Anti-Mobbing Policy and Whistleblowers 2026 — What Salons Need

Marta employs 6 stylists. One of them, Olena, says: "There's nothing in the work regulations about counteracting mobbing." And she's right that it's worth addressing — because every employer, even one with a single employee, has a statutory duty to counteract mobbing (art. 94³ of the Polish Labour Code). But there's a difference between that general duty and a formalized, written anti-mobbing policy — and most online guides confuse the two. In this article I keep them fully apart.

I break the topic down to its basics. The general duty to counteract mobbing (applies to everyone) versus a formal, written policy (headcount threshold). Separately: the whistleblower-protection act — and why a small salon is NOT covered by it. What a salon with 3, 6 and 9 stylists actually needs. And the real amounts of PIP fines (without the scaremongering "30 000 PLN fine" that neither the sanitary nor the labour inspector can impose on the spot).

Two different duties, two different acts

First trap: salon owners confuse the anti-mobbing policy with the whistleblower-protection act. These are two different duties, two different documents, two different legal bases — and two different thresholds.

• Counteracting mobbing. Stems from the Polish Labour Code (art. 94³ KP). The general duty — to counteract mobbing, discrimination and harassment — rests on every employer, even one with a single employee on an employment contract. A formalized, written anti-mobbing policy with a reporting procedure is part of the work regulations — and the duty to have work regulations (and therefore a formalized procedure) applies to employers with at least 9 employees.
• Whistleblower procedure. Stems from the whistleblower-protection act of 14 June 2024 (in force from 25 September 2024, implementation of EU Directive 2019/1937). Covers reporting legal violations — GDPR, tax, health and safety, money-laundering. The duty to have an internal reporting procedure applies only to entities for which paid work is performed by at least 50 people. This threshold is fixed — it does not "drop" each year.

The takeaway for a typical nail salon: if fewer than 50 people perform paid work for you (which is practically every salon), the whistleblower-protection act does not apply to you — you need neither a whistleblower procedure nor a reporting channel. What remains is the mobbing topic, which applies to every employer, and — from the threshold of 9 employees — the duty to have work regulations with a formal anti-mobbing procedure.

Counteracting mobbing — who is covered at which level

Art. 94³ KP imposes on every employer the duty to counteract mobbing. That means: you must take real action (informing, responding to signals, a reaction procedure), regardless of headcount. You are responsible for failing to do so even with one employee — if mobbing occurs and it turns out you did nothing to prevent it, you bear civil liability toward the injured party (compensation, damages).

A formal, written anti-mobbing policy (a documented procedure, reporting channel, sanctions) is part of the work regulations. The duty to have work regulations — and therefore a formalized procedure — applies to employers with at least 9 employees. Below that threshold, work regulations (and a formal policy) are not mandatory, but the general duty to counteract mobbing under art. 94³ still applies — which is why a documented procedure is good practice even in a smaller salon.

A note on dates: amendments to the Labour Code tightening anti-mobbing rules come into force with a transition period (typically a 6-month vacatio legis from the day the act enters into force), not from a rigid date like "31.03.2026". Before you put a specific deadline in your calendar, check the publication date of the final act in the Journal of Laws and count the vacatio from there.

What a well-written anti-mobbing policy in a salon should contain:

1. Definition of mobbing, discrimination and harassment. A quote from the Labour Code plus beauty-industry examples: humiliating a stylist in front of a client, favoring one stylist in the schedule for 6 months in a row, comments about appearance.
2. Mobbing reporting channel. Who the stylist reports to — the owner, the manager. In a salon with 6 stylists, this is usually a report to the owner, plus an alternative (e.g. an email to an external bookkeeper if the mobbing is attributed to the owner herself).
3. Review procedure. Deadline for review (14 days recommended), who talks to both sides, what evidence is collected, how it's documented.
4. Sanctions. List of consequences for the perpetrator of mobbing: reprimand, formal reprimand, termination of the employment contract without notice.
5. Protection for the reporter. Ban on retaliation against a stylist who reported mobbing — even if the report turns out to be unjustified (unless it was knowingly false).
6. Signatures. Every stylist on an employment contract confirms in writing that she has read the policy. Signed document goes in the personnel file.

During an inspection, PIP checks whether an employer (who is required to have work regulations) has a documented procedure and whether staff are familiar with it. Gaps here can be penalized by the labour inspector with a fine — the real amounts are below.

The PRO 249 PLN package (regular price 349 PLN) includes a template anti-mobbing policy for a nail salon with beauty-industry examples plus a signature sheet for each stylist's personnel file.

