Chief legal officer | Emitel

Hubert Kendziorek
Chief legal officer | Emitel
Team size: 5
What are the key projects that you have been involved in over the past twelve months?
The PSN Infrastruktura acquisition and integration. At the end of November 2024, Emitel finalised the purchase of 100% of the shares in PSN Infrastruktura from its previous owner, the French operator TDF S.A.S.. Following the acquisition, PSN Infrastruktura, a company with a 30-year history in the Polish market operating previously under names like Polskie Sieci Nadawcze and Arkena, was rebranded. On December 16, 2024, the company was officially renamed EM Cast Sp. z o.o. and registered with Emitel S.A. as its sole shareholder. The primary goal of the transaction was to expand Emitel’s portfolio of towers available for the colocation of telecommunications equipment and client antennas. This move solidifies Emitel’s position as an independent infrastructure operator, particularly in providing hosting services for mobile operators. The value of the transaction was not disclosed. PSN Infrastruktura was a key operator for various radio and television broadcasters and was responsible for emissions from several key sites across Poland, including facilities in Łódź, Opole, Białystok, and Kielce. The integration process culminated on June 30, 2025, when the District Court for the capital city of Warsaw registered the merger of the two entities. The merger was executed with Emitel S.A. as the acquiring company and EM Cast Sp. z o.o. (formerly PSN Infrastruktura) as the acquired company. Emitel assured that the merger would be seamless for customers. The company announced that it would assume all rights and obligations of EM Cast, ensuring no changes to existing commercial relationships with clients of the former PSN Infrastruktura. This final legal step concluded the integration of the acquired assets and operations into Emitel’s structure, streamlining the management of the expanded infrastructure network.
SMP (ex 18th market: Broadcasting transmission services, to deliver broadcast content to end users (wholesale market)) regulatory proceedings: winning the cases regarding the SMP regulation on the TV/radio infrastructure wholesale market, resulting in cancellation of the Reference Offer imposed by a telecom market authority as a part of Emitel’s regulatory obligations.
The regulatory proceedings began in January 2018, when the President of UKE concluded that the wholesale market for delivering broadcast content to end users (formerly known as the 18th market) was not sufficiently competitive. Consequently, UKE designated Emitel as an operator with a Significant Market Power (SMP) on both the radio and television broadcasting markets. Emitel contested these decisions from the outset, arguing that the market was competitive and that the regulations were unfounded, initiating a long-running legal challenge. Emitel’s persistent legal challenges began to bear fruit in 2023.
June 2023: The Court of Competition and Consumer Protection (SOKiK) delivered a pivotal ruling, upholding Emitel’s arguments and overturning UKE’s original 2018 decision that had imposed the SMP status for the radio broadcasting market.
July 2024: The case reached its definitive conclusion when the Warsaw Court of Appeal, on July 16, 2024, dismissed UKE’s appeal entirely. This verdict made the lower court’s decision legally final, effectively annulling the 2018 SMP designation for the radio market.
September 2025: Cancellation of the Reference Offer
With the SMP decision for the radio market legally void, the mandatory Reference Offer and its associated duties automatically became unenforceable. A separate case concerning the SMP designation on the television market is still pending before the courts.
What are the key trends that in-house counsel should be monitoring in 2026?
I see here three main areas: increasing AI/legal tech usage, cybersecurity and new law requirements and evolving regulatory landscape: AI Act, Data Act, NIS2, personal data protection.
For my department, the conversation around AI and legal technology is not about hype; it’s about tangible value and prudent risk management. Our guiding principle is to enhance, not replace, the strategic judgment of our legal professionals.
Our portfolio of contracts and assets has grown significantly. We are actively deploying AI-powered contract lifecycle management (CLM) tools to automate the review of routine agreements, extract key obligations, and create a searchable, data-rich repository. This frees up my team from low-value, high-volume work to focus on complex negotiations and strategic advice.
We are exploring the use of AI to monitor changes in the regulatory environment, flagging potential compliance gaps before they become issues. This proactive stance is essential for a company operating under the scrutiny Emitel faces.
Legal tech allows us to move from anecdotal evidence to hard data. When negotiating with clients or vendors, we can now analyse hundreds of past agreements to identify favourable terms and establish stronger negotiating positions.
On the other hand, my primary concern is the security of our sensitive data. Before adopting any new technology, my team conducts rigorous due diligence on the vendor, scrutinising their data protection protocols and ensuring our attorney-client privilege is not compromised. AI is a powerful tool, but it is not infallible. We have established a “human-in-the-loop” protocol for all critical outputs. Legal professionals must verify AI-generated summaries or risk assessments, ensuring our advice remains accurate and reliable. We are creating a clear governance framework that defines accountability for AI-assisted work.
Cybersecurity is not an IT issue; it is an existential business risk, especially for Emitel. An attack on our infrastructure could disrupt broadcasting for the entire nation. From a legal and governance perspective, my focus is on resilience and readiness. I work closely with our CTO to translate technical cyber risks into business and legal implications for our Management Board. My role is to ensure the board understands the legal duties of care, the potential financial and reputational damages of a breach, and to secure the necessary resources for our defence posture. Our cyber defence is only as strong as our weakest link. All teams have been directed to review and strengthen the cybersecurity clauses in all our ICT contracts. We require our partners to meet stringent security standards, grant us audit rights, and clearly define liability in the event a breach originates from their systems.
