Calculated and conscious attitudes

During these nearly 24 long years, the actions of the Italian oil giant Eni were intentionally malicious, cruel, and unjust, always aimed at causing me harm and suffering. These actions reflect a complete lack of empathy and reveal a degradation of ethical standards. In a calculated and deliberate manner, Eni acted with the purpose of harming me, completely disregarding the values of respect, integrity, and justice, as well as its corporate commitments, including its Code of Ethics, and international commitments "accepted" and "followed" by the company, such as the "OECD Guidelines for Multinational Enterprises", the "UN Guiding Principles on Business and Human Rights", and the "Global Compact".

✅ Learn more about my nearly 24-year-long journey to reclaim and restore my name, honor, and reputation - which have been systematically undermined by Eni through ongoing retaliation, including three SLAPP-style lawsuits filed in Italy in 2010, 2017, and 2022, respectively: 

1) "Fully proven facts known to the Board of Directors of Eni";

2) "Chronology of Facts" (2001 to 2022).

Chief Legal Officer of Eni: Unanswered Questions!

Last week, something curious caught my attention: the Chief Legal Officer of the Italian oil giant Eni, Stefano Speroni, created a LinkedIn profile and, shortly after, accessed my profile.

Why does this matter? Because for a decade now, I have been actively publishing about my nearly 24-year-long battle to reclaim and restore my name, honor, and reputation, which have been systematically undermined by Eni since my unjust dismissal from its Brazilian subsidiary after I reported wrongdoing - strictly in line with the words and spirit of the company’s Code of Ethics.

Over all these years, I have reached out to five different compositions of the company's Board of Directors (in 2002, 2009, 2014, 2020, and 2023) under the leadership of three different CEOs: Vittorio Mincato, Paolo Scaroni, and Claudio Descalzi. Additionally, Mauro Meggiolaro, a critical shareholder of Eni, has brought my case forward for discussion in four Shareholders’ General Meetings (in 2017, 2018, 2020 and 2021). In the 2018, despite positioning itself as our "mediator", the company never agreed to participate in a "mediation meeting". Eni adopted a similar stance in 2020 when it took part in the Mediation Agency of Rome - following an order from a judge of the Civil Court in the Italian capital - and again in 2023 during the "Good Offices" offered by the Brazilian NCP in response to my complaint regarding Eni’s non-compliance with the OECD - OCDE Guidelines for Multinational Enterprises.

As if that were not enough, I am currently facing three lawsuits with clear SLAPP (Strategic Lawsuit Against Public Participation) characteristics, filed by Eni in 2010, 2017, and 2022 - two in the civil sphere and one in the criminal sphere. All of these cases are for alleged "defamation" and "slander".

The fact that Eni’s Chief Legal Officer created this profile and accessed mine is a clear indication that the Italian oil giant is well aware of the reputational impact of my exposure and the growing reach of my story. If the company truly honored the commitments it proclaims in its Code of Ethics and the international agreements it "claims" to "follow", it would not need to resort to systematic retaliation, including three hashtag#SLAPP lawsuits, in an attempt to discredit, intimidate, and silence me.

The truth may be uncomfortable, but it must be told!

Finally, some questions remain unanswered: Does the Chief Legal Officer’s visit to my LinkedIn profile have anything to do with my proposal for an amicable settlement - a request made by the company itself in November 2020 through the highest-ranking Italian authority in Brazil, the Italian Ambassador, which, incredibly, remains unanswered by Eni? Or is this a sign of yet another act of "new retaliation" that Eni is planning against me?

Time will tell… And you will hear about it here!

OPEN LETTER to the CEO UN Global Compact

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

 

Read more: 

a) Whistleblowing Report to the UN Global Pact against Eni 

Eni and the practices of ethics-washing

How is it possible for an Independent Non-executive Director, Lead Independent Director, and Chairman of the Control and Risk Committee of the Italian oil giant Eni to not fulfill the role of "Guardian of Ethics," neglecting and disregarding the commitments made by the company, not only the principles enshrined in Eni's Code of Ethics but, more importantly, the international commitments that the company proclaims to the market and its stakeholders that it "accepts" and "follows," such as the "OECD Guidelines for Multinational Enterprises", the "United Nations Guiding Principles on Business and Human Rights", and principles 01 and 02 of the Global Compact? 

