Challenge of Addressing Sapin II Compliance
The French anti-corruption and whistleblower protection law, Sapin II, aligns France with evolving global anti-corruption standards. Largely based on the FCPA and UK Bribery Act laws, Sapin II defines regulations to prevent and detect bribery and corruption through increased corporate transparency, reinforced internal monitoring, and enhanced whistleblower protection. The most stringent standards apply to larger companies based in France with 500 or more employees and an annual turnover of at least €100m, or companies of the same size that are part of a parent company headquartered in France. These companies are required to implement a comprehensive compliance programme that includes an anti-corruption code of conduct, a risk assessment mechanism, procedures for conducting third-party due diligence, executive compliance training, a robust internal hotline reporting process to protect the confidentiality of whistleblowers and a procedure for measuring the effectiveness of the programme.