Module Learning Objective

assess programme instruments for consistency and currency

1. Regulatory Concept & Core Standards

Today we will learn to assess programme instruments for consistency and currency. 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. Audit compares criteria with evidence and reports findings within a defined scope. This course proposes an internal verification approach. It is not official certification or a guarantee that no wrongdoing exists. Access to reports must remain limited and justified during audit.

Documentary review checks content, approval, version, dissemination and connection to actual activity. A well-written model may not suit the entity. Confirm responsibilities and consistent procedures across documents. Repealed references or obsolete contacts can give incorrect instructions despite polished presentation.

National rule: For covered entities, the RGPC requires a compliance programme including a corruption risk prevention plan, a code of conduct, training and a reporting channel, together with appointment of a compliance officer. Confirm the scope and duties of each instrument under the applicable regime.

2. Practical Implementation & Procedure

Gather the PPR, code, training, channel procedures and appointments. Compare versions and dates. Check responsibilities against the current structure and applicable communications. Distinguish missing, inadequate and inconsistent documents. Cite criteria and evidence for observations rather than relying on drafting preferences. 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 procedure names a defunct team and the annual plan retains monthly returns based only on Recommendation No 7/2024. Review checks changed responsibilities and revocation by Recommendation No 1/2026, proposing reasoned updates. 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 an approved document necessarily remain suitable after organisational or legal changes? 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. Approval records a decision at a particular time. Check currency and application. Identify relevant changes and update needs without treating age alone as automatic non-compliance.

One mistake to avoid is: judging documents only by format or expected headings.

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: Lei n.º 93/2021 & RGPC (DL 109-E/2021), transposing Directive (EU) 2019/1937 of the European Parliament and of the Council on the protection of persons who report breaches of Union law.