Eni

The role of the administrative, management and supervisory bodies

Reference: Content index p.264 (cross-referenced to Management Report / Governance and Integrated Risk Management); Governance pp.30-41.

Eni applies the traditional Italian model: management sits with the Board of Directors, supervision with the Board of Statutory Auditors and statutory audit with the independent auditors (p.32). The Board has entrusted management to the CEO, "reserving the most significant strategic, operational and organizational responsibilities, in particular in the areas of governance, sustainability, internal control and risk management" (p.32).

Board composition (pp.34, 31). The Board appointed in May 2023 for 2024-2026 has 9 members, three of them appointed by minority shareholders. As of 25 February 2026, "8 non-executive Directors out of the 9 Directors in office are independent pursuant to law; moreover, of these, 7 Directors, including the Chairman of the Board of Directors, are also independent pursuant to the Governance Code" (p.34). The by-laws require at least 2/5 of the less represented gender for six consecutive terms (p.34). No new Directors or Statutory Auditors were appointed during 2025 (p.33).

Information provided to and sustainability matters addressed by the administrative, management and supervisory bodies

Reference: Content index p.264 (cross-referenced to Governance: the internal control system on mandatory sustainability reporting, and to Process and results of the double materiality assessment); pp.38-39, 147.

The Board approves the Strategic Plan, "which includes industrial business targets, economic and financial results and sustainability targets, including medium long term emission targets" (p.38). The Strategic Plan 2026-2030 was approved by the BoD on 18 March 2026 (p.38).

Sustainability topics addressed by the Board in 2025 are listed at p.39 and include: the medium-long-term plan with sustainability objectives and the short- and long-term incentive plans; board induction on energy scenarios; approval of Eni's "Slavery and Human Trafficking Statement" under the Modern Slavery Act; the local development and no-profit investment plan; the 2025 materiality analysis; approval of the 2024 Sustainability Statement and the 2024 voluntary report Eni for; the Financial Reporting Officer's report on the 2024 sustainability report; the independent auditors' management-letter suggestions on 2024 sustainability reporting; the HSE model and results; and Eni's 2024 ESG rating positioning versus peers.

Integration of sustainability-related performance in incentive schemes

Reference: Climate governance p.152; Content index pp.264-265 (listed under both ESRS 2 and ESRS E1).

Incentives are set through Eni's Remuneration Policy for Directors, General Managers, executives with strategic responsibilities and other executive managers (p.152):

• the equity-based Long-Term Incentive Plan carries environmental-sustainability and energy-transition objectives with an overall weighting of 35%, split into 20% Net GHG emissions Upstream Scope 1 and 2 and 15% biojet fuel production capacity;
• the Short-Term Incentive Plan includes an environmental-sustainability target on reducing net GHG emissions Upstream Scope 1 and 2, "consistent with the Long-Term Incentive Plan. This target has a weighting of 20% for the CEO, while for management the weighting varies according to assigned responsibilities".

A footnote records that "the remuneration linked to the Short-Term and Long-Term Incentive Plans for 2025 was paid on the basis of the performance of the Net Carbon Footprint Upstream indicator, defined on an equity boundary" (p.152, note 18) - the equity-basis indicator that Eni has now replaced with Net Scope 1+2 Upstream on a financial-control boundary.

Statement on due diligence

Reference: Statement on due diligence p.142.

Eni maps its disclosures against the five due diligence phases in a dedicated table (p.142):

1. Embedding due diligence in governance, strategy and business model - Governance (Annual Report); Code of Ethics and Policies; Process and results of the DMA; Environment and Eni's management system; Human Rights for Eni.
2. Engaging with affected stakeholders - DMA; Stakeholder engagement; Code of Ethics and Policies.
3. Identifying and assessing adverse impacts - DMA; materiality sections within the thematic chapters.
4. Taking actions to address those adverse impacts - Environment and Eni's management system; Human Rights for Eni; "Actions taken on material IROs" within the thematic chapters.
5. Tracking effectiveness and communicating - Environment and Eni's management system; Human Rights for Eni; targets and commitments and metrics within the thematic chapters.

Risk management and internal controls over sustainability reporting

Reference: Content index p.264 (cross-referenced to Governance / The internal control system on mandatory sustainability reporting); p.41.

With CSRD, Eni "redefined the internal organization, with the attribution of responsibility for the process of drafting and approving mandatory sustainability reporting to the Financial Reporting Officer", followed in 2025 by a new ECG Policy, "Eni's internal control system on mandatory financial and sustainability reporting", defining roles, responsibilities, processes and timelines (p.41).

The system is built "in line with the main international reference frameworks, such as COSO 'Achieving Effective Internal Control Over Sustainability Reporting'", and runs in five phases: integrated definition of the control environment with financial reporting; risk assessment; control activities; monitoring; information flows (p.41).

Strategy, business model and value chain

Reference: Content index p.264 (cross-referenced to Management Report / Activities, Business model and Strategy); pp.10-13, 150.

"Eni is an energy company, integrated along the entire value chain, operating in 62 Countries worldwide with over 32 thousands employees" (p.10). It is present in conventional oil and gas exploration and production and in gas/LNG marketing, and develops renewables, biofuels, biochemistry, CO2 capture and storage, and research lines including magnetic fusion and chemical recycling of plastics (p.10).

The distinctive feature is the satellite model: "the establishment of entities engaged in the development of products and solutions with reduced carbon footprint, capable, thanks to the entry of dedicated capital, of growing autonomously and financially independently, releasing value for the parent company, as evidenced by the successes of Enilive and Plenitude" (p.10).

Since 2024 activities are grouped into three structures (p.152): Transition & Financial (including Plenitude and Enilive); Global Natural Resources (upstream oil and gas, CCS, agri-hubs, power generation and marketing, trading); and Industrial Transformation (Versalis chemicals, refining conversion, Eni Rewind environmental remediation).

Interests and views of stakeholders

Reference: Stakeholder engagement pp.143-145.

Eni operates "in 62 Countries characterised by diverse socioeconomic contexts", and treats understanding the expectations of affected stakeholders, "particularly vulnerable groups", as essential (p.143). Engagement is supported by a Stakeholder Management System (SMS) operating centrally and at subsidiary level, which "maps over 7,400 stakeholders" and supports engagement strategies and the handling of requests and issues raised (p.143).

Four groups are singled out as central to a just transition (p.143): the workforce (social dialogue, listening initiatives, reskilling and upskilling to support redeployment); suppliers (managing transition impacts, with attention to SMEs); local communities (economic and social development); and consumers (responsible and efficient energy consumption).

A table at pp.144-145 sets out, for each of eight stakeholder categories, the engagement objective, the topics of engagement and the outcomes: people and unions; the financial community; local communities and cooperation organisations; contractors, suppliers and business partners; customers and consumers; national, European and international institutions; universities and research centres; and advocacy and trade associations.

Material impacts, risks and opportunities and their interaction with strategy and business model

Reference: Material topics for Eni and its stakeholders pp.147-149; The resilience of the strategy to material IROs p.151; Value chain and main impacts p.150; per-topic IRO sections in every thematic chapter.

The materiality table (pp.148-149) sets out, per topic, the impact description with sign and actual/potential flag, the time horizon, the value chain position (upstream, own operations, downstream) and the material risks and opportunities. 36 material impacts, 8 risks and 7 opportunity rows are presented across 14 topics - the eleven ESRS topics plus the entity-specific topics of payments transparency, cybersecurity and innovation, with health and safety spanning S1, S2 and entity-specific.

"During 2025, changes in both the Group's business activities and the external context were assessed; these analyses did not identify the emergence of new material topics compared to the previous reporting cycle" (p.146). Presentation of social impacts was aggregated more than in 2024 "without any changes to the underlying content" (p.146).

Description of the processes to identify and assess material impacts, risks and opportunities

Reference: Process and results of the DMA pp.146-149. The 2025 assessment "builds on the results of the 2024 assessment" (p.146). Six phases are described (pp.146-147):

• Identification of potentially material topics top-down, using Eni's objectives, benchmarking, the ESRS, GRI sector standards and the updated mapping of Salient Human Rights Issues.
• Identification of IROs: impacts from public sources plus internal functions; risks from the Integrated Risk Management (IRM) process; opportunities from the Strategic Plan.
• Assessment model: impacts scored on significance (scale, scope and, for negative impacts, irremediable character) combined with likelihood, on 1-5 scales; risks on likelihood times magnitude, using cash-flow, net-profit and reputational metrics. "The negative impact related to climate change is considered material based on recognised scientific consensus."
• Significance assessment via an IT platform "that enables the traceability of the evaluation process". Material impacts are Tier 1 and Tier 2 of three tiers; Tier 1 and Tier 2 risks are Eni's Top Risks; only Tier 1 opportunities were retained (p.147).
• Calibration and final list, shared with the Control and Risk Committee, the Sustainability and Scenarios Committee, the Board of Statutory Auditors and the BoD (p.147).

Disclosure requirements in ESRS covered by the undertaking's sustainability statement

Reference: Content index pp.264-273; Eni reporting system p.141.

Eni prints a full ten-page ESRS content index headed "Content index [ESRS 2 IRO-2]" (pp.264-273). It has four columns: Disclosure Requirement, Other EU Regulations, "Not material(*)/Phase-in", and Cross-reference to the 2025 Annual Report / 2025 Sustainability Statement. Cross-references are given as chapter and section names rather than page numbers.

The index covers ESRS 2 (BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2, and MDR-P/A/M/T) and the topical standards E1, E2, E3, E4, E5, S1, S2, S3, S4 and G1, plus entity-specific blocks for E-1, E-2, E-3, S-1, S-3, G-1, Innovation, Health & Safety (process safety and asset integrity), Tax strategy and payments transparency, and Cybersecurity.

