Anticorruption

In the past years Eni has actively taken part in the fight against corruption by expressly prohibiting in its Code of Ethics "practices of corruption, unlawful favours, collusive behaviours, direct or indirect solicitations for personal benefits and career gains for oneself or for others." All Eni personnel are required to comply with the Code of Ethics, which must be expressly accepted by all suppliers during their qualification process.

By adhering to the Global Compact and particularly to its 10^th Principle, Eni has committed to respect the principles of the United Nations Convention Against Corruption (UNCAC), the principles of the OECD Convention on Combating Bribery of Foreign Officials in International Business Transactions and the Business Principles for Countering Bribery issued by Transparency International.

Eni's commitment was also further strengthened by two initiatives:

• Following approval by the Board of Directors, Eni has published its "Anti-Corruption Guidelines" Eni Circular n. 377) with a view to providing its staff and associates with a systematic framework of the principles and rules that the company has had in place for some time to prevent and combat acts of corruption. The Anti-Corruption Guidelines aim to ensure Eni's maximum respect for and full compliance with both national and international anti-corruption legislation, as well as Eni's own Code of Conduct which, since 1998, expressly prohibits "acts of corruption, illicit favours, collusive behaviour, the direct or indirect soliciting of advantages, pecuniary or professional, for oneself or on behalf of others."
• the creation, within the Eni Legal Affairs Department, of a dedicated organizational structure denominated Anti-Corruption Legal Support Unit, in charge of providing the business units of Eni and of the non-listed subsidiaries, both in Italy and abroad, with ad hoc legal advice and support on specific anti-corruption issues, supervising the anti-corruption training and periodically reviewing and updating the Anti-Corruption Compliance Guidelines. The Anti-Corruption Legal Support Unit also submits an annual report on its monitoring activity to the Eni Watch Structure and receives the annual reports prepared by the Anti-Corruption Legal Support Unit of each listed/unbundled subsidiary.
  

Eni personnel have a duty to comply with the anti-corruption rules: to such end, all relevant documents are easily accessible through the Company's intranet portal and mandatory anti-corruption training programs for personnel "at risk" both in Italy and abroad have been organized to address and analyse specific cases and practical situations that may arise during the Company's activity. In such context, a role of primary importance is vested in the managers, who have a duty to monitor on their teams' compliance with the Anti-Corruption Guidelines and Ancillary Procedures. Moreover, Internal Audit examines and independently evaluates internal controls to ensure that the provisions of the Anti-Corruption Compliance Guidelines are complied with on the basis of their annual audit programme, as approved by the Board of Directors.

Any suspected or known breach of the anti-corruption laws or Anti-Corruption Compliance Guidelines must immediately be reported in accordance with the provisions set out in the Eni Whistle-blowing policy.

Disciplinary measures may be taken against Eni personnel found guilty of breaching the anti-corruption laws, who do not take part in the prescribed training programme, who omit to report violations they are aware of or who retaliate against others who report violations.

Lastly, Eni requires compliance with the anti-corruption laws by all its business partners. Among business partners, particular attention is dedicated to "Covered Business Partners", i.e. to those business partners who operate in areas at higher risk due to the probability that, in carrying out their activity in the interest of Eni, they have relevant contacts with public officials.