Criminal Compliance Program

The CCP is designed to ensure that the conduct of the company and its employees is in compliance with legislation and ethical rules. The CCP specifies and defines rules of conduct inside the company as well as the rules of external conduct of the company. 

The adoption of an effective CCP limits, to the greatest possible extent, conduct by any individual that would jeopardize the company as a whole, its credibility in the market or its future existence.

When imposing sanctions for infringements of legislation by a company, the supervisory authorities have for several years already taken into account whether the company has a thorough system of internal principles for its conduct, i.e. an effective and well-established CCP.

The goals of a properly configured CCP are, inter alia, to increase the resilience of the company and to provide the owner with assurance that they are protected from criminal sanctions. At the same time, all these measures improve communication and control and, as a result, the performance of the company itself.

Phases of CCP


A presentation of the purpose and value of the Criminal Compliance Program. Familiarization with the legal regulation of criminal liability of a legal person, including high-risk cases of internal and external corruption.


  • Of internal company processes

  • Of internal company documents (employment contracts, internal regulations, employment regulations)

  • Of supplier and partner contracts

  • Of customer contracts

  • Of OSH processes

  • Of participation in public procurement

  • Of compliance with tax obligations

  • Of compliance with legislation specifically binding on the company, where failure to comply may lead to criminal liability for the company


Preparation of the CCP includes, in particular:

  • Development of the CCP code
  • Modification of employment contract templates
  • Modification of internal regulations and employment rules
  • Elaboration of contract clauses, e‑mail and regular correspondence
  • Developing a plan for the prevention, detection, notification, investigation and resolution of incidents that may result in the criminal liability of a legal person.


  • Implementation of the CCP in all aspects of company life

  • Evaluation after the introduction of the CCP and its possible modification


  • CCP employee training

  • CCP knowledge test

  • Confirmation of employee familiarity with and understanding of the CCP rules


  • Regular annual certification of CCP implementation and compliance


  • Information on new legislation

  • Information on new CCP trends

  • Follow-up updates of processes, documents and plans

  • Training