Phase-in provisions are flagged for: E1-9, E2-6, E3-5, E4-6, E5-6, S1-11 (social protection) and S1-12 (people with disabilities), plus paragraph 48(e) of E1-1 (anticipated financial effects) and parts of S1-14 for non-employees and occupational illnesses. E2-5 (substances of concern) is marked "NON-MATERIAL".

A footnote qualifies the third column: "The indication 'Not material' is specified only for those KPIs that refer to other European regulations" (p.264). A reconciliation table at p.141 lists which ESRS requirements are answered in the Management Report rather than the Sustainability Statement.

Transition plan for climate change mitigation

Reference: Decarbonisation plan and targets pp.158-159; Decarbonisation levers pp.160-161; Assessment of locked-in emissions p.162; Capital allocation pp.162-163. Content index p.265 marks PHASE-IN only for paragraph 48(e) (anticipated financial effects).

"Five years have passed since Eni launched its pathway towards Carbon Neutrality by 2050" (p.158). From the 2025 cycle the plan has been recalibrated: Scope 1 and 2 move from an equity-share to a financial control boundary, Scope 3 moves from a lifecycle methodology to the GHG Protocol, and the indicators are renamed Net Scope 1+2 Upstream, Net Scope 1+2 Eni and Net Intensity Scope 1+2+3. The 2018 baseline was recalculated on the new boundary (pp.158-159).

Targets (p.159): Net Scope 1+2 Upstream 14.5 MtCO2eq. in 2018 to 4.7 in 2025 (-68%, against a -65% 2025 target), Net Zero by 2030; Net Scope 1+2 Eni 35.8 to 21.4 MtCO2eq. (-40%), Net Zero by 2035; Net Intensity Scope 1+2+3 63 to 59 gCO2eq./MJ (-6%), -15% by 2030 and Net Zero by 2050.

These are net targets: "For all targets, any residual emissions are compensated through the use of high-quality carbon credits" (p.158), up to 15 MtCO2eq. by 2030 and, in 2050, within 10% of the baseline Scope 1+2+3 value (pp.161, 163).

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 and the E1 scenario analysis sections (pp.153-158). This DR did not exist under the 2023 ESRS the report was prepared against.

Risk classification (p.153). Climate risk generates "transition risks (market, regulatory and legal, technological and reputational) and physical risks (acute and chronic)". "Climate change is considered by Eni to be a top risk."

Scenarios (p.154). "The IEA Net Zero Emissions (NZE) scenario was considered for assessing the resilience of Eni's strategy to transition risks, whereas the IPCC SSP5-RCP8.5 (C8) scenario was used for the analysis of physical risks." IPCC C1-C2 categories, "over 200 scenarios capable of limiting global warming to 1.5 C", are the reference for testing the decarbonisation plan. Eni notes the IEA "revised the assumptions underpinning the NZE scenario... shifting from a limited-overshoot pathway to a high-overshoot one" in WEO 2025.

Methodology and scope (p.156). Exposure is assessed for Eni's own assets and "the main third-party assets within the value chain whose unavailability could affect the operability of Eni's assets", using site coordinates and a third-party climate-risk modelling framework. "The analyses carried out in 2025 covered the entire Eni asset portfolio (around 900 sites)", run annually, charted for current and 2050 exposure by geography and business line (pp.156-157).

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 and the E1 "Resilience of the strategy to transition scenarios" sections, where this content is disclosed in the FY2025 report (pp.151, 156, 158). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Transition resilience is quantified (p.156). An ex-post sensitivity analysis tests Oil & Gas asset values against three stresses: a linear 10% cut in hydrocarbon prices across all projected cash-flow years; a one-percentage-point increase in the adjusted WACC; and application of the IEA Net Zero Emissions 2050 scenario for hydrocarbon prices and CO2 costs. "The overall value-in-use of Oil & Gas properties calculated under the various stress-test scenarios shows a margin ('headroom') above the carrying amounts. Under the NZE-IEA 2050 scenario in particular, the headroom stands at 18%, with potential impairments of EUR 3.4 billion." Detail is cross-referenced to Note 15 of the consolidated financial statements.

Policies related to climate change mitigation and adaptation

Reference: Policies p.152 [ESRS 2 MDR-P; E1-2]; Code of Ethics and Policies section.

Three instruments are tabulated (p.152):

• Code of Ethics - commitment "to contribute positively to the achievement of the Sustainable Development Goals and to support a lower carbon and socially just energy transition, also through innovative solutions aimed at reducing the impact of its operations by promoting the efficient use of natural resources, the protection of biodiversity and water resources, and by supporting mitigation and adaptation actions in the local contexts in which it operates"; and commitment, "as a signatory to the Paris Pledge, to support the objectives set out in the Paris Agreement".
• Supplier Code of Conduct - suppliers must commit to environmental protection, optimisation of resource use and contribution to plant efficiency and emission reduction targets, "thereby supporting Eni along its pathway towards Carbon Neutrality to 2050".
• Internal Regulatory System - procedures defining, in line with international standards, the methodologies for emissions reporting.

Actions and resources in relation to climate change policies

Reference: Actions taken on material IROs pp.158-163 (Decarbonisation Plan, Decarbonisation levers, Capital allocation); Energy consumption and energy mix p.167.

Delivered in 2025. Fugitive methane emissions are down 97% from 2014 to 0.6 kt CH4 through systematic LDAR campaigns, with methane emission intensity at 0.09% (0.08% including operating companies) against the OGCI "Aiming for Zero" 0.2% benchmark (pp.159-160). "Eni has confirmed the achievement of the 'zero routine flaring' target in 2025 for the operated boundary"; for operating companies it depends on projects in Libya expected during 2026 (p.160). Energy-efficiency work delivered "an effective saving of primary energy compared to baseline consumption of over 308 ktoe/year, deriving mainly from projects in the Upstream area (77%), with a benefit in terms of emission reduction equal to over 765 kt of CO2eq" - about 800 kt including Scope 2 (p.167).

Portfolio actions. Biorefining capacity reached 1.65 Mt in 2025, with the Livorno conversion launched in 2024 and start-up expected by end-2026 (p.160). Plenitude reached 5.8 GW of installed renewable capacity, "achieving an annual growth rate above 40%" (p.160).

Targets related to climate change mitigation and adaptation

Reference: Targets and commitments p.153; Decarbonisation targets p.159; Methane and flaring emission reduction targets in the Upstream business pp.159-160.

Group GHG targets (p.159), against a recalculated 2018 baseline on a financial control boundary:

Net Zero Upstream Scope 1+2 by 2030; Net Zero Eni Scope 1+2 by 2035; Net Zero Net Intensity Scope 1+2+3 by 2050, with a -15% versus 2018 milestone in 2030 (p.161). "In 2025 the target of -65% versus 2018 was exceeded, with a reduction of around -68%. The trajectory remains consistent with achieving the Net Zero Upstream target by 2030" (p.159).

Methane and flaring (pp.159-160). The 2016 target of an 80% cut in fugitive methane by 2025 versus 2014 was "achieved well ahead of schedule in 2019". Under OGCI's "Aiming for Zero Methane Emissions", Eni "confirms its commitment to maintaining methane emissions intensity below 0.2% for Upstream operated assets through to 2030". Zero routine flaring, set in 2015, was achieved in 2025 on the operated boundary.

All targets are net of carbon credits, capped at 15 MtCO2eq. by 2030 and at 10% of the Scope 1+2+3 baseline in 2050 (pp.159, 161).

Energy consumption and mix

Reference: Metrics / Energy consumption and energy mix pp.167-168. Content index p.265 marks ESRS E1-5 paragraphs 40-43 (revenue-based intensity) non-material because "the intensity indicators, and their trends, based on revenues are not representative for the sector as revenues are strictly dependent on the commodities prices".

2025, operated boundary (p.168), with 2024 comparatives:

• Total energy consumption 84,399,860 MWh (2024: 92,738,602)
• Total fossil energy consumption 83,851,801 MWh (2024: 92,151,343), of which fuel from crude oil and petroleum products 17,757,550 (2024: 22,658,539), fuel from natural gas 63,641,599 (2024: 67,054,303), other fossil sources 350,927, and purchased electricity/heat/steam/cooling from fossil sources 2,101,725
• Total renewable energy consumption 548,060 MWh (2024: 587,259), of which fuel from renewable sources including biomass 313,843, purchased renewable electricity/heat/steam/cooling 219,450, and non-combustible self-generated renewable energy 14,767

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: Metrics / GHG Metrics pp.164-166; methodological note p.166. Content index p.266 marks E1-6 paragraphs 53-55 (revenue-based intensity) non-material for the sector.

2025 (ESRS total, with the consolidated sub-total per E1-6 50(a) in brackets), versus 2024 (p.164):

• Scope 1: 28.4 MtCO2eq. (26.2), down 9% from 31.1 (27.4). Split: combustion and process 23.5, flaring 2.7, venting 2.0, fugitive methane 0.1. 61% of Scope 1 is covered by regulated emission trading systems (2024: 58%). Non-consolidated operated Scope 1 was 2.2 MtCO2eq. (E1-6 50(b)).
• Scope 2: 0.7 MtCO2eq. location-based and 0.8 market-based, both down (2024: 0.8 and 0.9). Non-consolidated operated Scope 2 was 0.04 location-based and 0.05 market-based.
• Scope 3: 182.3 MtCO2eq., up 1% (2024: 181.0), reported as a single category - Category 11, use of sold products, "the only category considered significant (~92.8% of total)". Consolidated companies alone accounted for 134.1 MtCO2eq.
• Total GHG emissions: 211.4 MtCO2eq. location-based and 211.5 market-based (2024: 212.8 and 212.9), both down 1% (p.165).

GHG removals and GHG mitigation projects financed through carbon credits

Reference: GHG emissions offsets and removals pp.163-164. Listed in the content index at p.266 with cross-references to Climate change: GHG emissions offsets and removals, and Operating review: CCS and Agri.

