Anti-corruption and transparency
From 1 to 14 March, our entire academic community and interested citizens commented on the updated three-year plan 2021-2023 for transparency and the prevention of corruption of the University of Milan.
Comments were assessed by the standing group for anti-corruption efforts, and possibly incorporated in the revised version of the plan, approved by the Board of Directors on 30 March.
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 preparing the anti-corruption and transparency three-year plan (PTPCT), based on the strategic guidelines issued by the governing board, and for monitoring its implementation. The RPCT oversees compliance with statutory disclosure obligations, and ensures that published information is complete, clear and up-to-date (pursuant to Legislative Decree no. 33/2013).
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.
Antonella Esposito, Head of Document Management - Institutional Affairs, 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, is Vice Rector with authority for ensuring Lawfulness, Transparency and Equal Rights, for the academic two-year period 2018/2020.
Moreover, 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 at least on a fortnightly basis 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 regularly 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 and administrative 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.
The anti-corruption and transparency three-year plan (PTPCT) is a tool aimed at identifying risk areas and 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.
Reporting offences is a civic duty that can unearth corruption or other conduct, which could be detrimental for the University and the public.
It should not be seen as an action "affecting work relations, but as a collaborative means to safeguard the public interest and the image of the administration". Please note that it is not intended to ascertain any violation of your rights as an employee, but rather to protect the public interest, and ensure the integrity of the public administration.
Whistleblowers are protected against discrimination and have a right to confidentiality pursuant to Law no. 179/2017.
Since September 2019, the University has made available to its community an encrypted platform to ensure that whistleblowers remain anonymous.