HSE University Anti-Corruption Portal
Vatican Adopts the Rules of Disclosure of Information on Corruption and Related Offences

The Office of the Auditor General of Vatican (hereinafter, the Office) has issued a document defining the reporting procedure for whistleblowers.

Under the regulation on the reporting procedure according to Article 7 of the Statutes of the Office of the Auditor General, a whistleblower is a person who, in the course of his/her own work, has reasonable grounds to believe that an offence associated with the following has been, is being or can be committed:

  • Anomalies in the use or allocation of financial or material resources;
  • Irregularities in the award of contracts or in the performance of transactions or disposals of property;
  • Acts of corruption or fraud.

The following persons can be considered as whistleblowers:

  • Members, officials and employees of the various Curial Institutions and Institutions linked to them, and of Vatican City State;
  • Pontifical Legates and diplomatic personnel of the Holy See;
  • Persons who perform functions of representation, administration or management, as well as those who exercise, even de facto, the management and control, of the Institutions directly dependent on the Holy See and registered in the register of juridical persons held at the Governorate of the Vatican City State;
  • Collaborators and advisers of Vatican City State, the Holy See and all the Institutions, Bodies and Entities connected to it or that refer to it, with any type of assignment or contract;
  • Any natural person who is a client, supplier, contractor or subcontractor; or employee or collaborator of companies that have relations with the Vatican City State, the Holy See or with Institutions, Bodies and Entities connected to it or that refer to it;
  • Any other person who holds, even de facto, an administrative or judicial mandate in the Holy See or in the Vatican City State, on a permanent or temporary basis, remunerated or free of charge, regardless of hierarchical level.

The document stresses, however, that this is not an exhaustive list of those who can be qualified as whistleblowers.

In order to make a report, the aforementioned persons can:

  • Send a registered letter with acknowledgement of receipt to the address of the Office, or deliver it by hand to the Auditor General;
  • Send a message to the dedicated email address of the Office;
  • Request a direct meeting or video conference with the Auditor General to make an oral report of an offence.

The report of an offence must contain the following information:

  • The name, surname, place of residence, domicile, workplace and email address of the whistleblower;
  • The facts indicating that an offence has been, is being or can be committed, indicating the Curial Institution or Entity to which it refers.

Reports submitted anonymously will not be followed up in accordance with the regulation.

The whistleblower, if considered appropriate, can also indicate:

  • How the fact/situation came to their knowledge;
  • The persons involved in the subject being reported;
  • The circumstances of time and place in which the fact was committed;
  • The persons potentially aware of the facts;
  • Any other information useful for reconstructing the reported facts.

The regulation also entitles whistleblowers to protection, including:

  • Safeguarding of the confidentiality of the whistleblower’s identity, restriction of access of those not authorised to the information that can disclose the identity of the whistleblower also indirectly (except for the cases where this information is requested by a judicial body explaining the need thereof for the purposes of investigation and judicial activities in its motivated decision);
  • Exemption from liability for breach of any constraints on the confidential character of such information.
Corruption whistleblowers

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