Medium-sized and large enterprises (with over 50 employees or turnover of more than EUR 10 million) will be required to make changes in their internal anti-corruption policies and codes of ethics. Companies in which public entities (such as the State Treasury) or companies controlled by such entities hold directly or indirectly at least 10% of share capital or shares, and also their board members, may expect significant information disclosure obligations and an obligation to submit asset declarations.
The draft act on transparency in public life aims to put into one legal act all existing regulations on lobbying, avoiding conflicts of interest by persons performing public functions, asset declarations and access to public information. The act also introduces the following new regulations:
1) Obligation to introduce an effective anti-corruption policy
2) Protection of whistleblowers before terminating their contract or changing its terms
3) Additional information obligations for a broad group of entities, in particular so-called obliged companies in which a public entity indirectly holds at least 10% of the share capital
4) Prohibitions arising from the obligation to avoid conflicts of interest with respect to board members of obliged companies.
The draft is currently undergoing public consultation. We will inform you about the above listed issues and any changes to the draft in future alerts.