Douglas Linares Flinto & ENI SpA
Lead NCPBrazil
Supporting NCP(s)Italy
DescriptionSpecific instance alleging a non-observance of the OECD Guidelines.
Theme(s)Concepts and principles, General policies, Disclosure, Human rights, Combating bribery, bribe solicitation and extortion
Date16 Jul 2020
Host country(ies)Italy
Industry sectorMining and quarrying
StatusIn progress

On 16 July 2020, Mr. Douglas Linares Flinto, an individual, submitted a specific instance to the Brazilian NCP alleging that ENI SpA, a company active in the oil and gas sectors, had not observed the Concept and Principles (Chapter I), General Policies (Chapter II) Disclosure (Chapter III), Human Rights (Chapter IV) and Combating Bribery (Chapter VII) provisions of the Guidelines. Specifically, the issue relates to alleged reprisals adopted by the company following the individual’s resignation from the company.

On 12 August 2020, the Brazilian NCP acknowledged the receipt of the specific instance and appointed a rapporteur within the Interministerial Working Group representing the Secretariat of Social Security and Labour of the Ministry of Economy.

On 16 October 2020, following the rapporteur’s recommendation, the Brazilian NCP accepted the case considering the issues merited further examination.

Given that the submission concerned a company headquartered in Italy, the Brazilian NCP informed the Italian NCP in order to coordinate the handling of the specific instance in November and December 2020.

According to the Brazilian NCP’s Rules of Procedure (ROP), the Brazilian NCP subsequently contacted the company to obtain its response to the allegations.