Draft Legislation On Public Transparency And Its Influence On Compliance

On 24 October 2017, the Polish Government Legislation Center published draft legislation on public transparency ("Transparency Paper"). Our analysis of the Transparency Paper's legal solutions indicates that the law will have a huge impact on compliance in Poland. From the compliance point of view, the Transparency Paper proposes the following major changes:

• Large and mid-size enterprises will be required to have internal anti-corruption policies in place, including:
  • a code of conduct, to be signed by each employee, associate and supplier;
  • anti-corruption clauses to be inserted in each contract;
  • a policy governing gifts and other advantages received by employees.