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.

In the organisational model proposed here, the responsibilities are allocated as follows. Management must provide the conditions for adopting and implementing the programme. The compliance officer monitors its application with the independence, decision-making autonomy and internal information needed. Operational teams carry out their assigned controls. Employees know and follow the procedures. The team receiving and following up reports needs defined roles and access rights; these functions should not all be assumed to belong to the same person.

Apply the following rule: The general threshold requiring an employer to establish an internal channel is 50 workers. Certain entities in regulated sectors are required to do so regardless of that number. The administrations of the Länder and municipalities require attention to their specific powers and provisions.

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.