What Has Happened with Sapin II and the AFA?

Sapin II passed in 2016, establishing the French Anti-Corruption Agency (Agence Française Anticorruption “AFA”). The AFA works to prevent corruption, establish corporate compliance guidelines, and drive transparency through the modernisation of business practices. As part of Sapin II companies are required to establish a compliance program that aligns with the AFA’s guidelines. The law also defines a whistleblower reporting procedure and prohibits retaliation against whistleblowers.

New guidance related to Sapin II is released every year. In January 2021 the AFA published new recommendations including practical procedures for implementing anti corruption policies based on three foundational principles:

  • Commitment to corruption-free performance
  • Understanding of the entities exposure to risk
  • Overall risk management

Sapin II Regulation TimelineSapin II Regulation Timeline


Does Sapin II apply to your business?

The AFA has authority over companies that meet all the following conditions:

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500 or more employees

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Incorporated or headquartered in France

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Annual revenues or consolidated revenues of at least €100 million

Both companies and individual corporate leaders may face injunctions and penalties should their company fail to comply.Changes in Global compliance are fast-moving, and professionals are challenged to ensure compliance across jurisdictions and country borders. As experts in global compliance needs, Convercent is a partner in understanding the impacts of Sapin II and other laws across your global business.


What is the French Anti-Corruption Agency

1. The AFA


The 8 Key Components of an AFA-Compliant Corporate Compliance Programme

1. Code of Conduct

2. Internal Whistleblowing Hotline

3. Risk Mapping

4. Third Party Due Diligence

5. Accounting Controls

6. Training for Employees and Leaders

7. Disciplinary Policy

8. Internal Controls

As experts in Sapin II we can help bring your compliance programme into alignment with the AFA’s guidelines.

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SOX Compliance Solutions

Convercent’s compliance solutions can provide a solid foundation for SOX compliance. When you combine multiple solutions, you get a more holistic view of risk, a more effective method for engaging employees with your policies, and a more compliant company. Click the links below to learn more about each solution.

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Policy Manager

Maintain, distribute, and track your financial control policies and procedures,prepping your company for audits and providing evidence of SOX compliance

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Provide employees with a user-friendly, multi-intake-channel whistleblowing hotline that allows you to track and prevent retaliation

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Ethics & Compliance Portal

Publish an engaging code of conduct that makes your stance on retaliation clear and connects your policies to company culture

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Inoculate managers and employees against misconduct and fraud with a training program that measures training success

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Ethics Cloud Platform

Combine Convercent solutions for greater risk visibility, stronger buy-in across the organization, more effective training, and deeper analytics

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Identify risk areas before misconduct happens with a comprehensive analytics platform that combines data from across the organization

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Third Party Risk Management

Third-party risk management software for ethics and compliance, with automated screening, due diligence, risk management, and ongoing monitoring

An Integrated Solution for Global Businesses

Our offices, located in London, UK and Denver, CO, USA, provide dedicated Customer Success and Technical Support in a timezone that suits you.

7.5 Million

people covered by the Ethics Cloud Platform


companies located in over 150 countries


languages available within our global hotline telephony


languages available within our web applications

Flexible compliance solutions that meet Sapin II and AFA guidelines now—and grow alongside your needs

Convercent offers tools built to evolve and grow alongside the needs of an ever changing regulatory environment, including Sapin II. Learn how Convercent’s solutions can help you build a compliance program that keeps your organisation ahead of the evolving landscape.

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