Module Learning Objective

turn an established weakness into prevention

1. Regulatory Concept & Core Standards

In this video we will consolidate a skill: turn an established weakness into prevention. 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. The private company Horizont is entirely fictional. It has 120 employees on 1 January and, in this model, is neither a public contracting authority nor subject to the special AML regime. An identified employee reports changed purchasing criteria and an alleged personal benefit. All people, documents and events are fictional.

A case can inform controls, risk assessment and training. Lessons must not reveal the reporting person or present unsubstantiated suspicions as facts. Measures need owners and verification. One fictional case does not prove organisation-wide compliance.

Apply the following rule: Written and oral reporting must both be available; a requested personal meeting must be arranged within a reasonable time, at most 14 days from the request. The competent person must meet section 10 requirements and act impartially under section 11; the instruction required by section 9 is recorded. Under section 19, an audio recording requires consent and the reporting person may comment on the record or transcript. Sharing, outsourcing and special AML rules need separate assessment. The Portuguese RGPC is not Czech law.

2. Practical Implementation & Procedure

Update the risk of criterion changes, define a control and a suitable test sample. Use a fictional training example preserving the lesson. Monitor cover, retaliation risks and channel accessibility, and verify the measure’s effect at the chosen review point. 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 subsequent check finds independent approval and retained history for new changes. The report states its verification scope. Training explains the task without names or data from the original 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: When does a case support real improvement? 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.

When findings lead to a proportionate measure whose operation is verified. Closing the file or distributing slides alone does not establish effectiveness. Preserve confidentiality when sharing lessons.

One mistake to avoid is: disclosing case details or claiming success without verification.

Now apply the national rule to a second decision. The team presents every integrity instrument as mandatory in every country. How should the message be revised?

Distinguish what national law actually requires, the conditions for its application to the entity and the proposed good practices. The specific rule just examined must appear in the corresponding procedure. Each duty needs a source; each management choice needs a purpose, an owner and evidence of implementation.

National Legal Framework: Zákon č. 171/2023 Sb. (Whistleblower 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.