Whistleblowers — why a small salon is not covered

The whistleblower-protection act of 14 June 2024 (in force from 25 September 2024) introduced the duty of an internal reporting procedure — but only for entities for which paid work is performed by at least 50 people. This threshold is fixed. It does not "drop to 25 from 2026" or "to 1 from December 2026" — that is false information circulating in guides that is not in the act.

What this means for a nail salon:

• Salon with 3 stylists. Below 50 people — a whistleblower procedure is NOT required. What remains is the general duty to counteract mobbing (art. 94³ KP).
• Salon with 6 stylists. Below 50 people — a whistleblower procedure is NOT required. From the threshold of 9 employees comes the duty to have work regulations with a formal anti-mobbing policy.
• Salon with 9 stylists. Below 50 people — whistleblowers NO. Duty to have work regulations (and therefore a formal anti-mobbing policy) — YES, because the threshold of 9 employees is reached.
• A chain with 50+ people. Only here does the duty of a whistleblower procedure and an internal reporting channel appear.

So if you run an ordinary nail salon, the topic of a "whistleblower channel," an "ethics hotline" and "3-year archiving of reports" simply does not apply to you. Focus on what's real: counteracting mobbing (everyone) and — from 9 employees — work regulations with an anti-mobbing policy.

Fines for failure — real PIP amounts

This is where there's the most misinformation. Let's sort out who can impose what:

• On-the-spot fine by the labour inspector (during inspection). Up to 2 000 PLN, and in the event of a repeat penalty for an offense against employee rights within 2 years — up to 5 000 PLN. That is all a PIP inspector can impose as an on-the-spot fine.
• Fine imposed by the court. If the case goes to court (a motion to penalize), the court may impose a fine from 1 000 to 30 000 PLN for an offense against employee rights (art. 281–283 KP). This is already a court fine, not a "fine on the spot" — it is not imposed by the inspector, but by the court, after proceedings.

In other words: the "30 000 PLN" amount exists, but as the upper limit of a court fine, not an on-the-spot inspector fine. When a guide writes "fine of 1 000–30 000 PLN," it mixes two different institutions. An on-the-spot fine is a maximum of 2 000 PLN (5 000 PLN on a repeat offense).

Realistic scenario for Marta's salon with 9 stylists (and therefore with a duty to have work regulations and a formal policy), if the anti-mobbing policy were missing: on a first inspection the inspector most often issues a demand/order to complete the documents, and the fine (if any) stays within the limit of up to 2 000 PLN. Higher-amount fines appear only in court proceedings for persistent non-compliance.

The PRO 249 PLN package (regular price 349 PLN) includes a template anti-mobbing policy, signature-sheet templates and a set of employment documents ready to implement in a salon.

FAQ — Frequently asked questions

Do I need a written anti-mobbing policy if I employ 3 stylists?

Formally, the duty to have work regulations (and therefore a formalized policy) applies to employers with at least 9 employees. With 3 stylists you have no duty to have work regulations — but you do have the general duty to counteract mobbing under art. 94³ KP. A written, signed procedure is then good practice and real protection, even though it is not formally required.

Does my salon need a whistleblower procedure?

Only if at least 50 people perform paid work for you. The threshold is fixed — it does not drop to 25 or to 1. An ordinary nail salon does not reach this threshold, so the whistleblower-protection act does not apply to it: you need neither an internal reporting procedure nor a whistleblower channel.

Is a stylist on B2B an employee for anti-mobbing purposes?

The Labour Code refers to employees on an employment contract — formally, the anti-mobbing policy as part of the work regulations applies to them. But if the B2B contract is a sham (one-sided turnover, no business risk, salon-owned tools), ZUS and PIP may recognize the relationship as an employment relationship by force of law — with full employee rights. Practical advice: a good work culture and a procedure for responding to mobbing are worth applying to everyone in the salon, regardless of contract type.

What is the maximum PIP fine for missing documents?

An on-the-spot fine imposed by the labour inspector is a maximum of 2 000 PLN (5 000 PLN on a repeat penalty within 2 years). Higher amounts — up to 30 000 PLN — are a fine imposed by the court in separate proceedings, not an on-the-spot fine.

Does the anti-mobbing policy have to be in Polish?

If you employ stylists who don't speak Polish (Olena from Ukraine, Vita from Belarus), employment documents should be in a language the employee understands. Most common solution: a bilingual version Polish + Ukrainian / English, printed side by side on a single sheet. The stylist signs both versions. A bilingual template is available in the PRO 249 PLN package (regular price 349 PLN).