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Clifford Chance

Clifford Chance

Briefings

Anti-corruption Compliance in Poland - new obligations and sanctions

31 October 2017

The Polish Government is working on the draft Act on Transparency in the Public Sphere (the "Draft Act"), which is to introduce a requirement that companies apply internal anti-corruption procedures. The penalty for failing to comply with this new requirement may be a fine of up to PLN 10,000,000 and a five-year ban on participating in public tenders.

The Draft Act is also to introduce legal protection for whistleblowers who have provided the authorities with information on possible offences (in particular corruption).

The work on the Draft Act is at a very early stage, but it is expected that the Draft Act will come into force in 2018.

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