Ep112 - Eni, what would you answer?

📅 November 12, 2026 | 25 Years of the Flinto Case

🔷 Eni, after more than 110 episodes of the ENI’S WAY — 25 YEARS OF TRUTH campaign, what would you answer if your stakeholders, including shareholders, requested clarification about the Flinto Case?

This question does not come out of nowhere.

In recent episodes, I have presented documents showing that different institutions requested explanations from Eni about my case.

The AIIA | Associazione Italiana Internal Auditors, the Presidency of the Italian Republic, CDP Cassa Depositi e Prestiti, the Italian Embassy in Brazil, and the WBCSD – World Business Council for Sustainable Development are among the key players in this documentary series.

And we must not forget two extraordinary facts:

📚 The Flinto Case was featured in the Italian bestseller Eni: The Parallel State (2016), the first work of investigative journalism about the Italian oil giant.

🏛️ Mauro Meggiolaro, a critical shareholder representing Fondazione Finanza Etica, raised questions about the Flinto Case at four Eni Annual General Meetings (2017, 2018, 2020, and 2021)! What a paradox! A case featured in a bestseller and brought before the company’s own shareholders at four Annual General Meetings still awaits the independent investigation I have been demanding!

📌 And how did Eni respond to these requests for clarification?

Repeatedly, it resorted to what I have come to call its “Corporate Narrative”: a lengthy account of my dismissal, the lawsuits bearing characteristics of SLAPPs, my public statements, and ENI’S WAY.

Much about the whistleblower. Little about the reported misconduct.

🔷 But which Eni are we talking about, exactly?

The Eni that has a Code of Ethics?

The Eni that maintains a Whistleblowing Policy and claims to protect those who report misconduct?

The Eni that holds ISO 37301:2021 certification (ISO - International Organization for Standardization) the international standard for compliance management systems?

The Eni that participates in the UN Global Compact Network Italia and holds Global Compact LEAD recognition?

The Eni that declares its commitment to the OECD - OCDE Guidelines for Multinational Enterprises?

Or the Eni that recognizes the United Nations Guiding Principles on Business and Human Rights (UNGPs), including Principle 12, which addresses internationally recognized human rights, encompassing protection against attacks on honor and reputation under Article 12 of the Universal Declaration of Human Rights?

🔷 So many declarations. So many commitments. So many policies. So many pages devoted to ethics and integrity. In theory, a true benchmark in corporate governance!

But there is one question that none of these corporate documents can answer on its own:
What happens when a whistleblower demands that these commitments be applied to a real case?

In my case, the answer has been a 25-year battle.

I reported irregularities at Agip do Brasil in 2001. I was dismissed. I suffered retaliation. I faced lawsuits brought by Eni. I approached Boards of Directors, shareholders, international organizations, and public authorities.

My case was featured in an Italian bestseller and raised at four Eni Annual General Meetings.
And throughout all these years, I have continued to demand something that should be perfectly normal for a company that proclaims so many commitments to integrity:

A truly independent, impartial, and transparent investigation into the reported misconduct and the retaliation I suffered!

📌 Now, let us imagine a very simple situation.

An institutional shareholder, an investor, an international organization, a public authority, or any other stakeholder decides to submit a request for clarification to Eni.

They do not ask about the bestseller Eni: The Parallel State.

They do not ask about the four Annual General Meetings at which the Flinto Case was questioned.

They do not ask about ENI’S WAY.

They do not ask how many emails I sent or how many times I criticized the company.

They ask only the following:

1️⃣ CODE OF ETHICS: Which provisions of Eni’s Code of Ethics were actually applied to investigate the irregularities reported by Douglas Linares Flinto in 2001?

2️⃣ WHISTLEBLOWING: If Eni claims to protect whistleblowers against retaliation, what concrete measures did it take to investigate the allegations of retaliation raised in the Flinto Case?

3️⃣ ISO 37301:2021: How does Eni demonstrate the conformity of its compliance management system in handling this case, particularly regarding impartiality, independence, and the effectiveness of the investigation?

4️⃣ UN GLOBAL COMPACT: How does Eni reconcile its public commitments to ethics, human rights, and integrity with the absence of disclosed findings from an independent investigation into the Flinto Case?

5️⃣ OECD GUIDELINES: How does Eni explain its decision to withdraw from the Good Offices conducted by NCP Brazil in March 2022, after having agreed to participate in the proceedings?

6️⃣ UNGP 31: How does Eni’s handling of the Flinto Case meet the criteria of legitimacy, accessibility, predictability, equitability, transparency, and rights compatibility established for effective grievance mechanisms?

