Neil Irwin, Marsh business development leader for Europe, said: "Although EU company law has now been enacted in the new member states, the final date for full implementation varies by up to three years. While the lack of awareness is alarming, when you add the fact that much of this legislation introduces practices and policies that are wholly new in many of the cultures, together with the different speeds of adoption, and the influence of local legislation, the result is a recipe for confusion."
Part of this stems from the different ways EU laws have been implemented in accession countries and those that have applied to join. For example:
- In Slovakia, it can be a crime to make untrue negative statements about a competitor's product
- Legislation in Poland and Hungary does not recognise punitive damages,
- Czech, Latvian and Slovak law invalidates attempts to limit director liability
- Hungarian law imposes up to eight years imprisonment for trading while insolvent.
To help businesses, Marsh has developed a series of country-specific handbooks in conjunction with the Economist Intelligence Unit.
