Requests of the Submitter to NCP Brazil

1) That the Final Statement of this Specific Instance is only published after the NCP Brazil take the necessary measures in relation to my requests here listed. These requests were also motivated by the guidance of the NCP Brazil Manual itself: “7.6: After hearing the parties, the NCP Brazil may initiate or resume the mediation process at any time during the preparation of the Final Declaration of a Specific Instance”;

2) That the NCP Brazil grant a “term” of 15 (fifteen days) for Eni to “manifest” itself on the “content” of this “new manifestation” (Doc. 01) of mine (dated October 03, 2022);

3) That the NCP Brazil can clarify to Eni about the need to carry out a “due diligence” on my case in the light of the guidelines of the "OECD Due Diligence Guidance for Responsible Business Conduct", to analyze the allegations and supporting documents presented in this Specific Instance, including the “chronology of the facts” (Doc. 02), so that it can be verified whether Eni caused (or did not cause), contributed (or did not contribute) to adverse impacts to my disadvantage;

4) If Eni does not accept the suggestion of the NCP Brazil, mentioned in item “c”, that the NCP Brazil can count on the “engagement” of the Italian NCP in order to inform the government of Italy — in the capacity of “controlling shareholder” of Eni — the need to “require” that the Board of Directors carry out a “due diligence” on my case, in accordance with the guidelines contained in the international commitment that Italy is an “adhering nation”: the UN Guiding Principles on Business and Human Rights (Principle 4);

5) In the event that Eni continues to insist on not performing the necessary “due diligence”, that the Final Statement may contain the following “determinations”:

● Eni's denials in relation to the requests mentioned in item “c” and “d” described above;

● That, regarding my case, Eni is not in compliance with the OECD Guidelines for Multinational Enterprises, including the guidance of the OECD Due Diligence Guidance for Responsible Business Conduct.

6) That NCP Brazil call for this Specific Instance an “expert” in “corporate investigations” so that a “due diligence” can be carried out in the “chronology of the facts” to “reconstruct the events” presented by me in this Specific Instance, including in the Final Statement this procedure adopted by the NCP Brazil and the "summary" of the result of this "technical opinion";

7) That this Final Statement may also contain “recommendations” for Eni regarding the “whistleblowing process”, especially on issues related to “protection of whistleblowers” and “due diligence” (internal audit);

8) That the NCP Brazil can carry out the necessary follow-up of the recommendations mentioned in item “g” during the period of 6 (six) and 12 (twelve) months after the publication of this Final Statement, preparing new statements on the corporate progress of Eni;

9) That the Final Statement is a “mirror” of everything that has been presented by the Parties in this Specific Instance, and that the content of this document is written in an organized and easy-to-understand manner;

10) And finally, that NCP Brazil may write this Final Statement according to the “model” (the “standard” of Final Statement) used in Specific Instance nº 02/2020, referring to the Brazilian multinational Vale S/A, published on October 28, 2021 (Doc. 03).

 These "requests" to NCP Brazil were "based" in everything described on this website as well as in the OECD Report (2020) called "Providing access to remedy 20 years and the road ahead”; in the suggestions of OECD Watch; in the OECD Procedural Guidelines and in several points listed in the OECD Due Diligence Guidance for Responsible Business Conduct, as we will see below: