Whistleblowing

They can make a report:

• employees ofUniversità Campus Bio-Medico di Roma with a permanent employment contract, determined by collaborators in whatever capacity the employment relationship exists (self-employed, private law, consultancy, collaboration), including the preliminary phases of selection and/or stipulation of the employment contract or during the probationary period;
• volunteers and interns, in constant performance of their activities;
• workers of companies supplying goods or services who operate at theUniversità Campus Bio-Medico di Roma;
• collaborators appointed, due to a professional consultancy or assistance relationship withUniversità Campus Bio-Medico di Roma;
• employees, collaborators or workers of companies supplying goods or services, following the dissolution of the legal relationship if the information on the violations was acquired during the relationship itself.

L'Università Campus Bio-Medico di Roma undertakes to manage, archive, keep confidential and evaluate any reports received anonymously, where they are adequately detailed and fall within the scope of applicability of the Whistleblow tooling.

The anonymous Reporter is however guaranteed the possibility of integrating the report made with his/her own identification data at any time, thus abandoning anonymity with the consequent opportunity to benefit from the guarantees of protection by theUniversità Campus Bio-Medico di Roma with respect to any retaliatory acts connected to the report.

Information on violations concerning facts (of any nature, even merely omissions), referable to people of the University or to collaborators of the same, which may constitute violations of Model 231 of the University and of the procedures that constitute the implementation of the pA and/or of the Code of Ethics and/or internal company regulations and/or in any case capable of causing damage or prejudice, even just to the image or reputation, of the University.

In particular:

• significant illicit conduct pursuant to Legislative Decree 231/2001;
• conduct contrary to the provisions of the Organisation, Management and Control Model pursuant to Legislative Decree 231/01, of the Code of Ethics and of the internal regulatory and procedural body;
• offenses that fall within the scope of application of European Union or national acts (indicated in Annex 1 to Legislative Decree 24/2023 to which reference should be made for further details)
• acts or omissions detrimental to the financial interests of the Union;
• acts or omissions relating to the internal market;
• acts or behavior which frustrate the object or purpose of the provisions set out in Union acts.

The reports must concern facts of which the Reporter is aware, the Reporter having reasonable grounds to believe that the information reported is true at the time of the report.

Reports must be made promptly with respect to knowledge of the facts in order to make verification possible in practice. 

They do not constitute whistleblower reportsing: disputes, claims or requests linked to a personal interest of the Reporter which relate exclusively to their individual working relationship, or inherent to their relationship with hierarchically superior figures.

Consequently, the University will arrange for the archiving of all Reports whose content concerns:

• a personal interest of the Reporter, which pertains to their individual working relationships or inherent to working relationships with hierarchically superior figures (e.g. labor disputes, or interpersonal conflicts between colleagues in the absence of a damage to the integrity of the entity or violation of Model 231);
• events or circumstances relating to the sphere and interests of private life not directly related to the work activities carried out on behalf of theUniversità Campus Bio-Medico di Roma or not indicative of situations of conflict of interest;
• any communications relating to alleged inefficiencies in health and/or social-health services provided within the NHS or privately provided by theUniversità Campus Bio-Medico di Roma;
• violations already regulated on a mandatory basis in some special sectors (e.g. financial services, prevention of money laundering denaro or terrorism);
• communications or complaints relating to commercial activities or services to the public.

Reports can be sent via: i) IT platform accessible from the University website and the company intranet; ii) electronic mail to dedicated email addresses; iii) ordinary mail to the bodies responsible for managing the report; iv) verbally, by means ofchiaration released by the Reporter in a specific hearing. A dedicated phone line/voice messaging system is being implemented.

The IT platform constitutes the preferred tool for sending and managing reports, as it is most suitable for guaranteeing, with IT methods, the confidentiality of the identity of the Reporter and adequate information security measures.

Through the platform it is possible:

• send a report;
• modify or update a submitted report;
• consult the status of a sent report;
• receive feedback on the follow-up given to the report.

The Legislative Decree n. 24/2023 provides for the possibility of making external reports to the National Anti-Corruption Authority (ANAC) and public disclosures of violations in the cases expressly provided for by the law. The possibility of making external reports to the ANAC is permitted only in the following cases:

• where the internal reporting channel is not active or if it does not comply with legal requirements;
• in cases where the Reporter has already made an internal report which has not been followed up;
• in cases where the Whistleblower has reasonable grounds to believe that, if he/she made an internal report, it would not be followed up effectively or that it could lead to the risk of retaliation;
• in cases where the Reporter has reasonable grounds to believe that the violation may constitute an imminent or obvious danger to the public interest.

The protections listed below apply, as provided for by the Legislative Decree. 24/2023, in addition to the reporting party, also to the following parties:

• to the facilitator (natural person who assists the reporter in the reporting process and operates within the same working context);
• to people from the same working context as the reporting person, the person who filed a complaint or the person who made a public disclosure and who are linked to them by a stable emotional or kinship bond within the fourth degree;
• to work colleagues of the reporting person or of the person who has filed a complaint or made a public disclosure, who work in the same working context as the person and who have a regular and current relationship with that person;
• to entities owned by the reporting person or for which the same people work as well as to entities that operate in the same working context as the aforementioned people.

By retaliation we mean any behaviour, act or omission, even if only attempted or threatened, carried out as a result of the reporting, the complaint to the judicial or accounting authority, or the public disclosure and which causes or may cause, to the reporting person or to the person who reported, directly or indirectly, damage ingright, to be understood as damage ingjustified.

Retaliation
Examples of retaliatory behavior:

• dismissal, suspension or equivalent measures;
• demotion or failure to promote;
• the change of functions, the change of place of work, the reduction of salary, the modification of working hours;
• the suspension of training or any restriction of access to it;
• negative merit notes or negative references;
• the adoption of disciplinary measures or other sanctions, including pecuniary ones;
• coercion, intimidation, harassment or ostracism;
• discrimination or otherwise unfavorable treatment;
• the failure to convert a fixed-term employment contract into a permanent employment contract, where the worker had a legitimate expectation of such conversion;
• failure to renew or early termination of a fixed-term employment contract;
• damage, including to the person's reputation, in particular on social media, or economic or financial prejudice, including loss of economic opportunities and loss of income;
• improper listing on the basis of a formal or informal sectoral or industry agreement, which may result in the person being unable to find employment in the sector or industry in the future;
• the early termination or cancellation of the contract for the supply of goods or services;
• the cancellation of a license or permit.