Reporting on the 10th principle of Global Compact

B1 A public declaration of the commitment to fight corruption in all forms, including extortion

The Ethical Code expressly forbids "corrupt practices, illicit favours, collusion, the request, either direct or indirect and/or through third parties, of benefits, of a personal or professional nature (i.e. career advancement) either for oneself or others". The Code also establishes the principle of transparency with regard to persons of the company, from local communities and all of eni's stakeholders.

The Ethical Code and model 231 are available on the company's web site and are distributed to all those with whom eni has relations.
In particular, all eni personnel, its commercial partners and suppliers are required to respect the principles laid out therein.

A letter from the CEO adhering to the initiative aimed at promoting the adoption of an implementation mechanism and review of the UNCAC Convention;

A statement by eni on the occasion of the V EITI Global Conference (held on  2,3 March in Paris);

B2 Respect for all relevant laws, including specific anti-corruption norms

Issue of Anti-Corruption guidelines and ancillary procedures; the integration of existing procedures with anti-corruption control standards; the updating of model 231; internal control management system.

Monitoring of the adoption of the Anti-Corruption Guidelines by all subsidiaries through the Anticorruption Legal Support Unit (ACLSU) function. Monitoring of legislative developments and eventual action on gaps that may emerge.

Participation in round table discussions and conferences to extend or update current legislation, or about new laws regarding the issue.

D2 Declaration of adherence to regional and international standards

The compliance of eni's Ethical Code with the highest international standards regarding corruption (GC Principles, the UNCAC and OECD Conventions).
Eni's Sustainability policy: "is based on correct behaviour, transparency, honesty and integrity and the company adopts the highest international standards and guidelines in the management of its activities in all the contexts in which it operates."
The Anti-Corruption guidelines are consistent with international best practice.
The "function" of the Anti-Corruption Legal Support Unit is consistent with the prescriptions of the leading international bodies involved in fighting corruption.

A letter from the CEO on eni's role as a promoter of the Implementation Mechanism Review of the UNCAC Convention and an accompanying letter to the Communication On Progress Global Compact, available on the company's web site.

Adherence to the Extractive Industry Transparency Initiative (EITI), the Global Compact and its 10th principle, and the LEAD programme;
A commitment to respect the Business Principles for Countering Bribery of Transparency International.
A commitment to comply with the highest international standards in agreements with trades union organisations;

D3 Risk assessment measures in areas considered to be of potential risk of corruption

The identification of business areas at greater risk of corruption, on the basis of type of activity (e.g. significant relations with public officials, joint ventures, sponsorships, intermediations) and the significance to eni of such activities.

The spread to partners in areas of activity considered to be at risk, of eni's anti-corruption compliance programme.

Participation in the working groups of the G C. Adherence to the sub-working group on Public Private Dialogue and Collective Actions, with a focus on Nigeria.
Participation in the world conference on the Least Developed Countries, with a special focus on aspects concerning governance and the fight against corruption.

D4 Detailed policies areas of high-risk of corruption

Ancillari Anti-Corruption Procedures on: the appointment of external legal counsel; donations; contractual clauses regarding "administrative responsibilities"; gifts, travel, hospitality and entertainment expenses involving third parties; intermediation contracts; joint venture agreements – the prevention of illegal activities; the purchase of consultancy or other professional services; expenses claims; sponsorship contracts; indications (also anonymous); the anti-corruption measures contained in the accounting procedures; the anti-corruption measures contained in the procedures governing recruitment and selection; the anti-corruption measures contained in the procedures governing acquisitions and disposals;

The ACLSU provides consultancy services and assistance regarding anti-corruption measures with a view to, among other things, implementing the anti-corruption procedures in eni and its subsidiaries.
Eni, through the ACLSU unit, also ensures that potential partners are aware of all anti-corruption laws and initiatives.

Participation in sub-working groups organised by Global Compact, in the context of the working group on the 10th principle regarding the fight against corruption.