"To achieve the 2050 Net Zero target for Net Intensity Scope 1+2+3, Eni intends to use carbon credits only after reducing 90-95% of its GHG emissions" (p.163).

Retired carbon credits (p.164): 7 MtCO2eq. in 2025 (2024: 5.9). The composition is stark and disclosed: 100% reduction credits, 0% removal credits - no biogenic removal, no technological removal - 0% from projects in the EU, and 0% subject to a corresponding adjustment under Article 6 of the Paris Agreement. 100% were verified to the VERRA standard. A footnote records that the credits "were retired in February 2026 for the 2025 accounting of the targets defined on the equity boundary", while approximately 5 MtCO2eq. was used for the financial-control-boundary indicators.

Internal carbon pricing

Reference: Internal carbon pricing p.155 [E1-8].

"In 2025, Eni applied an internal carbon pricing mechanism (shadow price) to assess the economic and financial exposure of its investments to the potential introduction of carbon pricing systems in the Countries where it operates" (p.155).

Price basis. "The analysis conducted in 2025 used the IEA's Net Zero scenario (World Energy Outlook), adopting a 2050 price range differentiated by level of economic development (advanced economies, emerging economies with and without Net Zero commitments)". The footnote gives the range: "between 180-250 USD/tCO2 (real 2024 terms). For emerging and developing economies (other than Brazil, China, India and South Africa), lower carbon price values are assumed, ranging between 55-180 USD/tCO2. Ref. Table B.6, IEA - World Energy Outlook 2025" (p.155, note 32).

Policies related to pollution

Reference: Pollution / Policies p.172 [ESRS 2 MDR-P; E2-1].

Two instruments are tabulated (p.172):

Code of Ethics - "Commitment to acting sustainably, by minimizing environmental impacts."

Internal Regulatory System - principles for the operational management of environmental impacts and risks, listed as: "(i) optimization of water cycle management; (ii) control and monitoring of water discharges; (iii) prevention, monitoring and control of pollutant emissions; (iv) prevention and monitoring of spills; (v) management of soil, subsoil, surface water and groundwater contamination and the relevant emergency safety and reclamation actions; (vi) emergency management." It also requires "prevention, protection and mitigation for the conservation and safeguarding of the environment from the release of pollutants, through effective monitoring and control mechanisms that are periodically verified, based on the results of assessments conducted to identify environmental impacts".

Actions and resources related to pollution

Reference: Actions taken on material IROs pp.173-174; expenditures p.175 [ESRS 2 MDR-A; E2-2].

Actions are grouped into air emissions, water emissions and spills (p.173).

Air. Continuous monitoring and control taking account of the territorial, environmental and regulatory context, with "particular attention... to potential atmospheric effects and odour impacts"; IED Monitoring and Control Plan compliance; periodic LDAR campaigns with repair of detected leaks; and promotion of BATs across the plant lifecycle (pp.173-174). Decarbonisation and energy-efficiency projects "generally also have positive effects on air pollutant emissions" (p.174).

Water. Systematic prevention, monitoring and control of discharges, with "internal pre-alert thresholds for specific pollutants, in order to promptly initiate any corrective actions"; development of water-treatment technologies and BAT application; and monitoring of total oil in produced water discharged from Upstream operations (p.174).

Targets related to pollution

Reference: Targets and commitments p.172 [ESRS 2 MDR-T; E2-3].

Eni discloses that it sets no quantitative pollution targets, and explains the position rather than leaving it silent: "Eni, while not setting quantitative targets, is consistently engaged in implementing actions aimed at safeguarding water resources, air quality and soils through an approach focused on the prevention and minimisation of risks and impacts related to emissions affecting these environmental matrices" (p.172).

Effectiveness is tracked in place of targets, consistent with MDR-T's alternative limb: "The Actions required to implement the management system are reviewed on a semi-annual basis, together with the analysis of Metrics useful for the detailed monitoring of performance, enabling an intervention in case of deviations" (p.172). Compliance is underpinned by the Internal Regulatory System and by HSE management systems certified to international standards.

Eni also signals a future change: "the adoption of quantitative targets on pollution is under evaluation for future Strategic Plans". It links this to water: "the commitment defined in terms of water positivity, in line with the principles of Positive Water Impact that Eni follows, intrinsically also considers the water quality dimension and therefore, where necessary, also aims at objectives for reducing water pollution" (p.172).

Pollution of air, water and soil

Reference: Metrics pp.175-176 [ESRS 2 MDR-M; E2-4]. Content index p.268 lists E2-4 with the SFDR paragraph 28 datapoint.

Air pollutants, operated boundary, 2025 versus 2024 (p.175):

• NOx (nitrogen oxides): 18.4 kt NO2eq. (2024: 21.9)
• SOx (sulphur oxides): 2.2 kt SO2eq. (2024: 2.4)
• NMVOC (non-methane volatile organic compounds): 6.7 kt (2024: 9.1)
• PM (particulate matter): 0.3 kt (2024: 0.5)

Eni states that "the data for the following pollutants correspond to Eni's total emissions and not only to those from sites above the thresholds set by the E-PRTR Regulation", drawn from a combination of direct measurements, calculations and estimates, with measured data preferred where available (p.175, note (a)). NMVOC from fugitive sources is estimated using EPA Method A21/2017.

Water. Hydrocarbons in wastewater are reported in tonnes, covering "total hydrocarbons released into the environment through final discharges into the receiving environment (surface waters or sea) and through partial discharges into third-party sewer networks", monitored under authorisation requirements using certified sampling and analytical methods (p.175).

Policies related to water and marine resources

Reference: Water resources / Policies p.179 [ESRS 2 MDR-P; E3-1]. Three instruments are tabulated (p.179):

• Code of Ethics - commitment to the fight against climate change "including innovative solutions aimed at reducing the impact of Eni's operations, also through the protection of water resources".
• Eni's position on water - commitments "to setting targets to minimise freshwater withdrawals in water-stressed areas, by seeking improved solutions or by reducing consumption through efficiency activities and by looking for solutions outside the Company and its operational boundary"; to carry out a periodic water risk assessment covering the areas where its operational assets are located; and to identify partnerships for optimal water management.
• Internal Regulatory System - a water resource management model covering "(i) identifying water-stressed areas; (ii) managing water withdrawals, use and discharges; (iii) identifying priority sites and related interventions; (iv) reporting and communication activities", with mitigation criteria "avoid, replace, reduce, recycle, replenish".

Water-stressed areas are identified using the WRI Aqueduct tool, monitored annually down to the individual site, and classified as stressed "when their Baseline water stress value exceeds 40%" (p.179, note (a)).

Actions and resources related to water and marine resources

Reference: Actions taken on material IROs pp.180-181 [ESRS 2 MDR-A; E3-2].

Eni's water resource management model is "based on identifying, assessing and minimising impacts on water resources, preventing adverse and/or unlawful environmental events and supporting the protection and enhancement of ecosystems", with all relevant projects subject to ESHIA (Environmental, Social and Health Impact Assessment) (p.180). An annual water-risk analysis assesses asset exposure and identifies improvement opportunities, prioritised by business activity. Supplier ESG performance including water management is monitored on a continuing basis.

"Based on the results of water risk analyses, the main improvement actions are directed and planned at the most significant sites in terms of freshwater withdrawals in water-stressed areas, namely downstream industrial sites located in central and southern Italy and Upstream assets in North Africa" (p.180).

Targets related to water and marine resources

Reference: Targets and commitments p.179 [ESRS 2 MDR-T; E3-3].

Eni endorsed the CEO Water Mandate and published Eni's position on water. "In 2024, Eni announced its ambition to achieve water positivity by 2050 in its operated sites", framed within an approach that "also considers measures at river basin level and is inspired by the Positive Water Impact (PWI) principles set out by the CEO Water Mandate" (p.179).

Water positivity is defined in a footnote as "ensuring that, at river basin level, water stewardship initiatives generate greater benefits than the impacts associated with the presence of an operational site, such as those related to the withdrawals required for industrial processes or to the quality of water returned to the environment" (p.179, note 74).

Intermediate milestone. "Eni is committed to achieving water positivity by 2035 in at least 30% of its sites that withdraw more than 0.5 Mm3/year of freshwater in areas identified as water-stressed, based on 2023 data (priority sites)". Those priority sites "account for over 90% of Eni's high-quality freshwater operated withdrawals in water-stressed areas in 2023 (baseline)" (p.179, note 75).

Water consumption

Reference: Metrics p.182 [ESRS 2 MDR-M; E3-4]. Content index p.267 marks the SFDR paragraph 29 revenue-based intensity datapoint non-material for the sector.

2025, operated boundary, with 2024 comparatives (p.182):

• Water consumption 42 Mm3 (2024: 45); in water-stressed areas 17 Mm3 (2024: 17)
• Reused and recycled freshwater 1,080 Mm3 (2024: 1,133)
• Water withdrawals 821 Mm3 (2024: 1,162), of which seawater 707 Mm3 (2024: 1,032) and freshwater 114 Mm3 (2024: 127)
• Water discharges 798 Mm3 (2024: 1,135)
• Freshwater reuse 90% (2024: 90%); reinjected produced water 56% (2024: 51%)

Withdrawals fell by 341 Mm3. Seawater withdrawals "fell by 326 Mm3 year on year, mainly due to shutdowns at the Italian petrochemical plants in Brindisi and Priolo (which together account for more than 60% of the reduction) and to lower production at the Enipower Brindisi power plant (where withdrawals decreased by more than 111 Mm3)", with further reductions from the end of Upstream activities in Eni UK (-18 Mm3) and the Taranto refinery shutdown (-10 Mm3), partly offset by higher withdrawals in Cote d'Ivoire (p.182).

Transition plan on biodiversity and ecosystems

Reference: Material impacts, risks and opportunities / Material risks and opportunities [E4-1] pp.184-185; Content index p.267 lists "E4-1 - Transition plan and consideration of biodiversity and ecosystems in strategy and business model" with a cross-reference to the Biodiversity chapter.

