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Establish internal reporting channels |
Governance |
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- Description:
- Establish internal reporting channels and procedures for internal reporting and follow-up.
- Frequency:
- Continuous
- Check frequency:
- -
- Products/Services:
- Activities and products covered by the areas and Union acts referred to in Article 2(1)
- Checking responsibility:
- -
- Check method:
- -
- Rule set:
-
-
- Source reference:
- Article 8(1)
- Source excerpt:
- Member States shall ensure that legal entities in the private and public sector establish channels and procedures for internal reporting and for follow-up, following consultation and in agreement with the social partners where provided for by national law.
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Secure and confidential reporting channels |
Governance |
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- Description:
- Design, establish and operate reporting channels securely so that the identity of the reporting person and any third party mentioned in the report remains confidential and unauthorised access is prevented.
- Frequency:
- Continuous
- Check frequency:
- -
- Products/Services:
- -
- Checking responsibility:
- The company or entrusted third parties operating the reporting channel
- Check method:
- -
- Rule set:
-
-
- Source reference:
- Article 9(1)(a)
- Source excerpt:
- channels for receiving the reports which are designed, established and operated in a secure manner that ensures that the confidentiality of the identity of the reporting person and any third party mentioned in the report is protected, and prevents access thereto by non-authorised staff members;
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Acknowledge receipt within seven days |
Other |
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- Description:
- Acknowledge receipt of a report to the reporting person within seven days.
- Frequency:
- Event-triggered
- Check frequency:
- -
- Products/Services:
- -
- Checking responsibility:
- Person or department responsible for handling reports
- Check method:
- Time check from receipt of the report
- Rule set:
-
-
- Source reference:
- Article 9(1)(b)
- Source excerpt:
- acknowledgment of receipt of the report to the reporting person within seven days of that receipt;
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Designate an impartial reporting function |
Governance |
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- Description:
- Designate an impartial person or department to follow up on reports, communicate with the reporting person, request further information where necessary and provide feedback.
- Frequency:
- Continuous
- Check frequency:
- -
- Products/Services:
- -
- Checking responsibility:
- An impartial competent person or department
- Check method:
- -
- Rule set:
-
-
- Source reference:
- Article 9(1)(c)
- Source excerpt:
- the designation of an impartial person or department competent for following-up on the reports which may be the same person or department as the one that receives the reports and which will maintain communication with the reporting person and, where necessary, ask for further information from and provide feedback to that reporting person;
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Diligent follow-up of reports |
Due Diligence |
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- Description:
- Diligently follow up on reports and, where provided for in national law, diligently follow up on anonymous reports.
- Frequency:
- Event-triggered
- Check frequency:
- -
- Products/Services:
- -
- Checking responsibility:
- The designated competent person or department
- Check method:
- -
- Rule set:
-
-
- Source reference:
- Article 9(1)(d)
- Source excerpt:
- diligent follow-up by the designated person or department referred to in point (c);
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Provide feedback within three months |
Other |
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- Description:
- Provide feedback to the reporting person within a reasonable timeframe not exceeding three months.
- Frequency:
- Event-triggered
- Check frequency:
- -
- Products/Services:
- -
- Checking responsibility:
- The designated competent person or department
- Check method:
- Deadline check from acknowledgement or expiry of the seven-day period
- Rule set:
-
-
- Source reference:
- Article 9(1)(f)
- Source excerpt:
- a reasonable timeframe to provide feedback, not exceeding three months from the acknowledgment of receipt or, if no acknowledgement was sent to the reporting person, three months from the expiry of the seven-day period after the report was made;
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Information on external reporting procedures |
Stakeholder Engagement |
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- Description:
- Provide clear and easily accessible information on procedures for external reporting to competent authorities and, where relevant, to Union institutions, bodies, offices or agencies.
- Frequency:
- Continuous
- Check frequency:
- -
- Products/Services:
- -
- Checking responsibility:
- The company
- Check method:
- -
- Rule set:
-
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- Source reference:
- Article 9(1)(g)
- Source excerpt:
- provision of clear and easily accessible information regarding the procedures for reporting externally to competent authorities pursuant to Article 10 and, where relevant, to institutions, bodies, offices or agencies of the Union.
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Enable written and oral reporting |
Governance |
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- Description:
- Enable reporting in writing or orally; oral reporting must be possible by telephone or other voice messaging systems and, upon request, through a physical meeting.
- Frequency:
- Continuous
- Check frequency:
- -
- Products/Services:
- -
- Checking responsibility:
- The company
- Check method:
- -
- Rule set:
-
-
- Source reference:
- Article 9(2)
- Source excerpt:
- The channels provided for in point (a) of paragraph 1 shall enable reporting in writing or orally, or both. Oral reporting shall be possible by telephone or through other voice messaging systems, and, upon request by the reporting person, by means of a physical meeting within a reasonable timeframe.
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Record and retain reports |
Record Keeping |
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- Description:
- Keep a record of every report received in compliance with confidentiality requirements and store it only for as long as necessary and proportionate.
- Frequency:
- Event-triggered
- Check frequency:
- -
- Products/Services:
- -
- Checking responsibility:
- The company
- Check method:
- -
- Rule set:
-
-
- Source reference:
- Article 18(1)
- Source excerpt:
- Member States shall ensure that legal entities in the private and public sector and competent authorities keep records of every report received, in compliance with the confidentiality requirements provided for in Article 16. Reports shall be stored for no longer than it is necessary and proportionate in order to comply with the requirements imposed by this Directive, or other requirements imposed by Union or national law.
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Document oral reports and meetings |
Record Keeping |
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- Description:
- Document oral reports made through recorded or unrecorded telephone or voice channels and physical meetings in a durable and retrievable form through a recording, complete transcript or accurate minutes, and allow the reporting person to check, rectify and approve the record.
- Frequency:
- Event-triggered
- Check frequency:
- -
- Products/Services:
- -
- Checking responsibility:
- Staff members responsible for handling the report
- Check method:
- -
- Rule set:
-
-
- Source reference:
- Article 18(3)
- Source excerpt:
- Where an unrecorded telephone line or another unrecorded voice messaging system is used for reporting, legal entities in the private and public sector and competent authorities shall have the right to document the oral reporting in the form of accurate minutes of the conversation written by the staff member responsible for handling the report. Legal entities in the private and public sector and competent authorities shall offer the reporting person the opportunity to check, rectify and agree the minutes of the conversation by signing them.
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