Module Learning Objective

explain how the risk prevention plan, code, training and channel work together

1. Regulatory Concept & Core Standards

This video's topic is the elements of a compliance programme. By the end, you should be able to explain how the risk prevention plan, code, training and channel work together. We will connect the information available, the criterion guiding the decision and the action that must be recorded. Follow the case and compare your answer with the proposed response. The General Regime for the Prevention of Corruption, abbreviated as RGPC, structures prevention in covered entities. This course helps each person recognise risks and understand how organisational instruments relate to decisions at work.

The compliance programme includes at least a risk prevention plan, a code of conduct, a training programme and a reporting channel. The risk prevention plan, or PPR, identifies risks and measures. The code guides behaviour. Training helps people apply rules. The channel enables concerns to be reported and followed up. Appointing a compliance officer provides coordination and monitoring of the programme.

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

Choose a process, such as procurement, and follow it through the four instruments. Locate the risk in the PPR, the rule in the code, the example in training and the route for reporting a suspicion. If a link is missing, assign a concrete action. Four files in a folder do not show that people know the rules or that controls work. 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 fictional organisation identifies a risk of favouring suppliers. The PPR requires documented criteria, the code regulates conflicts, training practises declarations of interests, and the channel receives a report of a possible breach. Analysis may reveal that a control needs strengthening. 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: An organisation has published a code, but nobody knows where to report a concern. Which connection in the programme is failing? 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 connection between the conduct rule, communication and the channel is failing. Check that the channel is accessible, explain the procedure and confirm that people can use it, as well as keeping the documents available.

One mistake to avoid is: confusing the existence of documents with the effective operation of a programme.

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.