🔷 Eni, six questions. Six opportunities to demonstrate that your words match your actions!

And please, this time there would be no need to repeat the story of my dismissal, mention the lawsuits, or portray my communications as a campaign against the company.

Your stakeholders do not need yet another narrative about the whistleblower. They need answers about the reported misconduct!

Because a company does not demonstrate its integrity merely by publishing policies, joining international initiatives, or displaying certifications.

It demonstrates integrity when its commitments are put to the test. Especially when the facts are uncomfortable.

📌 And here lies the great irony of this story:

Eni has a Code of Ethics, a Whistleblowing Policy, compliance structures, international certification, and commitments to the OECD and the United Nations.

The Flinto Case has been featured in an Italian bestseller, questioned at four Annual General Meetings, and brought to the attention of international institutions and authorities.

Yet, after 25 years, I am still asking the company to do what its own institutional commitments proclaim! There is no shortage of policies. No shortage of commitments. No shortage of questions. What is missing are answers backed by evidence of an independent investigation!

🔷 So, Eni, the question remains: 📌 IF YOUR STAKEHOLDERS, INCLUDING SHAREHOLDERS, REQUESTED THESE CLARIFICATIONS TODAY, WHAT WOULD YOU ANSWER?

Another version of your corporate narrative?

Or, finally, documents, evidence, and findings from a truly independent investigation?

🔴 INSTEAD, ENI SHOULD AUTHORIZE A TRULY INDEPENDENT, IMPARTIAL, AND TRANSPARENT INVESTIGATION INTO THE FLINTO CASE!

🔷 NEXT EPISODE: WHEN THE ROME PUBLIC PROSECUTOR’S OFFICE FAILED TO COMPLY WITH INTERNATIONAL TREATIES BETWEEN ITALY AND BRAZIL WHEN SUMMONING ME IN BRAZIL!

Ep111 - When WBCSD questioned Eni

📅 May 25, 2021 | Geneva, Switzerland

🔷 When one of the world's most important business organizations dedicated to sustainability received a complaint about the Flinto Case, what did it do?

In May 2021, I contacted Peter Bakker, President and CEO of the WBCSD – World Business Council for Sustainable Development, an international organization bringing together major companies committed to sustainable development, including Eni.

My message questioned the gap between the company's public commitments to ethics, transparency, and integrity and its conduct regarding the irregularities I reported in 2001, when I worked at Agip do Brasil.

At the time, I emphasized that my battle with the Italian oil giant was approaching 20 years, during which different Eni Chairmen and Boards of Directors had become aware of the Flinto Case.

I also mentioned the proposal for an amicable settlement requested by Eni itself in November 2020 through the Italian Ambassador to Brazil, the monitoring of the case by NCP Brazil (OECD - OCDE), and the absence of a truly independent, impartial, and transparent investigation into the facts originally reported.

📌 And how did the WBCSD react?

On May 25, 2021, Federico Merlo, Managing Director & Senior Management Team at the WBCSD (currently at PwC), sent a message to Stefano Goberti, an Eni executive, copying Peter Bakker and other professionals from the organization and the company.

The WBCSD representative explained that Peter Bakker had received a communication from me describing an approximately two-decade-long dispute with Eni.

He then made a straightforward request:

📌 Could Eni provide more information about the background of the case and clarify whether any action was being taken to resolve it?

The executive also emphasized that the WBCSD's objective was to understand the situation without making any prior judgment about the merits of the dispute.

🔷 Yet another stakeholder requesting clarification from Eni!

This request was not an isolated incident.

Before that, Eni had already received inquiries from the AIIA | Associazione Italiana Internal Auditors, critical shareholders, CDP Cassa Depositi e Prestiti, and the Italian Embassy in Brazil.

And these initiatives had one element in common: institutions and stakeholder representatives were seeking to understand what had actually happened in the Flinto Case and what measures the company had taken.

📌 But what did Eni tell the WBCSD?

Documents that later came to my attention revealed that Eni repeatedly used a "Corporate Narrative" in its responses to requests for clarification.

Instead of presenting an independent investigation into the irregularities reported in 2001 and the retaliation that followed, the company focused its arguments on the whistleblower's actions, the lawsuits, and allegations that my communications were damaging its reputation.

This narrative eventually incorporated references to discussions concerning a possible amicable settlement and the monitoring of the Flinto Case by NCP Brazil.

The Corporate Narrative could change its tone. But the essential question remained unanswered: where were the results of an independent investigation into the reported facts?

🔷 Corporate sustainability cannot exist only in words!

