COMPLIANCE UPDATE | Deadline of 15 July 2023
The first major private-sector deadline under Legislative Decree no. 24/2023 arrived on 15 July 2023, applying the new whistleblowing framework to larger employers and specified regulated entities.
The regime protects internal and external reports, establishes channel and feedback requirements and prohibits retaliation. Confidentiality extends to the reporter and other persons involved, while misuse of personal data creates separate exposure.
A global hotline may route reports abroad or permit access by a wide investigation team. That design must be tested against Italian responsibilities, language needs, conflicts and the rights of implicated employees.
Employers should define who receives and investigates reports, train that team, publish accessible information and review any employment action involving a reporter. The anti-retaliation analysis should be documented independently of the underlying investigation.