Eni does not present a separate biodiversity transition plan; it discloses how biodiversity is considered in strategy and business model, and reports a scenario-based resilience test.

"The Process and results of the double materiality assessment did not identify material risks (including systemic risks) or currently realised opportunities related to biodiversity. Nevertheless, Eni continues to monitor potential risks and opportunities by consulting publicly available scenarios" (p.184). Physical risks are framed as "ecosystem degradation and potential reduction of natural resources, which may affect the operability and profitability of assets"; transition risks as regulatory evolution, environmental protection policies and stakeholder expectations "which may result in limitations on access to natural resources or land use in certain geographical areas", including reputational risks that "could affect litigation, reputation and access to financing" (p.184).

Policies related to biodiversity and ecosystems

Reference: Biodiversity / Policies p.183 [ESRS 2 MDR-P; E4-2].

Five instruments are tabulated (p.183):

• Code of Ethics - innovative solutions to reduce operational impacts "including the protection of biodiversity, also in consideration of climate change".
• Eni Biodiversity and Ecosystem Services (BES) Policy - technical guidelines for biodiversity risk assessment "throughout the project lifecycle", and adoption of the mitigation hierarchy (anticipate and avoid, minimise, restore, offset), "prioritising preventive over corrective measures to avoid net biodiversity loss or, where feasible, achieving a net gain".
• Eni Position on Water - the link between water, biodiversity and ecosystem services and forest conservation.
• Eni No-Go Commitment - "Formal commitment not to perform Oil & Gas exploration and development activities within the boundaries of Natural Sites included in the UNESCO World Heritage List" (as of 31 May 2019).
• Eni Position on Biomass - traceability along the supply chain and contractual clauses "to ensure the sourcing of certified biomass only, not originated from land converted from areas of high biodiversity value".

The Internal Regulatory System sets the processes for identifying, prioritising, managing and monitoring biodiversity impacts within the HSE Integrated Management System.

Actions and resources related to biodiversity and ecosystems

Reference: Actions taken on material IROs and Metrics pp.185-186 [ESRS 2 MDR-A; MDR-M; E4 SBM-3; E4-3; E4-5].

Screening drives action. Each site conducts EIA studies under ISO 14001, and "Eni annually maps its sites and concessions to verify proximity to legally protected areas and Key Biodiversity Areas (KBAs), and to assess the potential presence of priority species from the IUCN Red List", using IBAT (p.183). Sites with the highest risk, especially those overlapping an important biodiversity area, receive deeper BES Assessments on a risk-based prioritisation "to verify the possible presence of significant unmanaged residual impacts" (p.184).

"If significant residual impacts are identified, they are managed through specific measures included in the site environmental management plans or through dedicated Biodiversity Action Plans (BAPs)" (p.184). BAPs concentrate on two priority interventions: "(i) the restoration of natural habitats that have been modified or degraded; and (ii) monitoring campaigns aimed at confirming the presence of species at risk and assessing potential impacts of activities on their conservation status at the local level" (p.186).

Targets related to biodiversity and ecosystems

Reference: Targets and commitments p.183 [ESRS 2 MDR-T; E4-4].

Eni discloses that it has set no Group-level quantitative biodiversity targets, and gives its reasoning rather than leaving the gap unexplained:

"While Eni has not established consolidated quantitative targets, it remains committed to implementing actions aimed at safeguarding biodiversity and ecosystem services by focusing on the prevention and minimisation of risks and impacts. Biodiversity is site-specific and characterised by unique features that vary significantly across geographical areas, environmental conditions of ecosystems, and ecological interactions. The lack of a universally recognised metric for measuring global biodiversity makes it complex to define aggregated targets at the Group level" (p.183).

The alternative is a stated management approach with local indicators: "For this reason, Eni applies a 'site-specific' management approach, implementing, where necessary, environmental management plans that identify targeted measures and local indicators... This approach allows the specific features of each environmental context to be addressed more effectively, ensuring that actions are concrete, measurable, and tailored to impacts on the territory" (p.183).

Impact metrics related to biodiversity and ecosystems change

Reference: Actions taken on material IROs and Metrics pp.185-186 [E4-3; E4-5].

The annual mapping of operational sites and Upstream concessions against protected areas and KBAs is reported as the impact metric (p.185):

Operational sites, non-Oil & Gas Upstream business lines (Oil & Gas Downstream, Enilive, Agribusiness, Plenitude, Enipower, Versalis):

• Overlapping sites - falling even partially within protected areas or KBAs: 39 (of which 25 are renewable energy sites); 74% in Italy, the remainder in Spain, France and Estonia
• Adjacent sites, within 1 km: 71 (of which 50 are renewable energy sites); mainly Italy (65%) and France (23%), only 3% in Australia and the United States
• Area: 3.2 and 3.3 thousand hectares respectively

Oil & Gas Upstream concessions overlapping protected areas or KBAs:

• With operational activities within the overlap area: 22 (Italy, the Netherlands, United Kingdom), 232 thousand hectares
• Without operational activities within the overlap area: 19 (Italy 84%, remainder United Kingdom, Netherlands, Congo, Tunisia), 132 thousand hectares

Policies related to resource use and circular economy

Reference: Resource use and circular economy / Policies p.188 [ESRS 2 MDR-P; E5-1].

Two instruments are tabulated (p.188):

Code of Ethics - "Commitment to the promotion of development models based on the regenerative principles of the circular economy that minimize the use of virgin resources and reduce waste, maximizing the recovery and valorisation of waste and residues."

Internal Regulatory System - "Implementing actions across its operations aimed to improve efficiency, reduce waste, maximise the recovery and valorisation of waste and by-products, use secondary raw materials or renewable sources, extend the useful life of assets and innovate processes and products, with the broader goal of creating long-term value for both the environment and society."

The policy commitment is operationalised through the HSE Management System, which "set[s] out operational guidelines for all business areas, informed by the operating context, environmental compliance requirements, stakeholder expectations, and the assessment of impacts, risks and opportunities", with semi-annual monitoring of the actions required to implement them (p.188).

Actions and resources related to resource use and circular economy

Reference: Actions taken on material IROs pp.189-190 [ESRS 2 MDR-A; E5-2].

Actions are organised into circular economy and waste, with the circular economy strand split by intervention type: "extension of useful asset life, asset conversion and redevelopment; use of circular raw materials and alternative feedstocks; recycling and recovery technologies" (p.189).

Eni "integrates circular economy principles into its business model, applying them both to the development of new product value chains and to existing ones, with the aim of improving efficiency in the use of resources and extending the lifecycle of assets and products" (p.189).

Resources (p.189). "The main resources allocated during the year to activities related to biorefineries and bio-feedstock production amounted to EUR 0.8 billion, while those dedicated to other circular economy initiatives totalled EUR 0.1 billion. For the next five-year period, Eni has allocated EUR 7 billion to biorefining/bio-feedstock activities and EUR 0.8 billion to other circular economy initiatives."

Targets related to resource use and circular economy

Reference: Targets and commitments p.188 [ESRS 2 MDR-T; E5-3].

Eni states plainly what it has and has not set: "Although Eni has not adopted quantitative targets, aside from the business target relating to biorefining capacity outlined in the Strategy section, the Company promotes the prevention of waste generation in line with the priority criteria established under EU legislation and ensures proper waste management in accordance with its Internal Regulatory System" (p.188).

The biorefining capacity target is quantified in the climate chapter: capacity of 1.65 million tonnes in 2025 rising to 5 million tonnes by 2030, "with optionality for more than 2 million tonnes of Sustainable Aviation Fuel (SAF)" (p.160).

In place of further targets, effectiveness is tracked - the MDR-T alternative limb: "the Company adopts an Internal Regulatory System and an HSE Management System that set out operational guidelines for all business areas, informed by the operating context, environmental compliance requirements, stakeholder expectations, and the assessment of impacts, risks and opportunities. The system also provides for semi-annual monitoring of the actions required to implement these guidelines, supported by the collection of specific KPIs enabling effective performance monitoring and prompt intervention in the event of deviations from expected trends" (p.188).

Resource inflows

Reference: Metrics / Circular Economy p.191 [ESRS 2 MDR-M; E5-4]. Content index p.268 cross-references E5-4 to Operating review: Refining and Chemicals and to Resource use and circular economy: Metrics.

Eni reports resource inflows for the bio-feedstocks used in its Italian biorefineries at Gela and Porto Marghera (p.191):

• Vegetable oils: 29,394 t in 2025 (2024: 23,646) - specified in the notes as "canola, croton, castor and soy"
• Waste and residues (used vegetable oils, oily residues derived from the processing of vegetable oils and other industrial processes): 696,249 t in 2025 (2024: 669,515)

The figures cover "feedstocks related to sold production certified as sustainable with a Proof Of Sustainability (POS), as required under the relevant certification schemes", and both years "are published for the first time in the Sustainability Statement" (p.191, notes (a) and (b)).

Sourcing geography is disclosed: "The volumes of bio-feedstock purchased during the year remained broadly consistent with those of 2024; in particular, it should be noted that, as regards waste, these feedstocks are predominantly purchased from Indonesia and Malaysia, while vegetable oils are sourced from Europe and Africa" (p.191).

Resource outflows

Reference: Metrics pp.191-192 [ESRS 2 MDR-M; E5-4; E5-5]. Content index p.268 lists E5-5 with the SFDR paragraphs 37(d) and 39 datapoints and cross-references to Operating review: Refining and Chemicals and Resource use and circular economy: Metrics.

The principal outflow reported is waste, split by hazard class and destination on operated and consolidated-not-operated boundaries (p.192; see also the Waste entry).