D5 Respect for anti-corruption laws by all business partners

Issue of Ancillary Anti-Corruption procedures regarding activities in areas considered to be at high risk.

Demand that business partners respect applicable laws, including anti-corruption laws. Particular attention is given to "Covered Business Partners" (business partners operating in high risk areas).

Participation in round table discussions and working groups, at both a national and international level, for the identification of best practice.

B3 Translation of action ongoing

The creation of the ACLSU function within eni's Legal Department for specialised legal advice and support for the business units of both eni and its non-listed subsidiaries, the supervision of anti-corruption training for personnel of eni and its  non-listed subsidiaries.

Implementation of the prescriptions foreseen by the ancillary procedures for partners operating in high risk areas.

Participation in round table discussions and working groups, at both a national and international level, for the identification of best practice.

B4 Support for corporate leadership in the fight against corruption

Guidelines approved by the eni board. Guidelines and ancillary procedures approved for adoption by the boards of eni subsidiaries.

A letter from the CEO adhering to the initiative aimed at promoting the adoption of an implementation mechanism and review of the UNCAC Convention;

A statement by eni on the occasion of the V EITI Global Conference (held on 2,3 March in Paris).

Participation of international leadership in international initiatives on the issue.

B5 Communication and training for all company personnel.

Training initiatives for Key Officers of eni, e-learning courses and interactive workshops; diffusion of procedures also on the company intranet.
Communication and staff training are also important requirements in the application of Model
231.

Publication on the corporate web site of the Anti-Corruption Guidelines, issued in Circular n. 377 in 2009, and ancillary anti-corruption procedures.
The promotion of responsible behaviour, with particular attention to conflicts of interest, both internally and that of suppliers, in line with the Ethical Code.
Best efforts by the representatives of eni in joint ventures to ensure the sharing of the anti-corruption compliance programme in line with that of eni

The promotion of a range of thematic seminars at a national and international level (including the Italian Network of the Global Compact) regarding anti-corruption issues and issue promoted by the ACLSU.
In the context of the working group on the 10th principle of the GC, the development of an e-learning tool (The Fight Against Corruption tool) aimed at the personnel of the companies.

D6 Actions aimed at encouraging business partners to apply he commitments undertaken.

Issue of procedure n. 379/2009 concerning joint venture agreements – prevention of illegal activities. Issue of ancillary procedures governing other activities considered to be at risk of corruption

A commitment to using one's influence to ensure that the companies and bodies in which eni has a non-controlling interest, the "Covered Business Partners" and other partners operating in areas at risk adopt and maintain an adequate compliance programme in line with eni's own compliance programme;
Diffusion of the principles and content of Model 231(that include the Ethical Code) to all those with whom Eni S.p.A. has contractual relations. A commitment to observing the law and the principles of reference of the Model 231 by third parties is foreseen in a specific clause of the contract.

Participation in round table discussions and working groups, at both a national and international level, for the identification of best practice.

D7 Management responsibility and the diffusion of a commitment to contrast corruption (or a relative policy).

Guidelines approved by the eni board. Guidelines and ancillary procedures approved for adoption by the boards of eni subsidiaries.
The responsibility of all eni personnel to respect anti-corruption guidelines and anti-corruption ancillary procedures. A dedicated channel for the communication of violations (Whistleblowing Procedure)
Specific training initiatives for top management.

Participation in round table discussions and working groups, at both a national and international level, for the identification of best practice.

Participation in round table discussions and working groups, at both a national and international level, for the identification of best practice.

D8 Inclusion of new clauses regarding human rights in supply contracts.

Standard compliance clauses that require partners to respect human rights, in addition to anti-corruption principles.
Inclusion of new clauses regarding human rights in supply contracts; violation measures for anti-corruption laws and/or the anti-corruption guidelines.

Participation in round table discussions and working groups, at both a national and international level, for the identification of best practice.

Participation in round table discussions and working groups, at both a national and international level, for the identification of best practice.

D10 Anti-corruption accounting and auditing procedures.

