Further, a new draft bill on the Act on Protection of Whistleblowers is currently being discussed in the Parliament and is estimated to enter into force on 1 July 2023. What obligations will it impose?

Employers with at least 50 employees, and other obligated entities, will have to establish an internal reporting system for receiving and processing reports of unlawful conduct, including certain criminal and administrative offences, as well as breaches of corporate income tax, money laundering or consumer and environmental protection rules. Employers will have to appoint a special officer responsible for receipt and investigation of such reports. Employers with fewer than 250 employees will be allowed to share the reporting system with another employer.

Further, the employers must ensure the protection of whistleblowers against any retaliation, which may include, for example, termination of the employment relationship, non-renewal of a fixed-term employment relationship, discrimination, reduction of remuneration, or other measures of similar nature. The internal reporting system must allow the reports to be submitted in writing, orally or even anonymously. Moreover, the system must be available to other persons – such as freelancers or customers – as well as employees. 

If you are an employer who might be subject to the new obligations, we recommend that you not delay until this act enters into force to make the necessary preparations.