Anti-Mobbing Policy and Whistleblowers 2026 — What a Salon With Six Stylists Actually Needs

Marta employs 6 stylists. From January 2026 one of them, Olena, can legally say: "I'm not signing the work regulations because they don't include a whistleblower channel or an anti-mobbing policy." And Marta won't be able to do anything about it, because PIP (Polish State Labour Inspection) expects the same from her. Fine for missing the policy: 1 000–30 000 PLN. Fine for missing the whistleblower channel (from 17.12.2026): another 1 000–30 000 PLN on top.

In this article you'll break the topic down to its basics. Two different acts, two different documents, two different deadlines. What a salon with 3, 6 and 9 stylists actually needs to have. Four ways to set up a technical channel for a whistleblower in a 35-square-meter space. Implementation calendar: March – June – December 2026. And specific fine amounts.

Two different documents, two different acts

First trap: most salon owners confuse the anti-mobbing policy with the whistleblower-protection act. These are two completely different obligations, two different documents, two different deadlines.

• Anti-mobbing policy. Stems from KP (Polish Labour Code — Kodeks Pracy), art. 94[3]. Covers mobbing, discrimination and harassment in the workplace. Procedure: how to report mobbing inside the company, who reviews it, what the sanctions are.
• Whistleblower procedure. Stems from the whistleblower-protection act (implementation of EU Directive 2019/1937). Covers reporting legal violations — not just mobbing, but also RODO (Polish GDPR) breaches, tax, health and safety, and money-laundering. Procedure: internal reporting channel + protection against dismissal.

The anti-mobbing policy goes into the work regulations or as a separate document in each stylist's personnel file. The whistleblower procedure is a separate document, a separate technical channel, a separate person receiving reports. You can't merge them into one A4 sheet — PIP sees that and challenges it.

Anti-mobbing policy from January 2026 — what changed

Until the end of 2025, the anti-mobbing policy was formally required only of employers with 50+ employees (above this threshold work regulations are mandatory). Salons with 3, 6 or 9 stylists had no formal obligation, although PIP recommended one.

The Labour Code amendment in force from 1.01.2026 changes that. The anti-mobbing policy becomes the obligation of every employer with at least one employee on a UoP (employment contract) — regardless of headcount. Micro-employers have an additional transition period until 31.03.2026 to implement it.

What the anti-mobbing policy in a nail salon must contain:

1. Definition of mobbing, discrimination and harassment. Best to quote KP plus add 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, an external commission. 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 dismissal, on changing working conditions, 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 a UoP must confirm in writing that she has read the policy. Signed document goes in the personnel file.

During an inspection, PIP checks two things: whether the policy physically exists (paper or PDF) and whether the stylists have signed it. Missing one of the two = fine of 1 000–30 000 PLN.

The PRO 349 PLN package 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 — who's covered in 2026

The whistleblower-protection act (in force from 25.09.2024) introduced the obligation of an internal reporting channel. The headcount threshold, however, changes every year:

• Until 31.12.2025: obligation only for companies with 50+ employees.
• From 1.01.2026: the threshold drops to 25 employees.
• From 17.12.2026: obligation for every employer with at least 1 employee on a UoP.

Calculation per typical nail salon:

• Marta's salon with 3 stylists (all on UoP). In 2026 anti-mobbing policy — YES from March. Whistleblower procedure — NO in January (threshold 25), but YES from 17.12.2026 (threshold 1).
• Marta's salon with 6 stylists (4 UoP + 2 B2B). Anti-mobbing YES (4 are on UoP). Whistleblowers — from 17.12.2026 YES (threshold 1+).
• Marta's salon with 9 stylists (6 UoP + 3 B2B). Anti-mobbing YES from January 2026. Whistleblowers — from 17.12.2026 YES.
• Marta's salon with 28 stylists. Anti-mobbing YES. Whistleblowers YES already from 1.01.2026 (threshold of 25 reached).

Does a stylist on B2B (sole-trader to sole-trader contract) count toward the whistleblower threshold? Yes, if she provides work to a single entity (one-sided turnover for 12+ months) — the whistleblower-protection act treats her as an employee. To be safe, count every person who works regularly in the salon. Better to roll out the channel than count days until a fine.

Whistleblower channel in a small salon — 4 ways

Technical problem: 35-square-meter space, six stylists, one reception desk. Where is the "internal reporting channel" the act mentions supposed to be? Four realistic solutions, from simplest to most professional:

Option 1: Dedicated email

An address like sygnalista@salonmarty.pl handled exclusively by the owner. Requires a separate inbox that no one else can access. Easiest to set up (15 minutes of configuration in the hosting panel), cheapest (0 PLN extra). Drawback: stylists have to trust that the owner doesn't check emails through Booksy or the reception computer that others use. Advantage: full digital trail, easy 3-year archiving (statutory obligation).

Option 2: Physical mailbox in the staff bathroom

Literally a lockable physical mailbox (A5 size, padlock, key only with the owner) hanging in a room that clients don't enter — the staff bathroom or back office. Anonymous paper reports. Advantage: full anonymity, no digital trail (the stylist is afraid an email is easy to trace). Drawback: limited volume, needs to be emptied once a week, no automatic archiving.

Option 3: Anonymous online form (Google Forms / Microsoft Forms)

A link to a form where the stylist enters her report without providing personal data. RODO clause at the top of the form: "You file this report voluntarily. You may remain anonymous. Data is stored for 3 years, only the salon owner has access." Plus a link to the whistleblower policy. Advantage: accessible from a phone, works at 11 PM, IP anonymization in the settings. Drawback: stylists sometimes don't trust Google.