Products and materials. Outflows in product terms are cross-referenced to the energy production table in the Climate Change chapter (p.168): biorefining capacity 1.65 Mt/year, and biofuel and renewable output alongside installed renewable capacity of 4,121 MW. The circular strand of production is described in the actions section as covering "extension of useful asset life, asset conversion and redevelopment; use of circular raw materials and alternative feedstocks; recycling and recovery technologies" (p.189), delivered through Enilive's biofuels and Versalis' "projects for the recycling of plastics and other materials" (p.189).

Waste

Reference: Metrics / Waste p.192; material impact description p.189.

2025, operated boundary, with 2024 comparatives (p.192):

• Total waste generated 4.6 Mt (2024: 4.4)
• Total hazardous waste 0.5 Mt (2024: 0.6); hazardous waste recovered/recycled 0.08 Mt (2024: 0.09); hazardous waste for disposal 0.4 Mt (2024: 0.6)
• Non-hazardous waste recovered/recycled 0.9 Mt (2024: 0.8), of which 0.6 recycled; non-hazardous waste for disposal 2.9 Mt (2024: 2.8), of which 0.1 to landfill and 2.8 to other disposal operations
• Total amount of non-recycled waste 77% (2024: 79%)

"In 2025, more than 4 million tonnes of waste were generated at Eni, of which 1.5 million tonnes from production activities and 3.1 million tonnes from remediation activities" (p.192). Production waste rose, "mainly driven by the increase in produced water at Eni Mediterranea Idrocarburi sites, in Sicily, the disposal of wastewater as waste at the Calenzano fuel depot (following the shutdown of the site water treatment plant due to the accidental event of December 2024), the volumes generated at the Livorno refinery in connection with the conversion of the site into a biorefinery, and those generated by construction works at the Porto Marghera biorefinery" (p.192).

Policies related to own workforce

Reference: Eni workforce / Policies p.199 [ESRS 2; MDR-P; S1-1]; Health & Safety / Policies p.207. Content index p.268 lists S1-1 with SFDR paragraphs 20, 22, 23.

Five instruments are tabulated at p.199:

• Code of Ethics - dissemination of knowledge; "strong focus on diversity and culture of plurality, with a commitment to creating an inclusive work environment that respects the dignity of each person".
• ECG Policy on Respect for Human Rights in Eni - "prohibition of any form of discrimination, distinction, exclusion or preference based on personal identifiers unrelated to the requirements necessary to perform a certain job"; "commitment to ensuring equal pay for women and men for work of equal value, based on objective criteria"; work-life balance and protection of maternity; and the "right of workers and employers to form trade union organizations, as well as the right to collective bargaining".
• ECG Policy on Diversity & Inclusion - prevention of discrimination on "colour, gender, religion, ethnic origin, political opinion, social origin or national ancestry, disability, gender identity, sexual orientation, social status, age".
• ECG Policy on Zero Tolerance against Violence and harassment in the workplace - "Prohibition, without exception, of all forms of violence and harassment in the workplace."

Processes for engaging with own workforce and workers' representatives about impacts

Reference: Employee engagement / Industrial relations pp.200-201 [S1 SBM-2; S1-2; S1-3; S1-8].

Nationally. Meetings under the INSIEME Industrial Relations Protocol, run by a dedicated industrial relations function, "including those of the Strategic Committee, which meets on a semi-annual basis or whenever necessary to address matters such as business unit divestments, workforce rationalisation and generational turnover, production site conversions, major organisational reviews, as well as issues related to the sustainable transition"; and bilateral commissions such as the Bilateral Committee on Agile Working (p.200).

Internationally. Eni established its European Works Council (EWC) in 1995, covering "activity programmes, investments, acquisitions or disposals of businesses, employment prospects, occupational health and safety, the energy transition pathway and sustainability", with Italian and European worker representatives, Italian unions and IndustriAll Europe. A European Observatory for Workers' Health, Safety and Environment shares accident and illness data (p.201).

"In January 2026, Eni signed the new Global Framework Agreement on International Industrial Relations, Corporate Social Responsibility and a Just Transition (GFA)", providing for annual engagement with international and European workers' delegates and IndustriALL Global Union (p.201).

Processes to remediate negative impacts and channels for own workforce to raise concerns

Reference: Employee engagement / Whistleblowing mechanisms and remediation processes p.201; Human Rights for Eni / Access to remedial measures, whistleblowing process and grievance mechanisms pp.197-198.

"In line with the commitments undertaken and in accordance with international standards, Eni has established mechanisms for receiving complaints and reports that can be used in the event of an alleged violations of human rights and consequently trigger a remediation process" (p.201).

The central channel is a dedicated platform at whistleblowing.eni.com, operated by an external service provider, "which guarantees the confidentiality of the identity of the whistleblower, the reported person and the contents of the communication". It provides separate channels for Eni SpA and for EU subsidiaries (proximity channels) under national law implementing EU Directive 2019/1937, and alternative tools including dedicated mailboxes and an integrated voicemail service (p.233). The governing instrument, Management of Whistleblowing Reports received by Eni SpA and by its Subsidiaries, has been in place since 2006 and was "most recently, in November 2025, aligned with national and international best practices" (p.232).

Taking action on material impacts on own workforce

Reference: Actions taken on material IROs pp.201-204 [ESRS 2 MDR-A; S1-4]; Health & Safety / Actions pp.208-210.

Actions are grouped into six areas: "(i) Human rights management model; (ii) Pay Equity; (iii) Work-life balance and welfare; (iv) Diversity & Inclusion; (v) People development and feedback; (vi) Training and skills development" (p.201).

Pay equity. Beyond the headline gender pay gap, "Eni performs additional analyses, based on the same objective factors mentioned above, in order to identify any unjustified gaps and implements appropriate corrective measures. In 2025, analyses conducted at comparable role and seniority levels identified an average global pay gap of 2.3%, which was not statistically significant and in line with 2024" (p.206).

Adequate wages. "Eni applies remuneration benchmarks in each Country of operation, that are significantly higher than applicable statutory or contractual minimum wages and above the 1 decile of the local remuneration market. The Company annually reviews the remuneration positioning of its workforce and adopts corrective actions where necessary" (p.206).

People development. "In 2025, performance evaluations covered 92% of Eni's executives, middle managers and young graduates. Full coverage was maintained for the executive population" (p.206).

Targets related to own workforce

Reference: Targets and commitments p.199 [ESRS 2 MDR-T; S1-5]; Health & Safety targets p.207.

Workforce targets, all on a fully consolidated scope (p.199):

Two targets are already ahead of their 2030 level; the internationalisation of leadership is moving backwards. The training target was cut from +15% to +10%, and Eni states why: "The reduction of the target from 15% to 10% reflects cost recovery initiatives launched in previous years" (p.199, note (a)).

Health and safety targets (p.207): TRIR at or below 0.50 for 2026-30 (2025 performance 0.55, against a 0.56 five-year average baseline); 85% of employees with access to psychological support services by 2028 (2025: 80%, from 68% in 2022); and 150 indoor air quality sensors installed by 2028 (2025: 140, from zero in 2022).

Characteristics of the undertaking's employees

Reference: Metrics pp.204-206 [ESRS 2 MDR-M; S1-6 ... S1-16].

Headcount at 31 December 2025 (p.204), with 2024 comparatives:

• Total employees 31,523 (2024: 31,669) - men 22,495, women 9,028
• By geography: Italy 21,591; Rest of Europe 4,182; Asia 2,514; Africa 1,791; Americas 1,358; Australia and Oceania 87
• Permanent employees 30,782 (women 8,812, men 21,970); fixed-term 741 (women 216, men 525)
• Full-time 31,118; part-time 405 (women 337, men 68)
• By age: under 30 2,965; 30-50 17,517; over 50 11,041

Movements (pp.204-206). "During the year, Eni carried out 2,790 hires (-6.4% ca. vs. 2024). Of these, 2,486 were permanent hires (-5% compared to 2024) with a proportion of female personnel equal to approx. 40.4%. Employees aged 30 or under accounted for around 46% of permanent recruitments. A total of 2,703 employment terminations were recorded (700 in Italy and 2,003 abroad). Of these, 2,378 involved employees on permanent contracts (-15% ca. vs. 2024)". The turnover rate was 7.5%, down 1.3 percentage points (2024: 8.8%).

Characteristics of non-employee workers

Reference: Metrics pp.204-205 [S1-7]. Listed in the content index at p.269 with a cross-reference to Eni workforce: Metrics.

Non-employees: 1,341 in 2025 (2024: 1,433), of whom 504 women and 837 men (2024: 526 and 907), reported under the label "Atypical temporary workers (agency workers, contractors, etc.)" (p.204) and again as "Non-employees" in the second metrics table (p.205).

The population is defined tightly: "Agency workers in Italy and abroad, calculated using the headcount methodology. Self-employed workers are excluded, as they are engaged under professional services contracts and are therefore classified as suppliers" (p.205, note (c)). Self-employed people are therefore covered by the S2 value chain workers chapter rather than here.

The trend is explained: "The number of non-employee workers varies according to business needs and operational flexibility requirements, as well as potential conversions into permanent contracts. Compared to 2024, the number of non-employee workers decreased slightly, mainly as a result of M&A transactions" (p.206).

Eni's own workforce boundary is stated in the S1 chapter: human capital "includes all direct employees operating in Italy and abroad. Contractors are excluded from this boundary and are instead considered as value chain workers" (p.200, note 102).

Collective bargaining coverage and social dialogue

Reference: Metrics pp.205-206; Employee engagement pp.200-201 [S1 SBM-2; S1-2; S1-3; S1-8].

Coverage (p.205): employees covered by collective bargaining - Italy 100%, abroad 48.3% (2024: 40.1%). Employees in trade unions 38.4% (2024: 36.7%), an indicator that within the European Economic Area "only Italy is considered, as it is the sole Country in which Eni operates with at least 50 employees and which represents at least 10% of the total workforce" (p.205, note (j)). The coverage indicator counts permanent employees "whose employment relationship is governed by collective agreements, whether at national, sectoral, company or site level, excluding individual agreements" (p.205, note (i)).

