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Home > Sustainability

SUSTAINABILITY

 

Reporting on the GC 10th Principle

By adhering particularly to the 10th Principle, Eni is committed to respect the principles of the United Nations Convention against Corruption (UNCAC), of the OECD Convention on preventing the corruption of foreign public officials involved in international economic transactions and of the Business Principles for Countering Bribery issued by Transparency International.

In 2009 this commitment was strengthened by two actions: the creation of an organisational structure aimed at fighting against and preventing corruption and the approval of a set of targeted operating procedures.

  • Eni's CommittmentEni's Committment
  • Implementation Implementation
  • monitoringmonitoring
Indicator Actions
B1 Public statement concerning the commitment to the fight against corruption in all its forms, including extortion

B2 Compliance with all applicable laws including laws that specifically address anti-corruption issues		 The Code of Conduct (2001-2008) and the Code of Ethics (in force since 2009) expressly prohibit "practices of corruption, unlawful favours, collusive behaviours, direct or indirect solicitations for personal benefit and/or career gains for oneself or for others". All Eni people and Eni’s commercial partners are required to comply with the Code of Ethics which must be expressly accepted by all suppliers during the process of their qualification.
D2 Statement of compliance with local and international standards Eni is officially committed to comply with the highest international standards (GC Principles, UNCAC and OECD Convention) in its Code of Ethics and in the agreements with Trade Unions, at Italian, European and international levels. The CEO’s letter stating Eni’s role as a promoter of the implementation mechanism review issued by the UNCAC Convention and the covering letter to the 2008 Communication on Progress (of GC) are a confirmation of this commitment.
D3 Risk assessments conducted in those areas potentially more exposed to corruption risks

D4 Detailed policies concerning the areas at a high risk for corruption		 Eni has identified specific areas which, within the scope of their normal activities, are exposed to a higher risk for corruption and has formulated, for these areas, a number of procedures aimed at ensuring compliance with all applicable anti-corruption law by Eni’s people. The Anti-Corruption Auxiliary Procedures, issued by Eni SpA include: Procedure for appointing external legal representatives; Procedure on donations; Procedure on contractual terms regarding Administrative Liability; Procedure on Gifts, Travel, Hospitality and Entertainment Expenses in favour of third parties; Procedure on Intermediary agreements; Procedure on Joint Venture agreements-Prevention of unlawful activities; Procedure on the acquisition of Consulting and Professional Services; Procedure on Expense Reimbursements; Procedure on Sponsoring Agreements; Eni’s Procedure on Anonymous Reporting; Anti-corruption provisions included in the Accounting Procedures; Anti-corruption provisions included in the procedures regulating personnel recruiting; Anti-corruption provisions included in the procedures regulating acquisitions and sales; Anti-Corruption Auxiliary Procedure on Intermediary Agreements; Anti-Corruption Auxiliary Procedure on Joint Venture Agreements.
D5 Compliance with anticorruption laws by business partners Eni requires compliance with all applicable laws, including anti-corruption laws, from all its business partners. Among the business partners, particularly critical are the Covered Business Partners (those who are operating under a higher risk): if the Covered Business Partner is an intermediary, the Anti-Corruption Auxiliary Procedure related to Intermediary agreements shall apply; if the Covered Business Partner is a joint venture partner, the Anti-Corruption Auxiliary Procedure related to Joint Venture agreements shall apply.
Indicator Actions
B3 Translation of commitments into actions Measures implemented in 2009:
  • creation of a dedicated organisational structure and approval of a set of operating procedures. The Anti-Corruption Legal Support unit is an integral part of the Legal Department of Eni SpA and provides legal advisory services and anti-corruption support to Eni’s business units and to the unlisted subsidiaries, as well as anti-corruption training sessions to Eni’s and unlisted subsidiaries’ employees;
  • issue of Anti-Corruption Guidelines and of the first two Anti-Corruption Auxiliary Procedures related to Joint Venture and Intermediary agreements, were issued following approval by the Board of Directors of Eni SpA. Additional procedures, addressing specific anticorruption issues, already completed and currently under review, will follow (see D4);
  • publication of all internal anti-corruption provisions on the Company’s Intranet to ensure their access by all employees.
D2 Statement of compliance with local and international standards Measures implemented in 2009:
  • training program for Eni’s people on Code of Ethics (translated in 19 languages with about 3,000 key officers trained);
  • meeting on the Anti-Corruption Guidelines and auxiliary procedures with 400 people from Eni and Eni’s subsidiaries, from 25 Countries;
  • launch of an anti-corruption mandatory training program for employees exposed to a higher risk because of their position and contractual functions within the Company, in Italy and abroad, which will consist of workshops and e-learning informative sessions.
D6 Actions aimed at encouraging the business partners to meet their commitments Eni is committed to use its influence (within reason, according to the circumstances) so that companies and organizations in which Eni holds a non-controlling interest, as well as the Covered Business Partners, adopt and maintain an adequate internal control system consistent with the requirements of anti-corruption laws.
D7 Management’s responsibility and widespread adoption of an anti-corruption commitment (or related policy)

