of eni's anti-corruption compliance program to partners in at risk areas of operation.

D4 Detailed policies for at high-risk areas of corruption Technical legal support in anti-corruption matters supplied by the internal department, also with the aim of implementing Anti-Corruption procedures in eni and its subsidiaries.

D5 Respect of anti-corruption legislation by business partners Request to respect applicable law, including Anti-Corruption law, by business partners, in particular the Covered Business Partners, which operate in areas at greatest risk. Participation in international and national round tables and working groups to identify best practices.

Implementation
B2 Translation of commitments to action Participation in national and international round tables and working groups to identify anti-corruption best practices: working groups of the UNGC and the Italian GC Network.

B4 Support by the organizations’s leadership for anti-corruption Eni Anti-Corruption regulations approved by the Board and adopted by subsidiaries.

B5 Communications and training on anti-corruption for all company staff Training of eni key officers, e-learning courses and interactive workshops. Diffusion of internal Anti-Corruption regulations also on the company intranet portal.

D6 Actions to encourage business partners to apply the commitments Publication of the procedure governing Joint Ventures for the prevention of illegal activity. Promotion of an adequate compliance programme in companies and bodies in which eni has a non-controlling interest, Covered Business Partners and other partners operating in areas at risk of corruption, and maintenance of such a programme.

D7 Management responsibility and accountability in the implementation of policy Responsibility of all eni staff in respecting regulations and anti-corruption instruments. Presence of dedicated whistleblowing channels. Special training for top management.

D8 Insertion of new clauses regarding human rights in purchase contracts Insertion of clauses regarding human rights in new purchase contracts. Action in cases of violations of the law or internal Anti-Corruption regulations.

D10 Anti-Corruption accounting and auditing procedures Internal monitoring of consultancy and support activities delivered in relation to requests.

D11 Participation in voluntary initiatives Participation in the Fraud Awareness W.G., and initiative sponsored by Shell with the aim of providing multinationals operating in West Africa with a platform for sharing best practices in the matter.

Monitoring
B7 Monitoring and development process Updating and periodic review of Anti-Corruption regulations. Examination and evaluation of internal monitoring by Internal Audit of respect of eni Anti-Corruption regulations. Application of the SA8000 standard in the supply chain.

D13 Management of violations Management of reports received directly and indirectly by the company and subsidiaries via the eni regulatory instrument on anonymous reports. Divulgation of the reporting procedure to employees and publication on the company website.

D14 Publication of legal proceedings in relation to AC Publication of the most significant fines and sanctions in the Annual Financial Report.

D15 Publication of legal proceedings in relation to AC Use of Independent certifications of the AC programme.

 

Level of actuation of the action:
completed     in process     to be started

 

The table shows the level of completion of reporting on the 10th Principle at 3 levels of analysis:

  1. internal: describes how eni handles the matter of transparency and corruption by defining policies, procedures and programmes;
  2. external: describes action taken by eni to share its experience and good practices with stakeholders;
  3. collective: describes eni's commitment to uniting its forces with those of other companies and stakeholders to promote transparency and combat corruption.

Last updated on 07/02/13