To address the high risks faced by the company in carrying out its activities, Eni has adopted an Anti-Corruption Compliance Programme – a system of rules and controls first introduced in 2009 aimed to prevent corruption in line with the principle of “zero tolerance” outlined in Eni’s Code of Ethics and international best practice. In particular, Eni SpA and all its subsidiaries in Italy and abroad are required to adopt and implement the Anti-Corruption Management System Guidelines approved by Eni’s Board of Directors in 2014 aimed at preventing all forms of corruption involving both public officials and private parties. The company’s anti-corruption compliance programme is further strengthened and updated, with a view to continuous improvement, by taking account of best practices . Moreover, Eni does everything it can to ensure that entities and companies not controlled comply with Eni’s anti-corruption standards. The Anti-Corruption Compliance Unit, which manages specialist activities to ensure the effectiveness of the Compliance Programme for Eni SpA and its unlisted subsidiaries in Italy and abroad, reports to the Eni SpA Executive Vice President Integrated Compliance Department. The Unit is responsible for the verification of due diligence assessments with regard to the integrity, professional reliability and reputation of potential contractual partners, in the management of “red flags” (or warning signs) and the drafting of contractual principals in areas at risk of corruption. It makes regular reports to the controlling bodies and the Watch Structure of Eni SpA. To make the strategy for combating corruption even more effective, Eni invests in continuous training programmes in Italy and abroad aimed at ensuring that staff have sufficient awareness about anti-corruption laws and internal regulations on anti-corruption. It also provides guidance on how to recognise and manage red flags. Disciplinary measures against employees as well as legal action and remedial measures in respect of contractual parties are foreseen in the event of violations.
The discipline of the “administrative liability of legal entities deriving from offences” (Legislative Decree 8 June 2001 no. 231), on which Eni’s Model 231 is based, decrees that companies may be subject to fines or other punishments for offences committed or attempted – in Italy or abroad – in the interest/for the benefit of the company by its representatives, Directors or managers, or one of its financially and functionally autonomous organizational units. This also applies to those with even de facto management and control responsibilities (such as senior managers) and to anyone subject to the direction or supervision of all the people mentioned above.
Eni’s Model 231, of which Code of Ethics is an integral part and essential general principle, was adopted for first time by Eni’s Board of Directors in December 2003 - January 2004 and subsequently amended (finally on the 27th October 2016). At the same time when Model 231 was adopted, Eni’s Board of Directors created also a Supervisory Board (“Watch Structure”) to oversee the Model’s effectiveness to report on its implementation to the top management. The Watch Structure is made up of internal and external members, including the Chairman. The same Watch Structure performs the functions of Guarantor of the Code of Ethics.
Responsibility for updating Model 231 lies with the Chief Executive Officer, with the exception of modifications to the General Principles, which must be approved by the Board of Directors after prior notification to the Board of Statutory Auditors. Eni expects all its subsidiaries, in Italy and abroad, to adopt a Model 231 and to nominate a Watch Structure. To this aim, Eni’s Model 231 represents the standard of reference for the definition of the organizational model of each subsidiary. The representatives nominated by Eni to the corporate bodies of partially owned companies, consortia and joint ventures are also required to promote the principles and contents of Model 231 within their respective areas of responsibility.
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