Despite the facts presented by me being fully proven, Eni is insisting on not conducting the necessary "due diligence" of my case to finally demonstrate, after 23 long years, that I was "unfairly" dismissed in "retaliation" by the executives I had reported, including directors of Eni's Brazilian subsidiary.

Read more:

1) "Fully proven facts known to the Board of Directors of Eni"

2) "Chronology of Facts" (2001 to 2022)

Eni: Violation of Human Rights (Art 12 - UDHR)

To
Interministerial Committee for Human Rights (CIDU)
Mrs. Sabrina Ugolini
President
Italy

 

Subject: Eni - Violation of Human Rights (Art 12 - UDHR)

  

Dear Mrs. Sabrina Ugolini,

A very important fact that needs to be noted by CIDU in relation to the "3rd version" about my dismissal from AGIP Brazil (former Brazilian subsidiary of Eni). Note that there are only two possibilities for the content of Eni's presentation - in the AGM 2017 - regarding the "3rd version" of my dismissal: either the version is "true" or the version is "false".

I have prepared a "new material" (see in the file below) so that you can analyze the strategy that Eni's executives has been using to handle my case: "a systemic imposition of instrumentally engineered retaliation and victimization - with attacks on my honor and reputation - that distorts and manipulates the truth to exempt itself from its own responsibility regarding all the damage I have suffered over these more than 21 long years".

This document fully proves that I am not the "villain" of this story, but the main "victim", despite having complied with Eni's Code of Ethics when I whistleblowing fraud and acts of corruption in AGIP Brazil with deviations million dollars a year. Therefore, I am the whistleblower, as recognized by the Labor Court of Brazil!

For this reason, I ask CIDU to request "clarifications" from Eni's Board of Directors on this situation, which is directly violating the commitments assumed by the company, whether corporate commitments or international commitments such as the "UN Guiding Principles on Business and Human Rights" (Principle 4: The nexus between the State and companies), especially that the Italian government is an adherent nation. 

And, because of this Principle 4 (UNGP 31), I request also that Italian government - as the "controlling shareholder” of Eni - require the company's Board of Directors to finally carry out a "due diligence" on my case in the light of the “chronology of the facts” (see in the file below) which was sufficiently capable of “reconstructing the events” about the “actions” and “omissions” of Eni’s Brazilian subsidiary and of Eni itself to my disadvantage.

I place myself, from now on, at your disposal, and I look forward to your contact.

Best Regards.

Douglas Linares Flinto
Chairman & CEO
Brazilian Business Ethics Institute

Read more:

1) Fully proven facts known to the Board of Directors of Eni

2) Chronology of Facts (2001 to 2022)

Eni & ILO Convention 190

Dear Mrs. Maria Teresa Bellucci (Vice Minister of Labour of Italy),

Italy is one of the first nations to “ratify” Convention 190. Therefore, the provisions of Convention 190 are “binding”, meaning they are “mandatory” for the Italian government, which is the “controlling shareholder” of the Italian oil giant Eni.

Convention 190 also applies to employees and former employees. Moreover, we can assert that “retaliation” (such as unfair dismissal, failure to protect whistleblowers as mandated by the Code of Ethics, SLAPP suits, and attacks on honor and reputation) constitutes a form of “harassment”.

The files below contain facts and full proofs of practices contrary to ILO Convention 190 imposed by Eni over a span of 23 long years against me.

I would appreciate information on what steps I can take to ensure that the Italian government (and Eni) comply with what is stipulated in Convention 190 in my favor.

I await your response as soon as possible.

Best Regards.

Douglas Linares Flinto
Founder & CEO
Brazilian Business Ethics Institute

Read more:

1) "Fully proven facts known to the Board of Directors of Eni"

2) "Chronology of Facts" (2001 to 2022)

Eni & Me: a story of incredible 23 years!

Dear Mr. Raphael Vermeir,

Today marks 23 long years since I was unfairly fired from Eni's Brazilian subsidiary in proven “retaliation”. And this is because, in accordance with Eni's Code of Ethics, I reported a “million-dollar scheme” involving, including, members of the Board of Directors of Agip Brazil.

