Bribery and corruption

Poland’s lack of progress in implementing reforms to boost fight against foreign bribery remains a serious concern


22/06/2021 – Since Poland’s last evaluation in 2013, the OECD Working Group on Bribery has repeatedly urged Poland to carry out key recommendations and implement legislative reforms to combat foreign bribery, consistent with its obligations under the OECD Anti-Bribery Convention.

Following its virtual High-Level Mission in November 2020, the Working Group is disappointed that Poland has still not taken steps to implement legislative reforms to amend liability of legal persons, to ensure the “impunity” provision cannot apply in foreign bribery cases, nor to increase fines for companies to ensure effective, proportionate, and dissuasive sanctions. In addition, Poland has not enacted legislation to protect from retaliatory or disciplinary action private and public sector employees who report suspected acts of foreign bribery. Further to concerns previously expressed about changes to the Polish judicial system, the Group reiterates the importance of preserving the full capacity and independence of prosecutors and judges.

The Working Group received a recent Action Plan proposed by Poland to organise police and prosecution resources to proactively detect, investigate and prosecute cases of foreign bribery, including through international co-operation. The Action Plan presented by Poland could be seen as a step in the right direction, although Poland needs to implement these enforcement measures with concrete activities, specific deadlines, and measurable indicators to determine their effectiveness. Poland will report to the Working Group in October 2021 on the status of its Action Plan, at which time the Group may recommend further measures in the absence of significant progress.

The Working Group will closely follow and take into account any further legal reforms and the enforcement of foreign bribery in practice, in particular in the context of Poland’s upcoming Phase 4 evaluation, currently scheduled for June 2022.

For further information, journalists are invited to contact Amelia Godber of the OECD Anti-Corruption Division or the OECD Media Division (+33 (0)1 45 24 97 00).  For more information on the implementation of the Anti-Bribery Convention in Poland, please visit

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