EUI Whistleblowing Policy
The EUI is committed to ensuring that all members of its community carry out their activities in accordance with the highest standards of behaviour, integrity, and ethical practice. The Institute also has a responsibility towards its stakeholders to conduct its affairs in a responsible, transparent, and accountable manner.
This page provides an overview of the EUI Whistleblowing Policy, including its aim, definitions, scope, responsibilities, how to make a whistleblowing claim, how claims are followed up, and the protection available to whistleblowers.
Any EUI member who becomes aware of illegal activities or serious irregularities is under an obligation to report them.
Examples of such concerns include fraud, corruption, embezzlement, theft and serious conflicts of interest in procurement and grant procedures.
The EUI Whistleblowing Policy aims to:
-
Strike a balance between safeguarding members of the EUI community who raise genuine concerns and protecting the Institute and its community against unfounded, inaccurate, or vexatious allegations that may negatively affect others.
Whistleblowing is the disclosure of information in the public interest, relating to suspected irregularities and potential dangers in the context of work-related activities at the EUI. Irregularities may include, but are not limited to:
- Criminal offences;
- Fraud;
- Conflicts of interest;
- Risks to the health, safety or security of the EUI community, the public or those involved in EUI activities;
- Environmental harm;
- Non-compliance with legal obligations, including EUI rules and applicable national, European, or international law;
- Deliberate concealment of wrongdoing;
- Serious breaches of EUI policies.
A ‘whistleblower’ is a person who raises genuine concern that irregularities are occurring, or that there is a potential danger to the EUI community, environment and/or wider public. The whistleblower does not need to be directly involved in, or be affected by, the activity they are reporting.
Scope, accountability and responsibilities
All members of the EUI community, including professional staff, faculty, academic staff, researchers, students, external collaborators and outsourced staff, are subject to the EUI Whistleblowing Policy.
This Policy covers all activities carried out on EUI premises as well as off-premises activities coordinated by the Institute.
What is not covered by the EUI Whistleblowing Policy?
Raising a concern under this policy may result in the activation of EUI investigative and disciplinary procedures.
Individual responsibility
At the individual level, all members of the EUI community have a duty to:
- Respond appropriately and with due care to any information on irregularities or potential dangers that should be disclosed in the public interest.
- Report any concerns in good faith and on a factual basis, in accordance with the established procedures.
- Respond appropriately if they are the subject of a report, and refrain from any form of retaliation.
- Maintain the confidentiality of information related to a whistleblowing case.
Any EUI member may raise a concern under this policy. The claim must fall within the scope of the EUI Whistleblowing Policy and should be a genuine, factbased concern that affects the public interest.
The whistleblower should file the concern fully anonymously, partially anonymously, or nonanonymously to the EUI Internal Auditor, who acts as an independent liaison between the whistleblower and senior management.
- Non-anonymous claims: The whistleblower agrees to the disclosure of their identity to all parties as required, and should complete the dedicated form managed by the Internal Auditor.
- Partially anonymous claims: The whistleblower should complete the dedicated form managed by the Internal Auditor, indicating that they wish to remain partially anonymous and that their name should not be disclosed beyond the President, Secretary General, and in particular not to the person concerned.
- Fully anonymous claims: The whistleblower remains completely anonymous and does not disclose their identity even to the Internal Auditor. In such cases, the whistleblower cannot be contacted for follow-up and may not benefit from certain protections.. The claim should be submitted by physical post (internal or external mail) to the Internal Auditor.
Mail to:
The Internal Auditor
European University Institute
Villa Il Poggiolo, Piazza Edison, 11, 50133 Firenze
Clearly indicate that the contents are HIGHLY CONFIDENTIAL.
For concerns relating to the President, the Secretary General, or the Internal Auditor, please refer to points 3.1.6, 3.1.7 and 3.1.8 of the EUI Whistleblowing Policy.
The Internal Auditor will acknowledge receipt of the concern within five (5) working days and will maintain the highest level of confidentiality, sharing the claim only with the Secretary General, who decides on the EUI’s most appropriate course of action.
If internal mechanisms are insufficient, or if the concern involves a serious threat to public health or safety or a violation of national or international law, the whistleblower may report the matter to an external entity or individual, in line with legal and institutional obligations. Public disclosure is permitted only as a last resort and under strict conditions.
The Secretary General is responsible for following up on any concerns raised under the Whistleblowing Policy. After receiving a whistleblowing claim, and consulting the President if needed, the Secretary General decides whether to:
- Refer the matter to another policy: The claim may fall within the scope of a different EUI policy (e.g., the EUI Harassment Policy). In this case, the whistleblower will be informed by the Internal Auditor to refer the concern to that policy.
- Dismiss the claim: The Secretary General may decide that the concern has no basis or merit, and therefore no further action is required. The Internal Auditor will inform the whistleblower of this outcome.
- Refer the matter to the Italian Authorities: In consultation with the President, the Secretary General may decide to inform or transfer the case to the competent Italian authorities, in view of the Headquarters Agreement stating that Italian legislation applies at the EUI unless the High Council has approved a regulation of its own.
- Initiate an investigation, which may involve a disciplinary procedure: The Secretary General may decide to start an investigation and appoint a lead investigator to carry it out on their behalf. Depending on the status of the EUI member involved, different procedures may apply.
- For nonanonymous and partially anonymous cases, the Internal Auditor updates the whistleblower on the progress of the investigation and the likely timeline. Anonymous claims are followed up in the same way as other cases; however, the whistleblower will not receive updates.
- The person concerned has the right to fair treatment, including being informed of the allegations and evidence and having the opportunity to respond before the investigation concludes. In anonymous and partially anonymous cases, the whistleblower’s identity is not shared. The Secretary General may also meet with the person concerned.
- When the investigation is completed, normally within 60 days, depending on the complexity of the case, the Secretary General informs the whistleblower of the outcome and ensures that a confidential incident report is produced.
The Secretary General is responsible for ensuring that the whistleblower is protected from any form of retaliation. The necessary protection measures are discussed with the whistleblower and put in place as needed.
If the whistleblower experiences any form of retaliation during the investigation or afterwards, they should report it to the Secretary General, who will decide on the appropriate followup or, if relevant, ask for the issue to be handled through the EUI Harassment Policy.
Additional care is taken during staff assessments and promotion exercises to make sure the whistleblower does not face any negative consequences.
Page last updated on 15 April 2026