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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 handling 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 in violation of laws and external regulations, principles contained in the Code of Ethic and rules included in Eni’s internal regulatory system. 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 management

(number) 2016 2017 2018
Report files opened during the year, of which 103 73 81
Internal control and risk management system reports divided according to the process that is the subject of the report 73 58 69
procurement 17 12 14
human resources 10 8 11
maintenance 6 5 8
commercial 10 10 6
logistics 6 4 6
HSE 4 3 5
others (security, operations, portfolio management and trading, ) 20 16 19
Reports on other matters relating to alleged violations of the Code of Ethics 30 15 12
Report files that have been closed during the year divided according to the outcome of the investigations, of which: 111 83 79
Justified 27 10 15
other matters 9 2 4
internal control and risk management system 18 8 11
Unfounded, with the adoption of improvement measures 36 35 30
other matters 11 8 2
internal control and risk management system 25 27 28
Unfounded/generic 48 38 34
other matters 18 12 8

(a) The data relating to the reports contained in this paragraph refer to reports concerning Eni SpA and its subsidiaries.

Management of whistleblowing episodes and respect for human rights

With regard to whistleblowing reports, in 2018 investigations were completed on 79 files, 31 of which included human rights aspects, mainly concerning potential impacts on workers’ rights.

Among these, 34 assertions were checked: the events reported were confirmed, at least in part, for only 9 of these, and actions were taken to mitigate and/or minimize the impacts including: (i) actions on the Internal Control and Risk Management System, relating to the implementation and strengthening of controls in place, and awareness-raising and training activities for employees; (ii) actions for suppliers and (iii) actions against employees, including disciplinary measures, in accordance with the Compliance Program (Model 231), the collective labour agreement and other national laws applicable.

At the end of the year 21 files were still open, 5 of which referred to human rights aspects, in particular potential impacts on workers’ rights.

Report on human rights violations

(number) 2016 2017 2018
Reports (assertions)b on human rights violations (closed during the year and divided by result of investigation and by type), of which 36 29 (32) 31 (34)
Assertions justified 11 3 9
potential socio-economic impacts on local communitiesc 0 0 0
potential impacts on health, safety and/or well-being of local communitiesd 1 0 0
potential impacts on worker rightse 9 3 6
potential impacts on workplace health and safetyf 1 0 3
Assertions unfounded, with the adoption of improvement measures 6 9 9
potential socio-economic impacts on local communitiesc 0 0 0
potential impacts on health, safety and/or well-being of local communitiesd 0 0 0
potential impacts on worker rightse 6 8 8
potential impacts on workplace health and safetyf 0 1 1
Assertions unfounded/generic 19 20 16
potential socio-economic impacts on local communitiesc 0 0 0
potential impacts on health, safety and/or well-being of local communitiesd 1 2 2
potential impacts on worker rightse 14 15 12
potential impacts on workplace health and safetyf 4 3 2
Reports (assertions)b on human rights violations (closed during the year and divided by result of investigation and by type), of which 36 29 (32) 31 (34)

(a) Whistleblowing report: it is a summary document of the investigations carried out on the whistleblowing report(s) (which may contain one or more detailed and verifiable assertions) including the summary of the investigation carried out, the results of such investigation and any identified action plan.

(b) 2016 data refers to the whistleblowing reports (and not to the assertions)

(c) Including issues related to consultation and/or compensation processes and increase in conflicts.

(d) Including spills, atmospheric pollution, accidents, etc.

(e) Including discrimination, violations of labour union rights, forced labour, child labour and unfit working conditions (including harassment and mobbing, salaries less than minimum wage and/or undignified salaries).

(f) Including unhealthy and/or insecure workplace environments.