OUR

MISSION

We are an energy company.

We concretely support a just energy transition,

with the objective of preserving our planet

and promoting an efficient

and sustainable access to energy for all.

Our work is based on passion and innovation,

on our unique strengths and skills,

on the equal dignity of each person,
recognizing diversity as a key value for human development,

on the responsibility, integrity and transparency of our actions.

We believe in the value of long-term partnerships

with the Countries and communities where we operate,
bringing long-lasting prosperity for all.

The United Nations 2030 Agenda for Sustainable Development, presented in September 2015, identifies
17 Sustainable Development Goals (SDGs) that represent common objectives of sustainable development
in today's complex social challenges. These objectives constitute an important reference for the
international community and for Eni in conducting its activities within the Countries in which it operates.

The association of the contents of the Code of Ethics with the SDGs was carried out taking into consideration the document
"Business reporting on the SDGs - An Analysis of the Goals and Targets" (published by GRI and UN Global Compact).
 CO
DE
OF
ETH
ICS
Approved by the Board of Directors
of Eni SpA on March 18, 2020

OUR COMMITMENT

E ni is committed to ensuring respect for internationally recognized Human Rights in its own activities
and those of its commercial partners, in line with the United Nations Guiding Principles on Business
and Human Rights (UNGP) and with the OECD Guidelines for Multinational Enterprises.
Eni's commitment to comply with the International Human Rights Treaties and Standards is expressed
in the Eni’s Statement on respect for Human Rights and is integrated into other fundamental documents
of the company's internal regulatory system. Eni's approach to Human Rights is further confirmed in the
Global Framework Agreement on International Industrial Relations and on Corporate Social Responsibility
renewed in 2019 and in compliance with the Voluntary Principles on Security and Human Rights.

Eni is determined to positively contribute to the achievement of the Sustainable Development Goals
(SDGs), to support a low-carbon and socially fair energy transition, and is one of the signatories of the
Paris Pledge, supporting the objectives of the Paris Agreement.
INDEX
INTRODUCTION
The values that guide our choices 5
Our responsibilities 6

WE RECOGNIZE AND PROTECT THE VALUE OF ALL OUR PEOPLE

We promote the health, safety and security of our people 12
We support the creation of an ethical work environment 14
We recognize the role of diversity and encourage cultural pluralism 16
We value the professionalism of our people 17

WE ESTABLISH RESPONSIBLE RELATIONS WITH OUR STAKEHOLDERS

We manage responsibly our relations with suppliers, commercial and industrial partners 20
We manage relations with customers and consumers transparently 21
We ethically create value for our shareholders 22
We cooperate transparently with authorities and institutions 23
We collaborate with the communities in which we operate to create shared value 24
WE COMMIT TO COUNTERING CLIMATE CHANGE AND ITS EFFECTS
We support a low-carbon and socially fair energy transition 28
We safeguard the environment and optimize the use of energy resources 29

WE OPERATE WITH INTEGRITY

We prevent and manage conflicts of interest 32
We fight corruption 34
We assure transparency and accuracy of information to our stakeholders 36
We operate in the market with loyalty and fairness, in compliance with the applicable regulations 37
We protect our stakeholders’ privacy rights 38

WE RESPECT AND PROTECT OUR COMPANY’S ASSETS

We use our corporate assets correctly 42
We protect corporate information and intellectual property 43
We protect our reputation 44

PUTTING OUR CODE TO ACTION 46

 INTRO
DUC
THE VALUES THAT GUIDE TION
OUR CHOICES

Our values tell who we are and what we believe in, guide our actions, define our commitment
and orient both our behavior and that of our stakeholders.

OUR VALUES APPROACH

Integrity We carry out our daily activities with responsibility, equity, fairness and good faith,
respecting internal and external regulations.

Respect We operate with respect for human dignity and Human Rights and we require the
and protection same commitment from all our partners. We ensure an inclusive work environment
of Human Rights that values uniqueness and diversity as fundamental resources for the development
of humanity.

Transparency We are attentive to the needs and expectations of our stakeholders. We are
committed to be engaged in continuous dialogue with our counterparts, providing
them clear, complete and truthful information, being aware that sharing objectives
and results is essential to maximize value and reduce business risks.

Promotion We work to support an efficient and sustainable access to energy resources that
of development protects the needs of future generations and respects Human Rights, the
environment and society as a whole. We favor an inclusive development that can
generate shared and lasting value in all territories in which we operate by working
alongside the communities.

Operational We guarantee the efficiency and integration of our activities, minimizing risks and
excellence creating opportunities along the entire value cycle.

Teamwork and We work with passion, believe in team spirit and value everyone's skills. We
collaboration recognize collaboration as a foundational element to building solid and lasting
relationships, through which we can express our potential and achieve corporate
objectives.

Innovation We believe that innovation is at the basis of personal and business growth.
We are committed to acquiring cutting-edge technological skills in order to develop
innovative ideas and improve our daily activities, contributing to the progress of civil
society by increasing safety and reducing environmental impact.

5
ENI CODE OF ETHICS

OUR
RESPONSIBILITIES

T he Eni Code of Ethics, inspired by the ideal

of cooperation amongst people, respects the
individual and constitutes a guide in
decision-making and action-taking that are
consistent with our culture of responsibility,
legality, transparency and long-term value
creation for all our stakeholders, by contributing
to sustainable development.

APPLICABILITY OF THE
CODE OF ETHICS

T he Code of Ethics is applicable to members

of the administrative and control bodies
and employees of Eni (hereinafter referred to
as "Eni’s People"), and to any third party who
collaborates or works on behalf of Eni’s interest.
The Code, therefore, applies to all of us, as
recipients, wherever we operate, and in any way
we contribute to create value for the company.

Understanding, adopting, and disseminating

the Code of Ethics not only strengthens our
values expressed in principles, commitments
and behaviors, but also helps to guide Eni's
strategic mission as an "energy company".
We take responsibility for knowing and
respecting the principles and contents of the
Code of Ethics, and the regulatory instruments
used to clearly communicate and regulate
our activities. Eni's administrators and
management are committed to guarantee the
principles and contents of this Code by always
setting the example, taking responsibility both
internally and externally, and strengthening
trust, cohesion, and the spirit of the group.

Under no circumstances acting in favor or in

the interest of Eni may even partially justify
behaving in conflict with the principles and
contents of this Code of Ethics.

