My whistleblowing on the Eni website

On September 8, 2023, I made a “report” on Eni’s website about the “attacks” on my honor and reputation carried out by the company in 2010 (lawsuit) and in 2017 (Eni AGM). These attacks were fully proven by abundant, rich, and robust documentation (see Doc. 01 and Doc. 02). 

However, to this date, I have not received any type of communication from Eni. For this reason, I have been monitoring whether there is any update on the “status” of my complaint, making daily consultations on Eni’s website using my “KEY-CODE” number. 

It is clear that I have a great expectation that Eni will carry out an “in-depth investigation” into the facts (and proofs) presented by me on its exclusive website to receive whistleblowing from its Stakeholders. 

Please note that, despite my insistent contacts with Eni’s Board of Directors, throughout these more than 22 long years of my “unfair dismissal” — in proven “retaliation”, carried out by those I had denounced, including members of the board of directors of Eni's Brazilian subsidiary — the company never carried out "due diligence" on my case in light of its "corporate commitments" (Code of Ethics and Whistleblowing Process) and "international commitments" that are "accepted" and "followed" by the company (OECD Guidelines for Multinational Enterprises, UN Global Compact, and UN Guiding Principles on Business and Human Rights). 

Also note that the Brazilian Labor Court itself “recognized” that I was the “whistleblower”, despite Eni never admitting this fact!? 

Therefore, I hope now that Eni finally has the dignity to do a “due diligence” on my case and report the “official result” of its investigations on its exclusive website for receiving “whistleblowing”, including “adverse impacts” on human rights. 

I will keep you posted!

Eni vs UN Guiding Principles on Business and Human Rights

 In its “Declaration on Human Rights”, ENI “publicly” states to all its Stakeholders that it follows the “UN Guiding Principles on Business and Human Rights” (UNGP 31).

Therefore, in my case, ENI should pay attention to what these principles guide, especially the principles concerning:

The corporate responsibility to respect human rights

Principle 11: “Business enterprises should respect human rights. This means that they should avoid infringing on the human rights of others and should address adverse human rights impacts with which they are involved”.

Principle 13: “The responsibility to respect human rights requires that business enterprises: (a) Avoid causing or contributing to adverse human rights impacts through their own activities, and address such impacts when they occur; (b) Seek to prevent or mitigate adverse human rights impacts that are directly linked to their operations, products or services by their business relationships, even if they have not contributed to those impacts”.

Principle 15: “In order to meet their responsibility to respect human rights, business enterprises should have in place policies and processes appropriate to their size and circumstances, including: (a) A policy commitment to meet their responsibility to respect human rights; (b) A human rights due diligence process to identify, prevent, mitigate and account for how they address their impacts on human rights; (c) Processes to enable the remediation of any adverse human rights impacts they cause or to which they contribute”.

Principle 17: “In order to identify, prevent, mitigate and account for how they address their adverse human rights impacts, business enterprises should carry out human rights due diligence. The process should include assessing actual and potential human rights impacts, integrating and acting upon the findings, tracking responses, and communicating how impacts are addressed”.

Principle 22: “Where business enterprises identify that they have caused or contributed to adverse impacts, they should provide for or cooperate in their remediation through legitimate processes”.

Principle 23: “In all contexts, business enterprises should: (a) Comply with all applicable laws and respect internationally recognized human rights, wherever they operate; (b) Seek ways to honour the principles of internationally recognized human rights when faced with conflicting requirements; (c) Treat the risk of causing or contributing to gross human rights abuses as a legal compliance issue wherever they operate”.

So, why does ENI, in my case, doesn't fulfill this "International Commitment"? 

Now, if ENI has no fear regarding the damage that I have repeatedly suffered over the years, it should at least fear all the unnecessary risks that the company is imposing on the Italian government, the “controlling” shareholder of the Italian oil giant and an "adherent nation" to the UNGP 31.

Italian Government vs Principle 04 (The State-business Nexus)

“Principle 4: "States should take additional steps to protect against human rights abuses by business enterprises that are owned or controlled by the State, or that receive substantial support and services from State agencies such as export credit agencies and official investment insurance or guarantee agencies, including, where appropriate, by requiring human rights due diligence”.

Commentary: States individually are the primary duty-bearers under international human rights law, and collectively they are the trustees of the international human rights regime.

Where a business enterprise is controlled by the State (as is the case with ENI) or where its acts can be attributed otherwise to the State, an abuse of human rights by the business enterprise may entail a violation of the State’s own international law obligations. Moreover, the closer a business enterprise is to the State, or the more it relies on statutory authority or taxpayer support, the stronger the State’s policy rationale becomes for ensuring that the enterprise respects human rights.

Where States own or control business enterprises, they have greatest means within their powers to ensure that relevant policies, legislation and regulations regarding respect for human rights are implemented.

Senior management typically reports to State agencies, and associated government departments have greater scope for scrutiny and oversight, including ensuring that effective human rights due diligence is implemented.

A range of agencies linked formally or informally to the State may provide support and services to business activities. These include export credit agencies, official investment insurance or guarantee agencies, development agencies and development finance institutions. Where these agencies do not explicitly consider the actual and potential adverse impacts on human rights of beneficiary enterprises, they put themselves at risk – in reputational, financial, political and potentially legal terms – for supporting any such harm, and they may add to the human rights challenges faced by the recipient State (In the case of ENI, besides the Ministry of Economics and the Treasury Office, the “agency linked formally” is the “CDP Bank” - Cassa Depositi e Prestiti SpA).

Italian government is an "adherent nation" to the UN Guiding Principles on Business and Human Rights (UNGP 31).

So, why does Italy, in my case, doesn't fulfill the "Principle 04" (The State-Business Nexus)? 

Eni vs Global Reporting Initiative

Global Reporting Initiative (GRI) is an international organization that helps companies, governments, and other institutions understand and communicate the impact of business on critical sustainability issues. Climate change, human rights, and corruption problems are some of these issues.

The “GRI Sustainability Report Standards” originated from the GRI Guidelines, which helps organizations identify the impacts of their operations on the environment, economy, and civil society. The objective is to provide reliable, relevant, and standardized information so that the company can evaluate opportunities and risks based on these impacts and make more informed decisions on the subject.

The indicators are arranged in interrelated modules and represent the best practices for reporting the economic, environmental, and social impacts of business, including specific mentions about the “Whistleblowing Process”, which differentiates two of its mechanisms:

a) Complaint: allows individuals to raise concerns about transgressions or violations of the law in the organization's operations or business relationships, regardless of whether they are being harmed or not;

b) Whistleblowing: allows Stakeholders to raise concerns and seek remediation and/or reparation for the organization's potential and actual negative impacts on them.

Why does Eni, in my case, doesn't fulfill the "GRI Standards"? 

Eni x UN Global Compact

Eni's website published:

Eni has today been confirmed as a Global Compact LEAD participant for its ongoing commitment to the United Nations Global Compact and its Ten Principles for responsible business.

Eni was identified as being among the most highly-engaged participants of the world’s largest corporate sustainability initiative.

Sanda Ojiambo, CEO and Executive Director of the UN Global Compact, said, “LEAD companies represent the highest level of engagement with the UN Global Compact. More than ever before, the world needs businesses of all sizes — like the ones announced as LEAD today — that continuously work to improve their sustainability performance and take action to build a better world”.

Claudio Descalzi, CEO of Eni, said “This recognition is an important testimony of our commitment to integrate sustainability into every aspect of our activities, to transform our industry respecting the dignity of every human being and to be open to new frontiers including that of sustainable finance in support of the SDGs. Pursuing this vision, we have strengthened our partnerships with international development cooperation agencies and organizations”.

Now, the duly proven “attacks” that Eni unfairly promoted against my honor and reputation (see Doc. 01 and Doc. 02) in 2010 (judicial process) and 2017 (ENI’s AGM), are condemned by the “Universal Declaration of Human Rights” (Article 12).

The UN Global Compact has two principles on Human Rights: 

Principle 1:
Businesses should support and respect the protection of internationally proclaimed human rights;

Principle 2:
Make sure that they are not complicit in human rights abuses.

So, why does Eni, in my case, doesn’t fulfill this “international commitment”?

Eni vs G20/OECD Principles of Corporate Governance

 

Eni say it "follows" and "accepts" the G20/OECD Principles of Corporate Governance that guides companies in this way:

Stakeholders, including individual workers and their representative bodies, should be able to freely communicate their concerns about illegal or unethical practices to the board and/or to the competent public authorities, and their rights should not be compromised for doing this.

