Ep106 - What did RINA really investigate?

📅 2017 — Two anonymous complaints, one audit, and unanswered questions!

In the previous episode, I revealed that Eni acknowledged the work generated by my whistleblowing reports in its November 8, 2021 court filing.

Among the events mentioned was a 2017 audit by RINA, concerning Eni's ISO 37001 anti-bribery management system.

BUT THERE IS MORE TO THIS STORY!

📩 TWO ANONYMOUS COMPLAINTS

In 2017, I received two anonymous complaints in Brazil, mailed from the USA and Italy, alleging misconduct involving Eni's operations in the Americas.

Those named included Eni executives Claudio Descalzi, Paolo Scaroni, Massimo Mantovani, Steve Ratcliffe, Corinna Carbone-Stephens, MBA, SHRM-SCP, ICF ACC, Massimo Melandri, Francesca Cottone, as well as Sergio Busato (Saipem), Antonio Del Pino and Ana Maria Girardi (PDVSA)

These were unverified allegations requiring investigation.

❓ WHY WERE THEY SENT TO ME?

Why contact my Institute instead of Eni's whistleblowing channel or Board?

Did the senders distrust Eni's reporting system?

📂 WHAT HAPPENED NEXT?

I forwarded both complaints to Eni and RINA, its ISO 37001 certification body.

RINA audited Eni between May 10 and June 12, 2017, examining compliance procedures, including complaint management.

But auditing procedures is not investigating corruption allegations!

⚖️ A DECLARATION FOUR YEARS LATER!

On June 4, 2021, during the OECD - OCDE NCP Good Offices proceedings in Brazil, Paolo Moretti, CEO of RINA, signed a declaration about the audit.

He confirmed that RINA had requested information from Eni and planned a supplementary audit, partly to provide me with an appropriate response.

The declaration stated that the sampled processes complied with ISO 37001.

BUT HERE IS THE CRUCIAL QUESTION:

❓ IF RINA PLANNED THE AUDIT TO ANSWER ME, WHY DID I NEVER RECEIVE A RESPONSE?

🔍 CERTIFICATION IS NOT AN INDEPENDENT INVESTIGATION!

RINA assessed management procedures. Its report did not establish whether the anonymous allegations were true or investigate the irregularities I reported in 2001.

I believe Eni again relied on an institutional document to support its narrative, as it did with its 2002 Annual Report in the Q&A for its 2017 AGM.

ISO CERTIFICATION CANNOT REPLACE AN INDEPENDENT INVESTIGATION!

🎯 AFTER 25 YEARS, ENI MUST AUTHORIZE A TRULY INDEPENDENT, IMPARTIAL, AND TRANSPARENT INVESTIGATION INTO THE FLINTO CASE!

Including the irregularities I reported in 2001, my dismissal, and the handling of my whistleblowing report.

⚖️ THE TRUTH SHOULD NEVER THREATEN A COMPANY THAT CLAIMS ETHICS AND INTEGRITY AS CORE VALUES!

❎ Learn more:

1️⃣ Anonymous complaint from the USA — 2017

2️⃣ Anonymous complaint from Italy — 2017

3️⃣ RINA Audit Report — June 12, 2017

4️⃣ Paolo Moretti's Declaration — June 4, 2021:
🔹 Italian
🔹 English

Ep105 - Eni really worked hard!

📅 In February 2022, during the Good Offices proceedings conducted by Brazil’s OECD - OCDE National Contact Point (NCP), I gained access to a 34-page court filing submitted by Eni to the Court of Rome in its second lawsuit against me.

I was astonished!

While Eni continued attacking my honor and reputation, its own court filing revealed the considerable efforts my whistleblowing reports had generated within the company.

📄 Here is what Eni told the Court:

“The immense number of communications relentlessly sent over the years by Mr. Flinto certainly required considerable effort and involved a great deal of work by Eni’s employees and executives in managing the entire case, in addition to a significant waste of resources.
And many emails sent by Mr. Flinto to third parties have generated ‘requests for clarification’ addressed to Eni.

Before presenting some of them, it is necessary to reiterate, once again, the company’s complex structure, organized into several autonomous business lines and support functions.

Over the years in which Mr. Flinto disseminated his communications, many Eni departments were involved in preliminary investigations, in-depth analyses, requests for clarification from stakeholders, as well as legal assistance”

🔥 ENI REALLY WORKED HARD!