Eni explains the gap outside Italy rather than leaving it bare: "In Italy, all employees are covered by collective bargaining agreements in accordance with applicable legislation. Abroad, coverage by collective bargaining agreements amounts to 48.32%, reflecting the different regulatory frameworks in place across the Countries where Eni operates. In contexts where employees are not covered by collective bargaining agreements, Eni nevertheless ensures full compliance with applicable international and local labour legislation, as well as the application of higher protection standards guaranteed across the Group through Eni's worldwide corporate policies" (p.206).

Diversity metrics

Reference: Metrics pp.204-205 [S1-9]; targets p.199.

Gender (pp.204-205). Of 31,523 employees, 9,028 are women and 22,495 men. Among 878 employees in positions of responsibility (senior managers) in 2025 (2024: 926), 174 are women (19.8%) and 704 men (80.2%); in 2024 the figures were 173 women (18.7%) and 753 men (81.3%). Women hold 28.6% of the workforce overall and 30.8% of leadership roles (senior and middle managers), both measured against 2020 baselines of 24.6% and 26.6% (p.199).

Age (p.205). Under 30: 2,965; 30-50: 17,517; over 50: 11,041. The average age of the global workforce rose to 45.3 years (46 in Italy, 43.6 abroad) from 44.9 in 2024, "mainly due to the lower turnover rate" (p.206). Employees under 30 are 9.4% of the workforce against a 2020 baseline of 6.6% and a 2030 target of +6.5 p.p. (p.199).

Nationality (p.205). Local employees abroad 85% (2024: 85%). Non-Italian employees in positions of responsibility 16.7%, down from 17.4% in 2024 and below the 2020 baseline of 18.6% - the one workforce target moving in the wrong direction (p.199).

Board-level diversity is disclosed separately in the Governance section: the by-laws require at least 2/5 of the less represented gender on the administrative and supervisory bodies for six consecutive terms (p.34).

Adequate wages

Reference: Metrics / Remuneration and adequate wages p.206 [S1-10]; content index p.269 cross-references S1-10 to Eni workforce: Metrics.

Eni describes its benchmark-based approach rather than reporting a single adequate-wage percentage:

"To ensure adequate and decent wages, Eni applies remuneration benchmarks in each Country of operation, that are significantly higher than applicable statutory or contractual minimum wages and above the 1 decile of the local remuneration market. The Company annually reviews the remuneration positioning of its workforce and adopts corrective actions where necessary" (p.206).

The reference points used are disclosed: "Benchmarks include statutory or contractual minimum wages and the minimum remuneration levels of medium-to-large local companies, which are well above the poverty thresholds defined by Eurostat for the European Union and by Wage Indicator for other Countries" (p.206).

The policy basis is the ECG Policy on Respect for Human Rights in Eni, which commits Eni "to ensuring equal pay for women and men for work of equal value, based on objective criteria" (p.199).

Training and skills development metrics

Reference: Metrics pp.205-206 [S1-13]; targets p.199.

2025, with 2024 comparatives (p.205):

• Total training hours 1,058,622 (2024: 1,027,822)
• Average training hours per employee 33.5 (2024: 32.1); average for women 27.5 (2024: 27.1); average for men 35.9 (2024: 34.0)
• Employees covered by performance assessment tools (senior managers, middle managers, young graduates) 92% (2024: 94%); women 91% (2024: 95%), men 93% (2024: 94%)

Average hours are calculated as "total training hours divided by the average number of employees during the year" (p.205, note (f)). The performance-review indicator covers "employees to whom a set of objectives was assigned (for managers, middle managers and young graduates) or who were subject to an annual performance review" (p.205, note (e)).

"In 2025, a slight increase was recorded across the various indicators compared to the previous year. In particular, total training hours increased by 3%, while average total hours per employee rose by 4.4%. Total training expenditure and average expenditure per employee also increased, by 2.5% and 4.1% respectively. During the year, more than one million training hours were delivered, 77% of which were completed by men and 23% by women, consistent with the previous year, with a 1.5% increase in average hours per woman" (p.206).

Health and safety metrics

Reference: Health & Safety / Metrics pp.211-212 [ESRS 2 MDR-M; S1-14]. Content index p.269 flags phase-in for paragraph 88(b) and (c) in respect of non-employees and for paragraph 88(e) on occupational illnesses, including for non-employees.

2025, employees and contractors reported separately, with 2024 comparatives (p.211):

"In 2025, the Total Recordable Injury Rate (TRIR) improved compared to 2024, both for contractors and employees... In addition, during the year there were neither fatal events nor events resulting in permanent disability. The Fatality Index was equal to zero for both employees and contractors" (p.211) - against five contractor fatalities in 2024. Lost days rose sharply for both groups even as injury counts fell.

Work-life balance metrics

Reference: Metrics p.205 [S1-15]; content index p.269 cross-references S1-15 to Eni workforce: Metrics.

2025, with 2024 comparatives (p.205):

• Employees who are entitled to parental leave: 100% (2024: 100%)
• Employees who have taken parental leave: 4% (2024: 3%); women 10% (2024: 6.8%), men 4% (2024: 3%)

Part-time working is reported alongside: 405 employees on part-time contracts in 2025 (2024: 421), of whom 337 women and 68 men - part-time is overwhelmingly taken by women, and the absolute number fell year on year (p.205).

Work-life balance is one of the six action areas in the S1 chapter, listed as "(iii) Work-life balance and welfare" (p.201), and is a stated engagement objective with people and unions: "Promote work-life balance" (p.144).

The policy basis is the ECG Policy on Respect for Human Rights in Eni, with a "commitment to ensuring a work-life balance and well-being within the organization, promoting measures to support parenthood, protecting maternity and guaranteeing the right to non-discrimination held by people with family responsibilities" (p.199).

Compensation metrics (pay gap and total compensation)

Reference: Metrics pp.205-206 [S1-16]. Content index p.269 lists S1-16 with SFDR paragraph 97(a) and Benchmark Regulation, and SFDR paragraph 97(b).

2025, with 2024 comparatives (p.205):

• Gender pay gap: 10% (2024: 6.8%)
• Total Remuneration Ratio: 138 (2024: 157)

The gender pay gap is "the difference between the average hourly remuneration of the male employees and the average hourly remuneration of the female employees, divided by the average hourly remuneration of the male employees; the indicator includes benefits in kind and allowances" (p.205, note (g)). The Total Remuneration Ratio is "the ratio between the remuneration of the CEO/Managing Director and the median employee remuneration... The indicator is based on fixed remuneration and total remuneration, which from 2024 onwards, also includes benefits in kind and allowances" (p.205, note (h)).

Both movements are explained. The ratio fell "mainly due to the lower value of the long-term share-based incentive" (p.206). The pay gap widened: "The global Gender Pay Gap amounted to 10%, increasing compared to the previous year following the integration of newly acquired companies in Countries characterised by heterogeneous workforce distribution structures and remuneration levels compared to other Countries" (p.206).

Incidents, complaints and severe human rights impacts

Reference: Human Rights for Eni / whistleblowing metrics and Disputes and non-judicial remedy mechanisms p.198 [TAXO; S1-17; S2-4; S3-4; S4-4].

Whistleblowing files (assertions) on human rights violations closed during the year, 2025 with 2024 comparatives (p.198):

• Files closed: 40 (68 assertions) in 2025, versus 32 (64) in 2024; of which employees 14 (2024: 11)
• Substantiated assertions: 16 (2024: 10)
• Unsubstantiated, not ascertainable or not applicable assertions: 52 (2024: 54)
• Inherent incidents of discrimination: 7 (2024: 3) - "of which one episode showed elements of substantiation" in 2025; in 2024 "the alleged episodes of discrimination did not show elements of substantiation"
• Assertions on human rights violations with potential socio-economic impacts on local communities: 1 (2024: 0), which "did not show elements of substantiation"
• Assertions with potential impacts on health, safety and/or well-being of local communities: 0 (2024: 1, comprising 2 assertions, neither substantiated)

Employee figures "are collected exclusively with reference to non-anonymous whistleblowing reports" (p.198, note (b)).

Policies related to value chain workers

Reference: Workers in Eni's value chain / Policies p.213 [ESRS 2 MDR-P; S2-1].

Six instruments are tabulated (p.213):

• Code of Ethics - expectation that business partners adopt socially responsible behaviour; "where these expectations are not met, Eni reserves the right to take appropriate measures".
• ECG Policy on Respect for Human Rights at Eni - respect for human rights across the supply chain through "(i) a dedicated supplier assessment model with a focus on human rights; (ii) contractual obligation to comply with... Eni's Code of Ethics and Supplier Code of Conduct"; and commitment "to identify and fight human rights violations across its supply chain, including forced labour, modern slavery and labour exploitation".
• Supplier Code of Conduct - "prohibition of child labour, forced, undeclared or compulsory labour, human trafficking and all forms of modern slavery", and the expectation that suppliers provide their own remedial mechanisms; "aligned with the ILO Declaration on Fundamental Principles and Rights at Work".
• Eni's Position on Conflict Minerals - reducing "the risk of human rights violations... related to the extraction, production and supply of certain minerals in conflict areas of Central Africa".
• Internal Regulatory System - a risk-based model and operational procedures for managing human rights within procurement.

Processes for engaging with value chain workers about impacts

Reference: Engagement of the workers in the value chain p.214 [S2 SBM-2; S2-2; S2-3].

Eni is explicit that engagement is mediated: "Engagement activities involving workers in the value chain take place primarily through the supplier, as the legal entity, and are embedded throughout all phases of interaction with Eni - from supplier qualification to sourcing and contract execution" (p.214).

