produce a list of requirements for a whistleblowing channel
1. Regulatory Concept & Core Standards
In this video we will work through a concrete decision: produce a list of requirements for a whistleblowing channel. The aim is to explain the criterion used and apply it to a workplace situation. We will start with the concept, move to the procedure and finish with a case to solve. Setting up a channel involves people, procedures and technology. The platform supports operations, but the organisation still needs clear decisions on responsibilities, information protection and follow-up. This course covers preparing the service before receiving real reports.
Map the legal framework and actual users, including shifts and sites. Section 9 requires written and oral reporting, with personal receipt on request. Section 12 requires the requested meeting within a reasonable time and no later than 14 days from the request. Practical access requires more than an intranet address available only to office staff.
Apply the following rule: Section 8 generally covers employers with at least 50 employees on 1 January, designated public contracting authorities and listed regulated entities. Municipalities below 10,000 residents and specified public bodies have separate exceptions. Act No 32/2025, article XIX, added to section 8(1)(e)(8) certain persons offering or seeking admission to trading of crypto-assets other than asset-referenced or e-money tokens, and issuers of asset-referenced tokens under MiCA. Assess the listed activity rather than assuming that every firm below 50 employees is exempt.
2. Practical Implementation & Procedure
Identify users, language and device needs, and any lawful section 9 limitation on internal acceptance. Confirm oral arrangements. Under section 19, use an audio recording with consent or a faithful record, allowing comments on the record or transcript. Separate required functions from optional service choices and describe only functions actually available. 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 fictional factory has 120 workers, half of whom do not use a computer at work. Publishing only an intranet link leaves some intended users without practical access. The team proposes information in common areas, mobile-compatible access and a clear explanation of secure follow-up. 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 requirement is missing if the channel works technically but only office employees can find it? 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.
Suitable access and communication for the actual audiences are missing. The needs assessment must document barriers and the proposed solution. The existence of an online address alone does not demonstrate that every intended user can use the service.
One mistake to avoid is: copying another organisation's requirements without considering the actual audiences and processes.
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.