Conflict of Interest #1

Last week, I presented several issues that the Internal Audit Report of Eni's Brazilian subsidiary failed to examine, despite the seriousness of the facts described in my whistleblowing report.

This week, I will present some examples of potential conflicts of interest that, in my view, also should have been identified and examined by a truly independent audit.

The first involves the management structure of the Cuiabá Regional Sales Office itself.

When I submitted my whistleblowing report to Agip do Brasil's Commercial Directorate, the Regional Sales Manager of Rio de Janeiro was a cousin of the Regional Sales Manager of Cuiabá.

During my vacation - precisely when Internal Audit carried out its investigation at the Cuiabá unit - it was the Rio de Janeiro Regional Manager who remained at the branch overseeing its activities.

The Internal Audit Report dated July 26, 2001, describes several operational and commercial irregularities.

However, it neither records nor evaluates the existence of this family relationship, nor does it assess whether it could have represented any risk from the standpoint of audit independence, corporate governance, or conflict-of-interest management.

Naturally, the mere existence of a family relationship does not, by itself, constitute evidence of any wrongdoing.

Precisely for that reason, however, an independent audit should have identified these circumstances, assessed them objectively, and documented its conclusions in a transparent manner.

Such an approach protects not only the company, but also the professionals involved.

The question, therefore, is straightforward:

📌 Shouldn't an independent audit, at the very least, have identified and assessed a family relationship between two managers directly involved in the matters under review?

After twenty-five years, I continue to ask for exactly the same thing:

🔴 that all the documentation be examined independently, impartially, and transparently.

❎ 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)

 

August 1, 2026: 25 years of truth!

On the day marking the 25th anniversary of my dismissal, I am sharing 25 facts that summarize a journey devoted to one simple request: that the documents be examined independently.

1️⃣ Today, August 1, 2026, marks exactly twenty-five years since my dismissal from Agip do Brasil, then the Brazilian subsidiary of the Italian energy giant Eni.

2️⃣ My dismissal came only a few weeks after I reported, in good faith, potential irregularities I had identified at the Cuiabá Regional Sales Office.

3️⃣ At the time, I believed the company would investigate the facts and protect the person who had chosen to do the right thing.

4️⃣ An investigation did, in fact, take place.

5️⃣ Agip's own Internal Audit Report confirms that.

6️⃣ However, it confirmed only part of the facts presented in my whistleblowing report.

7️⃣ A significant portion of the documented evidence contained in my dossier never appeared in the audit's conclusions.

8️⃣ Six days after that report was issued, I was dismissed.

9️⃣ At the time, I believed everything would soon be clarified.

🔟 Twenty-five years later, I am still waiting for an independent review of the documentation.

1️⃣ 1️⃣ Throughout this period, I preserved virtually every document related to the case.

1️⃣ 2️⃣ Letters, emails, audit reports, court decisions, corporate records, statements from public authorities, and official documents gradually became a fully documented chronology.

1️⃣ 3️⃣ My objective has never been to persuade anyone through personal opinions.

1️⃣ 4️⃣ My objective has always been to let the documents speak for themselves.

1️⃣ 5️⃣ Over these twenty-five years, I contacted six different Boards of Directors of Eni.

1️⃣ 6️⃣ I also submitted the documentation to three different Chief Executive Officers (CEOs) of the company: Vittorio Mincato, Paolo Scaroni and Claudio Descalzi.

1️⃣ 7️⃣ I further sought the attention of Brazilian and Italian authorities, as well as international organizations.

1️⃣ 8️⃣ I submitted the documentation to the OECD - OCDE, RINA, Autorità Garante per la protezione dei dati personali (GPDP), and other institutions.

1️⃣ 9️⃣ I also shared it with journalists, organizations representing the Internal Audit profession (The IIA), and corporate governance specialists.

2️⃣ 0️⃣ At no point did I ask anyone to accept my account as true.

2️⃣ 1️⃣ I asked only that the documentation be examined independently, impartially, and transparently.

2️⃣ 2️⃣ Truth does not depend on who presents it.

2️⃣ 3️⃣ It depends on the willingness of those who are prepared to examine it with intellectual honesty.

2️⃣ 4️⃣ After twenty-five years, I continue to make exactly the same request.

2️⃣ 5️⃣ Because companies truly committed to ethics, governance, and integrity should never fear an independent review of their own documents.


🔴 ENI'S WAY — 25 YEARS OF TRUTH

🔹 A quarter of a century later, my request remains exactly the same: let the documents speak for themselves.