Eni's narratives and my documentary evidence

Throughout this week, we have seen how a single document published by Eni in 2017 — "Questions & Answers before the General Shareholders' Meeting" — became the center of every discussion that followed.

We also saw that I submitted a formal request for rectification to Eni's Data Protection Officer (DPO), asking that certain statements be examined in light of the body of documentary evidence gathered over more than two decades.

The Company decided to leave the document unchanged.

From this point forward, however, the discussion is no longer about positions or interpretations.

It is about documents.

Over the coming weeks, I will present some of the key documents that form the body of evidence in this case.

🔹 Documents produced by ENI itself.

🔹 Documents issued by Brazilian public authorities.

🔹 Documents issued by Italian public authorities.

🔹 Documents produced by independent third parties.

Each publication will examine one specific issue.

Each document will be presented in the context in which it was created.

And each reader will be able to compare it directly with the statements contained in Eni's official document published in 2017.

The objective is not to convince.

The objective is not to ask anyone to accept my version of the facts.

The objective is exactly the same one that inspired the creation of Eni's Way:

To make the documents available so that each person can reach their own conclusions and perhaps answer one simple question:

📌 "Why has Eni never conducted an independent investigation into the Flinto Case?"

In the next publication, we will begin with the first issue:

The chronology of my dismissal and the sequence of events that led to the reporting of irregularities within ENI's Brazilian subsidiary.

Because, from this point forward, the documents will continue to speak for themselves.

To be continued on Monday.


✅ Learn more:

1️⃣ Memorial submitted to Eni's Board of Directors;

2️⃣ Chronology of Events for the Reconstruction of the Facts;

3️⃣ Questions & Answers before the General Shareholders' Meeting 2017.

Eni's response

Over the past few days, we have seen that, in July 2024, I submitted a formal request for rectification to Eni's Data Protection Officer (DPO) concerning the document "Questions & Answers before the General Shareholders' Meeting 2017", pursuant to Article 16 of the General Data Protection Regulation (GDPR).

The request was straightforward.

It asked that certain statements contained in that document be examined in light of the documentary evidence gathered over more than two decades.

On 22 August 2024, I received ENI's official response.

The Company rejected my request for rectification in its entirety.

According to the response issued by Eni's DPO, the purpose of the 2017 document was to record the questions submitted by shareholders and the Company's answers before the General Shareholders' Meeting.

For that reason, the DPO concluded that:

📌 "The information contained therein must be considered accurate, as it faithfully reflects the discussions held during the Ordinary General Shareholders' Meeting".

That response became the Company's principal justification for keeping the document published since 2017 unchanged.

However, after carefully examining that reasoning, I identified what I considered to be a fundamental issue.

The document "Questions & Answers before the General Shareholders' Meeting" does not record the discussions that took place during the General Shareholders' Meeting.

It contains only the questions submitted in advance by shareholders and the answers prepared by the Company before the meeting took place.

That issue became the turning point in this case.

Rather than continuing to debate the matter directly with Eni, I filed a formal complaint with The Italian Data Protection Authority(GPDP), the authority responsible for enforcing the GDPR in Italy.

Tomorrow, we will examine exactly why this distinction became one of the central issues in the proceedings currently pending before The Italian Data Protection Authority (GPDP).

Because, from this point forward, the documents speak for themselves.

To be continued on Friday.


✅ Learn more

1️⃣ Request for Rectification submitted to Eni's Data Protection Officer (2024);

2️⃣ Eni's Response (22 August 2024);

3️⃣ Complaint submitted to The Italian Data Protection Authority (GPDP).