6
 INTRO
DUC
TION
AS THOSE COVERED
UNDER THE CODE OF ETHICS:
• We act professionally and ethically in
compliance with the principles of the
Code.
• We set the example for others in
operating responsibly.
• We recognize the main risks in violating
the Code of Ethics and work to avoid
improper, illegal or unethical behavior.
• We maintain adequate documentation
of the activities carried out, in order
to always allow traceability and
verifiability.

AS ENI’S PEOPLE:
• We ensure that the people we work with
are aware of the importance of knowing
and respecting the Code of Ethics.
• We ask our managers or the Integrated
Compliance Function for advice in
case of doubts on the interpretation
of the Code of Ethics and the deriving
behaviors.
• We devote the utmost attention to the
training tools made available to us.

IF WE HAVE COLLABORATORS:
• We ensure that they comply with the
Code of Ethics and applicable laws
including participation in appropriate
training activities and we support them
in applying the Code.
• We pay attention to possible risks of
Code violation and encourage our
collaborators to promptly report any
potential violations.
• We take consistent and appropriate
actions, within the scope of our
competences, to deal with actual or
potential violations of the Code of Ethics.

7
ENI CODE OF ETHICS

WHAT WE EXPECT FROM THOSE WHO WORK WITH US

W e are committed, as Eni, to ensuring legality, transparency, fairness and honesty in all our
activities and creating long-term value for all our stakeholders. Therefore, we expect our
stakeholders to equally adopt socially responsible behavior and develop adequate ethical programs
and safeguards, consistent with the principles and behaviors presented in our Code of Ethics.
We reserve the right to take appropriate measures against those who do not meet the above
expectations and do not act in accordance with this Code’s principles.

WHAT TO DO IN UNCERTAIN CIRCUMSTANCES

T he Code of Ethics cannot provide specific recommendations for every possible situation. When we
are uncertain or feel particularly pressured to make a decision, we learn to ask ourselves the right
questions.

LET'S LEARN TO ASK THE RIGHT QUESTIONS

Is what I am doing allowed?

Am I observing the values and principles of Eni's Code of Ethics?

Is my behavior in line with company procedures?

Am I behaving correctly?

Would I be comfortable if my actions were made public?

If the answer to even one of these questions is "No" or if we have a doubt about the legitimacy of our
action or the application of a principle of the Code of Ethics, of a policy or of a behavioral standard,
we must stop and ask for advice through the most appropriate channel.
Expressing doubts and asking questions helps manage situations correctly and resolve potential
problems.

IF WE HAVE ANY QUESTIONS OR CONCERNS, WE MAY CONTACT

Our Direct Manager Can our manager answer our questions?

Other Managers Can another manager answer our questions?

The Integrated If we don’t know where to turn, the Integrated Compliance function is our
Compliance function “go to” in case of doubts on the interpretation of the Code of Ethics.

8
W e consider people the starting point
and the ultimate goal of all our
actions. For this reason, we work hard to
guarantee the health, safety and security of
each Eni individual and those around us.
Every day, we strive to build a work
environment free of discrimination and
harassment, based on dignified working
conditions, open dialogue and the
enhancement of diversity, aware that
dedication and team spirit are fundamental
elements to achieving operational
excellence.
We are committed to developing talent and
investing in the potential of our
collaborators, supporting and spreading the
culture of innovation and change.
 WE RECOGNIZE
AND PROTECT THE
VALUE OF ALL OUR
PEOPLE
 ENI CODE OF ETHICS

WE PROMOTE THE HEALTH, SAFETY

AND SECURITY OF OUR PEOPLE

BECAUSE OF THIS, WE:

provide suitable tools for prevention and

protection from any culpable or malicious
W e want every activity to be carried
out safely and securely.
We comply with the highest international
behavior, including from third parties, which
could cause direct or indirect damage to Eni's
health, safety and security standards People and/or to the company's tangible or
and the specific laws and regulations intangible resources, periodically updating the
of all Countries in which we operate. preventative measures and using the best
We aim for continuous improvement available protection technologies and practices
and empower all organizational levels
to ensure a management approach avoid any engagement in illegal or dangerous
based on the principles of precaution, behavior and report any situation that could
prevention, protection and risk represent a danger not properly managed
management.
abide by working times and rest periods in
compliance with the applicable legislation and
in line with international standards
? CONCERNS & SOLUTIONS

The contractor organizes a coordination spread a culture of health, safety and security
meeting amongst contractors to begin that represents our constant commitment
maintenance work on a plant. I work for
one of the contractors, but I do not consider clearly and transparently inform our people, the
it necessary to be present, as the activities
assigned to me are clear. Is my participation community and our partners about the
in the meeting really necessary? necessary preventive and protective measures
to be implemented in order to eliminate (and
Yes, participation is still necessary by when not possible, mitigate) the risks and
all contractors. This aids in coordination critical issues of the processes and activities in
with each other and mitigates the risk of
interference. which they are involved

DID YOU KNOW?

The term "security" refers to activities

aimed at preventing, facing and overcoming
events that may occur because of actions
normally produced by third parties,
terrorists, criminals, or otherwise illegal that
expose the Company’s people and property
(tangible and intangible) with potentially
harmful effects. When the security event
has a prolonged effectiveness over time
(e.g. kidnapping), it escalates into an
emergency.

12
 PEO
PLE

ENI FUNDAMENTAL REGULATIONS

> Public documents: Policy "The Integrity in our operations", and "Global Framework Agreement on International
Industrial Relations and Corporate Social Responsibility"
> Internal documents: MSG "HSE", MSG "Security"

13
 ENI CODE OF ETHICS

WE SUPPORT THE CREATION

OF AN ETHICAL WORK ENVIRONMENT

W e believe in our people as the fundamental factor for the success of the company.
We guarantee a working environment free from any form of discrimination or abuse,
in which we respect and support each other to fully develop our potential.

