Fondazione Bruno Kessler is a research and innovation organization. It partakes in the system established by the Autonomous Province of Trento of which it is a private instrumental body. Due to its configuration, the Foundation sometimes falls within the framework of the public sector, other times in the context of the private sector, depending on the context in which happens to be operating. Hence the complex system of internal and external authorities in charge of protecting the legality and integrity of its operations.
With a view to managing corruption risks, the peculiar configuration of the Foundation allows for two separate authorities, one being the Supervisory Body and the other the Corruption Prevention and Transparency Chief Officer. Both authorities, while maintaining autonomy of action and judgment, operate according to a logic of integration and synergy.
In this context and considering the level of corruption risk present in the Foundation, the risk management model adopted in the framework of the regulations drawn up by the National Corruption Prevention Authority and by the Corruption Prevention and Transparency Plan mainly focuses on mismanagement understood not only as decisions deviating from pursuing the general interest due to inappropriate control by personal interests but also as the failure to apply the principles of effectiveness, efficiency and affordability when executing the organizational and operational functions of the Foundation. Hence an approach to risk management inspired by compliance management models aimed at looking at the organization as a living and complex entity, an expression of rules, processes, people and values fitting into a constantly changing context.
In this context, the Corruption Prevention, Transparency and Privacy Unit, ensures the monitoring and organizational-functional support regarding corruption prevention and transparency as well as the dissemination of staff knowledge and awareness.
The FBK Corruption Prevention and Transparency Chief Officer (RPCT), appointed by the Board of Directoris pursuant to art. 1, c. 7 of the Corruption Prevention Act (Act. No. 190/2012), is Alessandro Dalla Torre.
Corruption Prevention and Transparency Three-Year-Plan
Organization, Management and Control Model pursuant to Legislative Decree No. 231/2001
Internal Auditing Activities
Monitoring and control over the implementation of this Plan and the relevance of the related measures are ensured by the Deming Cycle applied to the management of corruption and mismanagement risk. This process concerns the managers of the organizational units involved in the implementation of the Plan (first level monitoring and control) and the RPCT (second level monitoring and control). The monitoring and control activity is therefore to be considered constant with regular in-depth analysis sessions exploring the suitability of the planned measures that will be always documented in specific reports.
Above all, the second level monitoring and control activity (or third level when it is undertaken by the Supervisory Body of the Foundation or by the Board of Statutory Auditors) translates into two types of verification:
Sample checks, relating to recursive obligations as they refer to procedures that regulate or govern the appropriate performance of administrative functions (for example, compliance with procedures relating to the selection of a contractor).
Specific checks, relating to one-time obligations that are perfected and concluded at a set time (for example, the adoption of a regulation or a policy).
Reporting
Reporting of all second-level monitoring and control activities is prepared by the RPCT on an annual basis and then published in the “Transparent Administration” section of the Foundation's institutional website.
In the same section are also published the annual reports of the training provided on corruption prevention and transparency matters.
Starting from 2019, the monitoring system and training activities are integrated with the activities planned the data protection matters.
The RPCT, within the deadlines established by the National Corruption Prevention Authority, also draws up an annual report in which he gives an account of the activities conducted and the results achieved after the implementation of this Plan. This report is submitted to the Board of Directors and published in the website section dedicated to the “Transparent Administration”.
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Useful contacts
Head of Corruption Prevention and Transparency.
trasparenza@fbk.eu
anticorruzione@fbk.eu
anticorruzione@pec.fbk.eu