Given the resumption of work on the Bill on Liability of Collective Entities for Criminal Offences [LCE Act], which was submitted for public consultation at the end of the parliamentary term, we encourage you to implement internal procedures that may significantly reduce the risk of liability incurred by a collective entity.

In its current wording, the LCE Bill significantly broadens the scope of corporate liability in the above respect, and fines may amount up to PLN 60 million. Our experts are ready to support you in introducing or updating such procedures and provide training for your employees and associates.

Conducting an analysis your company’s structure/activity in terms of risks related to the liability of collective entities, including:

  • an analysis of your company’s structure and operations in terms of current business events, non-standard events and corporate arrangements to identify operations relevant to collective entity liability;
  • identification of areas of decision-making risk from the perspective of liability of collective entities;
  • an analysis of the scope of responsibilities of individual employees/co-workers of the Company in relation to the level/level of decision-making;
  • Presentation of conclusions in the form of a report.

Preparing and implementing procedures based on the conclusions of the report:

  • implementation of procedures governing the rules of conduct within your Company;
  • Preparation and implementation of instruments required by the LCE Act to protect your company and its individual companies from the consequences of offences;
  • Suggestion of modifications to the rights/duties of persons in particular positions in the context of the requirements of the CIP Act;
  • Implementation of a policy for your company should the procedure become inadequate as a result of an amendment to the law.
  • Compliance monitoring
  • Anti-mobbing
  • Conducting negotiations
  • Rules of conduct should a prohibited act be committed or threaten to be committed
  • Whistleblowing
  • Handling law enforcement inspections / dawn raids
  • Policy on giving and receiving gifts
  • Procedure for protection of company secrets
  • Internal investigation
  • Counterparty verification (criminal and compliance risks)
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