Module Learning Objective

apply consistent criteria to different relationships

1. Regulatory Concept & Core Standards

In this video we will consolidate a skill: apply consistent criteria to different relationships. Use the case to test what you would do in a similar situation. We will explain the proposed response step by step so that you can understand each choice and recognise when more information would be needed. Managing interests protects impartiality before a decision is affected. A conflict is not automatically proven corruption. An internal monetary limit does not make every offer below it lawful.

Family connection, previous cooperation and financial interest do not always carry equal weight. Assess the relationship to the decision. Wrongdoing is not automatically established.

Apply the following rule: The National Transparency Authority, EAD, manages the external channel under Law 4990/2022. It distinguishes general complaints, its own internal channel and the external whistleblowing channel. Select the route matching the relationship and subject.

2. Practical Implementation & Procedure

Describe interest and influence. Check the specific provision and policy. Select a proportionate measure through independent judgment and verification. 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.

Consider how a colleague taking over tomorrow would understand the decision. Identify the verified information and its source, who is authorised to decide and who checks the result. The record should connect the decision to the material actually used rather than repeat the whole file. State critical gaps and assign a specific action to resolve them. This makes continuity independent of one person’s memory. Apply the proposed organisational steps within legal powers. In the case, distinguish observation, conclusion and hypothesis. An observation describes available evidence, a conclusion explains what can reasonably be inferred and a hypothesis still needs checking. Do not infer motives merely from unusual behaviour. Identify which further information could change the decision and whether it can be obtained lawfully and proportionately. Incomplete knowledge justifies neither certainty of guilt nor indifference to an actual risk.

3. Case Study & Compliance Action

One committee member owns shares in a bidder. Another knows a representative from an old conference. 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: Must the same automatic solution apply? 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 each under legal criteria without ignoring real interests or overinterpreting a simple acquaintance.

One mistake to avoid is: identical conclusions for every personal contact.

Now apply the national rule to a second decision. An advice page is shown as the sole recipient for every report. What should be checked?

Check the recipient’s powers and function. Guidance, external receipt, investigation and protection may belong to different bodies. Instructions must lead to the correct procedure without steps that the law does not require.

National Legal Framework: Law 4990/2022 (Whistleblower Protection), transposing Directive (EU) 2019/1937 of the European Parliament and of the Council on the protection of persons who report breaches of Union law.