Eni supports the goal of preventing the exploitation and trade of minerals by armed groups that finance regional conflicts and contribute to humanitarian crises. In the Democratic Republic of the Congo ("DRC") region, human rights violations have been found to be partially financed by the exploitation and trade of "Conflict Minerals" (known as "3TG") – and which consists of Tantalum, Tin, Tungsten (and the minerals that they are derived from – Columbite-tantalite (coltan), cassiterite and wolframite and Gold). Because of these concerns, in 2012 the United States Security and Exchange Commission enacted the Section 1502 of the Dodd-Frank Act, requiring companies listed in the US markets to disclose their eventual use of conflict minerals.
As part of Eni’s commitment to corporate sustainability and respecting and promoting human rights in our own operations including the activities performed by our Business Partners, Eni has in place guidelines, procedures and standard contractual terms & conditions that:
- require compliance with human rights standards as prerequisite for qualification
- require compliance with the Eni Code of Ethics and Human Rights Guidelines as contractual obligations towards Eni
- require periodical checks of compliance with those standards through specific audits.
Due to the complexity of our supply chain, although we have made progress in implementing policies and procedures to help ensure reasonable due diligence and responsible sourcing of Conflict Minerals, it will take us a significant additional investment of time and resources to determine the mine or location of origin of our necessary conflict minerals with the greatest possible specificity . To date, we have implemented a number of initiatives to determine the use, source and origin of any Conflict Minerals which we deem to be necessary to the functionality or the manufacturing of our products.These include:
- we have established a "Conflict Minerals Compliance Program" to review any use of Conflict Minerals in our products or in the manufacturing of our products. We are developing this program based on the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and we will take into account other international standards as appropriate
- we have recommended our relevant suppliers to implement a policy regarding responsible sourcing of Conflict Minerals, including the exercise of due diligence to investigate the source of these minerals, and encouraging our suppliers to do likewise with their suppliers. To date all of our suppliers of conflict minerals have adopted a policy regarding responsible sourcing and have made progress in tracing the supply chain. We have obtained representations that the smelters in our supply chain are certified smelters with the CFSI program
- we have engaged with our suppliers so that they respond in a timely manner to our requests for evidence of compliance. Our suppliers’ willingness to comply with this initiative is a factor in our sourcing decisions
- we have updated purchasing terms and conditions to reflect this policy, which are being included in all new supply contracts entered into by the Eni Group regarding products that contain or may contain conflict minerals
- we are adopting procedures and controls and we are implementing training activities in order to raise internal awareness of the conflict minerals issues and accurately report on the Company’s activities regarding conflict minerals use and sourcing
- we endorse transparency in implementing this policy and we make available reports on our progress to relevant stakeholders and the public.
Grievance and whistle-blowing mechanisms
Concerns and violations of this policy can be reported to Eni via existing grievance channels for ethics or compliance violations at this link.
Ultimo aggiornamento 26 maggio 2016
Ultimo aggiornamento 26 maggio 2016