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Eni for 2016 | Operating model

Transparency

and anti-corruption

In line with the zero tolerance corruption (“Anti-Corruption applicable anti-corruption
principle in the Code of Ethics, Compliance Program”) and provisions and with
Eni has a structured system of a specific anti-corruption international conventions.
rules and controls to prevent unit, in line with the current

˛ Eni’s Anti-Corruption Compliance Program

LEGAL BASES OF ENI’S Italian Legislative US Foreign UK Bribery United Nations Convention on Combating
ANTI-CORRUPTION Decree 231/2001; Corrupt Practices Act Convention Against Bribery of Foreign Public
COMPLIANCE PROGRAM Anti-corruption Laws Act (FCPA) Corruption (UNCAC) Officials in International
Business Transactions
1 2 3 4 5 6

Top Level Adoption Eni Anti-Corruption Communication Due diligence Disciplinary
Commitment and implementation Compliance Unit and Training on the potential measures and
counterparty contractual
Eni’s Board of Unlisted subsidiaries Provides specialist In 2016 of resources remedies for
Directors approves adopt the assistance on trained in Italy and employees
the Anti-Corruption Anti-Corruption anti-corruption to abroad:
Management System MSG and the Eni SpA and unlisted • 10,229 through
Guideline Anti-Corruption subsidiaries in Italy e-learning;
Regulatory and abroad • 1,269 with
Instruments by workshops;
Board resolution • 1,214 with job
specific training
for specific
professional areas
at risk

INTERNAL AUDITS ON ACTIVITIES AT RISK OF CORRUPTION ˛ In 2016, 34 audits were carried out in 27 Countries

Eni’s experience in anti-corruption on the compliance of Eni SpA’s systems. For information
has also been gained using Anti-Corruption Compliance on the Anti-Corruption MSG,
participation in international Program with the requirements the tax strategy pursued
conferences and working of ISO 37001:2016 “Antibribery by Eni and organizational
groups: in 2016 Eni participated Management System”, the transparency, please see the
in PACI, B20 China and first international standard on specific section on the Eni
Germany, United Nations Global anti-corruption management website.
Compact, Fondazione Global
Compact Network Italia, ABC Eni SpA is the first Italian Company
Benchmarking Group (Steptoe
& Johnson LLP) and OCSE. to achieve ISO 37001:2016
Eni has successfully concluded
an audit conducted by RINA “Antibribery Management System”
Services SpA, Italy’s leading
certification company, certification