Frequently asked questions about whistleblower reporting channels
Who must establish an internal reporting procedure?
As a general rule, the provisions cover a legal entity for which at least 50 people perform paid work as of January 1 or July 1 of a given year. This number includes employees on a full-time-equivalent basis and certain people providing paid work under another legal basis. The Act provides exceptions to the threshold for certain regulated activities. A lawyer should assess the organization's exact obligation.
Does the Act require organizations to accept anonymous reports?
It does not impose a general requirement to accept anonymous reports. The procedure must, however, define how such information will be handled. Both AMODIT and the custom platform support anonymous reports if the organization provides for them in its procedure.
Is an electronic form sufficient to meet the obligations?
No. The platform supports a written electronic channel and actions performed in the system, but the Act requires reporting methods to include at least the option of oral or written reports. The organization also needs a procedure, designated personnel, confidentiality protection, follow-up action, a register, and information about external reports.
Must a whistleblower use the internal channel first?
No. Since December 25, 2024, a whistleblower may make an external report without first making an internal report—to the Polish Commissioner for Human Rights or the competent public authority. The organization's procedure should provide clear and easily accessible information about this option.
How does communication with an anonymous whistleblower work?
The whistleblower receives a secure way to return to the case without creating an account or disclosing their identity. They can read the team's question, provide a response or additional file, and check the report status.
What is the difference between AMODIT LITE and STANDARD?
LITE provides a form at a direct link, a standard process without customization, and a ready-made report. STANDARD adds form customization, process adaptation, custom reports, and broader AMODIT platform capabilities. Our completed STANDARD scopes have also included a test environment.
Can the channel support multiple companies?
Yes. We design separate addresses, forms, content, roles, and data for individual companies while maintaining a common group standard. A lawyer for the organization should confirm whether a shared procedure for the corporate group complies with the Act.
How long is data retained in the report register?
The Act specifies a 3-year period calculated according to rules linked to the end of the calendar year in which follow-up action was completed or proceedings initiated by that action ended. The client's lawyer defines the correct rule for the procedure, and we reflect it in the system's configuration and maintenance.
Where does the solution run?
AMODIT STANDARD runs in the cloud or on the client's servers. For a custom platform, we define the environment based on security, integration, and maintenance requirements. The project also covers backups, monitoring, updates, and responsibility for operating the environment.