On February 14, 2022, a group of Italian NGOs and environmental movements submitted a climate-related complaint to the National Contact Point of the OECD (Organization for Economic Cooperation and Development) alleging the inadequacy of the business plan pursued by the oil company ENI. Specifically, the complaint highlights that ENI has committed to net zero emissions by 2050, but its actions run contrary to this goal. For example, ENI plans to increase its oil production by 4% each year until at least 2024, and is proposing to rely on large amounts of negative emissions technology (7 million tonnes of CO2 stocked each year by 2030). The complaint alleges that ENI has not complied with the OECD Guidelines for Multinational Enterprises due to: (i) the fact that the company's strategic plan does not foresee a sufficient cut in GHG emissions in the coming years; (ii) the lack of a climate impact assessment of the company's activities; (iii) the absence of transparent and adequate information; and (iv) the failure to develop a plan for risk prevention and mitigation. As the National Contact Point is a non-judicial grievance mechanism, the applicants have requested mediation with ENI. The complaint follows a notice to desist sent to the company by the Legality for Climate Network on July 26, 2021.

Key environmental legal questions:

Whether the industrial plan of ENI is compatible with the current climate emergency.