For years, I had contacted executives, board members, shareholders, and authorities, seeking an independent investigation into my case.

Now Eni itself was acknowledging the impact of those efforts!

🔎 BUT THERE WAS MORE!

Eni also mentioned four requests for clarification involving:

1️⃣ Office of the President of the Italian Republic;

2️⃣ CDP Cassa Depositi e Prestiti, an Eni shareholder;

3️⃣ Italian Embassy in Brazil, in connection with the Italian Ministry of Foreign Affairs;

4️⃣ WBCSD – World Business Council for Sustainable Development.

The filing also mentioned a supplementary audit conducted by RINA, Eni’s ISO 37001 certification body.

📂 AND I HAVE THE DOCUMENTS!

In the next episodes, I will address the RINA audit, explaining why I maintain that it was unrelated to my case.

Then, I will present each of the four requests for clarification, supported by the corresponding documents.

📑 ALL DOCUMENTED!

For 25 years, my goal has remained unchanged: to uncover the truth, restore my honor and reputation, and ensure that corporate commitments to ethics and whistleblower protection are upheld in practice.

🎯 ENI MUST AUTHORIZE A TRULY INDEPENDENT, IMPARTIAL, AND TRANSPARENT INVESTIGATION INTO THE FLINTO CASE!

❓ If Eni mobilized so many departments, executives, employees, and resources to handle my communications, why not investigate the facts independently?

⚖️ THE TRUTH SHOULD NEVER THREATEN A COMPANY THAT CLAIMS ETHICS AND INTEGRITY AS CORE VALUES!

❎ Learn more:

1️⃣ Eni's Court Filing — November 8, 2021 (34 pages):
🔹 Original Italian
🔹 English translation

Ep104 - What Eni's court filing revealed

📅 February 2022 | BRAZILIAN NCP — OECD - OCDE

🔷 What did I discover in the documents Eni submitted to the Court of Rome?

While awaiting the next steps in the Good Offices proceedings conducted by Brazil's National Contact Point (NCP), I received documents from my Italian lawyer revealing information I had never seen before.

Among them was a 34-page court filing submitted on November 8, 2021, by Eni S.p.A. and two of its executives, Marco Petracchini and Massimo Mantovani.

The document was part of the second civil lawsuit filed against me and the Brazilian Institute of Business Ethics in 2017.

I received these documents in February 2022.

🔷 But what made these documents so important?

Over the years, I had read countless statements in which Eni challenged my allegations and my efforts to obtain explanations about what happened in 2001.

This time, however, I discovered something different.

In its court filing, Eni described the consequences of my repeated communications to the company's executives, shareholders, and other stakeholders.

The company also referred to the work carried out by its internal departments and executives in connection with the Flinto Case.

But there was more.

🔷 Eni had submitted correspondence involving requests for clarification from institutions and authorities that had been contacted about my case.

These documents included communications involving representatives of the Italian State, a major Eni shareholder, an international business organization, and institutions connected to internal auditing.

For the first time, I was able to examine how some of these stakeholders sought explanations from Eni — and how the company responded.

📌 Why was this discovery important?

Because these were not merely my allegations or interpretations.

They were documents and statements that Eni itself had chosen to submit to the Italian court.

And they raised questions that deserved closer examination.

🔷 Over the next four episodes, I will examine what Eni told the court, who requested explanations, when those requests were made, and how the company's responses evolved over time.

All based on documents submitted by Eni itself.

NEXT EPISODE: WHAT DID ENI TELL THE COURT ABOUT THE WORK CAUSED BY MY COMMUNICATIONS?

After more than 25 years, one question remains unanswered:

🔴 Why doesn't Eni submit the facts, documents, and different versions of my dismissal to a truly independent investigation?

I am not asking anyone to believe me.

Know the facts.

Examine the supporting evidence.

And reach your own conclusion.

❎ Learn more:

1️⃣ Eni's court filing — November 8, 2021 (34 pages):
🔹 Original in Italian
🔹 English translation

Ep103 - Good faith and reciprocity: My request to Eni

📅 January 31, 2022 | Brazilian NCP — OECD - OCDE

🔷 If Eni imposed conditions for participating in the Good Offices process, why couldn't I request the presence of representatives from its Board of Directors?

