Ep102 - Eni’s whistleblowing under scrutiny

📅 January 31, 2022 | Brazilian NCP — OECD - OCDE

🔷 What happens after a company receives a whistleblowing report? Who investigates it, and who receives the findings?

Following my preliminary meeting with the mediators, I proposed expanding the agenda of the OECD Good Offices process conducted by Brazil’s National Contact Point (NCP).

The NCP’s initial proposal addressed Eni’s Responsible Business Conduct practices, including protection of whistleblowers’ identities.

I considered this important, but insufficient for the Flinto Case.

🔷 Crucially, I based my proposed expansion on the whistleblowing procedures described on Eni’s own official website — not on standards I had invented.

My proposal was incorporated into item 10(a) of the sixth draft Work Plan, dated January 31, 2022, and forwarded to Eni.

The expanded agenda covered:

▪️ Management, analysis, and handling of whistleblowing reports;

▪️ Investigations and their findings;

▪️ Reporting findings to internal cross-functional bodies;

▪️ Reporting to senior management and the Board of Directors.

🔷 Most importantly, these stages were to be examined in relation to the facts and documents I submitted in Specific Instance No. 04/2020.

My question was straightforward:

📌 How had Eni applied its publicly described procedures to the reports I submitted in 2001?

A written policy does not, by itself, prove that it works in practice.

The inclusion of my proposal in the draft did not mean Eni had approved it or that substantive mediation had begun.

I also requested the participation of two members of Eni’s Board Control and Risk Committee as observers.

🔷 NEXT EPISODE: WHY DID I REQUEST THEIR PARTICIPATION?

After more than 25 years, one question remains unanswered:

🔴 Why doesn't Eni submit the facts, documents and different versions of my dismissal to a truly independent investigation?

I am not asking anyone to believe me.

Know the facts.

Examine the supporting evidence.

And reach your own conclusion.

❎ Learn more:

1️⃣ Good Offices Work Plan — Sixth Draft (January 31, 2022), incorporating my proposed amendments to the mediation agenda (Portuguese and English versions): https://lnkd.in/dvAU32ez