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Protection of whistleblowers - introduction call | Poland

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The new Polish Whistleblower’s Protection Act came into force on September 25, 2024, except for provisions concerning external reports, which will start three months later, on December 25, 2024. For employers with at least 50 employees, this means implementing an appropriate procedure.

An employer with at least 50 employees is required to develop an internal reporting procedure that ensures the confidentiality of whistleblower’s reports, defines the rules for accepting such reports, and creates channels for receiving them. This procedure should comply with the requirements of the Act, and includes inter alia:

  • Methods/channels for submitting internal reports.
  • Units responsible for receiving and verifying internal reports.
  • The duty to conduct follow-up actions.

Moreover, the employer is obliged to keep the register of internal reports.

Employers engaged in services, products, and financial markets, anti-money laundering and counter-terrorist financing, transportation safety, and environmental protection, to whom the Act applies, are obliged to follow the above procedures regardless of the number of employees.

We provide support with:

  • Consultation on the procedure,
  • Establishment of a report officer,
  • Determination of the internal reporting channel,
  • Introduction of a whistleblower protection framework,
  • Appointment of a person/unit responsible for investigating reports and taking follow-up actions,
  • Establishment of rules for conducting investigations,
  • Determination of the process for providing feedback to whistleblowers,
  • Clarification of the rules for maintaining a report registration system.

Use the free 15 minutes with our Polish legal specialist to better understand how we can support you comply with the Whistleblower Protection Act.

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