In compliance with Directive (EU) 2019/1937 and the related implementing legislation, the Sarbanes-Oxley Act of 2002, the Organizational, Management and Control Model pursuant to Italian Legislative Decree No. 231 of 2001 (hereinafter the “231 Model”), and the internal Anti-Corruption Governance Documents, we have adopted a system aimed at encouraging reports made in good faith and in Eni’s interest, while ensuring the confidentiality of the whistleblower’s identity and of any other persons involved, as well as protection against any form of retaliation.
Whistleblowers are encouraged not to disclose information regarding the report to third parties, so as not to undermine the protection of confidentiality. Eni’s reporting system must not be used to offend or damage the personal and/or professional reputation and dignity of the person(s) concerned by the reported facts, nor to knowingly spread unfounded accusations.
In accordance with applicable legislation, regardless of the subject matter of the report or the entity involved, everyone is always guaranteed the possibility of submitting reports directly to Eni SpA. Furthermore, the possibility of using the specific reporting channels established by subsidiaries, including Eni Plenitude SpA SB, remains available in the cases and in accordance with the provisions of the applicable legislation.
Regardless of the channel used, all Eni People—as well as anyone who operates or has operated in Italy or abroad in the name of, on behalf of, or in the interest of Eni, within the scope of their duties and responsibilities—are guaranteed the opportunity to report breaches identified in a work-related context, in compliance with local laws implementing Directive (EU) 2019/1937.
In particular, a report includes any communication concerning conduct that constitutes a breach of national or European Union laws and regulations, decisions of Authorities, the Code of Ethics, the 231 Model or the Compliance Model for foreign subsidiaries, and internal regulations (including, among others, the Zero Tolerance Policy against workplace violence and harassment), in accordance with the specific provisions of the local legislation implementing Directive (EU) 2019/1937.
The relevant rules are contained in the procedure “Management of Reports Received by Eni SpA and Subsidiaries” (available among the attachments on this page). The approval and updating of the procedure have been carried out in accordance with the provisions of Italian Legislative Decree No. 24/2023.
Reports can be submitted through a dedicated platform available at the following link.
This channel is considered the preferred reporting channel and is suitable for ensuring the confidentiality of the whistleblower’s identity through electronic means.
Please note that, alternatively, an oral report may be submitted by calling 800.60.20.099 in Italy.
The number can also be reached from abroad, where technically possible, free of charge to the caller or at the cost of a local call. In other cases, the following paid number may be used: +39 06 598.27323.
Without prejudice to the preferred use of the reporting channels made available by Eni SpA and Eni Plenitude SpA SB, in the cases expressly provided for under Article 6 of Legislative Decree No. 24 of 10 March 2023, reports may also be submitted to the competent authority (National Anti-Corruption Authority – ANAC) or through public disclosure.
Without prejudice to the preferred use of Eni’s internal reporting channels, in the cases expressly provided for under Articles 6 and 15 of Legislative Decree No. 24 of 10 March 2023, reports may also be submitted respectively to the competent authority (National Anti-Corruption Authority – ANAC) or through public disclosure.
In the case of Eni S.p.A. and Italian subsidiaries, a reporting person may submit an external report if, at the time of submission, one of the following conditions applies:
Information and personal data communicated in the context of reports are processed for the purpose of managing and following up on the reports, investigating the reported conduct where necessary, and adopting any required measures in accordance with applicable laws, including data protection legislation.
For further information on the methods and purposes of processing personal data included in reports and collected during the procedure, please refer to the privacy notices regarding the processing of personal data of reporting persons, reported persons, and any other third parties involved.
The activities of Third Sector Entities (ETS) consist of providing general support to reporting persons. The role of ETS is to promote awareness of the relevant regulatory framework and to increase understanding of the tools available, with a view to improving the quality of reports submitted. ETS are registered in a dedicated register maintained by ANAC, available at the following link: https://www.anticorruzione.it/-/whistleblowing