In order to comply with the relevant legislation (Legislative Decree 24/2023), Università degli Studi Guglielmo Marconi has adopted a whistleblowing system through which it is possible to report, to the competent bodies, any violations identified within the workplace in a confidential and protected manner.
Below are the main useful pieces of information regarding the reporting methods and channels, as well as the management of reports.
Reports
Reports consist of written or oral communications of information regarding violations, namely behaviors, acts, or omissions that harm the public interest or the integrity of the University and that relate to:
- administrative, accounting, civil, or criminal offenses not falling within the conduct indicated below (numbers 2, 3, 4, 5);
- violations falling within the scope of application of European Union or national acts indicated in the annex to Legislative Decree 10 March 2023, n. 24, or national acts implementing EU acts listed in the annex to Directive (EU) 2019/1937, even if not specifically listed in the aforementioned annex, relating to the following sectors:
- public procurement
- financial services, products and markets and prevention of money laundering and terrorist financing
- product safety and compliance
- transport safety
- environmental protection
- radiation protection and nuclear safety
- food and feed safety and animal health and welfare
- public health
- consumer protection
- protection of privacy and personal data and security of networks and information systems acts or omissions affecting the financial interests of the European Union referred to in Article 325 of the Treaty on the Functioning of the European Union, as specified in the relevant EU derived law;
- acts or omissions concerning the internal market, referred to in Article 26(2) of the Treaty on the Functioning of the European Union, including violations of EU competition and State aid rules, as well as violations relating to the internal market connected with acts that breach corporate tax rules or mechanisms aimed at obtaining tax advantages that undermine the purpose of applicable corporate taxation legislation;
- acts or behaviors that undermine the object or purpose of the provisions of EU acts in the sectors indicated above;
- violations of Legislative Decree no. 231 of 8 June 2001 and/or violations of the Organization and Management Model adopted by the University pursuant to that legislation.
The Whistleblower
Any individual who has a working relationship with UNIMARCONI may submit a report (the whistleblower), regardless of their legal or contractual status. This protection extends beyond the duration of the employment relationship and includes:
- all employees;
- self-employed workers carrying out activities at the University, including:
- self-employed workers referred to in Chapter I of Law no. 81/2017, including those with autonomous work relationships governed by Title III of Book V of the Italian Civil Code, including service contracts under Article 2222;
- holders of collaborative relationships referred to in Article 409 of the Italian Code of Civil Procedure, including coordinated and continuous collaborations primarily of a personal nature;
- collaborators referred to in Article 2 of Legislative Decree no. 81/2015, i.e., collaborations organized by the client that consist of exclusively personal and continuous work whose execution methods are organized by the client (“hetero-organization”);
- freelancers and consultants providing services to the University;
- volunteers and trainees, both paid and unpaid, who carry out activities at the University;
- workers or collaborators working for organizations that supply goods or services to the University or carry out work on its behalf;
- persons performing functions of administration, management, control, supervision, or representation within the University, even if such functions are exercised de facto.
Reporting Channels
A) Internal Channels at UNIMARCONI
Internal reports must be addressed to the persons responsible for receiving and managing them, namely the Director of the Prevention and Protection Department (DDPP); or, in the event of a conflict of interest involving the DDPP, the Deputy Director General (for example, when the report concerns conduct by the DDPP).
According to the applicable legislation, reports may be made in written or oral form.
Written Reporting Channels
Written reports may be submitted through:
- an online IT platform, accessible via the footer of the institutional website of Università degli Studi Guglielmo Marconi or through the link:
https://whistleblowersoftware.com/secure/9ad68892-2561-4b13-93ab-26da8c60a668 - postal service (ordinary mail or registered mail with return receipt), addressed to:
Director of the Prevention and Protection Department –
Università degli Studi Guglielmo Marconi
Via Plinio n. 44, 00193 Rome
with the wording “confidential personal – whistleblowing”
or
Deputy Director General –
Università degli Studi Guglielmo Marconi
Via Plinio n. 44, 00193 Rome
with the wording “confidential personal – whistleblowing”
(only if the report concerns conduct by the DDPP)
- hand delivery at the University premises (in a sealed envelope addressed to the DDPP with the wording “confidential personal – whistleblowing”).
