The Governance of Human Rights at Eni
Human rights take centre stage at Eni.
Focus on human rights starting from the top
Human rights are integrated into the governance of Eni’s sustainability, which is based on the central role of the Board of Directors: the Board approves – acting on a proposal of the CEO ‑ the Company’s strategy and objectives, including those for sustainability, while the CEO ensures the implementation of Board resolutions, periodically reporting the results to the Board.
The Board of Directors is also responsible for approving the most important internal policies, including the Eni’s Statement on respect for human rights and the Code of Ethics, an integral part of the Company’s Compliance Model (Model 231), which sets out rules of behaviour in the company’s activities, including respect for human rights. Another relevant body is the Eni Watch Structure, which acts as the Guarantor of the Code of Ethics, responsible for promoting and verifying the Code’s implementation. The Watch Structure is appointed by the Eni Board and is made up of both internal and external members, including the Chairman, who meet specific requirements for their independence, expertise and professionalism.
Moreover, human rights issues are integrated into Eni’s risk assessment process, with metrics for social, environmental, health and safety impacts.
In 2014, the Company’s commitment to sustainability and respect for human rights was further strengthened with the creation of the Sustainability and Scenarios Committee within the Board, which advises the Board on scenarios and sustainability issues. The Committee is also in charge of evaluating the processes, initiatives and activities aimed at supporting Eni’s commitment to sustainable development throughout the value chain.
The Rules of the Committee were updated in 2017, explicitly including human rights among the sustainability issues for which the Committee submits proposals and advice to the Board.
Regarding disclosure, Eni was a forerunner in the industry in adopting an Integrated Annual Report in 2010. This step was intended to enable Eni’s stakeholders, including non-shareholders, to understand interlinkages between financial performance and social and environmental performance, in line with Eni’s integrated business model. The Integrated Annual Report is approved by the Board and presented to the Annual Shareholders’ Meeting, which approves Eni’s financial statements.
Furthermore, beginning with the 2017 Integrated Annual Report, non-financial performance is detailed in the Consolidated Disclosure of Non-Financial Information, prepared in accordance with applicable legislation and included in the report on operations in the Annual Report. It reports Eni’s activities with regard to respect for human rights, reporting on initiatives undertaken and their results.
Human rights in the Board’s agenda
Sustainability issues play a key role in the Board’s agenda, and among these human rights are a focus of attention. In 2018, the Board addressed the following issues, which directly concern human rights or are particularly relevant to the topic:
- Eni’s Statement on respect for human rights, which presents Eni’s approach and the Company’s specific commitments to ensure respect for human rights, consistent with the United Nations’ Guiding Principles on Business and Human Rights;
- 2017 Annual Report, which includes the Consolidated disclosure of non-financial information;
- Remuneration Report, which includes sustainability objectives in the determination of performance incentives, including those for health and safety;
- 2017 Sustainability Reporting;
- HSE Performance in 2017, which examines issues with a direct impact on respect for human rights by Eni, such as, for example, the right to safe and healthy working conditions, the right to the highest attainable standards of physical and mental health, which applies not only to workers but also to local communities;
- Sustainability scenario, which sets out emerging issues – including those connected with respect for human rights – and the initiatives Eni has planned in this area;
- Updating of the UK "Modern Slavery Act" Statement 2017, which illustrates the measures taken to counter the adverse impact of modern slavery and human trafficking on workers both within Eni’s operations and in the supply chain, with a specific focus measures adopted to identify, prevent and mitigate risks on forced labour, contemporary slavery and human trafficking;
- Memorandum of Understanding with UNDP - United Nations Development Program, aimed at expanding the access of local communities to social and economic rights.
In 2018 the CEO has also informed the Board of specific sustainability initiatives, including those involving human rights.
The role of the Sustainability function
The Sustainability function is responsible for coordinating the overall approach of Eni to human rights, both by designing, implementing and overseeing Eni’s human rights due diligence related to the industrial projects and by supporting the other departments to effectively perform their human rights due diligence over the areas and processes under their responsibility. In order to do so, it continuously engages all Eni functions with a role in ensuring the company’s respect for human rights.
Within this framework, in 2017 the Sustainability function was appointed to coordinate the activities of an internal Working Group on Human Rights and Business (HRBWG). The strategic mission of the HRBWG was to further develop the company’s human rights agenda and improve internal policies and practices to make them aligned with the international standards and best practices.
To this aim, a gap analysis was performed in order to identify the main areas for improvement. The Danish Institute for Human Rights supported the company during the interviews. More than 40 colleagues were involved in an entire week of work and 15 interviews took place.
Besides identifying the main areas of improvement, the HRBWG led the company to identify its Human Rights Salient issues.
Management objectives as enablers
Eni integrates incentives linked to human rights performance into the objectives assigned to different management levels to ensure the implementation of Eni’s human rights strategies and commitments.