Module Learning Objective

distinguish the responsibilities of those involved in the compliance programme

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. 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.

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.

National rule: The general internal-channel obligation applies to legal entities with 50 or more workers and certain regulated entities regardless of headcount. The law has specific rules for public entities, resource sharing and branches. Assess the RGPC's scope separately.

2. Practical Implementation & Procedure

For each activity, identify who carries it out, who decides and who verifies it. Define cover for absences and conflict handling. A simple matrix can link the PPR review to its owner and channel management to the designated team. Access to reports must follow a functional need, not merely a senior position. 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 director requests access to every report to monitor the programme. One report concerns the director's own department and possible personal involvement. Management oversight can be supported by aggregated information and an independent body, avoiding unrestricted access to the case file. 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: Is membership of the management team sufficient to justify full access to every report? 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. Assess the person's role in handling the case, their need to know and any potential conflicts. Management's oversight duty does not remove the confidentiality or independence required in case management.

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

A subsidiary copies its foreign head office's policy without assessing its own activities and size. What must it check?

Identify the local legal entity, sector, national counting method and any public-sector or territorial regimes. Then link each obligation to a source and a responsible person. A group model can support operations but does not replace this assessment.

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.