Loi Sapin Compliance

France’s anti-corruption law Sapin II imposes a tough regime for the prevention and prosecution of corruption.

It places a binding obligation on corporates to implement robust anti-corruption compliance programmes. Under Sapin II, French companies and groups will be expected to:

  • implement an anti-corruption code of conduct
  • implement robust anti-corruption systems, controls and procedures
  • operate an internal whistleblowing system
  • conduct anti-corruption risk assessments taking into account geographic location and industry sector
  • conduct due diligence on intermediaries, agents, partners, suppliers and other third parties
  • implement accounting controls to ensure accounting systems do not conceal acts of corruption
  • offer training programmes for executives and employees most exposed to corruption risks
  • impose disciplinary sanctions for any breaches of the company’s anti-corruption procedures

GoodCorporation’s Référentiel Anti-Corruption incorporates the demands of Sapin II. We are working with French companies to test and strengthen their anti-corruption programmes, working across a range of sectors including telecoms, defence, logistics, extractives and agribusiness.

Contact us for further information.