In all these years, I have come into contact with five different compositions of the Board of Directors of Eni (2002, 2009, 2014, 2020 and 2023) under the management of three different CEOs. My intention has always been to raise awareness and convince the Italian oil giant to carry out the necessary "due diligence" of my case. But, instead of doing what needed to be done, Eni began to punish me for having had the boldness and courage to confront its executives with the truth of the facts, including three SLAPP suits.

Today I make new contact, this time with the “Control and Risk Committee” of the Eni Board of Directors of which you are the Chairman.

I would like you to be able to "require" Eni's Internal Audit Department so that, finally, "due diligence" is carried out on my case through the attached documents that make full proof that I am the “victim” of this story having my executive career destroyed and my retirement ripped out of my hands.

As an independent non-executive director to the Control and Risk Committee, you have an “ethical obligation” to definitely handle this case.

I hope you do the right thing!

Read more:

1) "Fully proven facts known to the Board of Directors of Eni"

2) "Chronology of Facts" (2001 to 2022)

The 3rd SLAPP suit against me!?

This is the sentence from the third SLAPP suit that the Italian oil giant Eni has filed against me. If two SLAPP suits in the civil sphere weren't enough, now Eni is filing a SLAPP suit in the criminal sphere. All these cases involve "slander" and "defamation", which are typical of a "SLAPP suit".

Now, instead of Eni using this kind of "retaliation" against me simply because I had the audacity and courage to confront the Board of Directors and top executives, the company should fulfill its commitments, both corporate and, especially, international commitments, and conduct the necessary "due diligence" on my case to prove that I am not the "villain" in this story as Eni wants its stakeholders to believe. Quite the opposite!

During these almost 23 years of struggle to restore my name, honor, and reputation, which have been systematically attacked by Eni, my story is an example of how powerful corporations use the justice system to punish "whistleblowers".

Read more: Judgment of the SLAPP suit (Criminal) against Me  

Eni & Whistleblowers

Are you an employee of the Italian oil giant? 

Are you thinking about complying with Eni's Code of Ethics and making a whistleblowing report? 

Be careful! I was also a whistleblower at the company's Brazilian subsidiary and, incredibly, I have been trying for almost 23 long years to recover and restore my name, honor, and reputation, which have been systematically tarnished by Eni. 

Therefore, I make the words of a song by Michael Jackson my own: 

"All I want to say is that they don't really care about us".

 

Eni & CSDDD

Wow! CSDDD will catch up with the Italian oil giant Eni! 

Will the company finally carry out "DueDiligence” on my case? 

Time will tell! 

Read more about "EU Corporate Sustainability Due Diligence Directive (CSDDD) in this LINK. 

Eni x CSDDD: due diligence on my case!

I have already been waiting for 22 long years, and if necessary, I will continue to wait until 2027 to demand from the Italian courts that Eni finally carry out due diligence on my case!

Read more:

1) "Fully proven facts known to the Board of Directors of Eni": 

2) "Chronology of Facts" (2001 to 2022): 

I’m the founder and CEO of the Brazilian Business Ethics Institute which, for over 20 years, has been promoting Ethics in Brazil in the business and student environment. In fact, we are the "only" institution in my country that promotes the topic of Business Ethics to students, the leaders of tomorrow's companies… And what drove me to found this institution? My story with the Italian oil giant Eni!

It's been more than 22 long years that I've tried to rescue and restore my name, honor and reputation that were destroyed by Eni.

In all these years, five different Boards of Directors, under the management of three different CEOs (2002, 2009, 2014, 2020 and 2023), were contacted by me. But Eni doesn't respond to my persistent messages!

Furthermore, a journalist and "critical shareholder" of the company took my case to be discussed at four Shareholders' Meetings (2017, 2019, 2020 and 2022), but, even though he positioned himself as our "mediator", Eni never agreed to participate in a "mediation meeting".

As if that wasn't more than enough, two other Italian journalists published my story in the first investigative book that told the "problems" in Eni's management for 25 years. The book, entitled "Eni: The Parallel State", became a bestseller in Italy in just a few months.