BECAUSE OF THIS, WE:

establish working relationships characterized by fairness, equality, non-discrimination, attention

and respect for the dignity of the person. We communicate opinions and objections in an
appropriate and respectful way and reject all behaviors that constitute physical or psychological
violence, compulsion, harassment, bullying or attitude attributable in any way to mobbing and
harassment practices

prohibit any type of sexual harassment, however carried out, and, despite the variation of legal
definition by jurisdiction, still consider any attitude or behavior that could create discomfort or
inspire fear in the other person, unacceptable and prohibited

refuse all forms of forced and/or child labor

respect workers' rights and trade union freedoms, such as in particular freedom of association
and collective bargaining also through a responsible and constructive dialogue with the worker’s
rights organizations, that promotes a climate of mutual respect in accordance with the principles
of fairness, transparency and participation

promote equal opportunities, in particular amongst genders, for every employee or candidate.
We guarantee evaluation processes based on merit, competence and fair treatment in relation
to the role, commitment and results achieved

promote a healthy and safe working environment: therefore, during the course of our work,
we prohibit the use, presence or distribution of narcotic substances, do not accept alcoholic
substances unless explicitly authorized, and do not smoke in the workplace unless allowed

14
 PEO
PLE

Harassment refers to all verbal and visual ? CONCERNS & SOLUTIONS

actions and expressions that are belittling Since my manager has clearly stated his
and offensive or in any case refer to sexual orientation and the relationship with
the characteristics of the person (sex, his partner, he has become the subject of
ethnicity, nationality, religion, political implicit messages and derisive jokes by
some colleagues. Without his knowledge,
affiliation, mental and physical diversity,
inappropriate comments, allusions and
sexual orientation, health condition, age nicknames are circulating which, in addition to
and any other personal data). being offensive, are ruining the atmosphere and
Sexual harassment may include by way collaboration in the office. What should I do?
of example and not limited to verbal
Eni is committed to creating a work
or written advances, offers of work
environment that is respectful of differences
advantages in exchange for sexual favors, and free from any type of discrimination.
proposals for unwanted appointments Report the circumstance to your manager and,
or physical contact, retaliation or in any case, to the Human Resources function.
threatening attitudes in the face of
refusals to advances or complaints in this
area. It may also include winking, gestural
or disparaging comments with a sexual
context and on the physical aspect as
well as jokes, ridicule, images or texts of
this nature.

ENI FUNDAMENTAL REGULATIONS

> Public documents: Policy "Our people", "Eni’s statement on respect for Human Rights", and “Global Framework
Agreement on International Industrial Relations and Corporate Social Responsibility"
> Internal documents: MSG "Human Resources", MSG "HSE"

15
 ENI CODE OF ETHICS

WE RECOGNIZE THE ROLE OF DIVERSITY

AND ENCOURAGE CULTURAL PLURALISM

BECAUSE OF THIS, WE:

adopt behaviors that convey and reinforce

W e consider plurality and diversity

as sources of enrichment and
resources for the development of
the values of diversity, avoiding and censoring
any form of discrimination

humanity. We respect and value the support organizational models that enhance
exclusive contribution of each individual cooperation amongst people from different
to our company, committing ourselves cultures, perspectives and experiences
to create an inclusive work environment
that respects every individual’s dignity and adopt measures (training, communication,
recognizes the power of differences. behavioral, and operational) that contribute
to an internal culture of active inclusion of
all diversities

ENI FUNDAMENTAL REGULATIONS

> Public documents: Policy "Our people", Policy
"Sustainability"
> Internal documents: MSG "Responsible
and sustainable enterprise", MSG "Human
Resources"

16
 PEO
PLE
WE VALUE THE PROFESSIONALISM
OF OUR PEOPLE

BECAUSE OF THIS, WE:

believe in training as a tool to enrich our people,

W e value the skills of our people,

at all levels, as fundamental for
operational excellence. We promote
spread ethical values and strengthen a common
corporate identity; we believe that Education &
Training are the basis of organizational
the dissemination of knowledge, which integration and the promotion of change: we all
enhances everyone's behaviors and actively contribute to knowledge management
contributions. We believe in the power processes in order to stimulate the search for
of sharing, the exchange of ideas and innovative solutions
comparison, to create the fundamental
synergy that characterizes teamwork and reward our people with adequate compensation
gives rise to excellent results. for the responsibilities acquired and the
contribution provided, in compliance with the
applicable regulatory and contractual guidance
and in line with the reference market wage
levels: equity, meritocracy, personal care, and
non-discrimination are fundamental elements
of our compensation & benefits systems

support and promote mobility and international

development, as relevant experiences for our
professional and personal growth

? CONCERNS & SOLUTIONS

I believe that I could further develop my

professionalism with an experience abroad.
What could I do to find out more?

Eni supports and promotes international mobility

and development, as important experiences in the
professional and personal growth of each of us.
Report your interest to your manager and to the
Human Resources function in order to deepen
existing opportunities abroad that are in line with
your professional profile.

ENI FUNDAMENTAL REGULATIONS

> Public documents: Policy "Our people"
> Internal documents: MSG "Human Resources"

17
W e are attentive to the needs and
expectations of our stakeholders,
with whom we establish transparent, fair
and responsible relationships.
We build and maintain solid relationships
with our suppliers and partners, based on
the principles of fairness, legality, respect
for Human Rights and protection of the
environment and the communities in
which we operate. We protect our
customers and consumers by gaining their
trust on a daily basis, behaving ethically,
and offering the most innovative and the
highest quality products and services.
We are committed to playing an active role
in supporting the communities in which we
operate, including strategic alliances with
local-based internationally-recognized
partners, by virtue of which the synergistic
action and knowledge sharing becomes
an engine for socio-economic growth.
We maintain correct, Human Rights
respectful, transparent and traceable
relationships with authorities
and institutions everywhere.
Only by respecting the principles of
responsibility and transparency we are able
to protect the value for our shareholders
and allow our company to continue to
grow and prosper.
 WE ESTABLISH
RESPONSIBLE RELATIONS
WITH OUR
STAKEHOLDERS
 ENI CODE OF ETHICS

WE MANAGE RESPONSIBLY OUR RELATIONS

WITH SUPPLIERS, COMMERCIAL
AND INDUSTRIAL PARTNERS
BECAUSE OF THIS, WE:

adopt accurate qualification, selection and

W e share our values and integrity with

suppliers, commercial and industrial
partners in order to build relationships
monitoring processes of our suppliers and
partners, based on the principles of
transparency and integrity. We do not tolerate
based on maximum transparency. collusive practices, in full respect of legality
In addition to proven professionalism,
we require our suppliers and partners to commit to defining and disseminating policies,
commit and share our principles. standards and rules that guide the action of our
We promote socially responsible behavior, suppliers and partners towards the respect for
work practices, and expect our suppliers Human Rights and our principles of sustainability
and partners to operate
in line with our high standards of respect promote long-term strategic partnerships based
for Human Rights and environmental on an integrated, coordinated and transparent
protection. We are committed to acting approach, encouraging an equitable sharing of
on every occasion with equity, integrity risks and opportunities
and fairness, in compliance with our
contractual commitments.