The WBCSD promotes commitments related to sustainability and corporate responsibility. But these commitments must also be demonstrated in how companies handle complaints, respect their stakeholders, and protect those who report potential irregularities.

After all, what is the point of a company proclaiming values of ethics, transparency, and integrity if, when questioned about the conduct of its executives, it fails to provide explanations supported by verifiable evidence?

And one more question: did the WBCSD consider Eni's explanations satisfactory?

🔴 INSTEAD, ENI SHOULD AUTHORIZE A TRULY INDEPENDENT, IMPARTIAL, AND TRANSPARENT INVESTIGATION INTO THE FLINTO CASE!

🔷 NEXT EPISODE: AFTER MORE THAN 110 EPISODES, WHAT WOULD ENI SAY TO ITS STAKEHOLDERS?

❎ Learn more:

1️⃣ Correspondence between the WBCSD and Eni — May 25, 2021:
🔹 Original document in English: https://lnkd.in/dHBqQ_79

Ep110 - Italian diplomacy meets Eni's narrative

📅 November 9–20, 2020 | Brasília, Brazil — Rome, Italy

🔷 When the Italian Ambassador to Brazil requested clarification about the Flinto Case, did Eni provide answers or repeat its corporate narrative?

In November 2020, my struggle against Eni, which began after the irregularities I reported at Agip do Brasil in 2001, reached the Italian Embassy in Brasília.

At that time, Eni's new Board of Directors, chaired by Lucia Calvosa, continued to ignore my requests for a truly independent investigation into the reported misconduct and the retaliation I had suffered.

Furthermore, my complaint concerning Eni's non-compliance with the OECD - OCDE Guidelines for Multinational Enterprises had already been accepted by Brazil's National Contact Point (NCP), giving rise to Specific Instance No. 04/2020.

📌 How did the Italian Embassy become involved?

On November 9, 2020, I wrote to the Italian Ambassador to Brazil, Francesco Azzarello, mentioning that Ambassador Ettore Sequi(Chief of Staff to Italy's Minister of Foreign Affairs) had suggested that we discuss my case, which had already dragged on for 19 long years.

The following day, I received a reply from Carlo Jacobucci, Counsellor and Head of the Commercial Department at the Italian Embassy in Brazil.

Writing expressly on behalf of Ambassador Francesco Azzarello, Jacobucci confirmed that the diplomatic mission would contact Eni and get back to me as soon as it received a response.

🔷 The Italian Embassy had decided to request explanations from Eni!

In my reply, I made a simple and entirely legitimate request: that the Ambassador also hear my side of the story, just as he would hear the Italian oil giant's version.

I needed just 15 minutes to tell my story!

I subsequently spoke with Ambassador Francesco Azzarello by telephone.

📌 And how did Eni respond to the Italian diplomatic mission?

On November 10, Carlo Jacobucci contacted Francesca Dionsi Vici, Eni's executive responsible for relations with foreign institutions and international organizations, requesting information about the Flinto Case.

The executive stated that she would prepare a briefing note together with the company's Legal Department.

On November 19, having received no response, Jacobucci followed up on his request for clarification.

The following day, November 20, 2020, Francesca Dionsi Vici forwarded Eni's response, which was subsequently shared with Ambassador Francesco Azzarello.

🔷 And what did Eni's response say?

Instead of providing evidence of an independent investigation into the misconduct originally reported, the company once again relied on arguments it had already presented to other institutions:

1️⃣ My dismissal: Eni maintained that the Brazilian courts had upheld the legitimacy of my dismissal from Agip do Brasil in 2001, without satisfactorily clarifying the circumstances surrounding my reports of misconduct and the retaliation I have continued to challenge.

2️⃣ The lawsuits: The company referred to the legal proceedings it had initiated against me, using them to support its account of my public statements and communications to third parties.

3️⃣ ENI'S WAY: Eni portrayed my communications and publications as a defamatory campaign against the company and its executives.

4️⃣ Brazil's OECD National Contact Point: Eni acknowledged that the Flinto Case was also being examined under Brazil's mechanism for implementing the OECD Guidelines for Multinational Enterprises.

🔷 But there was something new in Eni's Corporate Narrative!

The company had begun adding an apparently conciliatory statement to its institutional responses: initiatives were reportedly underway to find a path toward clarification and bring the dispute to an end.

Yet even in this response, Eni continued to blame the prolonged dispute on my allegedly unfounded and offensive conduct.

Eni was talking about reconciliation while continuing to attack the whistleblower's reputation!

📌 A corporate narrative that crossed borders and institutions!