You can learn more details about this story of "David" against "Goliath" in the attached files that demonstrate Eni's "attacks" against me that are totally contrary to "corporate commitments" (such as the Code of Ethics and Eni’s Declaration on Human Rights) and the "international commitments" that Eni trumpets to the entire world that it "follows" and "accepts": "OECD Guidelines for Multinational Enterprises", "UN Guiding Principles on Business and Human Rights", and the UN Global Compact .

Despite the facts being fully proven, Eni never carried out "Due Diligence". Quite the opposite! The company's strategy, in addition to using the courts to punish me, as I am a defendant in three "SLAPP lawsuits", is: “systemic imposition of retaliations with attacks on my name, honor and reputation, and victimization instrumentally architected to exempt Eni from its own responsibilities".

I would like you to tell my story, not because this story is unique, but because it is not!

Read more:

1) "Justification of Mr. Douglas Flinto to the major shareholders of Eni - Addition of new item to the AGM 2023 Agenda (May 10, 2023)"

2) "Chronology of Facts" to describe the events between ENI and DLF from 2001 to 2022

Eni it doesn't do what it says!

In my case, in more than 22 long years, the Italian oil giant Eni never complied with the words and spirit of the Code of Ethics because it never protected the whistleblower, quite the opposite! The company has been unfairly attacking my name, honor and reputation. 

And what's even worse! Eni, disregarding and neglecting the international commitments that the company claims to the market to “accept” and “follow”, never carried out the necessary "due diligence" on my case, even though I had contacted "five" different Boards of Directors under the management of "three" different CEOs (2002 - Mr. Vittorio Mincato, 2009 - Mr. Paolo Scaroni and 2014, 2020, 2023 - Mr. Claudio Descalzi). 

Furthermore, Mr. Mauro Meggiolaro, a "critical shareholder" of Eni took my case to four shareholder meetings (2017, 2018, 2020 e 2021) and, even though he positioned himself as our "mediator", Eni never agreed to participate in a "mediation meeting". 

The company had similar conduct during the "Good Offices" offered by the NCP Brazil, disregarding and neglecting the guidelines of the "OECD Due Diligence Guidance for Responsible Business Conduct", and refusing to carry out "due diligence" and make a "reparation" consistent with the adverse impacts that were fully proven.

This is Eni's Way!

OECD WPRBC: Thank you very much for your help!

After requesting help from the Chair of the "OECD Working Party on Responsible Business Conduct" (Mrs. Christine Kaufmann), NCP Brazil removed a paragraph from the Final Declaration of the Special Instance nº 04/2020 - in which I appear as Submitter and, the Italian oil giant Eni, as Respondent - that presented a text (demonstrably) untrue and that attacked my name, my honor, and my reputation. However, there is still a long way to go before this Final Declaration is completely “reliable” with everything that was presented and proven by me to NCP Brazil.

That’s because, said document was written in a disorganized manner, difficult to understand and omitted several important facts - fully proven - which resulted in the decontextualization of a history of almost 22 long years, privileging the Submitter. As if that were not enough, the wording of this document evidences an active, haughty and defensive participation of the NCP Italy in favor of the Respondent, revealing a serious and questionable conflict of interest in this Specific Instance, given that the NCP Italy is part of the “direct public administration” of the Italian government, “controlling shareholder” of Respondent.

Therefore, I will continue to fight, with all legal means at my disposal, for this Final Declaration to be drafted again.

Eni vs OECD Guidelines for Multinational Enterprises

The duly proven “attacks” that Eni unfairly promoted against my honor and reputation (see Doc. 01 and Doc. 02) in 2010 (judicial process) and 2017 (ENI’s AGM), are condemned by the “Universal Declaration of Human Rights” (Article 12).

Eni says it “follows” and “accepts” the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct. 

But what guides this "international commitment" of the Italian oil giant?:

IV. Human Rights 

States have the duty to protect human rights. Enterprises should, within the framework of internationally recognised human rights, the international human rights obligations of the countries in which they operate as well as relevant domestic laws and regulations:

1. Respect human rights, which means they should avoid infringing on the human rights of others and should address adverse human rights impacts with which they are involved.

2. Within the context of their own activities, avoid causing or contributing to adverse human rights impacts and address such impacts when they occur.

3. Seek ways to prevent or mitigate adverse human rights impacts that are directly linked to their business operations, products or services by a business relationship, even if they do not contribute to those impacts.

