The Guardians of Ethics vs. Their Own Ethics

Throughout this series, I have presented several issues that, in my view, should have been examined by the Internal Audit of Eni's Brazilian subsidiary.

But my search for an independent review did not end within the company.

Years later, I submitted a formal complaint to the Ethics Committee of The Institute of Internal Auditors (The IIA Global) concerning Marco Petracchini, then Senior Executive Vice President of Internal Audit (Chief Audit Executive) of Eni and a member of the Board of Directors of the AIIA | Associazione Italiana Internal Auditors.

My complaint alleged possible violations of the IIA Code of Ethics and the International Standards for the Professional Practice of Internal Auditing in connection with his validation of the Agip do Brasil Internal Audit Report.

My complaint was not based on opinions.

It compared specific conduct against the objective requirements established by the IIA's own Code of Ethics and International Standards.

Among other issues, I questioned whether the following fundamental principles had been respected:
🔹 independence;
🔹 objectivity;
🔹 due professional care;
🔹 proper risk assessment;
🔹 adequate documentation of audit conclusions;
🔹 transparent communication of audit results.

The complaint was supported by dozens of documents and pieces of evidence gathered over many years.

At the conclusion of the proceedings, however, the Ethics Committee determined that there were no grounds to establish any ethical violation.
Naturally, I respect that institutional decision.

But I continue to reflect on a question that, in my view, goes beyond my own case.

📌 How should the very institutions entrusted with safeguarding ethics respond when they are asked to examine an alleged violation of their own ethical principles?

This question is not limited to my case.

It concerns everyone who believes that independent internal auditing is one of the essential pillars of corporate governance, integrity, and public trust.

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 Complaint submitted to the Ethics Committee of The Institute of Internal Auditors (IIA Global):

2️⃣ Agip do Brasil Internal Audit Report:
🔹 Original in Portuguese
🔹 English translation

3️⃣ Chronology of Facts for the Reconstruction of the Events

4️⃣ Memorial (1999–2025)

Conflict of Interest #3

In my previous two posts, I presented situations involving family relationships among Regional Sales Managers of Eni's Brazilian subsidiary that, in my view, also should have been examined by Internal Audit.

Today, I present a third example.

When I submitted my whistleblowing report to Agip do Brasil's Commercial Directorate, the company's Commercial Director maintained a personal relationship with another Regional Sales Manager.

That manager's father was the Chief Executive Officer of a major multinational company operating in Brazil.

The same company sponsored the Commercial Director's son in Stock Car racing competitions.

I am not claiming that this relationship influenced any decision.

The mere existence of a personal or institutional relationship does not, by itself, constitute evidence of any wrongdoing.

Precisely for that reason, however, an independent audit should, at the very least, have identified this circumstance and assessed whether it could have represented any risk from the standpoint of corporate governance, decision-making independence, and conflict-of-interest management.

The Internal Audit Report dated July 26, 2001, contains no analysis of this issue.

Nor does it indicate that this relationship was disclosed, assessed, or taken into consideration during the investigation of the irregularities I had reported.
In modern compliance and governance programs, conflicts of interest are not examined because they prove misconduct.

They are examined precisely to preserve the impartiality of decision-making and protect the credibility of internal processes.

The question therefore remains:

📌 Shouldn't an independent audit have identified, documented, and assessed this relationship from the perspective of corporate governance and conflict-of-interest management?

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)