Responding department: Sustainability Department
Stock Exchange Symbol: (ENI:IM)
Does your company have a publicly available commitment to respect human rights?
- Since 2007 Eni has adopted a Guideline which regulates the protection and promotion of Human Rights in all the company’s actions;
- In the same year the Code of Ethics, which describes the company’s expectations with regard to various areas relating to Human Rights, was approved. The Human Rights Guidelines [link] and the Code of Ethics [link] are available on the company’s website;
- Over the years measures to respect Human Rights have been integrated in the various corporate regulatory instruments relating to Sustainability, Human Resources, Security, Sustainability Stakeholders Engagement and Community Relations, HSE, Planning and Control, Procurement, Energy and Environmental Industrial Project Development and Integrated Risk Management. In particular, the "Sustainability" policy includes a specific section on Human Rights [link] (read the section on Human Rights). Read all policies here: [link]
How are human rights governed in your company?
Respecting human rights is a shared responsibility within the company, deriving from the obligation to comply with the Code of Ethics, the Sustainability Policy and the other policies with an impact on human rights issues. The Sustainability Department, reporting to the company Chief Services and Stakeholder Relations Officer, maintains responsibility for developing guidance, monitoring performance, liaising with stakeholders and providing support to the eni businesses on human rights issues.
A dedicated committee of the Board, the "Sustainability and Scenarios Committee", appointed in 2014, provides recommendations and advice to the Board of Directors on scenarios and sustainability issues, i.e. the processes, projects and activities aimed at ensuring the Company’s commitment to sustainable development along the value chain, particularly with regard to: health, well-being and safety of people and communities; protection of rights; local development; access to energy, energy sustainability and climate change; environment and efficient use of resources; integrity and transparency; and innovation. Information on the committee [link] and its internal rules [link] are available on eni’s website.
Eni’s strategic four year plan includes human rights objectives among the key intervention areas. This demonstrates the strategic value that the company attributes to the topic and the commitment to improve its performance in this domain. The intervention areas and the related sustainability objectives are defined in relation to the company’s strategy and operations, the international framework and the requirements of the capital markets and the main stakeholders.
How are human rights managed within your company?
Eni has been developing processes and tools in order to implement international human rights standard and, in particular, the requirement of due diligence outlined in the Guiding Principles, including them in the work indications provided to its employees and monitoring compliance.
Information on these processes is available both on the company’s website, in the Due diligence page [link], in the impact assessment section and on eni for 2013 [link] (pages 25 and 26). In 2010 eni approved a standard integrated assessment that includes all the elements for the assessment of social impacts of its activities on the communities, in accordance with international standards. The company is now pursuing the goal to add the human rights perspective in the impact assessments. This work draws significant advantages from the participation in the IPIECA task force which develops shared guidelines from the oil industry in this area. The cooperation with leading Oil & Gas companies brought to the publication, in December 2013, of the IPIECA guideline "Integrating human rights into environmental, social and health impact assessments".
With regard to the integration of human rights into risk assessments, for the first time in the 2013 Risk Assessment cycle human rights were considered both in terms of contents – the corporate strategic risk assessment includes also screening on risks of human rights violations – and in term of impact assessment metrics. This process also benefits from the participation in an international project of the Global Corporate Community of Practice, the initiative for the integration of human rights in the Risk Management systems supported by the UN Working Group on Human Rights and Business, appointed in 2011 to assist countries and companies in the implementation of the guiding principles.
In addition, in 2008 the company launched the "Human Rights" project, organized in collaboration with the Danish Institute for Human Rights [link], with the goal of identifying a comprehensive system for monitoring and prevention of the areas of greatest risk. Within the project eight Human Rights Compliance Assessments (HRCA) have been carried out aimed at testing the ability to prevent risks arising from possible human rights violations and abuses by third parties, through the involvement of all potentially affected business functions. Detailed information on this project can be found here: [link]
This project proved extremely useful also in terms of awareness raising: so far, more than 100 managers have been invited to training sessions, interviews and follow-ups aimed at sharing challenges, questions and results achieved in the area of respect for human rights within their working experience.
As per training, In order to increase awareness of this aspect amongst its people, in 2013 eni, in collaboration with Eni Corporate University and the International Labour Organization, has developed an on-line course that provides more in-depth information on ILO Convention No. 111, the international regulation on discrimination in employment and occupation.
eni has implemented a human rights training programme for security managers [link] and security forces, both public and private, that perform their professional duties on company sites both in Italy and abroad. The project has been running since 2009 and was included by the United Nations Global Compact and by Principles for Responsible Investment in the publication “Responsible Business Advancing Peace” [link], presented at the Global Compact Leaders Summit on 19 September 2013. In 2013 training sessions were delivered to 208 people from public and private security forces involved in operations in Indonesia and Algeria. In Indonesia, employees of other Oil & Gas companies as well as representatives of local NGOs were also involved.
What is the company’s approach to the engagement of stakeholders (including workers, and local communities impacted by the company’s activities), on human rights issues?
