University principles on corruption and bribery

Università IULM has a publication of the university's principles and commitments on organized crime, corruption & bribery, detailing explicitly the university’s maintenance of a robust, legally grounded governance system to prevent, detect, and sanction any form of organized crime, corruption, or bribery, ensuring full integrity, transparency, and compliance across all its operations.

Formal Policy Framework

The University’s ethical and legal commitments are codified in the “Modello di Organizzazione, Gestione e Controllo” (Organizational, Management, and Control Model), adopted by the Board of Directors.
This model establishes:

A comprehensive set of organizational, management, and financial control procedures aimed at preventing offences such as corruption, bribery, fraud, and organized crime;
An independent Supervisory Body (Organismo di Vigilanza, OdV) empowered to monitor compliance, conduct investigations, and report directly to the Board of Directors;
A mandatory Code of Ethics, which defines the values, rights, and responsibilities of all members of the IULM community and external contractors, ensuring ethical conduct, transparency, and accountability;
A detailed disciplinary system applicable to faculty, staff, executives, and external partners, providing for sanctions in case of violations, up to termination or contract cancellation;
A structured risk assessment and mapping process identifying activities potentially exposed to corruption or criminal risks, and the related control protocols.

Whistleblowing and Reporting Mechanisms

IULM updated its integrity system by adopting a digital Whistleblowing Procedure, compliant with Legislative Decree 24/2023 (EU Directive 2019/1937).
The platform allows all members of the IULM community and external collaborators to report suspected violations anonymously and securely, guaranteeing full confidentiality and protection from retaliation.
Reports are received exclusively by the independent Supervisory Body (OdV) via dedicated digital channels and are handled under a formalized operational protocol that includes:

secure, encrypted communication systems;
verification, investigation, and documentation of each report;
mandatory non-retaliation and protection measures for whistleblowers;
sanctions against false or malicious reporting.

Implementation and Oversight

The OdV, operating with full autonomy and independence, ensures:

periodic monitoring of compliance and reporting to the Board of Directors;
training programs for academic and administrative staff on ethical conduct and legal responsibilities;
annual reviews of the Model’s effectiveness and updates based on new legislation and risk assessments;
disciplinary enforcement under the integrated IULM Code of Ethics and the national labor law framework.