Unethical and illegal practices by corporate officers may not only violate the rights of stakeholders but also be detrimental to the company in terms of reputational effects. It is therefore important for companies to establish a confidential whistleblowing policy with procedures and safe-harbours for complaints by workers, either personally or through their representative bodies, and others outside the company, concerning illegal and unethical behaviour.

The board should be encouraged to protect these individuals and representative bodies and to give them confidential direct access to someone independent on the board, often a member of an audit or an ethics committee.

Some companies have established an ombudsman to deal with complaints. Relevant authorities have also established confidential phone and email facilities to receive complaints. While in certain jurisdictions representative workforce bodies undertake the tasks of conveying concerns to the company, individual workers should not be precluded from, or be less protected, when acting alone.

In the absence of timely remedial action or in the face of reasonable risk of negative action to a complaint regarding contravention of the law, workers are encouraged to report their bona fide complaint to the competent authorities.

Many jurisdictions also provide for the possibility to bring cases of alleged violations of the OECD Guidelines for Multinational Enterprises to the relevant National Contact Point. The company should refrain from discriminatory or disciplinary actions against such workers or bodies.

So, why does Eni, in my case, doesn't fulfill this "International Commitment"? 

Eni vs OECD Guidelines for Multinational Enterprises

The duly proven “attacks” that Eni unfairly promoted against my honor and reputation (see Doc. 01 and Doc. 02) in 2010 (judicial process) and 2017 (ENI’s AGM), are condemned by the “Universal Declaration of Human Rights” (Article 12).

Eni says it “follows” and “accepts” the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct. 

But what guides this "international commitment" of the Italian oil giant?:

IV. Human Rights 

States have the duty to protect human rights. Enterprises should, within the framework of internationally recognised human rights, the international human rights obligations of the countries in which they operate as well as relevant domestic laws and regulations:

1. Respect human rights, which means they should avoid infringing on the human rights of others and should address adverse human rights impacts with which they are involved.

2. Within the context of their own activities, avoid causing or contributing to adverse human rights impacts and address such impacts when they occur.

3. Seek ways to prevent or mitigate adverse human rights impacts that are directly linked to their business operations, products or services by a business relationship, even if they do not contribute to those impacts.

4. Have a publicly available policy commitment to respect human rights.

5. Carry out human rights due diligence as appropriate to their size, the nature and context of operations and the severity of the risks of adverse human rights impacts.

6. Provide for or co-operate through legitimate processes in the remediation of adverse human rights impacts where they identify that they have caused or contributed to these impacts.

Now, why does Eni, in my case, doesn’t fulfill this “international commitment”?

Eni vs OECD Due Diligence Guidance for RBC

Eni states in its "Declaration of Respect for Human Rights" that it follows the “OECD Guidelines for Multinational Enterprises”.

Therefore, to implement these OECD Guidelines, Eni made use of the “OECD Due Diligence Guidance for Responsible Business Conduct”, which in its preface states that the purpose of this material “is to provide practical support to enterprises on the implementation of the OECD Guidelines for Multinational Enterprises by providing plain language explanations of its due diligence recommendations and associated provisions”, and it also “helps businesses (enterprises) to understand and implement due diligence for RBC as foreseen in the OECD Guidelines”.

In order to conduct business based on the premises, principles, and values of the “RBC”, company executives need to periodically consult this OECD Guide to “recognised that business activities may result in adverse impacts related to corporate governance, workers, human rights, the environment, bribery, and consumers”.

Therefore, in my case, Eni should carry out a "due diligence" according to the facts and the abundant, rich, and robust "supporting documentation" (see Doc. 01 and Doc. 02). The supporting documentation was also unquestionably able to "reconstruct the events" about the actions and omissions of both AGIP Brazil and Eni. And that's because, the duly proven “attacks” that Eni unfairly promoted against my honor and reputation in 2010 (judicial process) and 2017 (ENI’s AGM), are condemned by the “Universal Declaration of Human Rights” (Article 12).

And by proceeding in this way, the company would comply with the guidelines of the OECD Guide itself: “Due diligence is the process enterprises should carry out to identify, prevent, mitigate and account for how they address these actual and potential adverse impacts in their own operations, their supply chain and other business relationships, as recommended in the OECD Guidelines. Effective due diligence should be supported by efforts to embed RBC into policies and management systems, and aims to enable enterprises to remediate adverse impacts that they cause or to which they contribute”.