Eni’s approach to the engagement of stakeholders is described in the Company’s Annual Report 2013 (pages 237-238). As per local communities, the Management System Guideline (MSG) “Stakeholder Engagement and Community Relations” regulates the community relations sub-process in order to manage relationships with the local communities residing in a specific territory in which Eni operates, including responses to their demands, and generate value in the territory through projects for local sustainable development. The MSG gives indications on how to effectively and proactively involve stakeholders, analyse the context and assess social impact at the local level, apply tools for consulting with the community and involving it (i.e. grievance mechanism), plan, manage and measure community investment, so that local reporting can be performed. Eni identifies and assesses the environmental, social, economic and cultural impacts generated by its activities, including those on the indigenous peoples, ensuring their mitigation and implementing improvement processes. The company adopts appropriate tools to manage and plan projects in order to identify, define and manage the initiatives for the benefit of the local communities. The process involves the use of specific operating procedures: Stakeholder Management Process; Social Baseline Analysis; Social Impact Assessment, Community Investment Planning, Monitoring & Evaluation.
Given their vulnerability in some specific contexts, eni has also developed specific policies and commitments to apply in areas close to indigenous peoples lands.
Priority human rights issues: What are some of the priority human rights issues for your company?
- Health (including workplace health & safety, prevention of pollution)
- Workplace diversity / non-discrimination
- Freedom of association and trade union rights
- Displacement and community relocation
- Relations with security forces
- Indigenous peoples
Actions on freedom of association and trade union rights
On freedom of association and labour standards in general, eni is committed to progressively improving its capacity to monitor compliance with the ILO Conventions and encouraging their take-up by third parties. A targeted analysis has been conducted on the local laws covering maternity rights and existing business practices in the Countries where the company operates in order to assess the prospects for defining a management approach that is valid for all eni operations, in line with international standards. Further on, an applied study on minimum labour standards in five strategic Countries (Pakistan, Nigeria, Congo, Iraq and Hungary) was completed, highlighting, where applicable, any divergence between local Laws and the ILO conventions in this regard.
Actions on displacement and community relocation
On displacement and community relocation, eni’s goal is to develop uniform rules on land acquisition, consistent with international standards and best practice, in order to ensure respect for fundamental principles such as the right to fair compensation and consideration of the petitions of those who, despite not having any formal title to the land in question, are nonetheless dependent on it for their survival.
How are human rights commitments and information about how the company addresses its human rights impacts communicated, internally and externally?
We disclose our management approach and results in terms of Human rights performance in our Annual Report 2013 [link] (see pages 231-236), in the eni for 2013 publication [link] and at the Sustainability Section of eni’s website [link].
What provisions does your company have in place to ensure that grievances from workers and affected communities or individuals are heard, and can you provide examples of remedies provided?
eni has got a company-wide Whistleblowing procedure that allows employees, members of corporate bodies or third parties to forward (including confidentially or anonymously) complaints relating to problems in the internal control system (compliance with law and corporate policies, guidelines or procedures, fraud involving corporate assets, financial reporting, administrative liability of the Company, etc.) or other violations of the Code of Ethics (issues involving ethical conduct, mobbing, harassment, conflicts relating to human resource management, etc.). Information on the management of complaints is also available on the company’s website, both on the dedicated page [link] and in the Due diligence page [link], in the monitoring and reporting section.
Futhermore, local mechanisms for collecting and managing alerts are already active in Countries were Eni has a long established presence such as Nigeria, Kazakhstan and Pakistan; others are being strengthened in new countries of activity such as Ghana. Special attention is paid to situations where indigenous communities are present, such as in Australia, Ecuador and Norway. As part of its role in the project promoted by IPIECA to define sector-specific guidelines for the Grievance Mechanism, Eni has started a pilot project aimed at developing a site-specific mechanism for complaints in local communities and to define the basis for a valid best practice for the whole Group.
Which external and collaborative human rights initiatives does your company participate in, and what is the nature of your involvement?
An outline of eni’s collaborations on Sustainability and Human Rights is available in eni for 2013 [link] (page 14). Eni collaborates with the Danish Institute for Human Rights and has taken part to the Community of Practice promoted by the UN Working Group on Business and Human Rights in order to work on the implementation of the due diligence requirements as from the UN Guiding Principles, with a focus on the risk management systems. Furthermore it takes part in the Working Group on Human Rights in the Global Compact and the Business and Human Rights Project of IPIECA, association of Oil & Gas companies, which aims to develop common solutions to the experience of participating companies In addressing security issues, eni refers to the Voluntary Principles on Security & Human Rights.
Which are the key one, two or three elements of your approach to human rights that been developed or amended since June 2011? Please indicate if these actions were in response to the UN Guiding Principles.
The main workstream and progresses are described in the most recent eni publication on Sustainability issues, eni for 2013 [link]. The publication includes a section on objectives and progress for each priority area, including Human Rights (pages 10-11). Information on this is also available on eni’s website [link].
What are some of the obstacles and challenges that your company encounters in implementing its human rights commitments?
We have taken a performance approach to human rights and acknowledge that effective due diligence is a journey. Cooperation with international institutions, peers and NGOs is key to advancing in people’s enjoyment of the Human Rights they are entitled to.