Update on complaint against Eni – ISO 37301:2021

Dear Mrs. laura marti (Certification Compliance Director at RINA SERVICES)

As previously communicated, I submitted a formal complaint to RINA demonstrating that Eni may not fully comply with the fundamental requirements of ISO 37301:2021, particularly regarding the protection of whistleblowers, non-retaliation policies, and governance accountability and due diligence, including adherence to the EU General Data Protection Regulation (GDPR).

At the time, I was informed that RINA would conduct an audit, although no date had been set.

I now bring to RINA’s attention a new and highly relevant fact: after the ISO 37301:2021 certification was granted to Eni by RINA in January 2024, less than two months later, on March 6, 2024, ENI’s Board of Directors approved the update of the document “Management System Guideline – Whistleblowing Reports Management”, which is part of the Code of Ethics and defined by the company itself as its “Letter of Values”.

On August 25, 2025, I submitted a formal complaint directly to Eni’s Chief Compliance Officer (Mr. Luca Franceschini), with copies to the Board of Directors, requesting the concrete application of the aforementioned Whistleblowing Policy, as well as its Code of Ethics and ISO 37301 standard, in my case, which has already endured 24 years of institutional silence, victimization narratives, attacks on my honor and reputation, and systematic retaliation, including three processes with characteristics of SLAPP lawsuits.

In light of this new context, I respectfully reiterate that:

📌 RINA should consider my case as a practical and concrete test to assess whether Eni truly complies with the ISO 37301:2021 requirements, which justified the certification;

📌 Any refusal or omission by Eni to apply its own Whistleblowing Policy and Code of Ethics in my case will constitute a serious and systemic non-compliance with ISO 37301:2021 and with the organizational and governance duties;

As with the formal complaint submitted to Eni on August 25, 2025, this communication to RINA will also be made public on my LinkedIn profile and on the Eni’s Way website, to ensure full transparency regarding the certifier’s conduct in this case.

I emphasize that I remain available for any additional clarifications and inform you that the "Memorial of Facts" and the "Chronology of Events", containing over 70 supporting documents, are provided below in Italian to support RINA’s due diligence and audit.

I kindly request confirmation of receipt of this message, as well as the indication of the scheduled date for the audit at Eni, in accordance with the previous complaint and today’s new complaint.


✅ Read more:

1) Formal Complaint to Eni’s Chief Compliance Officer (August 25, 2025);

2) Memorial of Facts;

3) Chronology of Events (2001 to 2025);

4) Eni's Whistleblowing Policy.

Public Whistleblowing on LinkedIn

Dear Luca Franceschini,

For 24 years I have been denouncing a serious case of retaliation and ethical violations within Eni. Here is an objective summary of my complaint, which directly contradicts the principles of ENI’s Code of Ethics and its Whistleblowing Policy (approved by the Board of Directors in April 2024, less than two months after the company was certified by RINA Services under the ISO 37301:2021 standard):

1. After upholding the words and spirit of ENI’s Code of Ethics, I reported a multimillion-dollar corruption scheme in the Brazilian subsidiary;
2. On August 1, 2001, I was unjustly dismissed in clear retaliation by the reported executives, including members of AGIP Brazil’s board;
3. Since then, I have sought dialogue with five different compositions of ENI’s Board of Directors, under the leadership of three different CEOs (2002, 2009, 2014, 2020, and 2023);
4. Critical shareholder Mauro Meggiolaro, representing the Fondazione Finanza Etica, brought my case to four Shareholders’ Meetings (2017, 2018, 2020, and 2021);

Nevertheless, Eni has consistently remained silent, allowed acts of retaliation to occur, and has so far failed to conduct a thorough (due diligence) investigation of my case.

Instead of ensuring protection for the whistleblower, I experienced continued retaliation, including damage to my reputation and three SLAPP lawsuits (2010, 2017, and 2022).

