Module Learning Objective

produce a list of requirements for a whistleblowing channel

1. Regulatory Concept & Core Standards

In this video we will work through a concrete decision: produce a list of requirements for a whistleblowing channel. The aim is to explain the criterion used and apply it to a workplace situation. We will start with the concept, move to the procedure and finish with a case to solve. Setting up a channel involves people, procedures and technology. The platform supports operations, but the organisation still needs clear decisions on responsibilities, information protection and follow-up. This course covers preparing the service before receiving real reports.

The assessment starts with the legal framework and intended users. An organisation with several sites, shifts and service providers may need different access and communication arrangements from an entity operating in a single office. The channel must support secure reporting and follow-up. Practical accessibility depends on language, the available means and the ability to report without approaching a directly implicated manager.

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

List workers, service providers and other relevant audiences. Identify who lacks a work email address, which languages are needed and which methods will be offered. Distinguish legal requirements from service choices. Law No 93/2021 allows written and/or oral internal channels. Where oral reporting is available, consider applicable rules on in-person meetings on request and recording. 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 factory has 120 workers, half of whom do not use a computer at work. Publishing only an intranet link leaves some intended users without practical access. The team proposes information in common areas, mobile-compatible access and a clear explanation of secure follow-up. 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: What requirement is missing if the channel works technically but only office employees can find it? 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.

Suitable access and communication for the actual audiences are missing. The needs assessment must document barriers and the proposed solution. The existence of an online address alone does not demonstrate that every intended user can use the service.

One mistake to avoid is: copying another organisation's requirements without considering the actual audiences and processes.

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.