Module Learning Objective

choose measures addressing the causes of risk

1. Regulatory Concept & Core Standards

This video focuses on how to choose measures addressing the causes of risk. 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. A risk matrix should reflect actual organisational activities. The course presents a risk plan as a management tool. Example scales and controls are not universal Croatian statutory requirements. Match them to the entity’s specific obligations and procedures.

An effective measure addresses how risk can occur. It may prevent, detect or correct. Separation of duties, independent approval, third-party checks and decision records serve different purposes. Training helps but does not always replace process controls. The integrity programme should prioritise more thorough measures for high or maximum risks.

Apply the following rule: The employer adopts and makes accessible a general act on internal reporting and appointment of the confidential person and deputy. The employer must not interfere with their statutory handling to protect the reporting person. An unauthorised recipient must forward the report without delay and without alteration to the confidential person, protecting its data. Articles 17 and 18 regulate oral reports and requested meetings, including recording consent and the opportunity to check records. Portuguese RGPC is not Croatian legislation.

2. Practical Implementation & Procedure

Link each measure to its intended cause. Define performer, owner, frequency, evidence and implementation date. Assess feasibility and resources. In a small team, seek suitable compensating controls instead of describing impossible separation. Also identify who monitors overall implementation of the risk plan. 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

For bank-detail changes, the entity requires independent confirmation through a previously verified contact and a second approval. This addresses improper changes. A generic reminder to be careful did not offer equivalent prevention and verification. 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 distinguishes ‘pay more attention’ from documented independent confirmation? 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 specifies an observable action, a point in the process and evidence. The first is difficult to test. A sound measure shows who performed it, for which transaction and with what result.

One mistake to avoid is: assigning vague or unfunded measures to people unable to implement them.

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: Zakon o zaštiti prijavitelja nepravilnosti, transposing Directive (EU) 2019/1937 of the European Parliament and of the Council on the protection of persons who report breaches of Union law.