Activities are coordinated by the central procurement function with business procurement units and requesting units, and include: "(i) workshops and training on human rights and other social matters; (ii) workshops on health and safety-related topics; (iii) training activities on sustainability and the energy transition; (iv) training on anti-corruption matters; (v) training on responsible supply chain management" (p.214).

Direct contact with workers is reserved for higher-risk cases: "For companies considered to be more exposed to potential negative impacts according to the risk-based model, onsite audits are carried out, including interviews with the workforce on human rights-related aspects and business conduct" (p.214).

Effectiveness "is assessed through periodic evaluations of suppliers' performance, conducted through audits and reviews, followed by monitoring the implementation of jointly agreed action plans to address any identified gaps" (p.214).

Processes to remediate negative impacts and channels for value chain workers to raise concerns

Reference: Whistleblowing mechanisms and remediation processes [S2-3] p.214; Human Rights for Eni pp.197-198; Content index p.270.

"In line with its commitments and in compliance with international standards, Eni has established mechanisms for receiving complaints and reports, which are also accessible to suppliers' workers. These mechanisms may be used in cases of alleged human rights violations and can trigger a remediation process, including through collaboration with third parties" (p.214).

The channel is the same platform used for employees - whistleblowing.eni.com, operated by an external provider, open to "anyone who works or has worked in Italy or abroad in the name, on behalf, or in the interest of the Company", including anonymously (pp.232-233). "Eni also expects its suppliers to provide workers and communities with their own reporting and remedy mechanism, which should also be accessible on an anonymous basis" (p.214).

Taking action on material impacts on value chain workers

Reference: Actions taken on material IROs pp.215-216 [ESRS 2 MDR-A; S2-4]; Health & Safety pp.209-210; Sustainable supply chain management pp.236-237.

Measures are structured around four areas: "(i) safeguards in the procurement process; (ii) training and awareness-raising activities; (iii) health and safety of workers in the supply chain; (iv) the definition of a governance oversight model of the other business partners" (pp.214-215).

Risk-based supplier model (p.215). Suppliers are classified by "(i) the supplier's Country risk, derived from data provider information (Maplecroft)... and (ii) the risk of the activities performed, assessed by considering vulnerabilities related to specific conditions, such as labour intensity, the level of training and skills required for tasks, and health, safety, and environmental risks". Controls are "inspired by international standards such as SA8000: the higher the potential risk of negative impacts associated with a supplier, the more detailed the assessment and the actions undertaken." All companies must sign the Supplier Code of Conduct to obtain or maintain supplier status; contracts include human rights clauses and, in higher-risk cases, audit rights at the supplier's premises and rights to suspend or terminate.

Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

Reference: Targets and commitments p.213 [ESRS 2 MDRT; S2-5]; Sustainable supply chain management / Targets p.235.

The S2 chapter itself sets no separate numeric targets and says where they sit: "The targets set by Eni regarding respect for workers' human rights across its value chain are part of the broader objectives related to suppliers' ESG assessment and their engagement in achieving a fair and sustainable transition, as further detailed in the relevant section Sustainable Supply Chain Management, while for health and safety topics please refer to the Health & Safety section" (p.213).

Supply chain targets (p.235):

• "Maintain ESG assessments in procurement processes for more than 90% of the Italian awarded contracts" by 2025 - 97%, target achieved, from a 2023 baseline of 20%
• "Procurement processes with ESG assessment for over 90% of awarded contracts at Group level" by 2026 - the previously separate non-Italian target has been "incorporated into this broader target, which considers Group level procurement"

Policies related to affected communities

Reference: Local communities / Policies p.217 [ESRS 2 MDR-P; S3-1]; Human Rights for Eni pp.195-197. Content index p.271 lists S3-1 with SFDR paragraph 17 and the Benchmark Regulation.

Local communities are a material topic for Eni, with seven material impacts identified - one positive and six negative (p.148). The policy framework is anchored in the Code of Ethics and the ECG Policy on Respect for Human Rights in Eni, which is aligned with the United Nations Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises (p.142).

Eni's approach to communities rests on the "Dual Flag" model, described in the business model as based "on a deep respect for the individual, on knowledge of local instances and on the willingness to engage alongside countries to promote the sustainable development, also through partnerships with nationally and internationally recognized actors" (p.13). Priority areas of intervention are "access to energy, economic diversification, education and vocational training, access to water and sanitation services, health, and life on land" (p.217).

Processes for engaging with affected communities about impacts

Reference: Community engagement pp.219-220 [S3 SBM-2; S3-2; S3-3].

"Eni and its subsidiaries carry out engagement with local communities, including indigenous peoples and vulnerable groups, through free, prior and informed consultations. Responsibility for these consultations lies with the local Managing Director, supported by the Sustainability unit at both local and central level. In some contexts, dedicated liaison figures are also appointed to maintain ongoing relationships" (p.219).

Communities affected are identified "before any business activity begins in which Eni acts as operator", and the same approach applies to certain joint ventures where Eni plays a significant role in managing local stakeholders. The assessment covers communities within Eni's operational areas and those designated by national governments, "for example in offshore development zones", and may extend beyond the defined area of influence taking account of host-country agreements and National Development Plans (p.218).

Processes to remediate negative impacts and channels for affected communities to raise concerns

Reference: Whistleblowing mechanisms and remediation processes - Grievance Mechanism pp.219-220 [S3-3]; metrics p.223.

Alongside the whistleblowing platform, "Eni has defined and applies guiding principles for the management of Grievance Mechanisms, for which operational responsibility lies with all subsidiaries. These entities analyse the grievances and agree the resolution with the complainants, whether individuals or communities. Any request or complaint received is handled and monitored until closure through agreements with the parties concerned and a response is provided even when the issue is not directly related to Eni's activities" (p.219).

Access channels are deliberately plural: "online channels (including a dedicated e mail address and the institutional websites of subsidiaries), or physically at administrative/operational offices or via collection boxes located in areas affected by the project" (p.219).

All grievances "are tracked in the Stakeholder Management System... classified by topic and relevance, and the rate of resolution is monitored. The system also tracks timeliness of management, trends in recurring issues and potential escalation towards disputes" (p.219). "In relevant Countries, Eni conducts quarterly reviews on the status of grievances" (p.220).

Taking action on material impacts on affected communities

Reference: Actions taken on material IROs pp.220-223 [ESRS 2 MDR-A; S3-4]; metrics p.223.

Actions are grouped as "(i) environmental, social and health impact assessment (ESHIA) studies; (ii) Eni's management system for human rights; (iii) management of any resettlement and related compensation measures; (iv) local development projects; (v) security activities" (p.220). The starting point is analysis of the local socio-economic context "including the global Multidimensional Poverty Index" (p.220).

ESHIA (p.220). "In 2025, with the objective of evaluating potential health impacts on the communities involved, Eni completed 11 studies: 7 integrated into ESHIA processes in Oman, Indonesia and Cyprus, and 4 specific health studies, of which 3 in Italy and 1 in Cote d'Ivoire." For each ESHIA an Environmental and Social Management Plan is prepared, incorporating human rights measures and shared with the relevant authorities.

Local development (p.223). 2025 investment by sector: access to energy EUR 81.0 million (2024: 88.8); economic diversification EUR 43.1 million (2024: 46.0); education and vocational training EUR 21.3 million (2024: 25.4); access to water and sanitation EUR 1.6 million (2024: 0.9); life on land EUR 6.2 million. "For the next five years, Eni has allocated investments of approximately EUR 401 million for local development."

Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

Reference: Targets and commitments pp.217-218 [ESRS 2 MDR-T; S3-5].

Targets are "defined through a bottom up approach, bringing together individual initiatives and grouping them by specific indicators for each area of intervention, in line with the United Nations Sustainable Development Goals" and "were defined through direct engagement with stakeholders. For initiatives related to healthcare services, local health authorities were also involved in the process" (p.217).

Two of the tabulated targets (p.218):

• 20 million people supported in accessing sustainable energy through the distribution of improved cooking systems (clean cooking) by 2030; 2025 performance approximately 2.2 million people reached, against a 2023 baseline of 275,000 people reached. Applicable to all business lines.
• 315,000 new students supported in accessing education at primary, secondary and tertiary levels by 2030.

Further targets cover the remaining priority areas: economic diversification, access to water and sanitation services, health, and life on land (p.217).

Policies related to consumers and end-users

Reference: Customers and consumers / Policies p.224 [ESRS 2 MDR-P; S4-1].

Five instruments are tabulated (p.224):

• Code of Ethics - "Principle of transparent management of relationships with customers and consumers, inspired by best practices and the principle of professional loyalty"; "building commercial relationships focused on customer needs, enabling customers to choose freely and consciously".
• ECG Policy on Privacy and data protection - roles and responsibilities "for the collection, use, retention and deletion of data, including appropriate technical organizational measures for data protection".
• ECG Policy on Consumer Protection & Green Claims - "Compliance with rules and principles on consumer protection and on accurate environmental and sustainability communication (Green Claims and Sustainability Claims)", and tools "aimed at preventing the risk of breaches, including 'inadvertent' breaches, of Consumer Protection Regulation".
• Internal Regulatory System - compliance "with all regulations aimed at safeguarding fair competition and consumers' right to receive clear, accurate and comprehensive information on the products and services offered".

Material customer impacts sit primarily with Plenitude, "due to the existence of an ongoing contractual relationship" (p.225).

Processes for engaging with consumers and end-users about impacts

Reference: Customer engagement pp.225-226 [S4 SBM-2; S4-2; S4-3].

"Within Plenitude, there is a dedicated team responsible for market analysis and customer listening, aimed at identifying needs and areas for improvement, consumption trends, socio-economic developments and main concerns" (p.225).

Scale of research in 2025. "Each year, a wide range of qualitative and quantitative market research initiatives is carried out through multiple channels, including online, telephone and in-person surveys, with the support of specialised research institutes and companies operating in Italy and abroad, in line with recognised industry quality standards. In 2025, more than 120 research projects were conducted, involving over 190,000 current and potential customers. In addition, an initiative aimed at listening to calls made to the toll-free customer service number continued throughout the year" (p.225).

