On November 7, 2024, the Italian Anticorruption Authority (ANAC or the Authority) made available for a preliminary consultation the “Draft Guidelines on Whistleblowing Internal Reporting Channels” (the Draft Guidelines), aimed at providing additional clarifications as to the appropriate management of internal reporting channels under Decree No. 24/2023 (the Whistleblowing Decree). ANAC is now collecting comments and remarks from relevant stakeholders (to be provided by 9 December 2024), before finalizing and amending (where necessary) the Draft Guidelines.
The new Draft Guidelines are intended to update the guidelines originally published on July 12, 2023 with reference to external reporting channels. The main updates are as follows:
- Detailed guidance is provided on the role attributed to trade unions and how to get them involved in the activating procedure of the new internal reporting channels, as requested by the Whistleblowing Decree. In particular, ANAC specifies that the involvement of trade unions is “purely informative” in nature, aimed at acquiring any comments on the implementation of the internal channel. The deadline given to trade unions to submit their comments is not peremptory in nature and the opinion expressed by the trade unions is not binding. ANAC also clarified that in companies where there are
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