Dear Mrs. Sanda Ojiambo,
The conduct of the UN Global Compact Integrity Department – in relation to my allegations of systematic and egregious abuses, against the Italian oil giant Eni (a “Global Compact LEAD” company), dated January 25, 2023, due to “attacks” on my name, honor, and reputation – directly violates the “Integrity Measures Policies” of the UN Global Compact.
This policy states that: “The Global Compact Office or a Local Network should only proactively raise a matter under the dialogue facilitation process where there has been an admission by an authorized company representative or a finding of guilt by a competent court or other body relating to a matter that meets the definition of systematic or egregious as set out in the Integrity Measures Policy and FAQs”.
Note that a competent court in Brazil handed down a sentence that: “there was a Code of Ethics at Eni, there were irregularities and illegal activities in the Brazilian subsidiary of Eni and which Mr. Flinto reported to the company's internal channels, as is imperative in the code itself”. Therefore, my role as a “whistleblower” was acknowledged and admitted, proven and declared by the Brazilian justice system.
However, during the AGM 2017, Eni's Board of Directors stated that: “Contrary to what Mr. Flinto believes [...] The former employee was dismissed along with other actors of illicit behavior, for reticence, for having violated the obligation of confidentiality and for trying to instrumentally use ENI's Code of Ethics to obtain personal advantages of the company”.
And, to give credibility to this fallacy, Eni stated at the AGM 2017 that the result of this investigation had been published in the “Eni 2002 Balance Sheet”. However, in this official company document, there is not a single line about me. And there couldn't be! And that’s because Eni never carried out “due diligence” into my case. Not even during the “Good Offices”, offered by the NCP Brazil, in the period from 2020 to 2022!? It's a behavior that disregarded and neglected the guidelines of the “OECD Due Diligence Guidance for Responsible Business Conduct” that Eni boasts to the market that it “accepts” and “follows”!?
In this sense, as my allegations against Eni are “fully proven” (see file) – including the documents transferred in 2022, under Brazilian legislation, by the state-owned Petrobras, a company that purchased Eni’s Brazilian assets in 2004 – the Global Compact Integrity Department needs to handle my case in accordance with the Integrity Measures Policy itself:
1. If an allegation of systematic or egregious abuse is found not to be prima facie frivolous, the Global Compact Office will contact the participating company concerned, requesting:
a) written comments, which should be submitted directly to the party raising the matter, with a copy to the Global Compact Office;
b) that the Global Compact Office be kept informed of any actions taken by the participating company to address the situation which is the subject matter of the allegation.
2. The Global Compact Office would be available to provide guidance and assistance, as necessary and appropriate, to the participating company concerned, in taking actions to remedy the situation that is the subject of the matter raised in order to align the actions of the company with its commitments to the Global Compact principles.
For all these reasons, I ask for your help, as CEO & Executive Director of the UN Global Compact, so that the largest global initiative for “Responsible Business Conduct” can honor its own “Integrity Measures Policy”, thus, safeguarding the reputation, integrity, and good efforts of the UN Global Compact and its participants in relation to transparent means to deal with credible allegations of systematic or egregious abuse of the general objectives and principles of the UN Global Compact.
I await your response with great expectation.
Best Regards.
Douglas Linares Flinto
Chairman & CEO
Brazilian Business Ethics Institute
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