Why does Eni need to perform a “due diligence” on my case? The OECD Guide answers this question: “Due diligence should help enterprises anticipate and prevent or mitigate these impacts [...]. Effectively preventing and mitigating adverse impacts may in turn also help an enterprise maximise positive contributions to society, improve stakeholder relationships and protect its reputation [...]. An enterprise can also carry out due diligence to help it meet legal requirements pertaining to specific RBC issues, such as local labour, environmental, corporate governance, criminal or anti-bribery laws”.

So, why does Eni does note "honor" its own commitments??

Message to Eni's Shareholders by Claudio Descalzi (Eni's CEO)

 

“CEO Guide to Human Rights” an initiative of the WBCSD, Eni's CEO stated: 

“Eni's Statement on Respect for Human Rights reflects our salient human rights issues. It is a fundamental landmark in Eni's journey to improve further its business and human rights standards”.


However, Eni's corporate conduct, in my case, is completely contrary to the corporate discourse headed by the company's main executive.

Now, why does Eni does note "honor" its own commitments?

Read more at Eni's website about Human Rights.

What does "Eni's Statement on Respect for Human Rights" say?

 

The duly proven “attacks” that ENI unfairly promoted against my honor and reputation (see Doc. 01 and Doc. 02) in 2010 (judicial process) and 2017 (ENI’s AGM), are condemned by the “Universal Declaration of Human Rights” (Article 12).

ENI has a document on this topic. This is “ENI’s Statement on Respect for Human Rights”, where the company states that: “ENI’s vision on human rights builds on the dignity of every human being and on companies’ responsibility to contribute to the well-being of local individuals and communities”.

In this “public” statement, “ENI reaffirms its commitment to respect the human rights contained in the International Bill of Human Rights, the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work and the other applicable human rights as set out in international Treaties and Standards”, also recognizing that, “ENI adheres to the UN Guiding Principles for Business and Human Rights, the OECD Guidelines for Multinational Enterprises and the ten principles of the United Nations Global Compact”. 

ENI further states that, by being “consistent with established principles, ENI is committed to not violating human rights and to remedying any critical actions that may result from activities in which the company is involved”.

SO, WHY DOES ENI, IN MY CASE, DOES NOT “HONOR” ITS OWN COMMITMENTS?

What does "Eni's Whistleblowing Policy" say?

 Eni also has a robust policy to regulate the entire “Whistleblowing Process”, from the receipt of the complaint, through the analysis and investigation of the facts until its conclusion, including the appropriate measures to be taken, the feedback to the top executives and the Board of Directors, as well as the filing of the denounced event.

This corporate document, which was released in 2017 and updated in 2019, is part of the “Management System Guideline” and was called “Whistleblowing reports received, including anonymously, by Eni SpA and by its subsidiaries in Italy and abroad”.

It is necessary to highlight some points of this policy that are related to my case:

“Eni will take disciplinary action against employees who intentionally fail to detect or report any violations of the Code of Ethics or make threats or impose reprisals against those who report violations”;

“Eni will also take appropriate disciplinary action against those who fail to protect the whistleblower, who impose retaliation or discrimination against the whistleblower, as well as against anyone who makes reports in bad faith”;

“In assessing the disciplinary sanction to adopt towards anyone who adopts retaliatory or discriminatory measures against the whistleblower will take into account the seriousness of the retaliatory or discriminatory measures, of any damage to health suffered by the whistleblower as a result of these measures, as well as the circumstance that these measures were adopted in a repeated manner or with the participation of two or more people”.

SO, WHY DOES ENI, IN MY CASE, DOES NOT “HONOR” ITS OWN COMMITMENTS?

What does "Eni's Management of Whistleblowing Reports" say?

In compliance with the provision of the Directive (EU) 2019/1937 and the relevant transposition laws, the 2002 Sarbanes-Oxley Act, the company’s Organisational, Management and Control Model, pursuant to Italian Legislative Decree. n. 231 of 2001, and internal anti-corruption regulations, we have adopted a system for the management of whistleblowing reports that enables us to manage whistleblowing reports received, including anonymously, by Eni SpA and by its subsidiaries in Italy and abroad.

In compliance with applicable regulations, regardless of the content of the report and the entity of Eni concerned by it, it is always guaranteed that reports can be sent directly to Eni SpA or through specific reporting channels, set up by subsidiaries in the cases provided for by applicable regulations.