The response sent to the Italian Embassy followed the same pattern used by Marco Petracchini in his November 2016 correspondence with the AIIA | Associazione Italiana Internal Auditors, and subsequently repeated by the company in its official responses to questions raised by the critical shareholder at the 2017 Annual General Meeting.

More recently, in October 2020, the same narrative had been forwarded by Stefano Speroni to CDP Cassa Depositi e Prestiti, one of Eni's major shareholders.

Now, the company was once again resorting to that narrative before a diplomatic mission representing its own country.

But the Italian Embassy had not asked Eni for an assessment of my reputation. It had requested clarification about the Flinto Case!

And that raises three fundamental questions:

📌 Did Eni provide Ambassador Francesco Azzarello with evidence of a truly independent, impartial, and transparent investigation into the misconduct reported in 2001?

📌 If the company claimed to be seeking a conciliatory solution, why did it continue using arguments to discredit the whistleblower before its stakeholders?

📌 And why did Eni fail to explain, objectively, what concrete measures it had taken to investigate the reported misconduct and alleged retaliation?

The documents establish that the Embassy requested clarification, that Eni submitted its response, and that the Ambassador received it.

What this correspondence does not provide are the findings of an independent investigation into the facts that gave rise to the Flinto Case.

🔴 INSTEAD, ENI SHOULD AUTHORIZE A TRULY INDEPENDENT, IMPARTIAL, AND TRANSPARENT INVESTIGATION INTO THE FLINTO CASE!

🔷 NEXT EPISODE: WHEN THE WBCSD – World Business Council for Sustainable Development REQUESTED EXPLANATIONS FROM ENI!

❎ Learn more:

1️⃣ Correspondence between the Italian Embassy in Brazil and Eni (Nov 2020):
🔹 Original document
🔹 English translation

2️⃣ Correspondence with Carlo Jacobucci, on behalf of Ambassador Francesco Azzarello (Nov 9–10, 2020:
🔹 Original document
🔹 English translation

Ep109 - Eni’s Corporate Narrative strikes again!

📅 September 18 – October 9, 2020 | Rome, Italy

🔷 When one of Eni's major shareholders demanded explanations about the Flinto Case, how did the company respond?

On September 14, 2020, I sent a message to the Board of Directors of CDP Cassa Depositi e Prestiti, chaired by Giovanni Gorno Tempini, describing my nearly two-decade struggle against Eni and requesting its intervention as a major shareholder of the Italian oil giant.

Why did I turn to CDP Cassa Depositi e Prestiti?

Because Lucia Calvosa, the newly appointed Chairwoman of Eni's Board of Directors, had maintained the same stance as the previous four Board compositions: failing to commission a truly independent investigation into the irregularities I reported in 2001 and the retaliation I have suffered since then.

Despite my communications to the new Board, beginning in April of that year, I was still waiting for a substantive response.

In my message to CDP Cassa Depositi e Prestiti, I presented a documented history of the Flinto Case, including the investigative book published in Italy (Eni: The Parallel State), the court rulings, and the questions raised at Eni's Annual General Meetings by critical shareholder Mauro Meggiolaro, representing Fondazione Finanza Etica.

📌 What was I requesting?

That Eni recognize my case as a new whistleblowing report, commission an investigation into the reported misconduct, place the investigation under the supervision of its oversight body, and allow independent monitoring by Fondazione Finanza Etica.

My request also sought clarification of the circumstances surrounding my dismissal from Agip do Brasil in August 2001 and the retaliation I have reported suffering over the years.

Only after such an investigation should the Board address the critical shareholder's questions, which had remained without satisfactory answers.

🔷 Four days later, CDP Cassa Depositi e Prestiti demanded explanations from Eni!

On September 18, Manuela Sabbatini, Chief Audit Officer of CDP Cassa Depositi e Prestiti, forwarded my communication to Eni, bringing it to the attention of Stefano Speroni, the company's senior legal executive.

She requested information about the actions Eni had taken, in accordance with its internal policies, in response to the communications received from the whistleblower.

📌 And how did Eni respond?

On October 9, 2020, Stefano Speroni sent a written response to CDP Cassa Depositi e Prestiti, addressed to Manuela Sabbatini and another professional identified in the correspondence as Francesca.

At the time, Eni's audit structure also included Marco Petracchini, Chief Audit Officer, and Francesca Cottone, Vice President – Spot & Fraud Audit and Whistleblowing, reporting to Petracchini.

Instead of presenting the findings of an independent investigation into the misconduct reported in 2001 and the retaliation I have suffered, Speroni's response focused primarily on four arguments:

1️⃣ My dismissal: According to Eni, the Brazilian courts had upheld the legitimacy of my dismissal from Agip do Brasil in August 2001.