? CONCERNS & SOLUTIONS

While visiting a supplier's plant I noticed some

potentially critical elements in working conditions
(poorly maintained environment, employees who
work without the use of the appropriate personal
protective equipment PPE). I also heard complaints
about the payment of salaries in front of the coffee
machine. What should I do?

Report the incident to the Procurement Department

and to the Contract Manager who will discuss the
issue with the supplier and verify the content of
the employment contracts. If the reported incident
proves to be real, the company's expectations
regarding the corrective actions to be taken will
be clearly communicated to the supplier and the
implementation of the actions will be verified.

ENI FUNDAMENTAL REGULATIONS

> Public documents: Policy "Our partners of the value chain", "Slavery and Human Trafficking Statement",
"Conflict Minerals Report of Eni SpA", "Eni’s statement on respect for Human Rights", "Code of Conduct for suppliers"
> Internal documents: MSG "Procurement", MSG "Responsible and sustainable enterprise", MSG "Sales"

20
 STA
KE
WE MANAGE RELATIONS WITH CUSTOMERS HOL
AND CONSUMERS TRANSPARENTLY
DERS
BECAUSE OF THIS, WE:

implement all commercial initiatives aiming

W e operate in national and

international markets, basing our
commercial policies and strategic choices
to promote the company and encouraging the
purchase of its products and services, in
compliance with regulations on consumer
on best practices and on the principle protection and customer satisfaction
of professional loyalty to customers
and consumers. We build commercial ensure that our customers and consumers
relationships focused on customer needs, have complete and transparent information
allowing our customers to choose freely when deciding to enter into a relationship
and consciously. with us. We commit to guaranteeing that the
features of our products and services match
the information provided in order to allow
conscious choices
? CONCERNS & SOLUTIONS
ensure that our customers and consumers are
During the launch of a new product, protected not only during the "first contact"
we receive a last minute update on its
with us, but also during the entire duration
characteristics. Since the difference is
minimal, do we still need to update the of the contractual relationship. We commit
product specifications? ourselves to providing all necessary support
to guarantee the correct prosecution and/or
Yes, information on the specifications of completion of the contractual relationship,
a product/service or offer must always be
including continuous attention to customer
accurate. We are committed to ensuring
the clarity, completeness and truthfulness suggestions and complaints
of commercial information and we censor
any form of communication that could
constitute misleading advertising.

DID YOU KNOW?

Small businesses receive the same

protection as consumers when victims of
unfair commercial practices. These are in
particular the so-called "micro-enterprises”
that includes all those entities, companies
or associations who, regardless of the legal ENI FUNDAMENTAL REGULATIONS
form, carry out an economic activity by > Public documents: Policy "Our partners of the value
employing fewer than ten persons and chain"
achieving an annual turnover lower than € > Internal documents: MSG "Code of commercial practices
2 million. and advertising", MSG "Sales"

21
 ENI CODE OF ETHICS

WE ETHICALLY CREATE VALUE

FOR OUR SHAREHOLDERS

BECAUSE OF THIS, WE:

communicate clearly our strategies and the work

W e are committed to respecting

and promoting the rights of
our shareholders and protecting their
of the company management

ensure continuous and constructive dialogue

investment by maximizing the value with shareholders, paying attention to their needs
of our business. We adopt corporate and taking into consideration legitimate
governance best practices and ensure concerns
the utmost transparency and timeliness
of shareholders dialogue in order to commit to create value, also in the long-term,
create conditions for informed for the benefit of shareholders, ensuring the
decision-making. sustainable growth of our activities and providing
shareholder trust in the company, also
considering the interest of other stakeholders

ENI FUNDAMENTAL REGULATIONS

> Public documents: Policy "The corporate
governance"
> Internal documents: MSG "Corporate
governance for Eni Companies",
MSG "Corporate affairs and governance",
MSG "Investor relations"

22
 STA
KE
WE COOPERATE TRANSPARENTLY HOL
WITH AUTHORITIES AND INSTITUTIONS
DERS
BECAUSE OF THIS, WE:

avoid declaring, persuading or encouraging

W e promote and support active

dialogue and cooperation
with international, national and
false or not entirely true statements to
authorities and institutions

local authorities and institutions. In maintain relationships with authorities and

compliance with approved programs, institutions only within the limits of our
prior agreed interventions and actions, function’s competence and, in any case, we
we are committed to establishing fair and act only if authorized
transparent relationships with authorities.
In addition, Eni committs to express its refrain from making contributions to political
concern regarding Human Rights issues and trade union parties, movements,
that may emerge in a host Country, when committees and organizations. We refrain
necessary. from misusing our company name in personal
interactions with political parties, movements,
and committees

ENI FUNDAMENTAL REGULATIONS

> Public documents: Policy "Our institutional partners",
"Eni’s statement on respect for Human Rights"
> Internal documents: MSG "Government affairs",
MSG "Regulatory affairs"

23
 ENI CODE OF ETHICS

WE COLLABORATE WITH THE COMMUNITIES IN

WHICH WE OPERATE TO CREATE SHARED VALUE

BECAUSE OF THIS, WE:

consider the environmental, social, health,

safety and security aspects and respect
W e believe in the importance of
establishing strong, lasting relationships
and partnerships with the communities in
for Human Rights in all our activities,
since the earliest feasibility assessments,
which we operate in order to build lasting, in cooperation with local communities
shared value. We contribute to support
the development of the host Countries by promote continuous and transparent
implementing programs in line with the consultation in order to inform local
United Nations' strategic frameworks, sharing communities and ensure that their
our knowledge, and promoting synergies expectations are always taken into
and collaborations with main international consideration within our activities
cooperation organizations and institutions.
work with communities, development
enabler and local organizations to foster
autonomous, lasting, and sustainable local
? CONCERNS & SOLUTIONS
growth through both regular business
In the face of local community protests activities and local development projects
regarding the beginning of some seismic consistent with our vision to promote
activities, a representative of the authorities improvement of quality of life and
suggested that I ignore the protests, believing sustainable socio-economic development
that the complaints would soon dissolve
spontaneously. What should I do? in the contexts in which we operate

