The elements of a compliance programme

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 plan, code of conduct, training and reporting 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. An integrity programme connects risks, behaviour, controls and reporting. Duties are assessed under Slovenian law. The preventive model is recommended practice unless a specific applicable duty is identified.

An integrity programme can bring together risk assessment, rules of conduct, training and a reporting channel. The plan identifies risks and measures; the code guides decisions; training develops appropriate behaviour; and the channel helps detect problems. This structure is a management proposal. Present an element as legally mandatory only where the applicable national provision requires it.

Apply the following rule: Entities with an internal-route duty and external authorities report previous-year statistics to KPK by 1 March; this does not mean sending every identified case. The ZIntPK integrity plan has a different group of obliged entities. Current KPK guidelines apply from 1 January 2025, with reporting on implementation by 5 June. Portugal’s RGPC is not Slovenian law. Recommended organisational measures are not automatically universal legal duties.

2. Practical Implementation & Procedure

Choose a process, such as procurement, and trace it through the four elements. Locate the risk in the risk plan, the rule in the code, the example in the training and the route for reporting a concern. If a link is missing, assign a specific action. Keeping four documents in a folder does not demonstrate that people know the rules or that the 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

An organisation addresses supplier favouritism. The plan requires documented criteria, the code covers interests, training covers disclosure and the channel receives a report. Assessment may reveal a need for additional control. 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: The code is published but nobody knows where to report a suspicion. What is missing? 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 rule, communication and route. Check accessibility, explain the procedure and test whether people can use it.

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

Now apply the national rule to a second decision. The team describes every prevention measure as mandatory in every organisation. How should the explanation change?

Separate the specific duty and its obliged entities from recommended practice. Integrity plans, conflicts and public procurement have their own scope. Portugal’s RGPC does not transfer automatically. For a recommended control, identify risk, owner and evidence of effectiveness.