Pursuant to Decree-Law no. 91 of 8 August 2013
Established by the will of the Municipality of Spoleto, Maestro Gian Carlo Menotti, the Banca Popolare di Spoleto, the Cassa di Risparmio di Spoleto, and other local entities, the Festival dei Due Mondi ONLUS Foundation aims to ensure continuity to the Festival of Two Worlds.
Over the years, the main institutions and operating realities of the territory have joined together.
Since 2008, the Festival of Two Worlds has been organized directly by the Foundation.
The Festival dei Due Mondi Foundation is funded by the State on the basis of two laws, Law no. 418 of 15 December 1990 containing “Granting of a contribution to the Fondazione Festival dei Due Mondi di Spoleto”, and Law no. 238 of 20 December 2012 containing “Provisions for the support and enhancement of Italian musical and opera festivals of absolute international prestige”
With ANAC resolution 1134 of November 8, 2017, published in the Official Gazette on December 5, 2017, the subjective scope of application of Legislative Decree 33/2013 containing “Reorganization of the regulations concerning the obligations of publicity, transparency and dissemination of information by public administrations” was finally clarified, as amended by Legislative Decree 97/2016.
Due to what has been clarified by the National Anti-Corruption Authority, the Foundation is not one of the subjects required, by law, to publish the data and information provided for by the aforementioned Legislative Decree 33/2013.
The obligations deriving from other regulatory sources remain, including Legislative Decree 50/2016 “Code of Public Contracts” for everything related to procurement procedures and contracts, Legislative Decree 91/2013 “Cultural Value” with regard to the data and information that the subjects financed under the Single Entertainment Fund are required to publish, and Law 124/2017 “Competition Law” regarding public contributions assigned and received.
In this section, therefore, the user can consult the data required by specific regulations as well as all the information that the Foundation, by its choice, has decided to publish in the belief that the publication of the elements relating to its organization and the economic and financial situation is a positive act of ethical responsibility aimed at consolidating the relationship of trust with stakeholders.
The interested user can send requests for information or clarifications to the e-mail address info@festivaldispoleto.com.
The measures can be consulted in the database “Regulations”
Law No. 124 of 04/08/2017”Annual law for the market and competition” introduced in article 1, paragraph 125, the obligation to publish, starting from the year 2018, information relating to grants, contributions, paid positions and in any case to economic advantages of any kind received from public administrations or subsidiaries by law or in fact directly or indirectly from public administrations and from publicly held companies.
In this section, the annual report of the Head of Prevention of Corruption provided for by art. 1, paragraph 14, of law no. 190/2012 and the National Anti-Corruption Plan and drawn up according to the format issued by the National Anti-Corruption Authority (ANAC) is published.
Breach reporting systems Whistleblowing
The Festival Dei Due Mondi Foundation - ONLUS, in implementation of the discipline introduced by Legislative Decree no. 24/2023 (so-called Decree Whistleblowing), has adopted the”Procedure for reporting wrongdoing“, with the purpose of allowing the spontaneous disclosure, by the whistleblower, of illegal conduct relevant for the purposes of the legislation on Whistleblowing that I became aware of in the Foundation's working environment.
For this purpose, the Foundation provides a special Computing Platform (available by clicking on the following link https://festivaldispoleto.integrityline.com/ ) for the transmission and management of reports with object information on violations of European and national regulatory provisions concerning conduct, acts or omissions that prove to be such as to prejudice the public interest or the integrity of the Foundation and which consist of:
- significant illegal conduct pursuant to Legislative Decree no. 231/2001;
- violations of the Organization, Management and Control Model.
By way of example and not exhaustive, the following illegal conduct may be reported:
- undue perception of public disbursements;
- fraud against the State, a public body or the EU;
- public or private corruption;
- violation of accident prevention regulations;
- violations of environmental legislation and corporate crimes;
- tax crimes.
They can make a report Whistleblowing I subjects indicated below:
· Administrators and internal staff: members of the Board of Directors and, in any case, all those who perform management, administration, direction or control functions within the Foundation, as well as its employees;
· Other subjects: workers and collaborators of companies providing goods or services that carry out works for the Foundation, self-employed workers, freelancers and consultants, volunteers and trainees (paid and unpaid), candidates, probationary workers and former workers who work or have worked for the Foundation.
Please note that the person who intends to submit a report Whistleblowing you must specify that this is a report for which you intend to keep your identity confidential and, in the event of any retaliation, benefit from the protections provided for by Legislative Decree no. 24/2023, described in detail in the Procedure for reporting offenses adopted by the Foundation, to which reference should be made.
Indeed, this specification allows, if the report is incorrectly received by an incompetent person or through a channel other than those specifically provided for by the Decree, the timely transmission by the latter to the person authorized to receive and manage whistleblowing reports.
The Foundation has identified the person responsible for managing reports in the figure of Responsible for the Prevention of Corruption and for Transparency (RPCT).
With regard to the methods for submitting reports, it should be noted that they can be transmitted to the Foundation:
a) In the main street, through the Computing Platform available at the following URL (https://festivaldispoleto.integrityline.com/ ). In this regard, please specify that the indicated URL can be copied and pasted on a device of your choice; it is also recommended to log in from a device connected to a private network. In any case, it should be noted that, even if access to the Platform is made from a company device connected to the Internet or corporate intranet, there are safeguards to ensure that access is not tracked and/or stored in any way;
b) Alternatively, at the request of the whistleblower, by means of a direct meeting with the RPCT fixed within a reasonable time. For this purpose, it is necessary to send the relevant request via e-mail to the e-mail address of the RPCT (paolamacchi@festivaldispoleto.com).
It should be noted that the IT Platform guarantees, through the use of cryptographic tools, the discretion the identity of the whistleblower, the person involved and the person mentioned in the report, as well as the content of the report and the related documentation.
In addition, the whistleblower cannot be subjected to a Retaliatory measure, direct or indirect, affecting working conditions for reasons related to the report. Retaliatory measures mean any behavior, act or omission, even if only attempted or threatened, carried out as a result of the report and that may cause the whistleblower, directly or indirectly, unfair damage.
By way of example, the following constitute retaliation:
· negative merit notes or negative references;
· coercion, intimidation, harassment or ostracism;
· damage, including to the person's reputation, in particular on social media, or economic or financial prejudice, including loss of economic opportunities and loss of income;
· the cancellation of a license or permit;
· the request to undergo psychiatric or medical tests.
Le Retaliatory communications must be transmitted exclusively to ANAC, through an IT platform (available by clicking on the following link https://www.anticorruzione.it/-/whistleblowing) for the investigations that the law assigns to them and for the possible imposition of an administrative sanction on the person responsible.
Without prejudice to the preference for internal reporting channels, Legislative Decree no. 24/2023 introduced the possibility of carrying out a external reporting, through a channel activated and managed byANAC (accessible by clicking on the following the https://www.anticorruzione.it/-/whistleblowing), if one of the following conditions are met:
· although the mandatory activation of the internal reporting channel is required, it is not active or, even if activated, it does not comply with the requirements set out in the Decree;
· the whistleblower has already made an internal report and it has not been followed up;
· the whistleblower has well-founded reasons to believe that, if he made an internal report, it would not be followed up effectively or that the report could cause the risk of retaliation;
· the whistleblower has reasonable grounds to believe that the violation may constitute an imminent or obvious danger to the public interest.
For more details, before proceeding with the report, please read carefully the Procedure for reporting offenses and the Privacy Policy (available by clicking on the following link:
Procedure for reporting wrongdoing (Whistleblowing policy)