Option 4: Ethics hotline (external operator)

A paid service from an external company that runs a telephone line for whistleblowers. The stylist calls the number, speaks to an operator, who writes the report down and passes it on to the owner. Cost: 200–600 PLN / month for a micro-business. Advantage: full professionalism, channel independence, strong anonymity protection. Drawback: cost is disproportionate to the scale of a salon with 6 stylists.

For a typical 6-stylist salon, the recommended combination is: dedicated email + physical mailbox. Two channels, two alternatives for the stylist, total implementation cost under 50 PLN.

The PRO 349 PLN package includes a template whistleblower procedure with a description of two channels (email + mailbox) and a Google Forms template with a RODO clause ready to copy.

2026 implementation calendar

Three dates to mark in the annual salon calendar for 2026:

31.03.2026 — anti-mobbing policy deadline for micro-employers

Every salon with at least one employee on a UoP must have, by this date:

• A written anti-mobbing policy (paper or PDF, signed by the owner).
• A signature sheet confirming each stylist on a UoP has received the policy, kept in the personnel file.
• A designated person to receive mobbing reports (usually the owner plus an external alternative).

Fine for failure: 1 000–30 000 PLN. PIP usually imposes 3 000–5 000 PLN on the first inspection, escalating on a repeat one.

30.06.2026 — review after 6 months

Mid-year policy review: whether any reports were filed, how they were handled, whether the procedure held up in practice. Check:

• Whether every new stylist hired in the first half of 2026 signed the policy when signing the employment contract.
• Whether the signature sheet is up to date.
• Whether the whistleblower channel email address (if rolled out ahead of schedule) is working.

17.12.2026 — whistleblower procedure deadline for companies with 1+ employee

Every salon with at least one employee on a UoP (or a stylist on B2B with one-sided turnover) must have, by this date:

• A written internal reporting procedure (a separate document from the anti-mobbing policy).
• A working technical channel (email, mailbox, form or a combination).
• A designated person to review reports (with the right to confidentiality).
• An information clause for every stylist — written confirmation she has read the procedure.
• A mechanism for archiving reports for 3 years.

Fine for missing the whistleblower procedure: 1 000–30 000 PLN, independent of the fine for missing the anti-mobbing policy. Both fines can land at the same time.

Fines for failure — specific amounts

In 2026 PIP has three levels of sanctions for missing employment documents:

• On-the-spot fine during inspection. 1 000–2 000 PLN, no proceedings. Most common on a first inspection, small salon, good cooperation with the inspector.
• Motion to penalize filed with the court. 1 000–30 000 PLN. Used for a missing policy, missing whistleblower procedure, missing signatures in the file. The court awards 3 000–8 000 PLN on average.
• Administrative order + coercion fine. Up to 10 000 PLN for every additional month the document remains missing after the order. Escalates fast.

Realistic scenario for Marta's salon (6 stylists) with no policy and no whistleblower procedure after 17.12.2026:

• Missing anti-mobbing policy: 5 000 PLN
• Missing whistleblower procedure: 5 000 PLN
• Missing signatures in files: 1 500 PLN × 6 stylists = 9 000 PLN (PIP treats each missing signature as a separate offense, although in practice it tends to combine them)
• Realistic bill: 10 000–19 000 PLN in a single inspection.

The PRO 349 PLN package costs 1.8–3.5% of the potential fine in a first PIP inspection. Template anti-mobbing policy, template whistleblower procedure, signature-sheet templates, RODO clause template for the Google form. Eight documents ready to sign.

FAQ — Frequently asked questions

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

KP refers to employees on a UoP — formally, the anti-mobbing policy doesn't apply to stylists on B2B. But: if the B2B is a sham (one-sided turnover, no business risk, salon-owned tools), ZUS and PIP treat the stylist as an employee by force of law, including the rights under the anti-mobbing policy. The other point: the whistleblower-protection act (from 17.12.2026) explicitly covers people on B2B as well, if they provide work regularly. Practical advice: better cover all stylists with the policy, regardless of contract type.

What if the salon has 8 stylists on a shift, but formally 4 full-time positions?

What counts is the number of employees, not the number of people on a shift. 8 stylists on a shift, each working half-time — that's 8 people, not 4 full-time positions. For the threshold of 25 (whistleblowers from January 2026) headcount matters, not FTEs. For the threshold of 1 (from 17.12.2026) it makes no difference — you have the obligation either way. Safe rule: count heads, not FTEs.

Do I need a separate person to receive reports?

No. In a salon with 6 stylists, the owner can be the designated person to receive both anti-mobbing and whistleblower reports at the same time. The requirement is that this person holds a written authorization and is bound by confidentiality. Exception: if the report concerns the owner, there must be an alternative channel (e.g. an external bookkeeper or lawyer — named in the procedure). PIP asks about this alternative during inspections.

What if the report is false?

Whistleblower protection applies to unjustified reports too — provided the reporter acted in good faith (genuinely believed she was right). Only knowingly false reports (filed with premeditation, to harm a specific person) lose protection. The burden of proving "knowing falsity" lies with the owner. In practice this is almost never proven — the safer route is to end cooperation after the notice period for a different reason than to dismiss someone for a false report.

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, Anya from Georgia), the policy must 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. In 2026 PIP has a separate inspection form for employers of foreign workers — it checks document comprehensibility. A bilingual template is available in the PRO 349 PLN package.