Transparency, a value that guides us in every field

Transparency is a company value. We believe that it must be promoted so that we can inclusively manage resources for the benefit of community interests. Ethics underpins our activities and plays a key role in supporting a fair energy transition. We require people to carry out their daily activities with integrity and transparency and we oppose all forms of corruption. We work closely with governments around the world, which often receive major economic transactions, promote the responsible use of financial resources generated in the extractive sector, and publish “Country-by-Country”, a voluntary report to ensure transparency. As an energy company, we participate in policy-making consultations, including by making our energy and environmental expertise available to the community.

As a global energy tech company, we work closely with governments around the world, who are often our counterparties in major economic transactions. Our payments to governments therefore also represent socio-economic support to states, and their proper management contributes to achieving Sustainable Development Goal 16 of the UN Agenda 2030, which prioritises “Peace, Justice and Strong Institutions”. Precisely for these reasons, since 2015 we have included a voluntary disclosure of the payments we make to governments, and since 2017 we have published the “Report on Payments to Goverments”, in line with EU Directive 2013/34.

The criteria by which we draft this document are based on the prevailing interpretations of national and international legislation. Reporting includes payments made in connection with the exploration, prospecting, research, development and extraction of oil (including condensates) and natural gas. Payments relating to refining, natural gas liquefaction (LNG) and gas-to-liquids and other downstream activities are excluded.

Since 2005 we have been participating to the Extractive Industries Transparency Initiative (EITI), the global initiative promoting responsible and transparent use of financial resources generated in the extractive sector, as a supporting company.
In 2023 Eni was appointed as Board member of the EITI, the main decision-making body of the Initiative.

In each participating country, the EITI is supported by a Multi-Stakeholder Group in which government, mining companies and civil society work together to effectively implement the initiative. As part of our involvement with the EITI, we track activities at international level and in member countries, contribute annually to the preparation of reports, and participate in the activities of the Multi-Stakeholder Groups in Congo, Ghana, Timor-Leste and the United Kingdom. In Kazakhstan, Indonesia, Mozambique, Nigeria and Mexico, our subsidiaries liaise with the local EITI Multi-Stakeholder Groups through the trade associations present in the countries. In line with our participation in the initiative, we stand by our position advocating contractual transparency on the part of governments, expressing our support for initiatives that will be adopted in this regard by the countries in which we operate.

Eni’s position on Contractual Transparency

We believe transparency to be a prerequisite to combatting corrupt behaviours  Our commitment is confirmed by our active participation in the global multi-stakeholder EITI initiative. In this context, we promote numerous activities and a transparent approach in the management of our operations: we take part in EITI Board initiatives and – at local level – contribute to the activities of EITI Multi-Stakeholder Groups in countries where they are present, while also initiating dialogue with the governments of countries that have not yet formally joined the initiative.

The 2019 EITI Standard introduced an important new requirement for member countries to “disclose any contracts and licences granted, entered into or amended after 1 January 2021”, with the aim of strengthening community, stakeholder and investor confidence in governments and companies by enabling civil society to monitor and oversee the terms of these agreements, expected revenues and associated socio-environmental obligations. 

As a company supporting the EITI, we encourage governments to comply with the new standard on the publication of contracts and express our support for the mechanisms and initiatives that will be undertaken by countries to promote transparency in this area.

In compliance with Italian Law No. 208/2015, we voluntarily publish (although there is no regulatory obligation to do so) the “Country-by-Country Report” required by Action 13 of the “Base erosion and profit shifting - BEPS” project, promoted by the OECD with the sponsorship of the G-20, whose objective is to have the profits of multinational companies reported in the jurisdictions where the economic activities that generate them are carried out, in proportion to the value generated. The publication of this report has been recognised as best practice by the EITI. The CbC Report is a tool for assessing fiscal risk and is sent by the Italian tax administration to all other administrations with which it has an agreement for exchanging information. Regarding transparency, Italy adopted EU Directive no. 2021/2101 during 2024, mandating the disclosure of specific Country-by-Country Reporting (CbCR) details from the 2025 tax year onwards. Furthermore, in line with its disclosure on beneficial ownership, Eni publishes its company structure in its Integrated Annual Report.

Fighting corruption is based, above all, on prevention. This is why we ask all our people to commit to the Anti-Corruption Compliance Programme on an ongoing basis. This Compliance Programme is also inspired by the Code of Ethics, and sets out the principles and rules that must be followed to ensure compliance with anti-corruption laws for all Eni employees and all those working, in Italy and abroad, for or on behalf of Eni. Indeed, we believe it is important not only to ensure correct conduct among Eni employees, but also to disseminate it in the areas where we operate and among our counterparties.

Eni also implements anti-corruption measures across its Value Chain by including specific contractual clauses and compliance statements. These require adherence to the principles set out in Eni’s Code of Ethics and key internal anti-corruption laws (refer to the “Anti-corruption measures within the Eni Value Chain” section of the Sustainability Report).  

Since 2006, Eni has maintained a policy for handling whistleblowing reports, which was updated in March 2024. The policy enables employees or external parties to submit information about suspected violations observed in the workplace, which are then investigated by a specialised team. We run an anti-corruption training programme for employees that includes e-learning, classroom sessions and general workshops, and job-specific training. In keeping with the principle of top-level commitment, the members of Eni SpA’s top management, business directors/heads, and the CEOs (or equivalent roles) of its subsidiaries are also expected to participate in these sessions. In 2024, the online course “Code of Ethics, Anti-Corruption and Corporate Administrative Responsibility” continued to be offered to Eni personnel in Italy and abroad, together with the new online course on the Anti-Corruption Compliance Program, aimed at medium and high-risk personnel. In addition, a general anti-corruption workshop was held for Eni’s M&A function, in which some members of Eni’s Board of Directors and Board of Statutory Auditors also participated. As part of its training programmes for third parties, Eni held sessions for specific Enilive stakeholders (agents, LPG distributors, and lubricant resellers in Italy) and maintained an online course for suppliers at high risk.  

Our regulatory tools require at-risk third parties to undergo anti-corruption due diligence. As such, Eni has had a dedicated Integrity Due Diligence Competence Center for this purpose since 2023. The goal is to optimise and digitise compliance controls while leaving responsibility for the due diligence process with the head of the business lines.

Our activities enable us to make a significant contribution to the tax revenues and therefore to the development and social and economic well-being of the states in which we operate, including through payment of taxes, as well as through direct transactions with governments. We are aware of the importance of these financial flows for collective well-being, and we therefore adopt conduct consistent with the principles of transparency, honesty, fairness and good faith set out in our Code of Ethics. Our tax strategy aims to correctly assess taxes in the different jurisdictions in which we operate, to mitigate the risks of legal and economic double taxation of profits, and to prevent potential disputes with the tax and judicial authorities of the countries in which we operate.

Representing our interests at the various institutional forums is our duty, not only to protect the company, but also to permit a correct assessment of the impacts of our activities on the local area, as well as to improve the effects and effectiveness of our actions. For these reasons, we maintain a transparent dialogue with public institutions and civil society organisations in all countries. As an energy company, it is natural and appropriate for us to participate in policy-making consultations, including by making our energy and environmental expertise available to the community. In 2017, at national level, Eni took part in the consultation on the Energy Strategy at the initiative of the Ministry of Economic Development and the Ministry for Environment, Land and Sea Protection, contributing opinions and proposals to the institutional bodies involved in defining Italy’s long-term energy strategy.