This option is available only for internal staff reporting directly to the DDPP.
Due to security procedures at the premises, it is not possible for external persons to deliver a document by hand while maintaining anonymity.
When using postal service or hand delivery, the report must be placed in two sealed envelopes:
- the first containing the identifying details of the whistleblower together with a copy of an identity document;
- the second containing the report itself, so as to separate the whistleblower’s identity from the report.
Both envelopes must then be placed inside a third sealed envelope marked “confidential personal – whistleblowing.”
Oral Reporting Channels
Oral reports may be made through:
- telephone line by calling 06.37725510.
The line is not recorded. The report will be documented in writing by the DDPP through a detailed report of the conversation. The whistleblower may verify, correct, and confirm the transcription by signing it. - direct meeting with the DDPP, to be scheduled within 10 days of the request.
This option is also available only for internal staff due to security procedures that do not allow confidentiality to be guaranteed for external visitors.
These two options are not available for reports addressed to the Deputy Director General.
Within the University, the persons responsible for receiving and managing reports are:
- the Director of the Prevention and Protection Department (DDPP);
- the Deputy Director General, only when the report concerns conduct by the DDPP.
If a report is submitted to a person other than those authorized, and the whistleblower explicitly states or it can be inferred that they wish to benefit from whistleblowing protections, the report will be considered a whistleblowing report and must be forwarded to the competent internal body within seven days, notifying the whistleblower.
Otherwise, the report will be treated as an ordinary report, without the specific protections provided by Legislative Decree 24/2023.
Reports should be as detailed as possible, including:
- time and place of the reported event;
- description of the facts;
- identity or identifying elements of the person responsible.
Supporting documents and information on other persons potentially aware of the facts may also be included.
Anonymous reports are accepted only if sufficiently detailed and documented. They will be treated as ordinary reports, without the protections provided by Legislative Decree 24/2023.
B) External Channel
An additional reporting channel is available through the online platform of Autorità Nazionale Anticorruzione (ANAC) at:
https://whistleblowing.anticorruzione.it/#/
The whistleblower may use this channel if:
- they have already submitted an internal report to UNIMARCONI and no action has been taken within a reasonable period (at least 3 months);
- they have reasonable grounds to believe that using internal channels could result in ineffective follow-up or risk of retaliation;
- they reasonably believe the violation represents an imminent or evident danger to the public interest, such as threats to health, safety, or the environment.
Not all violations can be reported externally to ANAC. Violations of a criminal or financial nature fall outside the Authority’s competence.
Management of Reports
The manager of the reporting system will maintain communication with the whistleblower by:
- confirming receipt of the report within 7 days;
- providing feedback on the outcome of the investigation within 3 months from the acknowledgment of receipt.
Protection and Responsibility of the Whistleblower
The University guarantees protection against any form of retaliation connected directly or indirectly with the report, provided the report is made in good faith.
Protection also extends to: facilitators; persons in the same work environment; colleagues; legal entities owned by the whistleblower or connected to them; entities where the whistleblower works; anonymous whistleblowers who are subsequently identified.
The identity of the whistleblower and any information that may reveal it cannot be disclosed without the whistleblower’s explicit consent, except to authorized personnel responsible for handling the report and subject to legal obligations.
Sanctions are provided for anyone violating whistleblower protection measures.
Protections do not apply in cases of reports made with malicious intent or gross negligence that prove to be false, defamatory, or intended solely to harm the University or other persons involved. In such cases, the University may initiate legal action.
Protection of the Reported Person
During verification and investigation activities, individuals mentioned in the report may be involved or notified. However, no procedure will be initiated solely on the basis of a report without concrete evidence supporting its content.
Any further action may occur only if additional evidence emerges from the investigation.
Privacy
To guarantee the right to personal data protection, the collection and management of reports are carried out in compliance with applicable privacy legislation.