This question guided another amendment I proposed to the Work Plan prepared by Brazil’s National Contact Point (NCP).

As explained in previous episodes, Eni had imposed two conditions:

▪️ All communications had to take place exclusively through the mediators, without direct contact between the parties.

▪️ I had to remove publications containing negative publicity about Eni and refrain from launching new campaigns.

I accepted these conditions and took steps to comply with them.

However, I also believed the process should follow principles of good faith and reciprocity.

🔷 I therefore requested that Pietro Guindani and Raphael Vermeir CBE, members of Eni’s Board Control and Risk Committee, be invited to participate as “observers.”

My request was incorporated into item 11.A of the sixth draft Work Plan, dated January 31, 2022, forwarded to Eni.

It referred to Chapter IV of the "G20/OECD Principles of Corporate Governance", concerning stakeholders’ role in corporate governance.

📌 Why did I consider their presence important?

The Flinto Case involved documented questions about the handling of my 2001 whistleblowing reports, Eni’s internal oversight mechanisms, and the different versions provided by the company regarding my dismissal from its Brazilian subsidiary.

I believed their presence could help bring these matters to the attention of Eni’s corporate governance structures.

🔷 I did not ask them to act as mediators or negotiators — only as observers.

The Work Plan allowed observers to attend meetings without speaking, subject to confidentiality requirements.

My request was not a condition for participating in mediation, but a proposal to strengthen dialogue and transparency.

Its inclusion in the draft did not mean Eni had accepted it or that the Board members had attended any meetings.

Another important issue remained: the proposed mediation schedule.

🔷 NEXT EPISODE — NOVEMBER 2, 2026: WHAT ENI’S COURT FILING REVEALED!

After more than 25 years, one question remains unanswered:

🔴 Why doesn't Eni submit the facts, documents and different versions of my dismissal to a truly independent investigation?

I am not asking anyone to believe me.

Know the facts.

Examine the supporting evidence.

And reach your own conclusion.

❎ Learn more:

1️⃣ Good Offices Work Plan — Sixth Draft (January 31, 2022), incorporating my proposed amendments to the mediation agenda (Portuguese and English versions)

Ep102 - Eni’s whistleblowing under scrutiny

📅 January 31, 2022 | Brazilian NCP — OECD - OCDE

🔷 What happens after a company receives a whistleblowing report? Who investigates it, and who receives the findings?

Following my preliminary meeting with the mediators, I proposed expanding the agenda of the OECD Good Offices process conducted by Brazil’s National Contact Point (NCP).

The NCP’s initial proposal addressed Eni’s Responsible Business Conduct practices, including protection of whistleblowers’ identities.

I considered this important, but insufficient for the Flinto Case.

🔷 Crucially, I based my proposed expansion on the whistleblowing procedures described on Eni’s own official website — not on standards I had invented.

My proposal was incorporated into item 10(a) of the sixth draft Work Plan, dated January 31, 2022, and forwarded to Eni.

The expanded agenda covered:

▪️ Management, analysis, and handling of whistleblowing reports;

▪️ Investigations and their findings;

▪️ Reporting findings to internal cross-functional bodies;

▪️ Reporting to senior management and the Board of Directors.

🔷 Most importantly, these stages were to be examined in relation to the facts and documents I submitted in Specific Instance No. 04/2020.

My question was straightforward:

📌 How had Eni applied its publicly described procedures to the reports I submitted in 2001?

A written policy does not, by itself, prove that it works in practice.

The inclusion of my proposal in the draft did not mean Eni had approved it or that substantive mediation had begun.

I also requested the participation of two members of Eni’s Board Control and Risk Committee as observers.

🔷 NEXT EPISODE: WHY DID I REQUEST THEIR PARTICIPATION?

After more than 25 years, one question remains unanswered:

🔴 Why doesn't Eni submit the facts, documents and different versions of my dismissal to a truly independent investigation?

I am not asking anyone to believe me.

Know the facts.

Examine the supporting evidence.

And reach your own conclusion.

❎ Learn more:

1️⃣ Good Offices Work Plan — Sixth Draft (January 31, 2022), incorporating my proposed amendments to the mediation agenda (Portuguese and English versions): https://lnkd.in/dvAU32ez