We are facing a tsunami of new EU regulations that fundamentally reshape our obligations. My team’s mission is to move from a reactive compliance stance to a proactive, strategic approach. This is the approach we have applied in 2021, when we have introduced whistleblower protection policies more than two years ahead of implementation of relevant regulations in Poland.
What do you think are the most important attributes for a modern in-house counsel to possess?
The modern in-house counsel is a multifaceted professional who combines legal expertise with a strong business-centric approach. The key attributes here are: commercial acumen and business insight; exceptional communication and interpersonal skills in multilanguage environment; strategic and proactive mindset; adaptability and flexibility; leadership and influence also outside legal expertise; and technological competence, wisely using modern AI based tools.
The era of the siloed, reactive in-house lawyer is decisively over. Today’s corporate environment demands a multifaceted professional who combines deep legal expertise with a strong, business-centric approach. This evolution transforms the legal department from a cost centre focused on risk mitigation into a strategic partner actively driving value. Cultivating such a specific set of attributes is essential for making this leap and becoming an indispensable part of the organization’s leadership fabric.
At the heart of this lies commercial acumen and business insight. The modern GC must think like a business leader first and a lawyer second. This goes far beyond understanding the company’s products; it means having a firm grasp of financial drivers, market positioning, competitive threats, and operational realities. Armed with this insight, the lawyer’s mindset shifts from a prohibitive “no” to a creative “here’s how.” This proactive and strategic mindset allows them to anticipate legal and regulatory challenges on the horizon, embedding risk-mitigated solutions into business plans from the outset rather than reacting to problems after they emerge.
However, strategic insight is only valuable if it can be effectively communicated to influence decisions. This requires exceptional communication and interpersonal skills, especially in a global, multilanguage environment. This is not just about speaking different languages, but about translating complex legal jargon into the clear, actionable language of business, finance, and technology. This ability to articulate risk and opportunity builds trust and establishes the counsel’s leadership and influence far beyond their legal expertise. They become a go-to advisor for colleagues across all functions, leading not by formal authority but by demonstrating sound judgment and building cross-departmental alliances to achieve shared goals.
This strategic influence must be wielded in a constantly changing landscape, demanding profound adaptability and flexibility. The modern business environment is volatile, marked by shifting regulations, disruptive technologies, and unforeseen global events. The effective counsel must be agile, able to pivot seamlessly from a major M&A transaction one day to a critical data privacy incident the next (hopefully it never happens). This agility is increasingly powered by technological competence. Wisely using modern AI-based tools is no longer optional. It is the key to unlocking efficiency, automating routine tasks like contract review, and freeing up invaluable time for high-level strategic work. Crucially, this also involves understanding the governance and risks associated with these tools, ensuring they are deployed responsibly.
By intentionally cultivating these integrated attributes, the in-house counsel transcends the traditional legal function. They become a business-savvy strategist, an influential communicator, and an agile, tech-forward operator. In doing so, they are not just protecting corporate value; they are actively helping to create it, securing their indispensable place at the leadership table.
How can general counsel foster a corporate culture that supports ESG principles and compliance across all levels of the organisation?
As the corporate landscape evolves, the general counsel (GC) is uniquely positioned to champion a corporate culture that embeds Environmental, Social, and Governance (ESG) principles and compliance at every level of the organisation. ESG principles must be woven into the fabric of the company’s daily operations, by robust policies and partnering with other departments to integrate ESG into their processes, ensuring a shared commitment to “doing the right thing”.
To foster a corporate culture that genuinely supports Environmental, Social, and Governance (ESG) principles, the GC must move beyond the traditional legal role to become a strategic leader and ethical compass for the organisation.
A successful ESG culture starts with leadership. The GC is pivotal in advising the board and C-suite, framing ESG not merely as a compliance burden but as a crucial driver of long-term value and risk mitigation. By holding a position on the senior leadership team, the GC has the influence to ensure ESG is integrated into the core corporate strategy. If the board is hesitant, the GC can provide essential guidance on the significant legal, financial, and reputational risks of inaction. This involves establishing clear governance structures, such as a dedicated board committee, to ensure oversight and accountability at the highest levels.
To be effective, ESG principles must be woven into the fabric of the company. The legal department is central to developing and operationalising robust ESG policies, from codes of conduct to supply chain due diligence. This requires extensive cross-functional collaboration. The GC should partner with:
HR to integrate ESG goals into employee training, performance incentives, and recruitment to attract purpose-driven talent.
Supply chain to lead due diligence reviews that identify and manage human rights and environmental risks within the value chain.
Other teams to ensure ESG disclosures are accurate, transparent, and aligned with global standards to prevent “greenwashing.”
Stakeholders, from investors to employees, demand accountability. The GC’s team is central to establishing a comprehensive framework for transparently reporting on the company’s ESG progress and challenges. This builds trust and demonstrates a genuine commitment to responsible business practices. A critical component of this is creating effective grievance and whistleblower mechanisms that allow employees and external stakeholders to raise concerns without fear of retaliation, providing an early warning system for potential risks.
Ultimately, fostering a true ESG culture goes beyond policies and reports; it’s about embedding integrity into the company’s DNA. The GC must act as an ethical leader, advising not only on what is legal but on what is right. They are uniquely positioned to champion the company’s values and purpose, encouraging all employees to uphold high standards of responsible conduct. By modelling ethical behaviour and ensuring that business decisions align with the company’s stated values, the GC can transform the legal department into a proactive cultural leader, helping to build a resilient, respected, and sustainable organisation.