Whistleblowing
The regulations on whistleblowing, aimed at protecting those who report corruption and irregularities, are governed in Italy by specific legal provisions (implementing an EU Directive), which complement the legislation on the protection of workers in both the public and private sectors (Law 179 of 30/11/2017 and Legislative Decree 24 of 10/03/2023).
Specifically, a whistleblower—i.e., an individual who reports unlawful conduct to the competent authority that they became aware of due to their professional or employment relationship—cannot be penalized, demoted, dismissed, transferred, or subjected to any other discriminatory organizational measures that may have a negative impact on them.
The term “whistleblowing” literally derives from the English phrase “blow the whistle,” referring to the action of a referee signaling a foul or a police officer attempting to stop an illegal action. Whistleblowers are individuals who publicly disclose or report illegal activities to authorities, which may include violations of the law, threats to public interest, or the deliberate omission of required actions.
The Purpose of Whistleblowing
The collaboration of individuals within the company who report unlawful conduct encountered during their professional duties, as well as external parties who become aware of corrupt activities through other means, is crucial. The ultimate goal of such information is to bring to light corrupt practices, which can harm the company and its Organizational Model 231 in various ways, primarily through reputational damage. For this reason, the definition of corruption introduced by Law 190/2012 is broader than the criminal definition and includes situations where, during administrative activities, a person abuses the authority entrusted to them to gain advantages for private or public entities.
How to Report
Those who submit reports are entitled to specific protections, including:
– Protection of anonymity;
– Prohibition of discrimination against those making reports;
– Exemption of reports from access rights.
The procedure implemented by ICAM allows reports to be made through three channels:
1) Telephone contact
2) Submission of a physical document following ANAC Guidelines
3) Hand-delivered submission of a physical document following ANAC Guidelines
The system has been developed in compliance with the legal provisions of Legislative Decree 24 of 2023, which establishes the guidelines for whistleblowing in Italy.
Below is the link to ICAM SpA’s internal procedure:
At this link, employees and those who have dealings with the company can submit reports in accordance with the law.
Data Processing
For information on data processing, please refer to the privacy policy on whistleblowing.