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Eni’s management of whistleblowing reports

Eni is equipped with a system for handling whistleblowing reports, including the anonymous ones that operates for all Group companies in Italy and abroad.

We ensure the management, analysis and handling of whistleblowing reports received, by Eni and by its subsidiaries in Italy and abroad. 

Analysis and management of whistleblowing reports

In compliance with the provision of the 2002 Sarbanes-Oxley Act, the company’s Organisational, Management and Control Model, pursuant to Italian Legislative Decree. n. 231 of 2001, and internal anti-corruption regulations, we have adopted a system for the management of whistleblowing reports that enables us to manage whistleblowing reports received, including anonymously, by Eni SpA and by its subsidiaries in Italy and abroad.

We guarantee the management, analysis and handling of whistleblowing reports that are sent by or transmitted form anyone, stakeholders, Eni’s People (Eni personnel and anyone, physical or legal persons, who operate in Italy and abroad for achieving Eni’s objectives, each within the scope of their own functions and responsibilities) or other third parties, also when confidential or anonymous. Eni consider a whistleblowing report any communications concerning behaviours that relate to Eni's People in violation of the Code of Ethics, any laws regulations, provisions of authorities, internal regulations, Model 231 or Compliance Models for foreign subsidiaries, that may cause damage or prejudice to Eni, even if only to its public image. These include cases of fraud, against the company assets and/or in financial reporting, illegitimate behaviour pursuant to Italian Legislative Decree. n. 231 of 2001 and/or in violations of an intentional and/or fraudolent nature of Model 231 or the Compliance Models for foreign subsidiaries, possible corruptions or violations of anti-corruption regulatory instruments. The outcome of the investigation carried out by the Internal Audit function on the reported facts are presented to internal inter-functional bodies dedicated to manage whistleblowing reports, the Board of Statutory Auditors, the Supervisory Board and for whistleblowing reports within their area of responsibility to   Eni SpA’s Watch Structure and top management and to the top management and the control and supervisory bodies of each subsidiaries involved.

The company guarantees the strict confidentiality on the persons and facts reported and anonymity of whistleblowers to ensure that they are not subject to any form of retaliation.

Whistleblowing reports may be sent using a dedicated form, click here to send a report.
This channel is considered preferential and suitable for guaranteeing, with IT tools, the confidentiality of the identity of the whistleblower.

  2017 2018 2019 2020 2021
Whistleblowing files opened during the year categorized according to the process that is the subject of the report: (number) 73 81 68 74 73
Procurement 12 14 20 20 20
Human resources (a) 23 23 22 16 27
Maintenance 5 8 2 1 1
Commercial 10 6 3 12 6
Logistic, law materials and products 4 6 3 3 3
HSE 3 5 4 10 7
Others (security, operations, portfolio management and trading) 16 19 14 12 9
Whistleblowing files that have been closed during the year divided according to the outcome of the investigations: 83 79 74 73 74
Founded 10 15 18 22 10
Partially Founded(b) - - - - 13
Unfounded, with the adoption of improvement measures 35 30 26 32 18
Unfounded/Not ascertainable(c)/not applicable(d) 38 34 30 19 33
(a) The update of the Whistleblowing report procedure of May 8th 2020 - Annex C to Management System Guideline "Internal Control and Risk Management System" - provided for the unification of the methods for managing whistleblowing reports relating to the Internal Control System and Management of Risks and whistleblowing reports relating to violations of the Code of Ethics; the whistleblowing files relating to the Human Resources process therefore include, for the years 2017-2019, the number of files relating to violations of the Code of Ethics which in previous versions of this document was represented in a specific item of the table.
(b) Investigations conducted have revealed evidence that one or more of the assertions in the report are reasonably believed to be true (classification introduced from October 1st, 2021)
(c) Whistleblowing reports that do not contain any circumstantial, precise and/or sufficiently detailed elements and/or, for which, on the basis of the investigative tools available, it is not possible to confirm or exclude the validity of the assertion contained in the report
(d) Whistleblowing reports in which the facts reported coincide with the subject of pre-litigation, disputes and investigations in progress by public authorities (for example, ordinary and special judicial authorities, administrative bodies and independent authorities with supervisory and control functions). The assessment is carried out subject to the opinion of the legal affairs function or other competent functions.

