Module Learning Objective

prepare appropriate feedback and protected closure of the internal stage

1. Regulatory Concept & Core Standards

This video focuses on how to prepare appropriate feedback and protected closure of the internal stage. Follow the sequence of decisions in the example rather than simply memorising a list. Notice who is involved, what information is needed and the expected result. These points help turn the content into a practice that another person can verify. The private company Horizonte Equipamentos, its 120 employees and all events are fictional. Five episodes follow suspected improper benefit in purchasing. An internal procedural failure is not automatically a crime or a public procurement. Scope and competence are checked throughout.

The team records action, referral and control weaknesses without declaring the result of unfinished criminal proceedings. Internal feedback is due within three months after acknowledgement or after expiry of the seven-day period if none was sent. Separate article 17 outcome communication must protect the people concerned.

Apply the following rule: For internal reports, acknowledge receipt within seven days of receipt. Give feedback on follow-up within three months after acknowledgement or, if none was sent, after expiry of the seven-day acknowledgement period: article 16, points 1 and 4. Do not substitute 90 days or the opening date. Externally, article 23 requires immediate acknowledgement, no later than seven days after receipt, with exceptions for an express request or risk to identity protection. Feedback is due within three months, extendable to six in duly justified cases requiring an in-depth investigation. The article 26 report is due within three or, as applicable, six months of receipt. The external extension does not apply to internal reporting.

2. Practical Implementation & Procedure

Prepare accurate information under the applicable procedure and assess disclosure restrictions. Assign permissible procedural corrections and document reasons. At closure, apply Regulation No 1’s five-year period and exception for instituted related proceedings. Do not start the period automatically at receipt. Before moving on, turn this procedure into a sequence you could explain to a colleague. Identify the first check, the action that depends on its outcome and the record that allows the decision to be reconstructed. Follow the sequence on screen and identify the point where an error would change the result.

3. Case Study & Compliance Action

Feedback explains action and competent referral without attaching all interviews or personal employment data. The file retains the actual communication and date. Related proceedings inform retention without an automatic indefinite hold on everything. Now read the case carefully. Separate established facts from information you would still need to confirm. Do not add motives or events that have not been described. This distinction matters when choosing a response proportionate to the information available.

The exercise is as follows: Must meaningful feedback include the entire internal archive? Choose an answer and write one sentence explaining it. During the pause, compare your choice with the criteria we have just considered. Also think about the material you would retain to explain the decision later.

No. Meet the specific information duty while respecting confidentiality, personal data and affected rights. Neither an empty message nor automatic disclosure of every attachment is sufficiently justified.

One mistake to avoid is: confusing the feedback deadline with the final result of all proceedings.

Now apply the national rule to a second decision. The platform uses a fixed 90-day period for every country, starting when someone opens the message. Can this setting be retained?

Not without validating the local rule. Use the correct starting event and unit, distinguish acknowledgement from follow-up and allow only permitted extensions. Test receipt outside working hours, month-end dates and the responsible person's absence. Opening a message does not automatically change the legal date of receipt.

National Legal Framework: ZZLPSPOIN (Whistleblower Protection Act), transposing Directive (EU) 2019/1937 of the European Parliament and of the Council on the protection of persons who report breaches of Union law.