Anti-corruption and transparency

Preventing corruption and promoting transparency

The University of Milan, like any public administration, has its own Anti-Corruption and Transparency Officer (Responsabile della Prevenzione della Corruzione e della Trasparenza, RPCT), as required by Law no. 190/2012 to assess the organization's exposure to the risk of corruption and suggest mitigating measures.

The RPCT is responsible for drafting the Section on Corruption risks and transparency of the Integrated Plan of Activities and Organization (Piano Integrato di Attività e Organizzazione, PIAO), based on the strategic guidelines issued by the governing board, and for monitoring its implementation.

In addition to the RPCT, in October 2018, the University created the position of Vice Rector with authority for ensuring Lawfulness, Transparency and Equal Rights, and promoting ongoing dialogue and collaboration between governance boards, the RPCT and university administration on key anti-corruption and transparency issues.

Anti-Corruption and Transparency Officer (RPCT) 
Antonella Esposito 
email: [email protected]

Vice Rector with authority for ensuring Lawfulness, Transparency and Equal Rights
Prof. Maria Elisa D'Amico 
Email: [email protected]

For information: 
[email protected]


Antonella Esposito, Managing Director of the Institutional Affairs Division, has been the Anti-Corruption and Transparency Officer (RPCT) of the University of Milan since 1 January 2019.

Maria Elisa D'Amico, full professor of Constitutional Law, has been Deputy Rector for Legality, Transparency, Rights and Equality for the academic two-year periods 2018/2020, 2020/2022 and 2022/2024..

In November 2018, the University created an anti-corruption and transparency working group chaired by Vice Rector Maria Elisa D'Amico and consisting of the RPCT, professors and researchers in the legal field, as well as technical and administrative staff.
The group meets periodically to deal with the main issues related to transparency and the corruption risk management process, respond to solicitations from the academic community, and organize debates with anti-corruption and transparency officers. 

The University has also built a network of anti-corruption and transparency managers identified within its central and peripheral units, who meet usually quarterly to cooperate on these issues.

The 80-strong group includes:

  • two representatives for each Department (identified by the directors among professors and researchers as well as technical and administrative staff) 
  • one representative for each central administrative office, chosen among technical, administrative and library staff by their respective managers.

The need to identify anti-corruption and transparency managers reporting to the RPCT is strongly felt in a large institution such as the University of Milan, with many locations both in the urban area and in the wider region of Lombardy.

At the end of 2020, the RPCT and the Deputy Rector launched an inter-university technical roundtable on legality, to share past experiences, good practices and challenges related to transparency and the fight against corruption. Members of the roundtable included the University of Milan, the University of Milano-Bicocca, and the University of Insubria.

2023 saw the establishment of the Observatory on Legality, which replaced the technical roundtable while opening its doors to new members (the Lombardy Region and the Municipality of Milan, in addition to the three universities already mentioned).

Regulations and appointments

Formerly known as “Anti-corruption and transparency three-year plan” until 2021, the Section on Corruption risks and transparency of the PIAO is a tool aimed at identifying risk areas within the University, as well as the corresponding mitigation measures.

The corruption risk management process includes several steps:

  • analysis of the internal and external environment
  • corruption risk assessment: identification, analysis and weighting
  • corruption risk management: identification of appropriate preventive measures to mitigate risks
  • monitoring and review.

The key prevention measure is administrative transparency.

The Code of Conduct prescribes conduct to be adopted at work, in private relationships and with the public.

Based on fairness, transparency, good performance and impartiality of the public administration, the Code intends to combat unfair practices such as the abuse of position and the improper use of public resources and/or information acquired for business purposes.

It also regulates potential conflicts of interest, requiring public servants to avoid situations of actual or apparent conflict.

The reporting of internal wrongdoing, also known as whistleblowing, should be regarded as a civic duty, a way to unearth corruption or other illegal conduct that may harm the University or the public interest.

Rules on whistleblowing are not intended to make work relationships more tense, but should be understood as part of a collaborative strategy to safeguard the public good and the image of the administration. In fact, the goal of whistleblowing is not to ascertain any violation of your rights as an employee, but rather to ensure the integrity of the public administration, which is in itself a public interest.

Whistleblowers are entitled to specific safeguards when reporting cases of bad administration: notably, they cannot be discriminated as a result of their reporting, and their identity is kept confidential in compliance with Legislative Decree no. 24/2023.

In 2019, the University launched a whistleblowing platform that uses standard cryptographic protocols to protect the identity of employees and contractors who report illegal conduct.