Corruption in Poland

About

Corruption is a crime involving the abuse of entrusted authority or position for financial or personal gain. It ranges from the actions of individuals to complex mechanisms operating at organizational or institutional levels. There are various forms of corruption, from simple bribes to complex corrupt arrangements at the corporate or state level.

Official corruption occurs when the person who is to accept a pecuniary or personal benefit or the promise thereof is an official of a Polish or foreign state (passive official bribery – Article 228 of the Polish Criminal Code and active official bribery – Article 229 of the Polish Criminal Code). Managerial corruption, on the other hand, is when a person who is to accept a benefit or its promise is to influence business activities. Here, too, the crime is both passive managerial bribery (Article 296 § 1 of the Polish Criminal Code) and active managerial bribery (Article 296a § 2 of the Polish Criminal Code).

As part of the fight against corruption, the legislator has provided for the possibility of avoiding punishment (non-punishment clause) for the perpetrator of official bribery (Article 229 § 6 of the Polish Criminal Code) and managerial bribery (Article 296a § 5 of the Polish Criminal Code), who has notified the body established for criminal prosecution of the bribed party’s acceptance of a material benefit or its promise and has disclosed all the relevant circumstances of the crime before the body became aware of it.

The penalties provided by the legislature for corruption are severe, in most cases the legislation provides for imprisonment in such cases. Managerial corruption involving property worth more than PLN 5,000,000 (EUR 1,250,000) is a felony: the perpetrator of such a crime may be punished by 3 to 20 years’ imprisonment, and in the case of property worth more than PLN 10,000,000 (EUR 2,500,000) – from 5 even to 25 years’ imprisonment. A conviction for bribery in an executive position automatically triggers a ban on serving as a member of a company’s board of directors, supervisory board, audit committee or liquidator. Poland has a Central Anti-Corruption Bureau (CBA), which is a special service established to combat official and managerial corruption.

KKZ Law Firm within this service segment offers:

  • comprehensive training of managers and officials;
  • creation of a system of compliance procedures and internal codes;
  • internal audits;
  • representation in crisis situations (searches, interrogations, arrests, presentation of charges, detention on remand);
  • representation before law enforcement agencies, including the prosecutor’s office, police, CBA, and before the courts;
  • acting as defense counsel for suspects or defendants;
  • development of a litigation and communication strategy;
  • assistance in obtaining support from relevant organizations and institutions;
  • full support in protecting the company’s image, including cooperation with reputable PR agencies.

Our offer is addressed to:

  • representatives of state and local government authorities;
  • managerial staff;
  • entities harmed by corruption crimes;
  • persons accused of corruption;
  • companies struggling with an image crisis on the background of corruption.
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Understanding corruption

Perception of corruption: Corruption is a form of dishonesty or can be undertaken by a person or an organization which is entrusted in a position of authority, in order to acquire illicit benefits or abuse power for one’s personal gain. Corruption can involve politicians, government officials, public servants, business people or members of the public.

Corruption takes place anywhere: in business, government, the courts, the media, and in civil society, as well as across all sectors, corruption in higher education, corruption of the judiciary, corruption in the health sector. It would undermine the rule of law and weakens governmental mechanisms.

How to measure corruption

Given the scale, we can identify different levels of public sector corruption:

  •   Petty corruption – occurs at a smaller scale and takes place
  •   Grand corruption – occurs at the highest levels of government
  •   Systemic corruption – is a result of the weaknesses of an organization or processes adopted in the country. It encompasses different different forms of government corruption.
  •   Political / governmental corruption – it occurs in many forms such as bribery, lobbying, extortion, cronyism, nepotism, parochialism, patronage, influence peddling (high levels of corruption).

Causes of corruption

Factors which encourage corruption include :

  •   discretionary powers
  •   conflicting incentives
  •   lack of transparency
  •   law pay
  •   low economic development
  •   political and economic instability
  •   lack of anti-corruption mechanisms.

How to fight corruption

There are many forms and ways to measure  corruption both across and within countries. The process of moving from a high-corruption to a low-corruption society is long, but the first step is always transparency. Anti-corruption interventions need to be flexible, politically responsive ,and designed with potential backlash in mind.

Corruption in different countries is tackled by government institutions and agencies whose task is to stop corruption. There are also international institutions which have developed knowledge on how to lower corruption. The most well-known is Transparency International (transparency.org) which collects data on crime and corruption and publishes policy research working paper as well as teaches the best practices on how governments should take action against corruption.

Combat Corruption with Expert Legal Support

Corruption undermines trust, disrupts businesses, and erodes public confidence in institutions. Tackling this pervasive issue requires not only awareness but also a strategic and legal approach tailored to the complexities of each case. Our law firm provides comprehensive services to address corruption at every level—whether you are a victim seeking justice, an organization aiming to strengthen compliance, or an individual facing allegations.

We offer expert representation, internal audits, training programs, and strategic advice to help navigate legal challenges and protect your reputation. By collaborating with law enforcement and utilizing proven strategies, we ensure that your rights and interests are safeguarded.

