Responsibilities of management, designated officers and employees

1. Regulatory Concept & Core Standards

This video focuses on how to distinguish the responsibilities of those involved in the compliance programme. 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. An integrity programme connects risks, behaviour, controls and reporting channels. The obligation to protect whistleblowers must be assessed under national law. The prevention measures used in the examples are good practice unless identified as a specific legal obligation applicable to the organisation.

Management provides organisation and resources, while teams perform assigned controls. Designated staff under article 14 have specific report-handling duties and must avoid conflicts in each case. Wider prevention coordination is a separate organisational question. Seniority alone does not grant unrestricted access to identities and files. Apply the register’s special access rules and confidentiality requirements.

Apply the following rule: Article 12 covers public-sector employers, private employers with at least 50 workers and specified regulated activities regardless of headcount. Resource sharing is subject to conditions for small municipalities and private employers with 50–249 workers; confidentiality and individual duties remain. Article 14 requires designated staff without conflicts. Since the 2025 amendment, private obliged entities may outsource receipt and registration of reports; this does not automatically transfer all handling functions.

2. Practical Implementation & Procedure

For each activity, identify who performs it, who decides and who verifies it. Also define cover for absences and arrangements for handling conflicts. A simple matrix can connect risk-plan reviews to the responsible officer and channel management to the designated team. Access to reports must follow a functional need, not merely a senior position in the organisation. 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

A director requests access to every report to monitor the programme. One report concerns the director's own department and possible personal involvement. Management oversight can be supported by aggregated information and an independent body, avoiding unrestricted access to the case file. 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: Is membership of the management team sufficient to justify full access to every report? 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. Assess the person's role in handling the case, their need to know and any potential conflicts. Management's oversight duty does not remove the confidentiality or independence required in case management.

One mistake to avoid is: assigning all controls to the compliance officer and removing responsibility from operational teams.

Now apply the national rule to a second decision. A subsidiary copies its foreign head office's policy without assessing its own activities and size. What must it check?

Identify the local legal entity, sector, national counting method and any public-sector or territorial regimes. Then link each obligation to a source and a responsible person. A group model can support operations but does not replace this assessment.