Do not ignore the protests. It is necessary to respect rights of people and communities
establish dialogue that favors cooperation by recognizing and enhancing their
with local direct and/or indirect stakeholders culture, lifestyles, institutions, ties with the
involved in the business cycle to understand
their requests and potential complaints. land of origin and development models in
line with international standards

adopt security measures aimed at

protecting people and assets, respecting
Human Rights of local communities

24
 STA
KE
HOL
DERS

ENI FUNDAMENTAL REGULATIONS

> Public documents: Policy "Sustainability", "Eni’s statement on respect for Human Rights", and "Global Framework
Agreement on International Industrial Relations and Corporate Social Responsibility"
> Internal documents: MSG "Responsible and sustainable enterprise", MSG "Energy and Environmental Industrial Project
Development", MSG “Security”

25
W e recognize the need to actively
participate in tackling climate
change. For this reason, fostering an
effective and socially fair low-carbon
energy transition is our strategic priority,
as well as our ambition.
Our commitment to the fight against
climate change includes innovative
solutions aimed at reducing the impact
of our operations through the efficient use
of natural resources, the protection of
biodiversity and water resources, and the
support of mitigation and adaptive actions
in the contexts where we operate. We are
actively searching for technological
solutions capable of reducing the impact of
our products, favoring a circular approach.
Continuing on our decarbonisation path
towards a low-carbon future, we are
contributing to build a more sustainable
development in the interest of the planet
and well-being of the community.
 WE COMMIT
TO COUNTERING
CLIMATE CHANGE
AND ITS EFFECTS
 ENI CODE OF ETHICS

WE SUPPORT A LOW-CARBON
AND SOCIALLY FAIR ENERGY TRANSITION

W e all must commit to cooperate, within our own competencies, to reach our company’s goal
to respond to the dual challenge of tackling climate change and giving access to reliable
and clean energy, with concrete, rapid and economically sustainable solutions, contributing to the
development of Nations and their potential.

BECAUSE OF THIS, WE:

contribute in the definition and achievement of company targets regarding the efficiency of
our plants and the reduction of direct emissions, the promotion of a low-carbon impact energy
mix and a steady effort in research and development

play a proactive role in the international scenario promoting diversified solutions for climate
change, in line with our strategy, including the development of flexible mechanisms that favor
technology in developing Countries and the identification of new tools used to reduce
deforestation

commit ourselves to create long-term partnerships with the host Countries and communities in
order to build a future together in which everyone can access energy resources efficiently and
sustainably

promote development models based on the regenerative principles of the circular economy
that minimize the use of virgin resources and reduce waste, maximizing the recovery and
valorization of waste and scrap

ENI FUNDAMENTAL REGULATIONS

> Public documents: Policy "Sustainability"
> Internal documents: MSG "Technology research
and development", MSG "HSE"

28
 EN
VI
WE SAFEGUARD THE ENVIRONMENT AND RON
OPTIMIZE THE USE OF ENERGY RESOURCES
MENT
BECAUSE OF THIS, WE:

must individually commit, within the scope of

our duties, to actively participating in the
process of risk prevention and environmental
protection, a process that should be managed

E verywhere we operate, we are

committed to acting sustainably,
minimizing environmental impacts
in line with the principles of precaution,
prevention, protection and continuous
improvement
and optimizing the use of energy and
natural resources. We conduct our promote scientific and technological
activities through the responsible use of development aimed at protecting the
resources so as not to compromise the environment
needs of future generations, but rather,
to create value for our stakeholders and conduct all our activities in compliance with
the community. applicable regulations and adopt the highest
international standards and guidelines in all
contexts in which we operate

? CONCERNS & SOLUTIONS

While doing my job, I realize that an equipment

is corroded and could quickly release an
environmentally dangerous substance. I must report
what happened, but I am already late for a meeting
with my manager. Can I postpone the report?

No, you should immediately notify your plant

manager to start any safety operations.

ENI FUNDAMENTAL REGULATIONS

> Public documents: Policy "Sustainability", Policy
"The integrity in our operations"
> Internal documents: MSG "HSE", MSG "Operations"

29
R esponsibility, integrity and
transparency are the values that
inspire our Governance.
We define our organization and our
internal rules in order to comply with all the
applicable national and international laws
and regulations. We fight corruption and
operate and negotiate without ever
compromising our honesty or that of the
company.
We think and act in compliance with
legality and in Eni's best interest, we
repudiate any corruptive or collusive
practice, or any others that conflict with
our integrity and transparency standards.
We create value by supporting a
competitive market, operating fairly, and
fighting illegal practices.
We avoid conflicts of interest and practices
related to the commission or participation
in fraud.
We accurately maintain company
accounting, we protect and carefully use
information and personal data to which we
have access.
Based on our Internal Control and Risk
Management System (SCIGR), we
contribute to spreading a culture of risk
management and control that allows us to
run our business in a healthy, correct, and
aware manner.
 WE OPERATE
WITH INTEGRITY
 ENI CODE OF ETHICS

WE PREVENT AND MANAGE CONFLICTS

OF INTEREST

BECAUSE OF THIS, AS ENI’S PEOPLE, WE:

promptly refrain from intervening in

E ni recognizes and respects the right investigation, decision-making or control

of Eni’s People to participate in processes that can even just potentially lead
investments, business or other activities to conflicting situations
outside of Eni, provided that these are
activities permitted by law, compatible and report situations of conflict, even if just
not in conflict with your obligations to Eni. potential, in writing to our manager or to
Eni's People, in any case, protect and the body to whom we belong
promote the interests of the company by
taking objective decisions and avoiding, report situations in which to the best of our
wherever possible, any situation where knowledge we, our family members, or those
conflicts of interest may arise, acting in with whom we have close personal or business
compliance with the Code in all cases. relationships, are holders of economic and
A conflict of interests occurs in every financial interests regarding to suppliers,
situation where behaviors or decisions, customers, competitors, contracting third
in the context of working activity, are parties, or the related parent or subsidiary
capable of creating an immediate or companies, or hold corporate administration,
deferred advantage, even non-financial control or managerial roles
in nature that might arise for Eni's People,
or their family, or others with whom
they have close personal or business
relationships.
A conflict of interest, even potential, is a
situation in which the above-mentioned
personal interests:
> may interfere with the Person's ability
to make decisions and/or carry out
impartial assessments in the interest
of Eni
> can be favored by an Eni’s Person in
light of his/her position within the
company, and the information to
which he/she may have access to

Spouse, partner, parents, children, siblings,

grandparents, aunts/uncles, grandchildren and
cousins of the subject and of the spouse or of
the partner are considered family members;
the spouse or the partner of each of these
persons are also considered family members.

