Code of Ethics

Eni was one of the first European companies to create a Business Conduct Code. The first version dates back to 1994. On 14 March 2008, the Board of Directors approved the Code of Ethics along with Model 231 - which is part and parcel of this Code and which replaces the previous  Business Conduct Code – for the purposes of focusing on the objectives of sustainable development (responsibility with respect to the territories of reference, protection of third generation rights, defense and promotion of human rights) as well as on the general principles constituting the system of values of the Company and of the Group. The Board of Directors has, in fact, considered it to be of fundamental importance that the values and principles which guide Eni be clearly defined, both internally and externally, in order to ensure that all Company activities are implemented in compliance with norms and within an environment of fair competition, honesty, integrity, fairness and good faith as well as in accordance with the legitimate interests of all the stakeholders with which Eni enters into contact on a daily basis: shareholders, employees, suppliers, customers, commercial and financial partners, local communities and institutions within the countries in which Eni is operational.

These values are embedded within the Code of Ethics and serve as a commitment for all employees of Eni - starting with management – to comply and ensure the compliance with these principles within the realm of each individual tasks and responsibilities. The conviction that one is acting for the benefit of Eni may not, in any manner, justify behaviors which conflict with these principles; the Guarantor of the Code of Ethics acts in protection and in promotion of these principles and presents a report on the implementation of the Code, on a half-year basis, to the Internal Control Committee as well as to the Board of Statutory Auditors, the Chairman and the Chief Executive Officer who in turn report to the Board.

The Code also represents a general non-derogatory principle of Model 231, of which it is part and parcel.
The synergies between the Code of Ethics and the Model are also emphasized by the allocation of Guarantor functions with respect to the Code of Ethics to the  Watch Structure of Eni, the latter being established by Model 231. Similarly, each subsidiary assigns Guarantor functions with respect to the Code of Ethics to its own Watch Structure.

The Code of Ethics applies to all subsidiaries which are directly and indirectly controlled in Italy and abroad by Eni. Subsidiaries which are listed on the stock exchange and those of the gas sector which are subject to unbundling regulations adopt the Code and adjust it if  necessary, in accordance with their own company peculiarities and the principle of managerial  independence. The representatives specified by Eni for the corporate bodies of other shareholdings as well as in consortia and joint ventures promote the principles and contents of the Code within the realms of their respective spheres of competence. The commitment of Eni to spread the principles of the Code is further highlighted by the creation of a special Promotional Team for the Code of Ethics whose task involves providing all knowledge and clarifying tools relative to the interpretation and implementation of the Code by means of initiatives which are differentiated in relation to the various involved stakeholders; these initiatives also aim to stimulate observations on the Code so that the latter can be constantly updated on the basis of the needs of the companies in which Eni operates.