Update - Incorporation of EU Whistleblowing Directive in Greece - Deadline for Companies between 50 to 249 Employees

As we have previously noted in our May 2023 Briefing note, Law 4990/2022 (Official Govt Gazette A’ 210/11.11.2022) incorporated in Greece the provisions of the EU Whistleblowing Directive 2019/1937, imposing an obligation on companies to set up an internal reporting system for EU law breaches, including appointing an officer responsible for receiving and monitoring reports.

As part of the whistleblowing mechanism:

  • Companies of the private sector with over 249 employees had to appoint an officer responsible to receive and monitor internal reports until 11.05.2023.
  • For companies with a number of employees from 50 to 249, the above deadline is now approaching and expires on 17.12.2023.
  • The appointment of the monitoring officer must be notified to the Labor Inspectorate within two (2) months from designation.
  • Private sector entities operating in the fields of financial services, transport and the environment, as well as entities operating under a decision approving environmental conditions, or whose activities may by their nature pose a risk to the environment and public health, must designate a monitoring officer regardless of the number of their employees.
This Briefing is intended to provide general information and is not meant to constitute a comprehensive analysis of the matters set out herein or to be relied upon as legal advice. It is not meant to create a lawyer-client relationship. Legal and other professional advice should be sought before applying any of the information in this Briefing to a specific situation. Bernitsas Law Firm is a partnership of attorneys regulated by Presidential Decree 81/2005 and Law 4194/2013, as currently in force, with its registered address at 5 Lykavittou Street, Athens 106 72, Greece.
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