Management of whistleblowing Reports and respect for human rights

With regard to whistleblowing reports, in 2021 investigations were completed on 74 files1, of which 302 included human rights aspects, mainly concerning potential impacts on workers’ rights and occupational health and safety.

Among these, 40 assertions were verified with the following results: for 5 of them the reported facts were confirmed, at least in part, and corrective actions were taken to mitigate and/or minimise their impacts, including: (i) actions on the Internal Control and Risk Management System, relating to the implementation and strengthening of existing controls; (ii) actions against suppliers; (iii) actions against employees, including disciplinary measures, in accordance with the collective labour agreement and other national laws applicable.

At the end of the year, 15 files were still open, 5 of which referred to human rights aspects, mainly concerning potential impacts on workers’ rights.

1) Whistleblowing File: a summary document of the investigations carried out on the whistleblowing report(s) (which may contain one or more detailed and verifiable assertions) and that contains a summary of the investigation carried out on the reported facts, the result of the investigations and any action plans identified.

2) Of which 2 relating to subsidiaries not fully consolidated.

  2017 (a) 2018 2019 2020 2021
Whistleblowing files (assertions) on human rights violations closed during the year and categorized by results of the investigations and typology. (number) 29 (32) 31 (34) 20 (26) 25(28) 30 (40)
Founded assertions 3 9 7 11 2
Potential socio-economic impacts on local communities (a) 0 0 0 0 0
Potential impacts on health, safety and/or well-being of local communities (b) 0 0 0 1 0
Potential impacts on worker rights (c) 3 6 5 6 2
Potential impacts on workplace health and safety (d) 0 3 2 4 0
Partially founded assertions (e) - - - - 3
Potential socio-economic impacts on local communities - - - - 0
Potential impacts on health, safety and/or well-being of local communities - - - - 1
Potential impacts on worker rights - - - - 2
Potential impacts on workplace health and safety - - - - 0
Unfounded assertions, with the adoption of corrective/improvement measures 9 9 8 9 7
Potential socio-economic impacts on local communities 0 0 1 0 1
Potential impacts on health, safety and/or well-being of local communities 0 0 0 0 0
Potential impacts on worker rights 8 8 5 7 3
Potential impacts on workplace health and safety 1 1 2 2 3
Unfounded/Not ascertainable(f)/Not applicable assertions(g) 20 16 11 8 28
Potential socio-economic impacts on local communities(b) 0 0 0 0 1
Potential impacts on health, safety and/or well-being of local communities(c) 2 2 1 0 3
Potential impacts on worker rights(d) 15 12 10 8 14
Potential impacts on workplace health and safety(e) 3 2 0 0 10
(a) Including issues related to consultation and/or compensation processes and increase in conflicts.
(b) Including the requirements for the management of polluting products.
(c) Including delays in the recognition of due wages, discrimination, harassment, bullying and mobbing.
(d) Including unhealthy and/or insecure workplace environments.
(e) Assertions whose verifications have revealed partial elements confirming the validity of the facts reported in them (classification introduced from October 1st, 2021)
(f) Allegation that do not contain any circumstantial, precise and/or sufficiently detailed elements and/or, for which, on the basis of the investigative tools available, it is not possible to confirm or exclude the validity of the facts reported in them.
(g) Allegations in which the facts reported coincide with the subject of pre-litigation, disputes and investigations in progress by public authorities (for example, ordinary and special judicial authorities, administrative bodies and independent authorities with supervisory and control functions). The assessment is carried out subject to the opinion of the legal affairs function or other competent functions.