The Service Stations & The front-men

In my previous post, I showed that the Internal Audit Report of Eni’s Brazilian subsidiary confirmed “fictitious invoicing”, destroyed documents and other irregular transactions in Cuiabá.

But one fundamental issue was left out of its conclusions.

In the whistleblowing report submitted to the Commercial Directorate, I stated that the then Regional Sales Manager was allegedly operating two service stations owned by Agip through third parties - the so-called “front men.”

This fact was later recorded in a Public Notarial Declaration by the then President of Sindipetroleo Mt, who confirmed that he had reported it to Agip’s Commercial Director and General Manager of Internal Audit during the investigation conducted in Cuiabá.

Despite this, the report dated July 26, 2001, did not examine:
🔹 who effectively managed the service stations;
🔹 who received the financial proceeds from their operations;
🔹 the links between the formal operators and the regional manager;
🔹 any potential conflict of interest involving the use of company assets.

Months later, another internal document emerged, which I obtained in 2021 under Brazil’s Access to Information Law - applicable to the Brazilian state-owned company Petrobras, which succeeded Eni in the ownership of its Brazilian assets.

On February 7, 2002, Internal Audit itself informed the CEO of Agip do Brasil that the former regional manager did not appear in the official documentation of the two service stations, as would be expected in an operation conducted through third parties.

The memorandum was produced six days after I invoked the Ethics Committee and reiterated that the irregularities also extended to the operational area, despite the dismissal of the Regional Manager and four of his seven sales executives.

The question is unavoidable:

📌 If the operation of these service stations had been reported in June 2001, why was it neither investigated nor recorded before my dismissal?

And furthermore:

📌 Why did Internal Audit address the issue only months later, after a new report to the Ethics Committee?

The presence of third parties in the documents does not, by itself, prove who the ultimate beneficiary was.

But it represented a risk that an independent audit should have identified, investigated and documented.

The problem is not only what the report found.

The problem is everything it failed to examine.


✅ Learn more: Read the documents:

1️⃣ Internal Audit Report:
🔹 Portuguese
🔹 English

2️⃣ Public Notarial Declaration by the then President of Sindipetróleo-MT
🔹 Portuguese
🔹 English

3️⃣ Internal Audit Memorandum to the CEO (Feb 7, 2002)
🔹 Portuguese
🔹 English

The audit confirmed irregularities, but...

In my previous post, I presented the Agip do Brasil Internal Audit Report, dated July 26, 2001, prepared after my whistleblowing report and just six days before my dismissal.

Today, I begin examining its contents.

The report analyzed sales made by the Cuiabá unit to TELEMAT (Brasil Telecom) and recorded serious findings:
🔹 vehicle entry and exit control records had been destroyed;
🔹 powers of attorney and transportation responsibility documents were missing;
🔹 invoice receipt stubs contained illegible signatures;
🔹 contractual documents had been misplaced;
🔹 members of the commercial department confirmed “fictitious invoicing”;
🔹 other similar transactions had also occurred;
🔹 one of the companies examined was under investigation by the Fuel Parliamentary Commission of Inquiry.

The document confirmed that invoicing issued in TELEMAT’s name was used to reduce the price of fuel intended for a service station.

It also recorded similar transactions involving 260,000 liters of gasoline, worth R$359,469.50, as well as the sale of millions of liters of fuel to a carrier linked to service stations that did not purchase directly from Agip.

Therefore, these were not merely administrative failures.

The report confirmed irregular commercial transactions, weak internal controls, destroyed or missing documents, and practices known to members of the commercial department itself.

But my whistleblowing report was not limited to TELEMAT.

My dossier, containing more than 200 pages, described conflicts of interest, commercial relationships between employees and customers, company-owned service stations operated through third parties, and the transportation of Agip products by tanker trucks linked to managers.

These facts do not appear in the report’s conclusions.

The question remains:

📌 How could an audit confirm “fictitious invoicing,” destroyed documents and similar transactions - and still fail to investigate all the facts presented by the whistleblower?

In the next posts, I will show some of the main issues that were left out of this report.

For twenty-five years, I have not asked Eni to accept my account.

🛑 I have asked only that it compare my whistleblowing report and the existing documents with what Internal Audit examined - and with what it failed to examine.


✅ 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)