Whichever channel is used, we guarantee the receipt, analysis and management of whistleblowing reports that are sent by or transmitted from anyone, stakeholders, Eni’s People (Eni personnel and anyone, physical or legal persons, who operate in Italy and abroad for achieving Eni’s objectives, each within the scope of their own functions and responsibilities) or other third parties, also when anonymous. Eni consider a whistleblowing report any communications concerning behaviors that relate to Eni's People in violation of the Code of Ethics, any laws regulations, provisions of authorities, internal regulations, Models 231 or Models CE.

The outcome of the verification activities carried out on the reported facts are presented to the Board of Statutory Auditors, owner of the process, also by virtue of its role as Audit Committee under SOX.

The company guarantees the strict confidentiality on the persons and facts reported and on the identity of the reporting persons to ensure that they are not subject to any form of retaliation.

SO, WHY DOES ENI, IN MY CASE, DOES NOT “HONOR” ITS OWN COMMITMENTS?


Read more at Eni's web site.

What does Eni's Code of Ethics say?

The Code of Ethics is Eni's most important commitment! All other company commitments derive from the premises, principles, and values expressed in the Code of Ethics. 

Note that the section “Disciplinary Actions and Contractual Remedies” determines as follows: 

“Compliance with the rules of the Code of Ethics and corporate regulatory instruments is an essential part of our contractual obligations. For Eni's People, the violation of principles and contents of the Code of Ethics constitutes a breach of the primary obligations as an employee or a disciplinary offense. The violation will have all the legal consequences also in relation to the preservation of the employment relationship, based on the principle of gradation, and may result in compensation for any damages resulting from the violation itself”. 

Now, if the violation of the principles and contents of the Code of Ethics is caused by #Eni itself, will an employee be entitled to compensation or reparation? Evidently yes! The Code of Ethics, as well as being an extension of the employment contract, is a two-way street, that is, rights and duties are reciprocal! 

What do I expect from Eni?

I hope that the Italian oil giant Eni will honor its word and, in this way, that it is fulfilled in my favor everything that the company says it is committed to fulfill. 

This means that I hope that Eni can finally transform the commitments made (whether corporate commitments or international commitments) towards the market and its Stakeholders, into attitudes regarding my case, including a "due diligence" and the necessary "remedy" all the damage that I have been suffering over these more than 22 long years!

#Ethics #BusinessEthics #HumanRights #Integrity #Eni

Open Letter to the Chancellor of Italy

To
Farnesina
Mr. Antonio Tajani
Chancellor
Italy

Copy: CIDU, Italian Embassy in Brazil and The Permanent Mission of Italy and Brazil to the UN

              

Subject: CIDU Italy vs Eni SpA

 

Dear Mr. Antonio Tajani,

More than 120 days ago, I sent a message to the CIDU - Interministerial Human Rights Committee (see message below). Despite the seriousness of the allegations of non-compliance by Eni SpA in relation to Human Rights, “strangely” I did not receive any type of contact from CIDU.

It is important to observe CIDU's competencies, described on the institutional website:

. Scopo di  assolvere in via principale agli obblighi assunti dall’Italia in esecuzione dei numerosi accordi e convenzioni adottati sul piano internazionale nella materia della protezione e promozione dei diritti umani;

. Promuovere l’adozione di provvedimenti che si rendano necessari od opportuni per assicurare il pieno adempimento degli obblighi internazionali già assunti o che dovranno essere assunti dall’Italia a seguito della ratifica delle Convenzioni da essa sottoscritte;

. Seguire l’attuazione delle Convenzioni internazionali e la loro concreta osservanza sul territorio nazionale.


Note that Italy is an "adherent nation" to the UN Guiding Principles on Business and Human Rights (UNGP 31). Now, the duly proven “attacks” that Eni unfairly promoted against my honor and reputation (see Doc. 01 and Doc. 02) both in 2010 (judicial process) and 2017 (Eni’s AGM), are condemned by the “Universal Declaration of Human Rights” (Article 12).

Therefore, Eni, in relation to my case, is not in compliance with its own Declaration of Respect for Human Rights, much less with UNGP 31.

In all these more than 22 long years of "ethical conflict", Eni refused to carry out "due diligence" on my case. So, based on "Principle 4" of UNGP 31, which guides adhering nations on the nexus between the State and state-controlled companies, I request that the Italian government (Eni's controlling shareholder) "demand" that the Board of Directors of the Italian oil giant do due diligence on my case.

