The continous evolution of the eni anti-corruption internal regulations, anti-corruption training and actions on the international spread of principles and standards to fight against corruption.
In order to achieve the target, The most significant elements of new eni AC regulation are:
1) extension of the prohibited conduct in order to include also the bribery between private parties;
2) explicit prohibition of facilitation payments;
3) introduction of a register for gifts and economic advantages offered to, or received from, eni personnel;
4) Regulation of any eni relations with Business Partner.
Through Training: eni recognizes the value of awareness of eni personnel on the fight against corruption and invest in training programs to provide the necessary knowledge and tools about the eni AC regulations and to identify the so called “Red Flags” and to put in place the relevant actions.
Through membership and relevant collaboration. The collaboration with ISPAC shall be performed by Università Cattolica del Sacro Cuore of Milano, LUISS of Roma, Collège de France of Paris, Universidad de Castilla-La Mancha of Toledo and Northeastern University of Boston. Besides it is important to mention the active collaboration with the International Bar Association (with the support of the OECD) in order to empower the awareness on the issue in the main law firm in the word.
Updating of the new AC regulation to the UK Bribery Act. Specific risk areas identified and already regulated as entertainment expenses; JV ; Intermediary; Consultants; sales and acquisitions; no profit initiatives; appointment of external lawyers; consulting and professional services; sponsorship; selection of personnel; travel expenses; accounting regulation will be updated. Areas related gift and other benefits, Business partners will be included as well.
Empowerment of the AC training program made through 1) Web Training Seminar (WTS)to complete the online training for new nominated Key Officers and to update the WTS in order to include the new rules provided in the new eni internal regulations 2)Workshops and other workshop events planned in Italy and abroad taking into account the demands coming from eni's departments and from subsidiaries.
Continuation of the research started in 2012 in collaboration with ISPAC and with the support of the UN Office of Drug and Crime (UNODC) and performed by 5 important european universities in order to produce a compliance model that can be a reference standard for multinational companies in energy sector.
, General Counsel Legal Affairs Department - Senior Executive Vice President, email@example.com
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