Poland: New Obligations for Employers to Introduce a Remuneration Policy

The Act introduces the obligation for the general meeting to adopt a remuneration policy for management boards and supervisory board members. The amendment applies to public companies where at least one share is admitted on a regulated market. The regulation specifies what elements the policy should include – these are not only the components of remuneration, but also an indication of the period for which contracts were concluded with members of company bodies, a description of the process of establishing, implementing and reviewing the policy, as well as the regulation regarding the avoidance of conflicts of interest related to the policy.

The Act specifies that the solutions adopted in the remuneration policy should contribute to the implementation of the business strategy, long-term interests and the stability of the company, and that the policy itself should indicate how these objectives are implemented within its framework. If members of these bodies are to be paid variable components of remuneration, the policy must contain supplementary information with regard to this.

Companies are required to adopt the first resolution by 30 June 2020, and then, at least, every four years. The obligation also includes posting the content of the policy on the company’s website.