Module Learning Objective

prepare a verifiable improvement plan

1. Regulatory Concept & Core Standards

In this video we will consolidate a skill: prepare a verifiable improvement plan. Use the case to test what you would do in a similar situation. We will explain the proposed response step by step so that you can understand each choice and recognise when more information would be needed. An integrity programme connects risks, conduct rules, controls and reports. The Portuguese RGPC does not apply as national law in Greece or Cyprus. Each duty is assessed for the particular entity.

Assessment compares requirements, documents and actual operation. Outdated guidance, incomplete training and a broken link require different corrections. Few reports do not establish absence of wrongdoing.

Apply the following rule: Part II covers the listed EU-law fields, EU financial interests and the internal market. Law 148(I)/2025 adds specified breaches of EU restrictive measures in section 4(1)(d). Part III covers national offences, failures to comply with legal obligations, risks to safety or health and environmental harm. Apply the exclusions concerning defence/security, classified information, legal and medical confidentiality and judicial or criminal procedures.

2. Practical Implementation & Procedure

Collect evidence of operation. Record finding, risk, owner and correction deadline. Define a test of the result and limit conclusions to the examined sample. 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.

Consider how a colleague taking over tomorrow would understand the decision. Identify the verified information and its source, who is authorised to decide and who checks the result. The record should connect the decision to the material actually used rather than repeat the whole file. State critical gaps and assign a specific action to resolve them. This makes continuity independent of one person’s memory. Apply the proposed organisational steps within legal powers. In the case, distinguish observation, conclusion and hypothesis. An observation describes available evidence, a conclusion explains what can reasonably be inferred and a hypothesis still needs checking. Do not infer motives merely from unusual behaviour. Identify which further information could change the decision and whether it can be obtained lawfully and proportionately. Incomplete knowledge justifies neither certainty of guilt nor indifference to an actual risk.

3. Case Study & Compliance Action

The code is current but the channel link fails. The training record does not show who participated. 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: What should the assessment deliver? 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.

A specific corrective plan with an owner and completion evidence. Collecting documents begins the assessment rather than completing it.

One mistake to avoid is: calling a limited check full certification.

Now apply the national rule to a second decision. A report is automatically called protected because it includes the word corruption. What check is missing?

Assess the facts, work-related context and national protection conditions. The form label helps organise information but does not decide legal coverage. If the case is outside scope, identify an appropriate procedure without unnecessary disclosure.

National Legal Framework: Law 6(I)/2022 on Whistleblower Protection, transposing Directive (EU) 2019/1937 of the European Parliament and of the Council on the protection of persons who report breaches of Union law.