Compliance, AML and Whistleblowers

• compliance risk analysis and appropriate risk mitigation measures in individual areas (including HR, personal data protection, counteracting money laundering and terrorist financing, environmental protection, corporate matters, intellectual property rights),
• developing compliance regulations (policies, procedures, instructions),
• preventive and proactive consulting in the field of compliance – providing answers to current questions and giving opinions on new products,
• employee training tailored to the company’s risk profile,
• crisis management, in particular in the event of a threat of reputational damage,
• establish whistleblowing channels adapted to the nature of the organisation,
• identifying risks in establishing or continuing cooperation with business partners,
• implementing comprehensive AML and CFT documentation and procedures:
  • “know your client” policy,
  • effective client monitoring,
  • identification and verification of the ultimate beneficial owner,
  • risk assessment of the obliged institution and the principles for managing the risks identified,
  • measures applied to properly manage the identified risk of money laundering or terrorist financing arising from the business relationship or occasional transaction concerned,
  • rules for applying financial security measures,
  • rules for keeping documents and information,
  • rules of performing duties including providing the General Inspector of Financial Information (GIFI) with information about transactions and notifications,
  • principles of disseminating knowledge in the field of AML among employees,
  • rules on the reporting of actual or potential breaches of the AML provisions by employees, the rules on internal control or supervision of compliance by the obliged institution with the AML provisions and the rules of conduct set out in the internal procedure.
• employee training on anti-money laundering and counter-terrorist financing to provide obliged institutions and its employees with the knowledge and information to properly fulfil its obligations regarding the reporting of suspicions of money laundering, terrorist financing or other crimes, including fiscal offences,
• cooperation with law enforcement authorities and the GIFI.

Whistleblower protection

Member States of the European Union are required to implement Directive (EU) 2019/1937 of the European Parliament and of the Council of October 23, 2019 on the protection of persons reporting breaches of EU law (hereinafter referred to as the Directive) into their national legal systems, by December 17, 2021 (in relation to entrepreneurs employing more than 250 people; and until December 17, 2023 – in relation to entrepreneurs employing 50-249 employees).

Different stages of our service operations, tailored to the needs of your organisation:

1. Preparation of complete, customised internal documentation for your organisation, compliant not only with legal regulations but also with leading market standards.
2. Implementation of the developed procedures in your organisation, taking into account its characteristics, including its structure, type of activity, existing procedures, processes or regulations.
3. Designing channels (or adapting existing ones) to receive and manage notifications and dialogue with the whistleblower. We also offer the service of providing and operating an external reporting channel.
4. Developing optimal formulas for internal and external communication, tailored to the needs of your organisation, related to the implementation of a whistleblower protection system.
5. Immediate support in emergencies as well as on-going advice at every stage of the process of handling reports received.
6. Training for specific groups of employees during both the implementation and operational phases of the system.
7. To ensure that signalling becomes a useful business management tool, reducing losses, preventing loss of reputation and having a positive impact on staff motivation, we shall diagnose existing attitudes within your organisation towards the introduction of regulations in order to optimally design internal communication about the system and training for people at different levels of your organisation.

When designing our solutions, we take into consideration the provisions of law, the standards recommended for the compliance management system in the field of anti-corruption and whistleblower protection system in companies listed on the markets organised by the Warsaw Stock Exchange, as well as the guidelines of the International Organisation for Standardisation.

Soon, in July 2021, the ISO 37002 standard: “Whistleblowing management systems – Guidelines” will be published, containing guidelines for the effective implementation, management and assessment, maintenance and improvement of a responsible irregularity management system in enterprise.

There is no point in waiting until the last minute to start work on implementation. We provide solutions based on the so-called minimum level of protection set by the Directive and, after its implementation in the national legal order, a review and possible update of the adopted solutions.