Take a proactive stance against corruption. Contact us today to access professional legal guidance and comprehensive support designed to meet your specific needs. Together, we can work toward transparency, accountability, and justice.

How can
we help you?

Contact
the experts

Maciej Zaborowski

Advocate, Managing Partner

Paweł Gołębiewski

Attorney-at-law, Head of International Criminal Law Practice

FAQ

Corruption is defined as the abuse or misuse of entrusted power for personal or financial gain. Under Polish criminal law, corruption manifests through giving or receiving bribes as well as other illicit benefits aimed at influencing the performance or omission of official or private duties. It is a serious offense because it undermines the principles of fairness, transparency, and integrity in both public administration and business environments. Corruption can involve various forms such as bribery, trading in influence, nepotism, and embezzlement linked to power abuse.

  • Official bribery: This involves public officials accepting or soliciting benefits to perform, omit, or delay official acts inappropriately. The scope covers all levels of government and administration as outlined in Articles 228 and 229 of the Polish Criminal Code.
  • Managerial (corporate) bribery: Applies to individuals who hold managerial positions or significant influence in companies or organizations. This type concerns offering, accepting or soliciting undue benefits to secure or influence business decisions or operations, regulated under Articles 296 and 296a of the Penal Code.

    Both categories include active corruption (offering or giving bribes) and passive corruption (accepting or soliciting bribes).

  • Penalties for corruption are stringent and depend on the offense’s seriousness and circumstances.
  • For corruption involving amounts exceeding PLN 5 million (approx. EUR 1.25 million), imprisonment ranges from 3 to 20 years. If the sum exceeds PLN 10 million (approx. EUR 2.5 million), penalties escalate to 5 to 25 years.
  • Convictions for corruption in executive or managerial roles often lead to automatic disqualifications from holding various corporate positions (boards of directors, supervisory boards, audit committees, among others).
  • Additionally, courts may impose fines, asset confiscations, and damages compensation in favor of affected entities or the state.

Yes, Polish law includes a “non-punishment clause” encouraging self-reporting of corruption offenses:

  • If the individual who committed bribery reports acceptance of a bribe to authorities and fully discloses critical details before an investigation begins, they may avoid criminal liability.
  • This legal incentive supports anti-corruption efforts by encouraging transparency and cooperation, aiming to uncover larger corruption networks.
  • The Central Anti-Corruption Bureau (CBA) is the specialized state agency tasked with investigating corruption, especially in public administration and economic sectors.
  • The CBA collaborates closely with prosecutors, police, and judiciary to execute operational actions, conduct inquiries, gather evidence, and prosecute offenders.
  • Other law enforcement entities, including regional police and prosecution offices, also investigate corruption under their jurisdiction depending on case specifics.

Law firms skilled in corruption matters typically provide:

  • Training and consulting on anti-corruption laws, compliance frameworks, and ethical business conduct tailored to corporate and public sectors.
  • Development and implementation of comprehensive compliance programs, internal controls, and codes of conduct to prevent corruption risks.
  • Conducting internal audits and investigations to detect suspicious activities and support effective risk management.
  • Legal representation and defense in investigations, hearings, and trials related to corruption allegations.
  • Crisis management—handling searches, seizures, arrests, and media relations during corruption scandals.
  • Liaison with authorities and regulators ensuring procedural compliance and fostering transparent cooperation.
  • Engagement of PR firms to manage reputational risks associated with corruption accusations or proceedings.

Support is critical for:

  • Public sector officials and institutions striving to prevent and address corruption within government.
  • Corporate executives, managers, and business owners exposed to bribery allegations or seeking to establish compliance mechanisms.
  • Whistleblowers who report corruption and need legal protection.
  • Victims of corruption seeking redress or compensation.
  • Companies confronted with reputational threats or regulatory scrutiny from corruption investigations.
  • Establishing tailored criminal compliance programs integrating risk assessments and clear procedures aligned with Polish and EU regulations.
  • Conducting routine employee training and awareness campaigns focusing on ethical conduct and anti-corruption.
  • Providing whistleblower protections and confidential reporting systems to encourage disclosure.
  • Ensuring rigorous monitoring and auditing of transactions, contracts, and interactions with public officials or business partners.
  • Implementing transparent decision-making and approval processes reducing susceptibility to undue influence.

Aside from criminal sanctions against individuals, companies implicated in corruption face:

  • Loss of reputation impacting customer trust and investor confidence.
  • Exclusion from public procurement, bans from regulated markets, or suspension of licenses.
  • Reduced business opportunities and partnership dissolutions.
  • Increased regulatory scrutiny and ongoing legal costs.
  • Negative impacts on employee morale and organizational culture.

Corruption committed by company leaders or those in managerial positions is treated with particular seriousness. Beyond criminal prosecution, convicted individuals face:

  • Mandatory removal and prohibitions on occupying management or supervisory roles for lengthy periods.
  • Enhanced penalties reflecting the trust and responsibility inherent in their positions.
  • Corporate governance reforms are often mandated after corruption cases to restore confidence.
  • Preventive compliance becomes essential at executive levels to shield the company and ensure regulatory adherence.