Anticorruption

In the past years Eni has actively taken part in the fight against corruption by expressly prohibiting in its Code of Ethics "practices of corruption, unlawful favours, collusive behaviours, direct or indirect solicitations for personal benefits and career gains for oneself or for others." All Eni personnel are required to comply with the Code of Ethics, which must be expressly accepted by all suppliers during their qualification process.

By adhering to the Global Compact and particularly to its 10^th Principle, Eni has committed to respect the principles of the United Nations Convention Against Corruption (UNCAC), the principles of the OECD Convention on Combating Bribery of Foreign Officials in International Business Transactions and the Business Principles for Countering Bribery issued by Transparency International.

In 2009 Eni's commitment was also further strengthened by two initiatives:

• the issuance, after due approval by Eni’s Board of Directors, of the Anti-Corruption Compliance Guidelines and first two Anti-Corruption Ancillary Procedures, relating respectively to joint ventureagreements and intermediary agreements (which will be followed by additional Ancillary Procedures in specific risk areas, currently in the process of being revised); and
• the creation, within the Eni Legal Affairs Department, of a dedicated organizational structure denominated Anti-Corruption Legal Support Unit, in charge of providing the business units of Eni and of the non-listed subsidiaries, both in Italy and abroad, with ad hoc legal advice and support on specific anti-corruption issues, supervising the anti-corruption training and periodically reviewing and updating the Anti-Corruption Compliance Guidelines. The Anti-Corruption Legal Support Unit also submits an annual report on its monitoring activity to the Eni Watch Structure and receives the annual reports prepared by the Anti-Corruption Legal Support Unit of each listed/unbundled subsidiary.
  

The Anti-Corruption Compliance Guidelines and the Anti-Corruption Ancillary Procedures are aimed at providing a framework of the anti-corruption rules and procedures implemented over time in order to maximise Eni’s compliance with the Code of Ethics and the national and international laws applicable in Italy and abroad.

Both the Anti-Corruption Compliance Guidelines and the Anti-Corruption Ancillary Procedures are in the process of being adopted by all controlled subsidiaries of Eni, both in Italy and abroad. Eni personnel have a duty to comply with the anti-corruption rules: to such end, all relevant documents are easily accessible through the Company’s intranet portal and in 2009 an internal event was organised to inform Eni personnel on the Company’s most recent anti-corruption initiatives.

Such event was followed by the launch of a mandatory anti-corruption training programme for personnel "at risk" both in Italy and abroad, consisting of an on-line course aimed at providing a general framework of the anti-corruption rules and issues and of a series of interactive workshops to address and analyse specific cases and practical situations that may arise during the Company’s activity. In such context, a role of primary importance is vested in the managers, who have a duty to monitor on their teams’ compliance with the Anti-Corruption Guidelines and Ancillary Procedures. Moreover, Internal Audit examines and independently evaluates internal controls to ensure that the provisions of the Anti-Corruption Compliance Guidelines are complied with on the basis of their annual audit programme, as approved by the Board of Directors.

Any suspected or known breach of the anti-corruption laws or Anti-Corruption Compliance Guidelines must immediately be reported in accordance with the provisions set out in the Eni Whistle-blowing policy.

Disciplinary measures may be taken against Eni personnel found guilty of breaching the anti-corruption laws, who do not take part in the prescribed training programme, who omit to report violations they are aware of or who retaliate against others who report violations.

Lastly, Eni requires compliance with the anti-corruption laws by all its business partners. Among business partners, particular attention is dedicated to "Covered Business Partners", i.e. to those business partners who operate in areas at higher risk due to the probability that, in carrying out their activity in the interest of Eni, they have relevant contacts with public officials.