Anna Witkowska
Analyst-Author · Radca prawny
ESG / CSRD / Compliance
Bar admissionRadca prawny, OIRP Warszawa
SpecialisationCSRD, ESRS, Whistleblower compliance
LanguagesPolish, English
Practice · Chapter One
Compliance, ESG and Internal Investigations.
From CSRD double materiality assessment to a confidential board-level investigation. We design compliance frameworks that auditors approve, employees trust, and prosecutors recognise as genuine. Whistleblower channels, AML/KYC, anti-corruption, sanctions screening, ESG reporting.
Practice · 01
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Scope of services
- CSRD — scope analysis, double materiality assessment
- CSRD — Omnibus simplification — impact and implementation
- ESRS — full set implementation (E1–E5, S1–S4, G1)
- Whistleblower channels — design, policy, training, registry
- Internal investigations — fraud, harassment, board-level matters
- AML/KYC — beneficial ownership (CRBR), risk-based approach
- Anti-corruption — gifts & hospitality, conflict of interest policies
- Sanctions screening — EU/US/UK sanctions, wind-down
- Sanctions — Polish Act of 13 April 2022 specifics
- EU funds compliance — KPO/RRF eligibility, irregularities
- Beneficial ownership disputes — CRBR challenges
- ESG due diligence — supply chain, CSDDD readiness
- Code of conduct — drafting and rollout
- Compliance training programmes — design and delivery
CSRD reporting under Omnibus simplification: first reports for FY2025 due in 2026 for large entities.
Have a question about this practice?
Practice · 02
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How we work
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You describe
Send your situation in 5–10 sentences via form or call.
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Partner reviews
A partner — not a junior — reads it within 2 business hours.
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Scope & fee
We propose the scope, timeline, and fee — before any commitment.
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Engagement
Work begins only after you approve the engagement letter.
Practice · 03
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Lead team for this practice
Practice · 04
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Key jurisdictions
Most common cross-border matters in this practice arrive from:
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Related insights
We publish in-depth analyses weekly. The full archive is available in the Insights section →.
Practice · 06
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Frequently asked questions
Who must report under CSRD in Poland?
After the Omnibus simplification: large companies (1,000+ employees AND either EUR 50m+ turnover or EUR 25m+ balance sheet) report from FY2025. Listed SMEs from FY2026. Non-EU parents above EUR 450m EU turnover from FY2028. We help with scoping, the double materiality assessment, and ESRS data point inventory.
How quickly must a whistleblower complaint be acknowledged?
Under the Whistleblower Protection Act (14 June 2024): acknowledgment within 7 days, feedback within 3 months of acknowledgment. We design the workflow, draft the internal regulation, register the channel, and train the handlers. Common pitfall: anonymous reports must also be processed if they contain credible information.
What does sanctions screening involve under the Polish Act?
The Polish Sanctions Act (13 April 2022) goes beyond EU sanctions — it includes additional Polish-listed persons and a domestic blocking-list mechanism. Obligations: screening of clients, counterparties, ultimate beneficial owners; freezing actions; reporting to GIIF and KAS. Penalties up to PLN 20m and criminal liability. We design risk-based screening that meets both EU and Polish requirements.
Discuss your matter with a partner
Describe the situation briefly. A partner — not a junior associate — will respond within 2 business hours.