I await your contact as soon as possible.

Best Regards.

Douglas Linares Flinto
Chairman & CEO
Brazilian Business Ethics Institute

To

CIDU – Comitato Interministeriale Diritti Umani

Mr. Fabrizio Petri

President

Italy

Copy:       Chancellor Italy (Farnesina)

Chancellor Brazil (Itamaraty)

Ministry of Human Rights – Brazil

Embassy of Italy in Brazil

Permanent Mission of Italy to the UN

Permanent Mission of Brazil to the UN

 

Subject:       CIDU - Whistleblowing against ENI for violation of “human rights”

(Article 12 - Universal Declaration of Human Rights)

 

 

Dear Mr. Fabrizio Petri,

  

A very important fact that needs to be noted by CIDU in relation to the "3rd version" about my dismissal from AGIP Brazil (former Brazilian subsidiary of Eni). Note that there are only two possibilities for the content of Eni's presentation - in the AGM 2017 - regarding the "3rd version" of my dismissal: either the version is "true" or the version is "false".

I have prepared a "new material" (see attached document) so that you can analyze the strategy that Eni's executives has been using to handle my case: "a systemic imposition of instrumentally engineered retaliation and victimization - with attacks on my honor and reputation - that distorts and manipulates the truth to exempt itself from its own responsibility regarding all the damage I have suffered over these more than 21 long years".

This document fully proves that I am not the "villain" of this story, but the main "victim", despite having complied with Eni's Code of Ethics when I whistleblowing fraud and acts of corruption in AGIP Brazil with deviations million dollars a year. Therefore, I am the whistleblower, as recognized by the Labor Court of Brazil!

For this reason, I ask CIDU to request "clarifications" from Eni's Board of Directors on this situation, which is directly violating the commitments assumed by the company, whether corporate commitments or international commitments such as the "UN Guiding Principles on Business and Human Rights" (Principle 4: The nexus between the State and companies), especially that the Italian government is an adherent nation.

 

And, because of this Principle 4 (UNGP 31), I request that Italian government - as the "controlling shareholder” of ENI - require the company's Board of Directors to finally carry out a "due diligence" on my case in the light of the “chronology of the facts” (see attached file) which was sufficiently capable of “reconstructing the events” about the “actions” and “omissions” of ENI’s Brazilian subsidiary and of ENI itself to my disadvantage.

I place myself, from now on, at your disposal, and I look forward to your contact.

Best Regards.

 

Douglas Linares Flinto

Chairman & CEO

Brazilian Business Ethics Institute

 

Open Letter to the Eni's Board of Directors

To
Eni’s Board of Directors
Mr. Giuseppe Zafarana
Chairman
Italy

Copy: Eni’s Management

Subject: Whistleblowing Report vs Eni’s Statement on Respect for Human Rights

Dear Mr. Giuseppe Zafarana,

The duly proven “attacks” (Doc. 01 and Doc. 02) that Eni unfairly promoted against my honor and reputation both in 2010 (judicial process) and 2017 (ENI’s AGM), are condemned by the “Universal Declaration of Human Rights” (Article 12).

Eni has a document on this topic. This is “Eni’s Statement on Respect for Human Rights”, where the company states that: “Eni’s vision on human rights builds on the dignity of every human being and on companies’ responsibility to contribute to the well-being of local individuals and communities”.

In this “public” statement, “Eni reaffirms its commitment to respect the human rights contained in the International Bill of Human Rights, the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work and the other applicable human rights as set out in international Treaties and Standards”, also recognizing that, “Eni adheres to the UN Guiding Principles for Business and Human Rights, the OECD Guidelines for Multinational Enterprises and the ten principles of the United Nations Global Compact”.

Eni further states that, by being “consistent with established principles, ENI is committed to not violating human rights and to remedying any critical actions that may result from activities in which the company is involved”.

Therefore, I reiterate my request that the Eni Board of Directors can finally do "due diligence" on my case, according to my "whistleblowing" reported on the Eni Whistleblowing Channel which received the number 2719 0442 4028 1367 (Doc. 3).

Note that it is necessary for the Eni Board to be guided by “Eni’s Management of Whistleblowing Report” available on the company’s website (Doc. 04) and also by “Whistleblowing reports received, including anonymously, by Eni SpA and by its subsidiaries in Italy and abroad” (Doc. 05).

Best Regards.

