PRINCIPALI CRITICITÀ DELLA DISCIPLINA ITALIANA IN MATERIA DI WHISTLEBLOWING ALLA LUCE DELLA NUOVA DIRETTIVA EUROPEA: LIMITATO CAMPO DI APPLICAZIONE E SCARSI INCENTIVI

The present article aims to reach two main goals. Firstly, it stresses out the discrepancy between the Italian three heterogeneous legal regimes on whistleblower protection and the new European legal framework. In order to do so, the present analysis shows the inconsistency of maintaining the current differences between private and public sector regulations in comparison with the single regime introduced by new directive, together with its wide personal and material scope. Secondly, having regard to the overall framework of both the new European directive and the actual Italian legislation the present analysis focuses on those incentives the mentioned legal regimes fail to provide in order to possibly stimulate reporting.