In light of ENI’s own public statements about me, published on its website since 2017, I now demand coherence:

• In January 2024, the company prominently announced obtaining the ISO 37301:2021 certification on compliance management systems, including your own words: "The certification represents further recognition of Eni's commitment to promoting and fostering a compliance culture, which guides behavior and business management to respect the values of integrity, fairness, transparency and sustainability. This important achievement is part of a path, strongly supported by top management over the years, to enhance ethical and compliance issues. It has led to the establishment of an integrated, independent compliance function focused exclusively on ethical and compliance issues, under the direct responsibility of the CEO. Furthermore, the Code of Ethics has been redefined as a charter of values to guide people in progressing the company's objectives in compliance with Eni’s principles of integrity and transparency".
• In March 2024, the Board of Directors approved the new Management System Guideline – Whistleblowing Reports Management, a document forming part of ENI’s Code of Ethics.

Therefore, I demand that my case be addressed in accordance with the commitments that ENI proclaims to the world:

• Ensure an independent and impartial investigation of my case, in accordance with the Whistleblowing Policy approved in 2024;
• Call as "observations" the members of Eni's Control and Risk Committee;
• Protect my status as a "whistleblower", already recognized by the Brazilian Labor Court, against further retaliation;
• Implement corrective measures, including the rectification of the document "Questions and Answers before the Shareholders' Meeting 2017" with the real reasons for my dismissal, in compliance with European GDPR – a “rectification” that was denied by Eni’s DPO in July 2024.
• Formally and transparently communicate with me regarding the measures adopted.

Inside the company’s own Compliance office, the responsibility to uphold these principles lies in your hands. However, rather than protecting those who report abuses, Eni has repeatedly chosen silence, omission, and has not yet carried out a thorough (due diligence) investigation of my case.

This prolonged silence goes beyond mere negligence. Each year of inaction further undermines ENI’s credibility, creating the perception that the Code of Ethics is not being applied in practice as intended.

At this point, Luca, the question is no longer whether ENI has a Code of Ethics on paper. The question is how ENI will ensure its effective application in practice.

Eni’s omission in applying its own Whistleblowing Policy, ISO 37301:2021, and the Code of Ethics in the “Case Flinto”  would constitute a serious ethical and reputational non-compliance, under the direct responsibility of the Chief Compliance Officer and the Board of Directors.

The full "memorial" of the case and the detailed "chronology of facts" (with more than 70 supporting documents that provide irrefutable proof of the facts) are linked below for proper review and due diligence.

In accordance with the aforementioned Whistleblower Policy, I request that Eni confirm receipt of this report within 7 (seven) days.

✅ Read more:

1) Fully proven facts known to the Board of Directors of Eni

2) Chronology of Facts (2001 to 2025)

Six months of silence

In March this year, I wrote a personal message to Eni’s CEO, Claudio Descalzi. It was not about legal disputes or formal reports — I have already submitted many of those over almost 24 years to five different Boards of Directors. My intention was different: to speak directly to the conscience of the person who holds the highest leadership position in one of the world’s largest energy companies.

In that message, I emphasized that the truth about what happened to me cannot be erased. It is known, both inside and outside the company, but has been systematically ignored in favor of silence and retaliation.

Almost six months have now passed, and I have received no response. The company remains silent, as if nothing ever happened.

But here is a point for reflection:

📌 What legacy does a leader build when choosing to ignore the truth?

📌 How can the ethics and reputation of a global corporation be sustained while an innocent man has suffered for decades — someone who only followed what the words and spirit of Eni’s Code of Ethics encouraged me to do: to speak up?

📌 How far does the power of a signature go — one that could end an injustice, but instead chooses to perpetuate it?

I remain steadfast, because I believe that business ethics is not just a fine speech for stakeholders. It is practice. It is decision. It is the courage to do what is right.

My struggle is not only personal: it touches the very essence of what it means to lead with integrity. And this is the call I leave here, publicly, to Eni and to all who believe that the corporate world can — and must — be different.


✅ Read more:

1) "Fully proven facts known to the Board of Directors of Eni";

2) "Chronology of Facts" (2001 to 2025).