Whistleblowing

REGULATION

The whistleblowing institution protects the worker who reports illegal conduct of which he has become aware during his employment relationship (Article 54-bis, Legislative Decree no. 165/2001, as amended by Law no. 190/2012 ).

The whistleblower cannot be sanctioned, demoted, fired, transferred, or subjected to any other organizational measure having direct or indirect negative effects on the working conditions determined by the report.

The Government Management is obliged to guarantee the confidentiality of the identity of the whistleblower.

WHO CAN REPORT

• the employees of the Government Management;
• collaborators or consultants, with any type of contract or assignment and for any reason;
• workers and collaborators of companies carrying out public works and suppliers of goods or services and carrying out works in favour of Government Management.

WHO TO REPORT

The recipient of the report is the Head of Corruption Prevention (hereinafter RPC).

The whistleblower is also protected in the event that he contacts the ANAC and the ordinary judicial and accounting authorities.

Reports to ANAC can be sent through various channels, among which the online platform accessible at the address:

https://servizi.anticorruzione.it/segnalazioni/#/

WHAT TO REPORT

The unlawful acts that are the subject of whistleblowing reports include not only crimes against the public administration referred to in Title II, Chapter I, of the criminal code but also all situations in which, in the course of the administrative activity, abuse by a subject of the power entrusted to him in order to obtain private advantages (for example, the illegal conduct subject to the reports worthy of protection can include the following: behaviour not compliant with official duties, improper access to information systems, improper use of institutions to protect the employee, irregularities and distorted use of discretion in the context of procedures for awarding public contracts and irregularities in the performance of administrative proceedings).

The report should be as detailed as possible and has as its object facts known and found directly by the whistleblower (and not reported by others).

HOW TO REPORT

To facilitate the use of this important tool for combating and preventing offences, the Government Management provides a specific reporting method.

The report can be submitted using the appropriate form, available in the attachment, which must be completed in its entirety. It is always possible to send a report with a different structure from that envisaged in the model, provided that it contains the same essential elements and is signed.

The report can be sent:

• to the personal email of the RPC of the Governmental Management luca.bassi@navigazionelaghi.it
• to ANAC at https://servizi.anticorruzione.it/segnalazioni/#/

The Head of Corruption Prevention, upon receipt of the report, initiates a first summary internal investigation. If indispensable, it can request clarifications from the whistleblower and/or any other persons involved in the report, adopting the appropriate precautions aimed at ensuring maximum confidentiality.

On the basis of an assessment of the facts that are the subject of the report, it may decide, in the event of evident and manifest groundlessness, to file the report.

Otherwise, it assesses who to forward the report to in relation to the unlawful profiles found among the following subjects: manager of the structure to which the fact is attributable; Personnel office for disciplinary measures; Judicial authority; Court of Auditors; ANAC.

FORM FOR REPORTING ILLEGAL CONDUCT