32
 IN
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MANAGING CONFLICTS OF INTEREST
In managing reports of conflicts of interest, even potential:
the manager, with possible support of the competent units and the Integrated Compliance
function, or the body to which Eni’s People belong, identifies the appropriate measures to
safeguard in the specific situation, the transparency and correctness of the conduct in carrying
out the activities and in all cases without undermining the person's interests, when possible
eventually, the manager or the body to whom the Eni’s People belongs communicates to the
involved person specific instructions on how to manage the conflict of interest

Eni adopts rules to ensure substantial and In all cases, in the exercise of their
procedural transparency and correctness of responsibilities, Eni's People must act fairly and
transactions involving the interests of directors impartially in any situation in which a conflict
and statutory auditors and transactions with of interest could arise and in full compliance
related parties. with the principles and contents of the Code.

? CONCERNS & SOLUTIONS

1) My father took an executive position in a refrain from any decision-making processes while
competitor company. What should I do? awaiting further instructions.

There is a potential conflict of interests and

an in-depth analysis is needed. You must 3) My daughter works in the company that provides
promptly report the situation to your manager translation services for Eni. Can I participate in the
and wait for instructions. tender process, without decision-making powers,
for the award of translation services in which my
daughter's company also participates?
2) I am part of a committee that selects
candidates for recruitment in Eni. My partner's Even if you have no decision-making powers,
son participates in the selection. What should your participation in the tender process may
I do? interfere making impartial decisions. For this
reason, you must immediately refrain from the
Immediately report the conflict of interest activities, report the conflict of interest to your
to the committee and your manager and manager, and wait for further instructions.

ENI FUNDAMENTAL REGULATIONS

> Public documents: MSG "Anti-Corruption", MSG "Transactions involving the interests of the directors and statutory
auditors and Transactions with Related Parties"
> Internal documents: MSG "Procurement", MSG "Human Resources"

33
 ENI CODE OF ETHICS

WE FIGHT
CORRUPTION

BECAUSE OF THIS, WE:

do not offer, promise, or accept under any

I n line with the "zero tolerance" principle,

we prohibit and fight all forms of
corruption, in favor of anyone, without
circumstances economic advantages or other
utilities in order to improperly expedite, favor,
or facilitate the performance of an activity
exception. We have adopted rules and
controls to prevent and combat the risk expressly prohibit facilitation payments
of corruption in the performance of our
activities. do not offer or accept under any circumstances
We strongly believe that corruption, gifts or hospitality that could be interpreted
in addition to being illegal, can curb by an impartial, third party observer as
economic development, undermine exceeding normal commercial practices or
legitimate business activities, distort professional courtesy, or however aimed at
fair competition, destroy the company's improperly influencing a decision or activity
reputation, and expose companies and
individuals to high risk. ascertain the ethical and reputational reliability
of our potential business partners by
preliminarily checking our counterparts and by
asking them to undertake and share our
anti-corruption principles

if a situation seems suspicious,

we immediately inform our manager
or the Anti-Corruption Support Unit

? CONCERNS & SOLUTIONS

During the tender of a service supply

contract for which I have to evaluate the
offers, I receive a bottle of champagne
as a gift from one of the participating
companies. Can I accept the gift?

No, you must refuse the gift and follow the

internal procedures regarding gifts and
hospitality. The contractor's conduct could
be interpreted by an impartial observer
as exclusively motivated by the desire to
DID YOU KNOW?
exercise undue influence in your evaluation
of the offers.
A risk that you may incur in, especially in those
Countries where it is considered an almost normal
practice, is the request for so-called facilitation
payments, which are unofficial payments made
ENI FUNDAMENTAL REGULATIONS to public officials in order to expedite, favor or
> Public documents: MSG “Anti-Corruption” facilitate a routine activity.

34
 IN
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35
 ENI CODE OF ETHICS

WE ASSURE TRANSPARENCY
AND ACCURACY OF INFORMATION
TO OUR STAKEHOLDERS

BECAUSE OF THIS, WE:

where required by our function, clearly maintain

true and correct accounting records, ensuring
T he attention we pay to providing
accurate, timely and complete
information also translates into a
through the appropriate processes and controls
that no behavior could compromise the
constant commitment to precision in transparency and traceability of the financial
the accounting books. We ensure that all statement information
company documents, including financial
statements, non-financial reporting, maintain adequate supporting documentation
contracts and agreements, accurately of activities carried out in order to allow easy
provide a truthful representation of and timely accounting registration, the
the facts. identification of various levels of responsibility,
and the division and segregation of tasks, to
guarantee an accurate traceability

refrain from falsifying, omitting or altering any

information within our corporate documents

ENI FUNDAMENTAL REGULATIONS

> Public documents: Policy "The global compliance", Policy "Sustainability"
> Internal documents: MSG "Eni’s internal control system over financial reporting", MSG "Finance", MSG "Responsible
and sustainable enterprise”

36
 IN
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WE OPERATE IN THE MARKET WITH LOYALTY GRI
AND FAIRNESS, IN COMPLIANCE WITH
THE APPLICABLE REGULATIONS TY
BECAUSE OF THIS, WE:

comply with competition laws (also known as

"antitrust laws"), to prevent any form of
W e believe in business freedom
and free competition and we are
inspired by principles of loyalty and
illegitimate restrictions on fair competition

fairness pursuing our success both by do not tolerate collusive practices with
offering quality products and services at competitors when defining commercial
competitive conditions and by abiding strategies, particularly with regard to prices,
by market principles when managing production quantities, the markets where we
relationships with suppliers. We also operate and participation in tenders
believe that our conduct should in no
way enable or tolerate Human Rights do not abuse our market power where we are
violations or other illegal activities, such in a dominant position on the market
as money laundering and any form
of terrorist financing. We, therefore, carry out our activities in compliance with the
guarantee, through our conduct, applicable laws on Economic and Financial
full respect and effectiveness of the Sanctions as well as on Trade Control, in
restrictions and limits set by national and particular through preliminary checking of all
international legislation on Economic and our counterparties and demanding the same
Financial Sanctions and Trade Control. degree of diligence from our contractual
partners

DID YOU KNOW?