4. Have a publicly available policy commitment to respect human rights.

5. Carry out human rights due diligence as appropriate to their size, the nature and context of operations and the severity of the risks of adverse human rights impacts.

6. Provide for or co-operate through legitimate processes in the remediation of adverse human rights impacts where they identify that they have caused or contributed to these impacts.

Now, why does Eni, in my case, doesn’t fulfill this “international commitment”?

Eni vs OECD Due Diligence Guidance for RBC

Eni states in its "Declaration of Respect for Human Rights" that it follows the “OECD Guidelines for Multinational Enterprises”.

Therefore, to implement these OECD Guidelines, Eni made use of the “OECD Due Diligence Guidance for Responsible Business Conduct”, which in its preface states that the purpose of this material “is to provide practical support to enterprises on the implementation of the OECD Guidelines for Multinational Enterprises by providing plain language explanations of its due diligence recommendations and associated provisions”, and it also “helps businesses (enterprises) to understand and implement due diligence for RBC as foreseen in the OECD Guidelines”.

In order to conduct business based on the premises, principles, and values of the “RBC”, company executives need to periodically consult this OECD Guide to “recognised that business activities may result in adverse impacts related to corporate governance, workers, human rights, the environment, bribery, and consumers”.

Therefore, in my case, Eni should carry out a "due diligence" according to the facts and the abundant, rich, and robust "supporting documentation" (see Doc. 01 and Doc. 02). The supporting documentation was also unquestionably able to "reconstruct the events" about the actions and omissions of both AGIP Brazil and Eni. And that's because, the duly proven “attacks” that Eni unfairly promoted against my honor and reputation in 2010 (judicial process) and 2017 (ENI’s AGM), are condemned by the “Universal Declaration of Human Rights” (Article 12).

And by proceeding in this way, the company would comply with the guidelines of the OECD Guide itself: “Due diligence is the process enterprises should carry out to identify, prevent, mitigate and account for how they address these actual and potential adverse impacts in their own operations, their supply chain and other business relationships, as recommended in the OECD Guidelines. Effective due diligence should be supported by efforts to embed RBC into policies and management systems, and aims to enable enterprises to remediate adverse impacts that they cause or to which they contribute”.

Why does Eni need to perform a “due diligence” on my case? The OECD Guide answers this question: “Due diligence should help enterprises anticipate and prevent or mitigate these impacts [...]. Effectively preventing and mitigating adverse impacts may in turn also help an enterprise maximise positive contributions to society, improve stakeholder relationships and protect its reputation [...]. An enterprise can also carry out due diligence to help it meet legal requirements pertaining to specific RBC issues, such as local labour, environmental, corporate governance, criminal or anti-bribery laws”.

So, why does Eni does note "honor" its own commitments??

What's hell is this?

Without a doubt, these are the "international commitments" most accepted and followed by multinational companies: "OECD Guidelines for Multinational Enterprises", "UN Global Compact" and the "UN Guiding Principles on Business and Human Rights", all of which reflect the assumptions, principles, and values of Responsible Business Conduct (RBC), which has Business Ethics as its greatest and main foundation.

Note that all these international commitments have one thing in common: none of them are "legally binding", that is, accepting and following these "standards of conduct" is a "purely voluntary" attitude for multinational companies.

Despite this "voluntariness", "adherent" multinational companies end up receiving, at no cost, countless benefits, including and mainly, undeniable "reputational" gains with Stakeholders and Shareholders.

However, many, if not most, of these companies, when participating in a "Specific Instance", do not follow the invaluable guidance of the OECD Due Diligence Guidance for Responsible Business Conduct to verify that, in fact, the company caused (or did not cause), contributed (or did not contribute) to adverse impacts to the detriment of "one single person" (or a community) who raises the allegation of non-compliance with the OECD Guidelines to an NCP around the world, in the hope of receiving some kind of of "reparation" for the "proven" damages and losses suffered.

So we can conclude that many multinational companies will continue to act freely and with impunity! And that's because the Boards of Directors and the C-Levels, hiding behind "voluntariness", are guaranteed not to run any kind of risk against their most valuable asset: the "corporate image".

On the other hand, this absolutely "comfortable" situation is not envisioned when a multinational company is a "signatory" of the UN Global Compact.

