The Greece Whistleblower Protection Act

Greece Whistleblower Protection Act overview

Greece enacted a whistleblower protection law at the end of 2022 to transpose the EU Whistleblower Protection Directive’s requirements into national law. The amendments define new and expanded whistleblower protections for anyone reporting violations of EU law only – not violations of Greek national law as well. 

The new legislation covers all public and private organizations with at least 50 employees, requiring them to establish mechanisms to allow for whistleblower reports and to protect whistleblowers. Employers must also appoint someone to investigate whistleblower claims, and this can be an internal manager or an external third party. 

The law protects whistleblowers and those assisting them from retaliation for submitting a report. It also allows them to report their concerns externally to Greece’s National Transparency Agency; or even directly to the press if the whistleblower believes reporting via the other two channels will be ineffective.

What does the Greek whistleblower protection law cover?

The law adopts the minimum standards for whistleblower protection outlined in the EU Whistleblower Protection Directive. These requirements include: 

• A secure and confidential channel for receiving whistleblower reports must be in place. 
• Acknowledgment of the receipt of every whistleblowing report must be provided to the whistleblower within seven days. 
• An impartial person or department must be appointed to follow up on the reports. 
• Records must be kept of every report received in compliance with confidentiality requirements. 
• There must be diligent follow-up of the report by the designated person or department. 
• Feedback on the follow-up or investigation must be given to the whistleblower within three months of receiving the report. 
• All processing of personal data must be done in accordance with GDPR.

All covered business must meet the following basic requirements

The law requires all covered businesses to 

• Set up a whistleblowing system with comprehensive whistleblower protections.
• Adopt a policy on reporting legal violations and other misconduct. Businesses must also train employees on how to use the hotline and on the importance of non-retaliation.

Confidentiality, retaliation and disclosures

Companies are allowed to outsource the management of their hotline to a third-party service provider, although companies that do so are still responsible for responding to whistleblower complaints on the timelines outlined above. 

Greece’s law does not expressly encourage anonymous reporting, but does say that if an anonymous reporter’s identity is discovered at a later point, that person is entitled to the same whistleblower protections as any other reporter.

Report intake and management

Whistleblowers are allowed to submit reports in writing, verbally, or in person, and the company must preserve a record of every report submitted. The law also prohibits retaliation of any kind against whistleblowers: harassment, pay cuts, withholding of promotion, canceling expected employment contracts, and so forth. Whistleblowers who believe they’ve suffered retaliation are entitled to free legal advice, and can receive compensation if their retaliation claims are proven true.

What are the risks of non-compliance?

Companies that fail to implement the required whistleblower program can be subject to fines ranging from €10,000 to €500,000.