La deontologia come fonte del diritto. La codificazione dell’etica medica in Francia, Germania e Italia.

The role of professional ethics as a source of law: a comparative analysis of the codification of medical ethics in France, Germany and Italy. The paper aims at analysing, from a comparative perspective, the role of the codes of medical ethics in France, Germany and Italy. The survey focuses on the formal aspects of the interrelationships between law and medical ethics, describing the codification of medical ethics, the regulatory function of the medical councils, the binding value of the codes of medical ethics and their position in the hierarchy of norms. From a more substantial perspective, the essay also gives a few examples of how the concrete role of medical ethics depends on the combination of some essential factors characterising the multi-layered relationships between law, medical ethics and professional associations.