Douglas Linares Flinto
Chairman & CEO
Brazilian Business Ethics Institute

Open Letter to the CDP Group

 

To
CDP SpA
Chairman and CEO
Italy

Copy: Board of Directors, Board of Statutory Auditors and Executives 

 

Subject: Whistleblowing Report vs Eni's Statement on Respect for Human Rights

 

Dear Mr. Giovanni Tempini and Mr. Dario Scannapieco,

CDP Group and MEF are Eni's largest shareholders and therefore have responsibility for the "actions" and "omissions" of Eni's Board of Directors.

For your information, I forward a message sent to Eni's Board of Directors (read text below) the expectation that CDP Group (and MEF) may "require" Eni to carry out "due diligence" on my case, due to the guidelines in "Principle 4" (The State-Business Nexus) of the UNGP 31 that Italy is an "adherent nation".

Best Regards.

Douglas Linares Flinto
Chairman & CEO
Brazilian Business Ethics Institute

To

Eni’s Board of Directors

Mr. Giuseppe Zafarana

Chairman

Italy

 

Copy: Eni’s Management

 

   

  

Subject: Whistleblowing Report vs Eni’s Statement on Respect for Human Rights

 

 

 

Dear Mr. Giuseppe Zafarana,

 

The duly proven “attacks” (Doc. 01 and Doc. 02) that Eni unfairly promoted against my honor and reputation both in 2010 (judicial process) and 2017 (ENI’s AGM), are condemned by the “Universal Declaration of Human Rights” (Article 12). 

 

Eni has a document on this topic. This is “Eni’s Statement on Respect for Human Rights”, where the company states that: “Eni’s vision on human rights builds on the dignity of every human being and on companies’ responsibility to contribute to the well-being of local individuals and communities”. 

 

In this “public” statement, “Eni reaffirms its commitment to respect the human rights contained in the International Bill of Human Rights, the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work and the other applicable human rights as set out in international Treaties and Standards”, also recognizing that, “Eni adheres to the UN Guiding Principles for Business and Human Rights, the OECD Guidelines for Multinational Enterprises and the ten principles of the United Nations Global Compact”. 

 

Eni further states that, by being “consistent with established principles, ENI is committed to not violating human rights and to remedying any critical actions that may result from activities in which the company is involved”. 

 

Therefore, I reiterate my request that the Eni Board of Directors can finally do "due diligence" on my case, according to my "whistleblowing" reported on the Eni Whistleblowing Channel which received the number 2719 0442 4028 1367 (Doc. 3).

 

Note that it is necessary for the Eni Board to be guided by “Eni’s Management of Whistleblowing Report” available on the company’s website (Doc. 04) and also by “Whistleblowing reports received, including anonymously, by Eni SpA and by its subsidiaries in Italy and abroad” (Doc. 05).

 

Best Regards.

 

Douglas Linares Flinto

Chairman & CEO

Brazilian Business Ethics Institute

Open Letter to the Ministry of Economy and Finance

 

To
Mr. Giancarlo Giorgetti
Ministry of Economy and Finance
Italy

Copy: Department of Treasury Department of Finance

 

Subject: Whistleblowing Report vs Eni's Statement on Respect for Human Rights

Dear Mr. Giancarlo Giorgetti,

Ministry of Economy and Finance and CDP Group are Eni's largest shareholders and therefore have responsibility for the "actions" and "omissions" of Eni's Board of Directors.

For your information, I forward a message sent to Eni's Board of Directors (read text below) the expectation that Ministry of Economy and Finance (and CDP Group) may "require" Eni to carry out "due diligence" on my case, due to the guidelines in "Principle 4" (The State-Business Nexus) of the UNGP 31 that Italy is an "adherent nation".

Best Regards.

Douglas Linares Flinto
Chairman & CEO
Brazilian Business Ethics Institute

 

To

Eni’s Board of Directors

Mr. Giuseppe Zafarana

Chairman

Italy

 

Copy: Eni’s Management

 

   

  

Subject: Whistleblowing Report vs Eni’s Statement on Respect for Human Rights

 

 

 

Dear Mr. Giuseppe Zafarana,

 

The duly proven “attacks” (Doc. 01 and Doc. 02) that Eni unfairly promoted against my honor and reputation both in 2010 (judicial process) and 2017 (ENI’s AGM), are condemned by the “Universal Declaration of Human Rights” (Article 12). 

