Module Learning Objective

define independent and proportionate follow-up for the Horizonte case

1. Regulatory Concept & Core Standards

Today we will learn to define independent and proportionate follow-up for the Horizonte case. 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. The organisation Horizonte Equipamentos, its people and events are entirely fictional. The private company employs 120 workers and operates an internal channel. Five episodes follow suspected serious favouritism in purchasing. This is private procurement; public procurement law is not assumed to apply automatically.

Normal routing sends procurement matters to the director mentioned in this report. Automatic allocation would create a conflict and unnecessary exposure. The company has an independent alternative. A planned system migration next week may also affect version records needed for assessment.

Apply the following rule: The Act does not impose a universal duty on internal schemes to accept anonymous reports. The National Whistleblower Scheme accepts anonymous reports and allows further dialogue through its portal. Internal information must describe the actual service. Confidentiality also protects indirectly identifying information. Public workplaces may have investigation duties under other rules when anonymous information is received; the absence of a general duty under this Act does not justify ignoring every such report.

2. Practical Implementation & Procedure

The team blocks director allocation, appoints an independent handler and records why. It requests authorised preservation of relevant procurement records. It assesses urgency and any external reporting obligations. Initial plans and questions must not ask the reporting person to seek information 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

The independent handler asks when the change appeared. The author saw the second version two days before the decision but does not know who created it. The team records that limit and examines system logs instead of demanding a name. 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: Should the procurement director receive the whole case merely because they normally lead the department? 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. The director is mentioned and a conflict must be addressed. Use the defined independent route with appropriate access. Departmental review must not undermine impartiality or unnecessarily expose the reporting person's identity.

One mistake to avoid is: retaining automatic routing when its recipient is a person concerned by the report.

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: Lov om beskyttelse af whistleblowere, transposing Directive (EU) 2019/1937 of the European Parliament and of the Council on the protection of persons who report breaches of Union law.