The situation
The number of employees in each group company
A Gdynia ship-repair group has three Polish companies, with 420, 160 and 38 workers. The parent set up a reporting line years ago for the group’s code of conduct. The HR lead has been asked whether that line meets the law for each company, or whether each needs its own procedure, and to draft what is missing.
The directive’s headline duty is clear. The detail sits in the Polish act: how employees are counted, who can receive and follow up reports, how the procedure is consulted and announced, and what a group may share. The existing line answers some of this and not the rest.
What the research has to settle
The rules behind the answer
- Fifty workers triggers the duty
- The Whistleblowing Directive requires private-sector employers with 50 or more workers to set up internal reporting channels. Entities in certain financial-services areas must have them regardless of size.
- Medium-sized companies can share resources
- Companies with 50 to 249 workers may share resources for receiving reports and investigating them. The duties to keep the reporter’s identity confidential and to give feedback stay with each company.
- Fixed deadlines for the reporter
- A report must be acknowledged within seven days, and the reporter given feedback within a reasonable time of no more than three months from the acknowledgement. The reporter’s identity is protected.
- The Polish act adds procedure
- Poland implements the directive in its own act, which sets how the internal procedure is adopted, including consultation with a trade union or employee representatives before it takes effect. Check how the act counts employees for each company.
How it runs in azta
From the question to the document
The question, as you would type it
Polish sp. z o.o. with 160 workers, part of a group whose parent runs a group-wide ethics hotline. Does the group hotline satisfy the Polish whistleblower protection act for this company, or must it adopt its own internal procedure? What must the procedure contain and how is it adopted?
You start with
The number of employees in each group company
- 01
Give the group structure
List the companies, their employee numbers and the existing reporting line. azta searches the directive and the Polish whistleblower protection act.
Cited research· Free - 02
Read the Polish provisions
Open the cited provisions in the reader, in Polish, with their in-force status.
Atlas statute reader - 03
Draft the procedure
Ask for an internal reporting procedure for each company that needs one, covering channels, deadlines, confidentiality and adoption. Edit it in Canvas.
Canvas · Ask azta· Pro - 04
Export for consultation
Export to Word for consultation with the employee representatives.
Word export· Pro You send
An internal reporting procedure and a note on which companies need one
What you get
An internal reporting procedure and a note on which companies need one
Internal procedure · draft
Internal reporting procedure: Bałtyk Remonty sp. z o.o.
Scope. This procedure sets out how workers, contractors, applicants and others connected with the company can report breaches of law internally, and how the company receives and follows up those reports.
Receiving reports. Reports can be made in writing through the reporting form or orally by telephone. The company acknowledges each report within seven days and gives feedback within three months of the acknowledgement. Reports are followed up by the compliance officer, who acts impartially and keeps the reporter’s identity confidential.
Adoption. This procedure was consulted with the employee representatives before adoption and takes effect after it has been announced to workers in the manner the act requires. It is reviewed whenever the law changes.
Outcomes on your numbers
What azta is worth on this task
Pro pays for itself after
20 minutes a month
At €85 an hour, that is all the time Pro (€27 a month) has to take off your desk to cover its price.
Example figures. Replace them with your own.
- Hours back a year
- 25
- Capacity at your rate
- €2,142
- More whistleblowing procedure reviews a quarter
- 0.8
- Return on Pro
- 6.6×
- Research
- Drafting
- Your review
A scenario you set, not a promise. The hours that come back go to another client, or deeper into this one.
Want these numbers on your team’s real workload?
Book a demoWhat stays with you
- Appointing the people who receive and follow up reports.
- The consultation with employee representatives.
- Running the channel and protecting reporters in practice.
Frequently asked questions
- Is a group-wide hotline enough?
- That depends on the national act and each company’s size. Describe the group structure and azta researches what each company must keep in its own hands.
- Does azta run a reporting channel?
- No. It researches and drafts the procedure. The channel itself runs on your own tools or a provider’s.
- Does it cover our companies in other countries?
- Yes. Ask about each country and azta researches its implementing act alongside the directive.



