Sapin II Ethics and Compliance Software Solution


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:

Sapin II Employee Number Icon

500 or more

Sapin II Location Icon

Incorporated or headquartered in France

Sapin II Money Icon

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.

Request a Demo

Technology Enables Transparency

Convercent solutions can provide a solid foundation that brings your programme into compliance with Sapin II and the AFA guidelines. When you combine these solutions, they provide a more holistic view of risk, helping you prevent misconduct. Click the links below to learn more about each of our solutions.

White Ethics and Compliance Portal Icon

Publish an interactive code of conduct that makes your stance on corruption easy to find and even easier to understand

White Helpline Icon

Provide employees with a human-centric, user-friendly whistleblowing hotline that allows you to track and prevent retaliation

White Policy Manager Icon

Update your policies, distribute them, and track their performance from one centralised policy manager

White Learning Icon

Create a training program that inoculates employees and managers against misconduct and corruption, while measuring training success

White Disclosure Icon

Empower employees and third parties to easily disclose gifts, hospitality, and potential conflicts of interest with a comprehensive disclosures Manager

White Insights Icon

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


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.

Request a Demo

Ethics & Compliance Software Computer Image