Observe carefully what multinational companies may face if they violate any of the 10 Principles enshrined in the UN Global Compact, all in accordance with the Integrity Measures Policy which provides guidance on "Allegations of Systematic or Egregious Abuses":

"Safeguarding the reputation, integrity and good efforts of the UN Global Compact and its participants requires transparent means to handle credible allegations of systematic or egregious abuse of the UN Global Compact's overall aims and principles. The UN Global Compact Office can assist or provide guidance in this regard, by means of the measures described below.  

The purpose of these measures in the first instance always will be to promote continuous quality improvement and assist Participants/Signatories in aligning their actions with the commitments they have undertaken with regard to the Global Compact Ten Principles.

Thus, when a matter is either presented in writing to the Global Compact Office or is raised by the Global Compact Office or a Local Network (active or advanced in status only), the Office will:

• If an allegation of systematic or egregious abuse is found not to be prima facie frivolous or if it is raised by the UN Global Compact or a Local Network, the UN Global Compact Office or Local Network will contact the participating company concerned, requesting:  

1. Written comments, which should be submitted directly to the party raising the matter, with a copy to the UN Global Compact Office or the Local Network (if the matter is raised by the Local Network);
2. That the UN Global Compact Office or the Local Network (if the matter is raised by the Local Network) be kept informed of any actions taken by the participating company to address the situation which is the subject matter of the allegation. If the matter was raised by a third party, the UN Global Compact Office will inform the party raising the matter of the above-described actions taken by the UN Global Compact Office. 

• The UN 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 UN Global Compact principles. The UN Global Compact Office may, in its sole discretion, take one or more of the following steps, as appropriate: 

1. Use its own good offices to encourage resolution of the matter; 
2. Ask the relevant country/regional UN Global Compact Network, or other UN Global Compact participant organization, to assist with the resolution of the matter;
3. Refer the matter to one or more of the UN entities that are the guardians of the UN Global Compact principles for advice, assistance or action;
4. Share with the parties information about the specific instance procedures of the OECD Guidelines for Multinational Enterprises and, in the case of matters relating to the labour principles, the interpretation procedure under the ILO Tripartite Declaration of Principles concerning Multinational Enterprises and Social Policy;
5. Refer the matter to the UN Global Compact Board, drawing in particular on the expertise and recommendations of its business members;
6. As a last resort, after consultation with the UN Global Compact Board, in cases where the alleged abuse is admitted by an authorized company representative or is the subject of a finding of guilt by a competent court of other body, and meets the criteria in the FAQs of a systematic or egregious abuse, delist the company from the UN Global Compact.
   
   If the participating company concerned refuses to engage in dialogue on the matter within three months of first being contacted by the UN Global Compact Office under subparagraph above, it may be regarded as "non-communicating", and would be "identified" as such on the UN Global Compact website until such time as a dialogue commences.
   
   If, as a result of the process outlined above and/or based on the review of the nature of the matter submitted and the responses by the participating company, the continued listing of the participating company on the UN Global Compact website is considered to be detrimental to the reputation and integrity of the UN Global Compact, the UN Global Compact Office reserves the right to "remove" that company from the list of participants and to so indicate on the UN Global Compact website.A participating company that is designated "non-communicating" or is "removed from the list of participants" will not be allowed to use the UN Global Compact name or logo if such permission had been granted.
   
   If the participating company concerned has subsequently taken appropriate actions to remedy the situation that is the subject matter of the allegation and has aligned its actions with the commitments it has undertaken with regard to the UN Global Compact principles, the company may seek reinstatement as an "active" participant to the UN Global Compact and to the "list of participants" on the UN Global Compact website".  

For all the reasons presented here, I suggest that the OECD WPRBC (and the OECD advisory bodies) be "inspired" by the UN Global Compact and present "new guidelines" to the OECD's "Department of Responsible Business Conduct" with the purpose of defining "Integrity Measures Policy" for companies that adhere to the OECD Guidelines and, in this way, drastically reduce the power imbalance between Submitter and Respondent, with the imposition of "penalties" to those multinational companies that commit duly proven systematic or flagrant adverse impacts, for the OECD Guidelines cannot serve only to grant reputational gains to adherent companies, including, of course, the Italian oil giant ENI.