2️⃣ The first lawsuit: The company referred to the civil defamation proceedings it had initiated against me over communications I had sent to Eni, institutions, and third parties.

3️⃣ My public statements: Speroni portrayed my initiatives, including ENI'S WAY, as part of a defamatory campaign against the company and its executives.

4️⃣ The second lawsuit: Eni referred to the proceedings initiated in 2017, also concerning my public statements, attributing to them the intention of damaging the company's reputation.

🔷 A familiar Corporate Narrative!

The response contained striking similarities to the arguments presented by Marco Petracchini in his November 2016 letter to the AIIA | Associazione Italiana Internal Auditors, and subsequently repeated by Eni in its official responses to the critical shareholder's questions at the 2017 Annual General Meeting.

The pattern of Eni's "Corporate Narrative" remained unchanged: rather than addressing the misconduct originally reported and the alleged retaliation, the company focused its arguments on the whistleblower's conduct, initiatives, and reputation in an effort to discredit him.

But CDP Cassa Depositi e Prestiti had not requested an assessment of my reputation. It had requested information about the actions Eni had taken!

And that raises two fundamental questions:

📌 Did Eni provide CDP Cassa Depositi e Prestiti with evidence of an independent, impartial, and transparent investigation into the reported misconduct?

📌 Did CDP Cassa Depositi e Prestiti consider the company's explanations satisfactory?

The documents establish that CDP Cassa Depositi e Prestiti requested clarification and that Eni responded. They do not, however, reveal how CDP Cassa Depositi e Prestiti assessed that response.

🔴 INSTEAD, ENI SHOULD AUTHORIZE A TRULY INDEPENDENT, IMPARTIAL, AND TRANSPARENT INVESTIGATION INTO THE FLINTO CASE!

🔷 NEXT EPISODE: WHEN THE ITALIAN EMBASSY REQUESTED EXPLANATIONS FROM ENI!

❎ Learn more:

1️⃣ Correspondence between CDP Cassa Depositi e Prestiti and Eni — September and October 2020:
🔹 Original document in Italian
🔹 English translation

📌 NOTE: Both Manuela Sabbatini and Lucia Calvosa blocked my LinkedIn profile after being tagged in previous ENI'S WAY posts.

As a result, I can no longer tag either of them in this publication.

Their decision does not change the documented facts or the questions that remain unanswered.

Ep108 - When Italy’s Presidency questioned Eni

📅 November 25, 2018 | Rome, Italy

🔷 The Flinto Case reached the Presidency of the Italian Republic (Palazzo del Quirinale). And Eni had to prepare a response!

On November 21, 2018, I sent a message to the Italian Presidency, describing my long struggle against Eni and requesting attention to the allegations I had been raising since 2001.

Four days later, on November 25, Simone Guerrini, from the Italian Presidency, forwarded my message to Claudio Granata, an Eni executive, asking:

“Do you know this case?”

📌 Eni's internal reaction is revealing.

On November 25, 2018, at 11:27 p.m., Granata forwarded the message to Alberto Piatti, copying Francesco Gattei and Marco Bollini, stating:

“They are asking us for a briefing note to understand the case. We need to prepare one.”

🔷 This was not just another message I had sent to the company. It was the Presidency of the Italian Republic requesting explanations!

And there was something I already knew very well: Eni's “corporate narrative,” identified in Marco Petracchini's 2016 letter to AIIA and repeated, in its essential arguments, in the company's 2017 responses to a critical shareholder.

The documents confirm that the Italian Presidency's request reached Eni and prompted an internal reaction.

But what explanations actually reached the Presidency? Did Eni conduct an independent investigation, or did it once again rely on the narrative used against the whistleblower?

These questions are essential to understanding how the company handled my case before external institutions.

🔴 INSTEAD, ENI SHOULD AUTHORIZE A TRULY INDEPENDENT, IMPARTIAL, AND TRANSPARENT INVESTIGATION INTO THE FLINTO CASE!

🔷 NEXT EPISODE: WHEN CDP BANK DEMANDED EXPLANATIONS FROM ENI!

❎ Learn more:

1️⃣ Correspondence between the Presidency of the Italian Republic and Eni (2018):
🔹 Original in Italian
🔹 English translation

📌 NOTE: Following the publication of this episode, Simone Guerrini and Marco Bollini blocked my LinkedIn profile. As a result, their names could no longer be tagged in the post.

The questions raised in this episode remain unanswered.