Module Learning Objective

develop an initial plan proportionate to the report received

1. Regulatory Concept & Core Standards

Today we will learn to develop an initial plan proportionate to the report received. 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. 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.

Initial review checks facts, statutory scope, competence and risks and is distinct from a complete investigation. Article 22 requires protective action within the person’s competence without delay. Risk of losing relevant records may require prompt lawful preservation with proportionality and restricted access.

Apply the following rule: Article 4 covers the listed EU-law fields, EU financial interests and the internal market. The 2025 amendment adds restrictive-measures legislation in the Annex and specified offences against the economy and official duties, embezzlement and bribery of representatives. Other breaches of national law are covered where they also threaten the public interest. Check the work-related context in Article 6, the protection conditions in Article 12 and the exceptions and special rules in Articles 4 and 5.

2. Practical Implementation & Procedure

Separate allegations by subject and identify available information for each. Select initial checks, their owner and the planned date. If the case involves the designated team, activate an independent alternative. Assess any legally required communications to authorities; internal analysis must not delay applicable external obligations. 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 report states that approval records will be deleted following a system change. There is not yet proof of favouritism, but there is a concrete risk of information loss. The team requests authorised preservation of relevant records without indiscriminately blocking every organisational system. 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 first step seek to prove the allegation immediately or preserve material needed for the assessment? 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.

Where loss is a risk, preserve relevant material lawfully and proportionately while organising the assessment. This measure does not establish the responsibility of anyone mentioned.

One mistake to avoid is: treating the first reading as a final decision on the truth of the allegations.

Now apply the national rule to a second decision. A report is automatically classified as protected because it contains the word corruption. What check is missing?

Read the facts and apply the national scope, context and conditions for protection. A form label helps organise information but does not determine the legal framework. If the case falls outside the regime, identify an appropriate route without unnecessarily disclosing information.

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.