Module Learning Objective

formulate clear, neutral and useful requests for clarification

1. Regulatory Concept & Core Standards

This video's topic is requesting clarification and communicating. By the end, you should be able to formulate clear, neutral and useful requests for clarification. We will connect the information available, the criterion guiding the decision and the action that must be recorded. Follow the case and compare your answer with the proposed response. Handling a report requires continuity: each stage must leave enough information for the next. This course follows the team's work, distinguishing case administration, factual analysis and communications with the reporting person. The examples concern internal channels.

Contact should clarify facts without pressuring the person to identify themselves or conduct their own investigation. Open questions collect context; specific questions clarify dates, documents or participants. Avoid suggesting answers. Communications must also protect third parties' identities and avoid disclosing investigative steps where disclosure could prejudice the assessment.

Apply the following rule: Anonymous reports should be handled in accordance with section 16, but the HinSchG does not generally require a technical facility for anonymous submission. Check sector-specific requirements and the service actually provided before advertising it.

2. Practical Implementation & Procedure

Prepare a small number of questions linked to specific gaps. Explain what needs clarification and allow the person to say they do not know. Use the channel's secure means and record the reply. Distinguish direct observation from information heard from others. Do not ask the person to obtain documents they cannot lawfully access. 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

Instead of asking whether the director received money, the team asks what behaviour was observed, when and what supports the account. The person explains that they saw a written instruction but no payment. The investigation no longer rests on an unverified inference. 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: Which is the better opening question: ‘Can you confirm there was bribery?’ or ‘What facts did you observe, and when?’ 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.

The second. It collects information without imposing a conclusion. More specific questions may follow, always distinguishing observation, third-party information and interpretation. The team must accept that some details may be unknown.

One mistake to avoid is: turning a clarification request into a demand that the whistleblower collect additional evidence.

Now apply the national rule to a second decision. The form always requires a name and identity document, but the page advertises anonymity. How should this be corrected?

First apply the national regime and define what the channel actually offers. Where identity is unnecessary, do not require it for technical convenience. Where it is a condition for a particular status, explain that before submission. Correct the fields and public information together while preserving material already received.

National Legal Framework: HinSchG (Hinweisgeberschutzgesetz), transposing Directive (EU) 2019/1937 of the European Parliament and of the Council on the protection of persons who report breaches of Union law.