Rapid changes in the international political

framework make it increasingly common
for states and international organizations
to resort to coercive measures aimed
at tackling crisis scenarios through the
adoption of legal measures (i.e. sanctions)
that prohibit and restrict economic, financial
and commercial transactions with certain
subjects or Countries. The Compliance
on Economic and Financial Sanctions
and Trade Control aimed at ensuring
compliance with these provisions in the
context of corporate activities, including, ENI FUNDAMENTAL REGULATIONS
for example, prohibiting transactions with > Public documents: Policy "The global compliance"
certain commercial counterparties listed > Internal documents: MSG "Antitrust", MSG "Economic
in specific public lists or prohibiting the and Financial Sanctions", MSG "Market conduct and
supply of weapons to certain countries financial regulation", MSG "Market Information Abuse
or organizations. (Issuers)"

37
 ENI CODE OF ETHICS

WE PROTECT OUR STAKEHOLDERS’

PRIVACY RIGHTS

BECAUSE OF THIS, WE:

constantly place security first when we select,

A s part of our business, we collect a

significant amount of personal data
and confidential information and are
define, and execute procedures, even IT, to
process personal data and confidential
information in order to protect the
committed to complying with laws of fundamental rights, freedom, and dignity
privacy, data protection and confidentiality of the concerned persons
as well as best practices applicable in the
jurisdictions where we operate. pay the utmost attention when we collect,
We, therefore, protect the privacy rights store, use, process, communicate and disclose
of Eni’s People, customers, suppliers and personal data, remaining aware that the data
business partners, and those with whom we may only be used for legitimate business
establish relationships, using personal data purposes. We guarantee data protection,
only for defined and appropriate purposes. integrity and confidentiality, in accordance
We promote a sense of trust towards our with what is prescribed by applicable laws
stakeholders that can be preserved only and our procedures
through virtuous behaviors in line with our
principles.

? CONCERNS & SOLUTIONS DID YOU KNOW?

I mistakenly sent a file containing the "Personal data" is all information that identifies,
personal data of Eni's customers to directly or indirectly, a person and that provides
an external supplier rather than to the indications of his/her characteristics, habits,
marketing manager, since both have the lifestyle, personal relationships, economic situation,
same surname. What should I do? characteristic elements of his/her identity, etc.,
and data related to criminal convictions or crimes
Contact your manager immediately to (e.g. criminal records and pending charges).
inform him/her of the incident and send Personal data includes "sensitive data", such as
communication to the data_breach@eni. personal and contact information related to ethnic
com inbox to report the accident. or race, personal, religious and philosophical
beliefs, political opinions and membership
of parties, unions, associations or organizations
of a religious, philosophical, political or trade union
nature as well as personal data capable
of revealing the state of health and sexual life.

38
 IN
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ENI FUNDAMENTAL REGULATIONS

> Public documents: Policy "The global compliance"
> Internal documents: MSG "Privacy and data protection"

39
W e are aware that our work is closely
related to the use of corporate
assets and the exchange of a large amount
of information. The management and
communication of these assets involves a
series of risks. For this reason, we ensure
protection against illegal behavior or
improper use of company resources,
including information and intellectual
property that can damage our company,
including its reputation, or give our
competitors an unfair advantage. We are
committed to protecting our history,
preserving our image, and gaining and
maintaining the trust of our stakeholders
every day and in every place where we
operate.
 WE RESPECT
AND PROTECT OUR
COMPANY’S ASSETS
 ENI CODE OF ETHICS

WE USE OUR CORPORATE

ASSETS CORRECTLY

BECAUSE OF THIS, WE:

promote, through the application of advanced

E ach of us is responsible for the

appropriate and correct use of the
assets made available by the company for
technologies and high management and
technical standards, the highest levels of
infrastructure safety and integrity throughout
the proper performance of the work. We are the asset life cycle
all, therefore, required to guarantee assets
integrity by protecting them against theft, monitor the asset's operating conditions and
abuse, sabotage, loss or damage. report any situation that could represent an
inadequately managed danger

allow a limited personal use of the assets

assigned to each individual, as long as such
use does not adversely affect work
performance or harm the environment and
does comply with our internal rules

? CONCERNS & SOLUTIONS DID YOU KNOW?

To increase production, can I propose to my Our information technology systems are

manager the postponement of a scheduled an essential component of our business
maintenance of an equipment based only operations and are provided for authorized
on the fact that this does not present commercial purposes. Any information that we
operating anomalies? create, share or download on Eni's information
systems belongs only to the company. In this
No, before postponing a maintenance, it is regard, Eni reserves the right to monitor, record,
always necessary to acquire every element disclose, check and delete at any time, without
useful to have a complete picture of the prior notification and to the extent permitted by
actual conditions of the equipment to prevent law, the data present on the information systems
possible malfunctions. connected to our business.

ENI FUNDAMENTAL REGULATIONS

> Public documents: Policy "Our tangible and intangible assets"
> Internal documents: MSG "HSE", MSG "Security", MSG "Human Resources", MSG "Operations"

42
 RE
SOUR
WE PROTECT CORPORATE INFORMATION CES
AND INTELLECTUAL PROPERTY

W e ensure the correct management,

internal and external, of all
corporate information which, if improperly
BECAUSE OF THIS, WE:

refer relations with the media exclusively to

disclosed, can undermine corporate
the functions and company figures delegated
competitiveness and damage corporate
to do so; we do not disseminate data or news
reputation. All company information,
concerning Eni without such dissemination
if not previously approved to be
being previously agreed upon and authorized
disclosed externally, must be considered
by the company
confidential and, therefore, classified and
protected. We all have a responsibility
ensure the correct management of company
to recognize, protect and defend Eni's
information and, in particular, inside
intellectual property, and respect that of
information, with reference to issues of abuse
third parties.
of market information, industrial espionage or
sabotage: any behavior that may constitute or
even facilitate the commission of market
abuse is expressively prohibited

ensure compliance with the rules of conduct

also in the management of information that
may be inside information for third parties

