Employment policy modern slavery

Università IULM has a formal and enforceable policy commitment against forced labour, modern slavery, human trafficking, and child labour, applicable to all employees, contractors, suppliers, and partners.

This policy is embedded in the IULM Code of Ethics (Rectoral Decree No. 14661), which defines respect for human dignity and the protection of individual rights as fundamental principles of the University’s conduct.

IULM’s commitment is implemented in compliance with:

• Legislative Decree No. 24/2014 – prevention and repression of human trafficking and protection of victims;
• Legislative Decree No. 81/2008 – health and safety in the workplace;
• Law No. 977/1967 and Legislative Decree No. 345/1999 – prohibition of child labour under 16, except for protected educational internships;
• EU Directive 2011/36/EU and Directive 2009/52/EC – prevention of human trafficking and sanctions against exploitative labour;
• ILO Conventions No. 29, 105, 138, and 182 on forced and child labour, ratified by Italy.

Protection of workers’ well-being

In line with its ethical standards, IULM’s Collective Labour Agreement (2022–2024) also enshrines the “right to disconnect”, ensuring that all employees are free from work-related digital communications outside working hours.
Specifically, staff members have the right to disconnect from all technological tools and digital platforms between 7:30 p.m. and 8:00 a.m., except in cases of institutional emergencies.
This measure protects employees’ rest time, psychological well-being, and work–life balance, and aligns with the principles of decent and sustainable employment under SDG 8.

In addition, in accordance with Legislative Decree No. 81/2008 (in force as updated to 09/08/2025), IULM implements mandatory occupational health surveillance and the “fitness-for-duty” medical examination (idoneità alla mansione specifica) conducted by the Competent Physician. As set out under Title I, Section V (Arts. 38–41), fitness assessments are carried out at hiring, periodically, upon change of tasks, and after prolonged absence, with formal fitness judgements (fit; fit with restrictions/prescriptions; temporarily or permanently unfit) issued to ensure that assigned duties are compatible with the worker’s health and safety.

Whistleblowing and accountability mechanisms

To ensure real and continuous enforcement of its ethical commitments, IULM has established a dedicated Whistleblowing System in full compliance with Legislative Decree No. 24/2023, which implements the EU Directive 2019/1937 on the protection of whistleblowers.

This mechanism provides a secure, confidential, and accessible platform through which any member of the university community—employees, students, collaborators, suppliers, or third parties—can report violations of human rights, including:

• suspected cases of forced labour or servitude;
• human trafficking or exploitation of workers within the supply chain;
• child labour or recruitment practices involving minors;
• psychological or economic coercion in employment relationships;
• or any conduct inconsistent with the principles of dignity, safety, and fairness.

Reports can be submitted anonymously through a protected digital portal, or confidentially via the Designated Whistleblowing Officer, under the direct supervision of the Rector and the General Directorate.
Every report is subject to formal assessment, with guaranteed protection for whistleblowers from retaliation, discrimination, or adverse treatment.

Through this system, IULM ensures that its anti-exploitation policy is not only declarative but actively monitored and enforceable, guaranteeing transparency, integrity, and institutional accountability.