Every whistleblowing channel needs someone to manage it. Italian Legislative Decree 24/2023, implementing the EU Directive, leaves organisations free to choose between an internal and an external solution, but sets two clear requirements: independence and training. In this article we look at what the manager does, how to choose one and which tools can help.
If you still need to work out whether your company is required to set up a channel, first read who must have a reporting channel.
The manager's role and tasks
The manager follows the report from arrival to closure. Their main tasks are:
- Acknowledgement of receipt: confirms to the whistleblower within 7 days that the report has been received.
- Communication: keeps in touch with the whistleblower and, where needed, asks for clarification or additional information.
- Verification: examines the report and assesses the facts reported.
- Feedback: informs the whistleblower of the outcome or status of the report within 3 months.
In Italy, failing to verify reports is one of the situations ANAC can penalise, with fines of €10,000 to €50,000: that is why the manager's role should be taken seriously from the outset.
Internal or external manager
Legislative Decree 24/2023 allows the channel to be managed by:
- an internal person;
- a dedicated internal office;
- an external party, which must also be independent and trained.
| Aspect | Internal manager | External manager |
|---|---|---|
| Knowledge of the organisation | Already knows people and processes | Has to acquire it |
| Distance from the facts reported | To be assessed case by case | Generally greater |
| Requirements | Independence and training | Independence and training |
There is no choice that suits everyone: it depends on the size of the organisation, its structure and the skills available. In any case, the choice must be stated in the whistleblowing procedure.
Independence and training requirements
Independence means the manager must be able to examine reports without undue influence, even when they concern people in positions of responsibility. In practice, it helps to clarify who the manager reports to and what resources they have.
Training means knowing the law, the timeframes, the protections for whistleblowers and the rules on data processing; in Italy data is kept for no more than 5 years from the final outcome.
Conflicts of interest
In general terms, the manager should not assess reports that concern them directly or involve people with whom they have a relationship that could compromise their impartiality. It is worth setting out in the procedure what happens in these cases, for example by naming an alternative person. For specific situations, consult a professional.
Training the manager
A training programme for the manager can cover these topics:
- the content of the EU Directive, Legislative Decree 24/2023 and the ANAC Guidelines;
- reporting methods: written, oral and in-person meetings;
- the 7-day and 3-month timeframes and how to meet them;
- protections for whistleblowers and the ban on retaliation;
- confidentiality and data retention;
- using the reporting platform.
It is useful to refresh the training when laws, guidelines or tools change.
Support tools
A dedicated platform makes the manager's work easier. Two features are particularly useful:
- Activity log: records every step, from receipt to feedback.
- Notifications: alert the manager when a new report arrives, so timeframes can be met.
Whisper whistleblowing software provides a Supervisory Body/Whistleblowing activity log, email notifications and alerts, and automatic routing of reports. To compare platforms read how to choose whistleblowing software, and for the basics of the law what whistleblowing is.
A practical example
A written report arrives through the platform. The manager receives the notification, sends the acknowledgement within 7 days and asks the whistleblower for some clarification. They examine the facts, record every step in the activity log and, within 3 months, provide feedback. Every stage remains documented.
Checklist for choosing the manager
- Does the manager have the independence needed to examine even sensitive reports?
- Have they received adequate training, and do they know how to keep it up to date?
- Is an alternative person named in case of conflicts of interest?
- Do they have the time needed to meet the 7 days and the 3 months?
- Do they have a tool with an activity log and notifications?
- Is the choice stated in the procedure and communicated to employees?
Two useful terms
Communication: the dialogue between manager and whistleblower while the report is being handled. Activity log: the orderly record of all the steps taken on each report.
F.A.Q. - Frequently asked questions
Who can manage the whistleblowing channel?
An internal person or office, or an external party, provided they are independent and trained.
What does the channel manager do?
Sends the acknowledgement of receipt within 7 days, maintains contact with the whistleblower, investigates the report and provides feedback within 3 months.
Does the manager need to be trained?
Yes, training is one of the manager's requirements, together with independence.
Which tools help the manager?
An activity log and notifications when reports arrive. Whisper provides a Supervisory Body/Whistleblowing activity log and email notifications and alerts.
Request a demo
Find out how Whisper helps the manager with an activity log, notifications and routing of reports.
General information only, not legal advice: check your situation with a professional and consult the latest ANAC Guidelines.