D8 Inclusion of new terms concerning human rights in the procurement contracts

D9 Communication channels and follow-up mechanisms applied to reporting and requests for assistance

D11 Participation in voluntary initiatives		 All Eni’s people are required to comply with the Anti-Corruption Guidelines and with the Anti-Corruption Auxiliary Procedures. All managers are responsible to ensure that compliance is met by employees and co-workers. Any suspected or known violation of anti-corruption laws or of the Anti-Corruption Guidelines must be immediately reported to the direct manager/supervisor or to the primary contact in Eni in the case of a Business Partner; to the Supervisory Body; to the Anti-Corruption Legal Support Unit or, in all cases, by using the dedicated channels (Whistleblowing Procedure).

Clauses concerning respect for human rights are being included in the new procurement contracts.

Eni’s people shall be subjected to disciplinary actions (up to termination of employment or legal proceedings) if: they violate anti-corruption laws and/or the Anti-Corruption Guidelines; they do not participate in a required training or they do not complete it; they omit reporting violations; they retaliate against others who have reported a violation.

Eni participates in several voluntary initiatives on corruption issues:

  • in 2005, it joined the Extractive Industries Transparency Initiative (EITI), with a financial support to the Secretariat of $50,000 per year;
  • in cooperation with the Ministry of Foreign Affairs and with the Ministry of Economic Development, it participates in international round tables regarding the level of EITI implementation in the corporate contexts;
  • has been a member of Global Compact since 2001;
  • participates in the Italian Network of Global Compact in the dual capacity as promoter toward other Italian firms, and as "facilitator" in theme seminars;
  • participates in the Working Group Global Compact on Human Rights and Anti-Corruption;
  • consults systematically with Transparency International and participated, in 2009, in the formulation of a questionnaire for sector reporting within the Promoting Revenue Transparency (PRT) project;
  • consults systematically with Transparency International Italia (analysis of whistleblowing and "Transparency Reporting Against Corruption - TRAC questionnaire" specific reporting).
Indicator Actions
B7 Monitoring and development process The Anti-Corruption Legal Support Unit is responsible for periodically reviewing and updating the Anti-Corruption Guidelines. The Internal Audit office is responsible for examining and evaluating independently the internal controls in place to ensure compliance with the provisions of the Anti-Corruption Guidelines and of the Anti-Corruption Auxiliary Procedures, in accordance with its own annual auditing program approved by the Board of Directors of Eni SpA. The business units, the Supervisory Body, the Internal Audit office and the external auditors offer suggestions for improving the Anti- Corruption Guidelines. If violations are identified, the Anti-Corruption Legal Support Unit evaluates if any revision or change is necessary to the Anti-Corruption Guidelines or to any of the procedures in order to prevent a re-occurrence of the violation. Each Eni subsidiary is required to respond appropriately in order to remedy any critical issue that may emerge from its compliance program.
D12 Level of leadership in the monitoring and development of the results Eni’s Anti-Corruption Legal Support Unit submits to the Supervisory Body an annual report on its monitoring activities and receives the annual report prepared by each of the Anti-Corruption Legal Support Units of the listed and unbundled subsidiaries of Eni SpA.
D13 Violations management See D9



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Last updated on 26/07/10