Whistleblowing

Internal whistleblowing

IVASS has defined in an internal circular how employees and other entitled persons can report illegal conduct to protect the public interest and the procedure for managing whistleblowing by the Institute. The circular identifies measures to protect the whistleblower and the person they are raising concerns about (person involved).

Whistleblowing reports can be sent to the Anti-Corruption Officer (Responsabile della prevenzione della corruzione e della trasparenza - RPCT) through an IT procedure, which can be used by IVASS employees, staff seconded from the Bank of Italy, and external staff with a user account to access IVASS systems. All information collected through the IT procedure is encrypted and the identity of the whistleblower can only be revealed to the Anti-Corruption Officer, which also serves as identity custodian.

By following to a “guided path”, the IT platform enables the compilation, submission and receipt of reports of alleged violations.

Information on how to access the platform is published on the Institute's intranet.

Whistleblowing reports by external staff

All external staff can report any wrongdoing by IVASS employees that has come to their attention through their working relationships.

External staff include: employees and collaborators of contractors and suppliers of the Institute, consultants and collaborators of IVASS, including members of the Guarantee Committee and the Insurance Arbitrator, trainees, interns, those who perform functions of administration, management, control, supervision or representation; members of the Board and staff of the Institute's auditor and in general all those who do not have an IVASS user account.

You can use the 'Whistleblower report' form to submit a report.

The form is transmitted, in a sealed envelope marked “Strictly confidential-whistleblowing report,” to the address IVASS, via del Quirinale, 21, 00187 Roma, to the attention of the Anti-Corruption Officer.

In addition to the report, the envelope must include a further sealed envelope containing the whistleblower's tax code, a copy of their identification document and their signature.

It is also possible to request a meeting in person with the Anti-Corruption Officer to make an oral report. The request can be made by telephone or email to the Anti-Corruption Officer at the address  RPCT@ivass.it 

Finally, a whistleblower report may be filed to the Italian National Anti-Corruption Authority (ANAC) using the tools made available by the Authority, in any of the following circumstances:

• no internal whistleblowing channel is available, or the internal whistleblowing channel does not comply with the requirements envisaged in the decree with regard to whistleblowers and submission of whistleblowing reports;
• there was no follow-up on an internal report;
• the whistleblower has reasonable grounds to believe that there would be no effective follow-up on an internal report or that there is a risk of whistleblower retaliation;
• the whistleblower has reasonable grounds to believe that the offence poses a risk of imminent or obvious harm to the public interest.

Submission and examination of the whistleblowing report

The whistleblowing report is examined by the Anti-Corruption Officer. During the investigation, the whistleblower may be contacted for further information or clarification.

The whistleblower will be notified of the outcome of the investigation.

If it is well founded, the report shall be submitted to the competent offices or to the judicial authority, as the case may be, anonymously in order to ensure that the identity of the whistleblower remains confidential.

Information on personal data protection

In accordance with the provisions of European and Italian privacy regulation, IVASS processes the personal data of the whistleblower and of the other persons involved in the whistleblowing report for the purposes of handling such report.

Personal data processing is required for corruption prevention purposes according to Article 13 of Legislative Decree No. 24 of 10 March 2023.

To ensure the management and traceability of the activities carried out, the Anti-Corruption Officer shall ensure that whistleblower reports and the attached documents are retained for five years from the date of notification of the final outcome of the whistleblowing procedure.

Paper documentation to be stored at the preliminary stage (reports pertaining to facts outside the scope of whistleblowing, or with no important element) shall be kept under strict confidentiality for the time strictly necessary to proceed to its destruction.

Whistleblowers' personal data and data relating to the persons involved and mentioned in the whistleblower reports may be disclosed only to the Anti-Corruption Officer and to his/her staff. The data will not be disclosed externally and may only be communicated to third parties in the cases provided for by Article 12 of the abovementioned decree.

Data are processed in compliance with the guarantees protecting the whistleblower and the subjects involved, with the use of appropriate security measures to maintain the confidentiality of the information and protect it from unauthorised access by third parties.

Whistleblowers may exercise the right of access to personal data and any other rights under the law by contacting the Data Controller - IVASS - Servizio Gestione Risorse - via del Quirinale 21, 00187 ROMA, email gestione.risorse@pec.ivass.it.