Responsibilities of management, designated officers and employees

1. Regulatory Concept & Core Standards

This video focuses on how to distinguish the responsibilities of those involved in the compliance programme. 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. An organisation needs clear decision rules and a way to respond to breaches. The Polish whistleblower Act governs reporting and protection, while other provisions address corruption, procurement and public-sector management control. This course connects these areas without presenting every recommendation as an obligation for every company.

In the organisational model proposed here, the responsibilities are allocated as follows. Management must provide the conditions for adopting and implementing the programme. The compliance officer monitors its application with the independence, decision-making autonomy and internal information needed. Operational teams carry out their assigned controls. Employees know and follow the procedures. The team receiving and following up reports needs defined roles and access rights; these functions should not all be assumed to belong to the same person.

Apply the following rule: Article 23 generally requires an internal procedure where at least 50 people perform paid work, assessed on 1 January or 1 July. Count employees as full-time equivalents and qualifying paid non-employees who do not employ others for that work. Specified regulated activities are exempt from the threshold; local public units have separate rules. Consult unions or worker representatives for 5–10 days; the procedure takes effect seven days after announcement under article 24.

2. Practical Implementation & Procedure

For each activity, identify who performs it, who decides and who verifies it. Also define cover for absences and arrangements for handling conflicts. A simple matrix can connect risk-plan reviews to the responsible officer and channel management to the designated team. Access to reports must follow a functional need, not merely a senior position in the organisation. 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 chief executive requests every reporting person’s name to assess channel performance. Aggregated data are sufficient to assess timeliness. The team limits the information to what the oversight task requires. 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: Does seniority alone justify access to reporting persons’ identities? 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. Access needs a basis, authorisation and necessity for the specific task. Management reporting should limit identification where it is unnecessary for the decision.

One mistake to avoid is: assigning all controls to the compliance officer and removing responsibility from operational teams.

Now apply the national rule to a second decision. A subsidiary copies its foreign parent’s procedure without assessing its own activities and size. What should it check?

Identify the Polish entity, sector and number of people under Article 23, using the correct reference date and counting method. Check sectoral and public-sector exceptions. Consultation and commencement under Article 24 also matter. A group template does not replace assessment of responsibility or the lawfulness of shared access.