identify and report any violation, even

DID YOU KNOW?
potential, of Eni's intellectual property and do
Company information is classified not violate the property rights of third parties
according to its level of criticality as
damage resulting from its unauthorized ensure an effective IT security management
disclosure and/or illegal use. Information system: we protect the information assets
rated as “critical” may include: business
plans and strategies, pricing, sales
of the company, its customers, other
information, research, new product stakeholders and the security of our
development, marketing activities, transactions
product costs, wages and benefits,
earnings, forecasts, major restructuring,
potential acquisitions, change of
auditor, or important organizational
and managerial changes.
"Inside information" relating to Eni
or referring to other companies is precise,
non-public information for which public
exposure could have a significant effect ENI FUNDAMENTAL REGULATIONS
on the price of the company's listed > Public documents: Policy "Our tangible and intangible
financial instruments. It is, therefore, assets", Policy "Information Management"
necessary to limit communication > Internal documents: MSG "Security", MSG "Information &
of inside information to only those Communication Technology", MSG "Market Information
who need to know for professional Abuse (Issuers)", MSG "Market conduct and financial
reasons. regulation", MSG "Technology research and development"

43
 ENI CODE OF ETHICS

WE PROTECT
OUR REPUTATION

O ur reputation represents the perception

and the historical memory that
stakeholders have of the company and
committed to protecting our reputation,
complying with the principles of this Code of
Ethics, and safeguarding our relational capital,
its activities. It is a determining factor of taking into consideration the expectations of
our history, behaviors, and results. We are our stakeholders.

44
 RE
SOUR
BECAUSE OF THIS, WE: CES
adopt excellent behaviors by feeding our relational capital

commit to use the Eni brand consistently with our mission and associate it with
activities and events always in line with Eni's values expressed in the Code of Ethics,
opposing its improper or unauthorized use

are aware that all actions that we take on social networks is in the public domain and
shall not cause even potential damage to Eni's reputation

ENI FUNDAMENTAL REGULATIONS

> Public documents: Policy "Our tangible and intangible assets"
> Internal documents: MSG "External communication", MSG "Identity Management"

45
 ENI CODE OF ETHICS

PUTTING OUR CODE

TO ACTION

subsidiaries, consortiums, and joint ventures

PROMOTION AND
appointed by Eni must promote the principles
DISSEMINATION OF THE CODE and contents of the Code in their respective
OF ETHICS areas of competence.
The Integrated Compliance function is
The Code of Ethics is made available to all committed to ensuring correct and effective
stakeholders and may be retrieved on Eni SpA dissemination of the principles contained
and its subsidiaries websites and intranets. The within this Code of Ethics, promoting
Code of Ethics is delivered to all of Eni’s and its it through communication and training
subsidiaries employees upon hiring and will be programs in order to ensure that each of us
disseminated when updates or changes occur. is correctly informed about the Code and
Subsidiaries receive and must adopt the Code that its contents are aligned to changes
of Ethics. Representatives of non-controlled in legislation and the company's choices.

46
 AC
TION

The Integrated Compliance function can Each day, we follow not only our
be contacted directly in order to obtain Code of Ethics, policies, applicable
clarification about the contents of the Code, laws and regulations, but also our
without prejudice to the fact that possible common sense. If something does
violations will be ascertained within the not seem right to us or seems to
whistleblowing process. put our company, colleagues or
Once obtaining the opinion of the Board of customers at risk, we step forward.
Statutory Auditors and the Control and Risk Whenever we express a question
Committee, this Code and any subsequent or concern, we help preserving our
amendments must be approved by the Board reputation and allow our company
of Directors of Eni SpA based on the Chief to continue to thrive.
Executive Officer’s recommendations in
agreement with the Chairman.

47
 ENI CODE OF ETHICS

REPORTING CHANNELS:
WHISTLEBLOWING REPORTS
• Eni website and intranet:
www.eni.com

I f we think that someone is not applying,

or is about to violate, one of the principles
of the Code of Ethics, it is our duty to report
myeni.eni.com

• By mail to the address: Eni SpA, Direzione Internal Audit,

it. Eni seriously examines all reports of
P.le E. Mattei 1, 00144, Rome, Italy
suspected violations of the Code of Ethics
or applicable laws and analyzes them
• By fax to the number: +39 06 598.27335
promptly.
We should always feel free to express fears • By email to one of the following addresses:
or draw attention to actions with possible [email protected], or
ethical implications. Eni will not tolerate, [email protected]
under any circumstances, any form of
retaliation against any person who has • Eni voicemail via:
raised concerns in good faith and in no case the national number: +39 06 598.27323
will take or threaten any adverse action or the national toll-free number 8006020099
discrimination of any kind against those and numbers for each country where Eni operates
who report wrongdoings or express concerns available in the Whistleblowing Poster published on Eni
regarding ethical issues. website
The channels for reporting potential
violations of the Code of Ethics are shown • In company offices that do not allow widespread
in the this box and the regulatory reference access to computer workstations, the HR Business
to manage them is the specific procedure Partner functions responsible guarantee the presence
"Annex C – Whistleblowing reports received, of alternative tools for the collection of whistleblowing
including anonymously, by Eni SpA and by reports (e.g. dedicated "yellow-box" mailboxes)
its subsidiaries in Italy and abroad".

DISCIPLINARY ACTIONS AND CONTRACTUAL REMEDIES

C ompliance with the rules of the Code

of Ethics and corporate regulatory
instruments is an essential part of our
relation to the preservation of the employment
relationship, based on the principle of gradation,
and may result in compensation for any
contractual obligations. damages resulting from the violation itself.
For Eni's People, the violation of principles For all the other addresses of the Code
and contents of the Code of Ethics constitutes of Ethics, in the event of violation of
a breach of the primary obligations as an the principles and contents of the Code,
employee or a disciplinary offense. The violation contractual remedies provided under the
will have all the legal consequences also in applicable law will be activated.

48
Eni SpA
Registered Office
Piazzale Enrico Mattei, 1 - Rome - Italy
Share capital: € 4,005,358,876.00 fully paid-up
Business Register of Rome,
Taxpayer’s code 00484960588

Other Branches
Via Emilia, 1
San Donato Milanese (MI) - Italy

Piazza Ezio Vanoni, 1

San Donato Milanese (MI) - Italy

Page layout and supervision

K-Change - Rome - Italy

Eni could pay royalties to persons entitled in the case

of sources for which the authors have not been traced.