Share transfer restrictions in shareholders’ agreements

27 January 2023 | Knowledge, News

The imposition of restrictions on the transferability of shares and the introduction of relevant related procedures are among the most important issues to be negotiated prior to the conclusion of shareholders’ agreements.

The following is an overview of the most common types of clauses restricting the ability to dispose of company shares.

Consent to disposal

Shareholders’ agreements often contain provisions making the disposal of shares subject to a company’s consent or other restriction (similarly to solutions that can be introduced into the articles of association, in accordance with relevant provisions of the Commercial Companies Code).

Consent to the disposal of shares, which must be given by the company management board, is the most common of these. However, the following entities are often indicated as authorised to give such consent:

  • another body (e.g. the supervisory board or the general meeting),
  • a majority shareholder,
  • a third party.

The right of first offer and the right of first refusal

Both the right of first offer (Polish: prawo pierwokupu) and the right of first refusal (Polish:  prawo pierwszeństwa) contained in a shareholders’ agreement entitle the entity concerned to acquire the shares of another shareholder if the latter intends to sell them to a third party.

Importantly, the right of first refusal is broader than the right of first offer, since it applies to any sale of shares and not only to a sale under a conditional SPA.

Drag-along and tag-along clauses

Drag-along clauses are becoming increasingly common in the Polish market. Thanks to their introduction, in the event of a desire to sell shares to a potential external investor, who is often interested in acquiring 100% of the shares, a person who has reached an agreement with the investor on the disposal of his/her own assets may require the other shareholders to sell their shares on analogous terms and conditions.

A tag-along clause is a kind of a reverse mechanism that allows shareholders to require the one who has attracted an external investor to cause that investor to make an offer for acquiring their shares on identical terms and conditions.

Call option

A call option grants the right for a potential buyer to demand a particular transaction to be performed.

If the call option is exercised, the buyer will be able to purchase shares from their seller at a specific price and time, with the latter being obliged to transfer the shares to the buyer on request or upon the fulfilment of certain conditions indicated in the agreement.

Lock-up

Lock-up clauses in shareholders’ agreements prevent certain shareholders from disposing of their shares for a specific period of time.

The purpose of such clauses is to obtain a guarantee by an investor that a particular person will remain in a company for a certain period of time. Most often, such a clause applies to company founders or key employees who also hold shares in the company.

Summary

Share transfer restrictions in shareholders’ agreements are a solution that effectively safeguards the interests of shareholders.

If such restrictions are imposed, however, due care must be taken to ensure that they function properly.

 

Source: Rzeczpospolita

Date: 22.12.2022

Any questions? Contact us

Rafał Rapala

Dominik Karkoszka

Adam Czarnota

 

Latest Knowledge

What EU businesses need to know about foreign subsidies

Just two months after the Regulation came into force, the Commission launched a high-profile investigation into a contract awarded by the Bulgarian Ministry of Transport and Communications for the purchase of electric trains from a major Chinese manufacturer. This was intended to emphasise the EU’s stance on unfair competition and its determination to combat this phenomenon.

Labour law: what lies ahead in 2026?

Changes to the way the length of service is determined, new executive ordinances for foreigners, and new powers for the National Labour Inspectorate are just some of the changes in labour law that will come into force in 2026.

Protecting designs exhibited at trade fairs

How can intellectual property and designs that have already been presented to the public, for example at trade fairs, be protected? All you need to do is exercise your exhibition priority right. This mechanism allows you to file an application for such a design at a later date without affecting its novelty. Let’s see how it works in practice.

Contractual practices prohibited under the Data Act 

One of the key aspects of the Data Act is the introduction of provisions on prohibited contractual practices. These provisions are intended to protect businesses operating within the broadly understood digital industry that have a weaker contractual position.

Those who have data have power. The Data Act redistributes this power

The EU Data Act, which came into force in September 2025, represents a breakthrough in the regulation of data access and use. Data generated by devices, ranging from agricultural tractors and industrial machinery to solar panels and transport fleets, is no longer the sole property of manufacturers. Other market participants now have the opportunity to access and use this data to develop new, innovative products and services. The Data Act marks a departure from business models based on data monopolisation, to one requiring data to be shared in accordance with its rules. We are therefore entering a completely new reality.

KSeF and transfer pricing: a new era of transparency and operational challenges

The introduction of the National e-Invoice System (KSeF) represents one of the most significant challenges for group companies in recent years. Although the KSeF is intended to simplify the invoicing process and reduce tax abuse, it also has a significant impact on transfer pricing, particularly with regard to the documentation and settlement of TP adjustments.

Contributing assets to a family foundation – what to keep in mind

A family foundation is a legal entity whose purpose is to manage wealth effectively and ensure its succession without the risk of dispersing assets accumulated over generations. Therefore, a key issue related to the activities of such an organisation is the contribution of this wealth to the foundation in the form of various types of assets that will work for the beneficiaries. Let’s take a look at what this process involves in practice.

Cloud migration after the Data Act: new rights, lower costs and greater freedom

The Data Act requires a significant change in approach to cloud services. Companies should review their contracts and start planning updates immediately. It is crucial to introduce appropriate switching provisions and remove or renegotiate exit fees. Companies must also prepare their infrastructure, both technically and organisationally, for interoperability and migration in accordance with the new regulations.

Contact us:

Rafał Rapala

Rafał Rapala

Attorney-at-law / Partner / Head of Corporate Law and Corporate Litigation / M&A and Private Equity Transactions

+48 608 444 650

r.rapala@kochanski.pl

Adam Czarnota

Adam Czarnota

Advocate / Senior Associate / Corporate Law / Mergers & Acquisitions

+48 787 389 207

a.czarnota@kochanski.pl