Internal monitoring of consultancy and support services provided on the basis of various requests.
Strict rules of conduct for accounting practices as foreseen by the anti-corruption guidelines.
Inclusion of anti-corruption control principles with regard to accounting practices in all ancillary procedures.  
Eni's Internal Audit function examines and evaluates, independently, internal controls in order to verify respect for the requirements of the guidelines and ancillary procedures.

Targeted and sample audits.

Participation in round table discussions and working groups, at both a national and international level, for the identification of best practice.

D11 Participation in voluntary initiatives

Internal application of he principles and rules of conduct related to voluntary initiatives to which eni adheres

Publication of payments made to governments which adhere to the EITI.
The promotion of negotiations between the various operators in the petroleum sector, aimed at the sharing of standard anti-corruption clauses to facilitate negotiations.

In cooperation with the Italian Foreign Ministry and the Ministry for Economic Development, eni participates in international round tables for the implementation of the EITI at corporate level.
Since 2001 eni has been a member of the Global Compact and participates in round table discussions concerning the 10th principle against corruption.
Eni participates in the Italian Network of the Global Compact as a promoter to other Italian companies and as a e facilitator at thematic seminars
Eni participates in the Global Compact Working Group on Human Rights and Anti-Corruption, where it is the promoter of the creation of an oil & gas working group (launched on 16 May 2011 in Copenhagen)
Eni is in systematic dialogue with Transparency International

B7 The monitoring and development process.

The Anti-Corruption Legal Support Unit regularly re-examines and updates the anti-corruption guidelines
The Internal Audit function examines and evaluates, independently, internal controls in order to verify respect for the requirements of the guidelines and ancillary procedures, on the basis of its own annual audit programme, approved by eni's board of directors.
The business units, the supervisory board, the internal audit function and the company's external auditors recommend improvements to the anti-corruption guidelines. If a violation is discovered, the Anti-Corruption Legal Support Unit evaluates eventual revisions or modifications to the anti-corruption guidelines or to any of the procedures that can help to prevent a repetition of the violation.
All of eni's subsidiary companies are required to take steps to adequately any eventual critical areas that emerge from the compliance programme

Regarding supply chain controls, both before and after the allocation of contracts, the creation of a database of sub-contractors;
The definition of a vendor management system for the qualification of suppliers, feedback, inspections and auditing and relative corrective actions;
The application of the SA 8000 standard in the supply chain;

Participation in round table discussions and working groups, at both a national and international level, for the identification of best practice.

D12 Level of leadership in the monitoring and development of results

Eni's Anti-Corruption Legal Support Unit submits an annual report of its monitoring activities to the supervisory board and receives an annual report from each of the Anti-Corruption Legal Support Units of listed subsidiaries and unbundled companies.

D13 Management of violations

Through an anonymous whistleblowing procedure, eni is able to manage indications received, directly or indirectly, by the company and its subsidiaries. This ensures the recording, analysis and handling of such indications relating to problems in the area of internal control, corporate reporting, accounting responsibility, fraud or other violations of the Ethical Code, submitted by people from within the company, by members of corporate bodies or third parties.
eni takes adequate disciplinary action, in line with applicable national legislation, collective labour contracts and Model 231, against an eni employee (i) who has acted in violation of anti-corruption laws or relative procedures, or (ii) who unreasonably omits to reveal or report eventual violations or threatens or attempts to bribe anyone reporting such violations. Such disciplinary action may also include the unilateral termination of employment.

The guidelines establish that eni must not discriminate in any way personnel who, in good faith, report a violation of anti-corruption laws or relative procedures.

To spread the mechanism for the notification, the procedure is communicated to employees and published on the company's web site.

Participation in round table discussions and working groups, at both a national and international level, for the identification of best practice.

D14 Publication of legal procedures regarding the issue of corruption.

Information about relevant fines and sanctions is included in the 2010 Annual Report.

D15 Use of external certification for anti-corruption programmes