Measurement. "Customer satisfaction is monitored on a continuous basis and is measured as the percentage of customers assigning an overall satisfaction score above 7 out of 10 to Plenitude as an energy supplier." Additional KPIs include the Net Promoter Score and the complaint rate (p.225).

Processes to remediate negative impacts and channels for consumers and end-users to raise concerns

Reference: Reporting mechanisms and remediation processes p.226 [S4-3]; Human Rights for Eni pp.197-198.

"In Italy, Plenitude manages customer reports in compliance with the regulations of the Authority for Energy, Networks and Environment (ARERA). These reports are analysed both qualitatively and quantitatively to understand customer issues and to activate corrective actions" (p.226).

Channels (p.226). "Customers may submit reports through multiple channels, including remote channels (website, customer area/app, chat, call centre, e-mail and postal service), a dedicated assistance service in Italian Sign Language, as well as direct and indirect physical channels across the territory. Information on available contact channels is provided on eniplenitude.com, on bills and within commercial and contractual documentation. Regardless of the channel used, Plenitude ensures the receipt, analysis and handling of reports, including anonymous submissions, while guaranteeing the highest level of confidentiality."

Taking action on material impacts on consumers and end-users

Reference: Actions taken on material IROs p.226 [ESRS 2 MDR-A; S4-4].

"Plenitude provides for the implementation of several actions to remedy potential negative impacts on customers and consumers. The effectiveness of these actions is monitored through operational indicators (such as unsolicited activations, complaint rate, NPS, etc.) on a monthly or weekly basis" (p.226).

Actions are grouped as "(i) actions for customer management; (ii) customer protection and fraud management; (iii) initiatives for vulnerable customers; (iv) customer engagement in the energy transition" (p.226).

Control of the sales channel (p.226). Consumer protection mechanisms "also extend to intermediaries carrying out commercial activities on its behalf. All sales operators are subject to a preliminary assessment aimed at verifying their financial soundness, sector-specific experience, the adequacy of their commercial structure and their technical and commercial training requirements", after which their personnel must complete a mandatory training programme.

Vulnerable customers. Plenitude "engages with relevant Authorities and institutions at both national and local level, through consultations and hearings, including on matters related to the protection of vulnerable customers" (p.226).

Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

Reference: Targets and commitments pp.224-225 [ESRS 2 MDR-T; S4-5].

Tabulated targets (p.225):

Eni explains both the miss and the plan change. On digital contracting: performance "reached 86% in 2025 (vs. a 90% target), mainly due to the different levels of digital maturity across the European Countries considered and to the different mix of customer acquisition channels" (note (c)). On charging points: the installation plan "has been updated compared to the disclosures set out in the 2024 Sustainability Statement, in response to market trends" (note (a)).

"Customer service performance is monitored on a weekly basis through business review processes" (p.224).

Business conduct policies and corporate culture

Reference: Business conduct / Policies p.229 [ESRS 2 MDR-P; G1-1]; Actions taken on material IROs pp.230-233. Content index p.272 records the SFDR paragraph 10(d) whistleblower datapoint as "NOT APPICABLE - there are 'whistleblowers' policies in place".

Three instruments are tabulated (p.229):

• Code of Ethics - "Commitment to act in line with the values of responsibility, integrity and fairness, and with a culture of legality and transparency"; and to "prohibit and fight all forms of corruption, in favour of anyone, without exception, through the adoption of rules and controls".
• ECG Policy on Anti-Corruption - "Prohibition, without exception, all forms of corruption, active, passive, direct and indirect, in favour of and by anyone"; prevention of corruption and money laundering with rules "to verify ethical-reputational reliability of potential counterparties"; and promotion of training and awareness for Eni people and third parties.
• Management of Whistleblowing Reports received by Eni SpA and by its Subsidiaries - a system "aimed at encouraging the reporting of misconduct and guaranteeing the confidentiality of the whistleblower and other subjects involved, protecting them from retaliatory consequences".

Management of relationships with suppliers

Reference: Sustainable supply chain management pp.235-237 [G1-2]; Metrics p.237.

The strategy rests on three pillars (p.236):

Systemic and inclusive approach. Eni promotes Open-es, "launched with Boston Consulting Group and Google Cloud in 2021, to create a multi-stakeholder initiative among the industrial, financial and associative sectors to support companies in the process of measuring and improving their ESG performance. To date, more than 30 partners have joined... and over 40,000 companies have registered, of which over 9,400 belong to Eni's supply chain."

Development of best practices. Tools for measuring ESG maturity with peer benchmarking; "Sustainable Supply Chain Finance" (launched 2023) for early invoice payment without impact on credit lines - "In 2025, invoice advances were granted for a total amount of approximately EUR 240 million"; and the "Energia di filiera" programme for SMEs in areas affected by Eni's industrial transformation, focused in 2025 on the Versalis Transformation Plan and "involving more than 200 SMEs, half of them contractors located in the Italian industrial districts of Brindisi, Priolo, and Ragusa".

Metrics (p.237): suppliers on Open-es 9,416 (2024: 7,512); active contracts with those suppliers 80% (2024: 70%); value of those contracts 91% (2024: 82%).

Prevention and detection of corruption and bribery

Reference: Actions taken on material IROs pp.230-234 [ESRS 2 MDR-A; G1-1; G1-3; G1-4].

Risk assessment (pp.230-231). Eni runs "a structured Compliance Risk Assessment and Monitoring process aimed at: (i) identifying, assessing and tracking corruption risks within its business activities...; (ii) periodically analysing trends in identified corruption risks...; (iii) contributing to the identification of Eni employees most exposed to corruption risk". Activities identified as exposed include contracts with third parties such as intermediaries, consultants, joint-venture partners and brokers; acquisitions and disposals of equity interests and exploratory mineral rights; non-profit initiatives and sponsorships; sale of goods and services and trading or shipping; hiring; gifts and hospitality; and relationships with public administrations and public officials.

"During 2025, Compliance Monitoring activities focused on the risk areas of 'Joint Ventures', 'Sponsorships and Non-Profit Initiatives', and 'Transactions for the acquisition, disposal and management of exploratory mineral rights'; the outcomes of the analysis confirmed the expected level of risk, as well as the overall adequacy and effectiveness of Eni's anti-corruption compliance model" (p.231).

Targets related to business conduct

Back-filled from the business conduct chapter, where targets are addressed as part of the MDR-T disclosures rather than as a numbered disclosure requirement. G1-3 became a standalone DR only in the 2025/2026 ESRS; the content index lists the topic under "ESRS 2 Targets MDR-T" rather than a numbered G1 targets DR (p.272).

Eni discloses commitments rather than outcome-based numeric targets: "Eni has defined specific commitments on business conduct matters, shared with its stakeholders, relating to the maintenance of ISO 37001:2016 and ISO 37301:2021 certifications, the continuous improvement of its Anti-Corruption Compliance Programme and training on the Programme for personnel exposed to medium and high levels of risk" (p.229).

Consistent with the MDR-T alternative limb, effectiveness is tracked in the absence of quantified targets:

Incidents of corruption or bribery

Reference: Actions taken on material IROs pp.230-231 [G1-4]. Content index p.272 lists G1-4 with SFDR paragraph 24(a) and the Benchmark Regulation, and SFDR paragraph 24(b).

Convictions and cases. "In 2025, neither the Company nor members of senior management were involved in criminal proceedings resulting in final convictions for violations of anti-corruption regulations" (p.230), with further detail cross-referenced to Note 28 "Guarantees, commitments and risks" of the consolidated financial statements.

"As in 2024, in 2025 the number of substantiated corruption cases relating to Eni SpA was 0 and, consequently, no dismissals related to such cases occurred" (p.231). Substantiated cases are defined as "final convictions relating to criminal proceedings for domestic and/or international corruption in which the occurrence of a corruption offence has been established on the merits" (p.231, note 140).

For ongoing proceedings and "the total number of significant cases of non-compliance with laws and regulations (including any anti-competitive behaviour and violations of antitrust and monopoly regulations)", the statement cross-refers to the Legal proceedings section of the Annual Report (p.231).

Political influence and lobbying activities

Reference: Institutional Engagement Activities [G1-5] pp.233-234.

"Eni engages in dialogue with policymakers both directly and indirectly through trade associations, without providing political contributions" (p.233).

2025 activity (pp.233-234). Engagement focused on "(i) participation in economic promotion initiatives, meetings and roundtables...; (ii) presenting Eni's positioning on energy transition and decarbonisation at public events and major international multilateral forums (e.g., B7, B20, COP30); (iii) engaging and maintaining dialogue with institutions - also through partnerships and memberships - as well as with think tanks, associations and international organisations...; (iv) presenting projects and organising visits for institutional delegations, political representatives and associations to industrial facilities, operational sites and research centres."

Payment practices

Reference: Supplier payment practices [G1-6] p.237; Other information p.275.

"In line with an approach based on transparency and fairness in supplier management, Eni has adhered to the Italian Responsible Payments Code, established by Assolombarda in 2014" (p.237).

Standard terms. "Generally, supplier payments at Eni are managed according to uniform criteria and standardized procedures, without distinction by type, size, or geographical location. Eni's standards establish a supplier payment term of 60 days for contracts under private law and 30 days for those governed by the Public Contracts Code (Italian Legislative Decree No. 36/2023). Individual contracts of Eni SpA and its subsidiaries adopt this payment terms, except in cases where applicable regulations or specific business requirements dictate otherwise" (p.237).

Actual payment time. The Other information section reports: "In 2025, payments to Eni's suppliers were made within 45 days, in line with contractual provisions" (p.275).

Legal proceedings. "During the reporting period, no judicial proceedings were pending in Italy against Eni SpA or its Italian subsidiaries regarding late payments to their suppliers" (p.237).