Has your company put in place appropriate internal mechanisms and tools to carry out enhanced due diligence of your supply chains, intermediaries, customers and end-users to understand the risk of your products’ diversion to Russia? If yes, please provide details.
Eni has in place and implements adequate internal procedures designed to ensure compliance with applicable sanctons, which include specific counterpartes’ screenings and due diligence controls aimed at identfying, inter alia, restricted counterpartes and concerns regarding counterpartes’ reputaton and behaviour. Internal controls are significantly strengthened in case of counterpartes referable to countries at risk of sanctons or other possible red flags. Our export to Russia of the sole product inserted in the parallel imports list adopted by the Russian Ministry of Industry and Trade – i.e., lubricants – was a largely marginal business linked to a now dismissed downstream presence in Russia. Given the background and nature of our business, we do not think that diversion to Russia is a live risk in this context.
Does your company consider potental red flags that suggest the use of front companies that may hide the true end-users of your products and thereby evade sanctons and export controls? If yes, please provide details.
We do evaluate red flags, including those included in public guidance issued by relevant authorites. Our distributon network and customers of the sole product inserted in the parallel imports list adopted by the Russian Ministry of Industry and Trade have been made aware of existng restrictons and are contractually prohibited from further distributng Eni’s products. (Potental red flags may include companies registered recently; companies based in Armenia, Belarus, Turkey, Kazakhstan, Kyrgyzstan, Uzbekistan or other countries helping Russia circumvent sanctons; companies making large orders of products within a short space of tme; companies with obscure beneficial ownership structures, etc.)
Has your company taken any other actons to prevent re-export of your products to Russia?
We have implemented adequate internal policies to ensure compliance with sanctons and export control provisions. However, as mentoned above, given the background and nature of our business, we do not think that diversion to Russia is a live risk in this context.