Whistleblowing

The Istituto per le Opere di Religione, in accordance with the provisions of Article 120-bis of ASIF Regulation no. 1, has adopted a system for reporting illicit activities, fraud or irregularities at the workplace (so-called whistleblowing), adopting a specific policy that contributes to identifying and countering possible illicit acts and to spreading a culture of ethics and legality within the Institute.

The whistleblowing process, therefore, makes it possible to report illicit conduct, i.e. any action or omission, taken or attempted, that causes or is likely to cause damage or harm to the Institute, its employees or customers, through a secure, independent and absolutely confidential channel.

Who can submit an offence report
Whistleblowers:

• Employees of the Institute
• Third parties having a commercial relationship with the Institute

It should be noted that the whistleblowing channel is not to be used to receive complaints or requests of an operational/commercial nature.

How to submit offence reports
Reports must contain a circumstantiated description of the facts and conduct considered to be illicit, incorrect or immoral, including, where possible, documents, an indication of the rules that are considered to have been breached and any other evidence that may be useful for investigating the facts alleged. Finally, whistleblowers have an obligation to indicate their position or function within the Institute and to declare whether they have a personal interest in relation to their report.

Anonymous reports, i.e. lacking elements that could serve to identify their authors, even if submitted by the means envisaged by this document, will be taken into consideration only if their content is adequately detailed and circumstantiated.

The head of the Internal Audit function is mandated with ensuring that the process is properly carried out.

Internal offence reports
Reports may be submitted using one of the following options:

• By Confidential/Personal registered letter with acknowledgement of receipt addressed to:
  Responsabile Funzione Internal Audit
  Istituto per le Opere di Religione
  Cortile Sisto V
  CAP 00120 Città del Vaticano
• Via email to:
  [email protected]
• In person, requesting, through the above channels, a meeting for the purpose of filing a report. The content of the conversation will be minuted and assigned a protocol number

External offence reports
An external report can be submitted to the Financial Intelligence and Supervisory Authority (FSA) if one of the following conditions is met at the time of submission:

• An internal report has already been made and has not been followed up
• There are reasonable grounds to believe that, if an internal report had been made, it would not have been effectively followed up or that the report could involve the risk of retaliation
• There are reasonable grounds to believe that the breach may constitute an imminent or obvious danger to the public interest