Module Learning Objective

design a management structure with cover arrangements and conflict handling

1. Regulatory Concept & Core Standards

Today we will learn to design a management structure with cover arrangements and conflict handling. Throughout the video, consider the difference between knowing a rule and applying it to a decision. We will work through an example, identify a possible failure and develop a response that can be used at work. 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.

Sections 10 and 11 regulate the competent person and impartiality. General section 8(2) permits another person to operate the system, while responsibility remains with the obliged entity. Sharing under section 8(3) has separate conditions, including the limit of 249 employees for each eligible entity, rather than the group total, and designated receipt and acknowledgement functions. Municipalities have their own sharing provision. Assess special AML rules separately.

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

Determine the competent person, absence cover and conflict procedure before giving access. Distinguish outsourcing from sharing. The Ministry FAQ calls for data and functional separation where a provider is itself an obliged entity, including an appropriate separation of competent-person roles. Do not assume that a group contract permits every company to read every report. Verify the requested-meeting duty and available resources. 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

The sole channel manager takes three weeks of leave. A report arrives on the first day and nobody monitors the inbox. An automatic notification does not solve the problem: there was no authorised substitute with tested access and clear instructions on the work required. 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 is the most appropriate preventive measure for the channel manager's absence? 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.

Appoint and prepare a substitute in advance, grant proportionate access and define the period of cover. Substitution must respect conflicts of interest in each case and leave a record of the actions taken.

One mistake to avoid is: assuming that buying software amounts to contracting the entire report-handling service.

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.