What wasn't investigated... Why?

Throughout this week, I presented the Internal Audit Report of Eni’s Brazilian subsidiary, dated July 26, 2001 - after my whistleblowing report and just six days before my dismissal.

The document confirmed serious irregularities at the Cuiabá unit, including “fictitious invoicing”, missing records, weak controls, similar transactions and companies under investigation by the Fuel Parliamentary Commission of Inquiry.

I also showed that the report failed to examine key matters raised in my dossier:
🔹 two Agip-owned service stations allegedly operated through third parties for the Regional Manager’s benefit;
🔹 tanker trucks linked to the same manager and used for deliveries and product transfers;
🔹 fictitious financing granted to customers to fund those vehicles;
🔹 who received Agip’s payments for those operations.

The report was not irrelevant.

It confirmed part of the irregularities, but failed to reveal the full extent of the facts reported to Agip do Brasil’s Commercial Directorate.

An effective investigation should have cross-checked corporate records, contracts, financing, payments, ownership records, transport operations and the true economic beneficiaries, as I did in my dossier.

None of this appears in the report’s conclusions.

My report also identified personal, family and commercial relationships involving other Regional Sales Managers and Agip do Brasil’s Commercial Director.

These relationships do not, by themselves, prove wrongdoing. But they represented conflicts of interest that should have been disclosed, assessed, managed and documented by a truly independent audit.

Beginning on August 3, I will present three of these cases.

Later, I will also present the complaint submitted to the Ethics Committee of IIA-The Institute of Internal Auditors concerning Marco Petracchini, then Eni’s Chief Audit Officer, and the Agip do Brasil Internal Audit Report.

The complaint questioned whether his conduct complied with the internal auditors’ Code of Ethics and Eni’s own Internal Audit policies. I will also present the response issued by the AIIA | Associazione Italiana Internal Auditors, whose governing body at the time included Petracchini.

The question that closes this week is simple:

📌 Why did an audit that confirmed serious irregularities fail to examine all the facts presented by the whistleblower?

After twenty-five years, I continue to ask for only one thing:

🛑 an independent, impartial and transparent review of all the documentation.


✅ Learn more:

1️⃣ Agip do Brasil Internal Audit Report:
🔹 original in Portuguese
🔹 English translation

The Tanker Trucks & The front-men

In my previous posts, I showed that the Internal Audit Report of Eni’s Brazilian subsidiary confirmed “fictitious invoicing”, the destruction of documents, similar transactions, and other serious facts at the Cuiabá unit.

But my whistleblowing report was not limited to invoices issued in TELEMAT’s name (Brasil Telecom).

Among the facts presented in my dossier was the existence of tanker trucks linked to the then Regional Sales Manager of Cuiabá.

These vehicles were incorporated into Agip’s transport fleet and were used for two activities directly connected to the company’s business:
🔹 delivering fuel to customers in the State of Mato Grosso;
🔹 transferring gasoline and ethanol from facilities in São Paulo to Cuiabá.

In other words, the trucks performed services paid for by Agip itself and took part in an essential stage of the company’s operations: transporting the products it sold.

The information and documents gathered in my report also indicated that some of these vehicles may have been acquired through “fictitious financing” granted to Agip customers who allegedly participated in the fraud and corruption scheme I had reported.

The arrangement described was serious: financing formally granted to fuel retailers may have been used to fund the purchase of trucks later employed to transport the company’s own products.

Despite this, the Internal Audit Report dated July 26, 2001, neither identified nor examined:
🔹 how many trucks were linked to the Regional Sales Manager;
🔹 in whose names the vehicles were registered;
🔹 how they had been financed;
🔹 which customers had received the funds;
🔹 how much Agip paid for deliveries and product transfers;
🔹 who the ultimate economic beneficiaries of those payments were.

The documents I later examined raised a fundamental question: why did the audit fail to identify the carrier, the tanker trucks linked to the Cuiabá Regional Sales Manager, and the fuel retailers who allegedly received fictitious financing?

📌 How could an audit of Agip’s largest regional sales unit in Brazil fail to investigate the vehicles used to transport the company’s own products and the source of the funds used to acquire them?

The information concerning these trucks and transport operations required a thorough review of vehicle ownership records, contracts, financing arrangements, payments, and ultimate beneficiaries.

None of this appears in the report’s conclusions.

Once again, the problem is not only what Internal Audit found.

The problem is everything it failed to follow up, investigate, and document.


✅ Learn more:

1️⃣ Agip do Brasil Internal Audit Report:
🔹 original in Portuguese
🔹 English translation

2️⃣ Chronology of Facts for the Reconstruction of the Events

3️⃣ Memorial (1999–2025)