Administrative Responsibility

Organisational, management and control Model 231

The discipline of the “administrative liability of legal entities deriving from offences” (Legislative Decree 8 June 2001 no. 231), on which the Model 231 is based, provides that companies may be subject to fines or other sanctions for offences committed or attempted – in Italy or abroad – in the interest or for the benefit of the company by its representatives, directors or managers, or one of its financially and functionally autonomous organizational units. This also applies to persons (such as senior managers) discharging, even de facto, management and control responsibilities and to anyone subject to the direction or supervision of all the people mentioned above.

Eni encourages the adoption and effective implementation by all its subsidiaries of adequate systems for the prevention of the risks of corporate responsibility deriving from crime. To this aim, the rules of Eni internal regulatory system ensure that all Eni’s subsidiaries adopt, in the management of the activities at risk of corporate liability, control principles and instruments that are consistent with the control principles and instruments laid down in Eni’s Model 231.

TTPC’s Model 231, of which Eni Code of Ethics constitutes a fundamental principle of reference, has been firstly adopted on July 28, 2005 and subsequently updated, in order to extend it to the new crimes pursuant to administrative liability of companies; until the new version adopted by Board of Directors resolution on June 22, 2020.

  • Model 231