 

Eni has a document on this topic. This is “Eni’s Statement on Respect for Human Rights”, where the company states that: “Eni’s vision on human rights builds on the dignity of every human being and on companies’ responsibility to contribute to the well-being of local individuals and communities”. 

 

In this “public” statement, “Eni reaffirms its commitment to respect the human rights contained in the International Bill of Human Rights, the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work and the other applicable human rights as set out in international Treaties and Standards”, also recognizing that, “Eni adheres to the UN Guiding Principles for Business and Human Rights, the OECD Guidelines for Multinational Enterprises and the ten principles of the United Nations Global Compact”. 

 

Eni further states that, by being “consistent with established principles, ENI is committed to not violating human rights and to remedying any critical actions that may result from activities in which the company is involved”. 

 

Therefore, I reiterate my request that the Eni Board of Directors can finally do "due diligence" on my case, according to my "whistleblowing" reported on the Eni Whistleblowing Channel which received the number 2719 0442 4028 1367 (Doc. 3).

 

Note that it is necessary for the Eni Board to be guided by “Eni’s Management of Whistleblowing Report” available on the company’s website (Doc. 04) and also by “Whistleblowing reports received, including anonymously, by Eni SpA and by its subsidiaries in Italy and abroad” (Doc. 05).

 

Best Regards.

 

Douglas Linares Flinto

Chairman & CEO

Brazilian Business Ethics Institute

Open Letter to Eni's Largest Shareholder

To

Mrs. Giorgia Meloni
President of the Council of Ministers
Italy

Copy: CIDU – Comitato Interministeriale Diritti Umani, General Secretariat of the Presidency of the Council of Ministers, Minister of Giustizia, Farnesina, Ambassador of Italy in Brazil and Fabio Porta (Italian-Brazilian deputy)

 

Subject: Eni SpA: UNGP31 - Principle 04 (The State-Business Nexus)

 

Dear Mrs. Giorgia Meloni,

Italy's government is Eni's largest shareholders and therefore have responsibility for the "actions" and "omissions" of Eni's Board of Directors.

For your information, I forward a message sent to Eni's Board of Directors (read text below) the expectation that Italy’s government may "require" Eni to carry out "due diligence" on my case, due to the guidelines in "Principle 4" (The State-Business Nexus) of the UNGP 31 that Italy is an "adherent nation".

Best Regards.

Douglas Linares Flinto
Chairman & CEO
Brazilian Business Ethics Institute

 

To

Eni’s Board of Directors

Mr. Giuseppe Zafarana

Chairman

Italy

 

Copy: Eni’s Management

 

   

  

Subject: Whistleblowing Report vs Eni’s Statement on Respect for Human Rights

 

 

 

Dear Mr. Giuseppe Zafarana,

 

The duly proven “attacks” (Doc. 01 and Doc. 02) that Eni unfairly promoted against my honor and reputation both in 2010 (judicial process) and 2017 (ENI’s AGM), are condemned by the “Universal Declaration of Human Rights” (Article 12). 

 

Eni has a document on this topic. This is “Eni’s Statement on Respect for Human Rights”, where the company states that: “Eni’s vision on human rights builds on the dignity of every human being and on companies’ responsibility to contribute to the well-being of local individuals and communities”. 

 

In this “public” statement, “Eni reaffirms its commitment to respect the human rights contained in the International Bill of Human Rights, the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work and the other applicable human rights as set out in international Treaties and Standards”, also recognizing that, “Eni adheres to the UN Guiding Principles for Business and Human Rights, the OECD Guidelines for Multinational Enterprises and the ten principles of the United Nations Global Compact”. 

 

Eni further states that, by being “consistent with established principles, ENI is committed to not violating human rights and to remedying any critical actions that may result from activities in which the company is involved”. 

 

Therefore, I reiterate my request that the Eni Board of Directors can finally do "due diligence" on my case, according to my "whistleblowing" reported on the Eni Whistleblowing Channel which received the number 2719 0442 4028 1367 (Doc. 3).

 

Note that it is necessary for the Eni Board to be guided by “Eni’s Management of Whistleblowing Report” available on the company’s website (Doc. 04) and also by “Whistleblowing reports received, including anonymously, by Eni SpA and by its subsidiaries in Italy and abroad” (Doc. 05).

 

Best Regards.

 

Douglas Linares Flinto

Chairman & CEO

Brazilian Business Ethics Institute