Sapin II Ethics and Compliance Software Solution


What Has Happened with Sapin II and the AFA?

The passage of Sapin II in France in 2016 established the French Anti-Corruption Agency (Agence Française Anticorruption “AFA”), with a mission to prevent corruption, establish corporate compliance guidelines, and drive transparency through the modernisation of business practices. It requires companies 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.

Sapin II Regulation TimelineSapin II Regulation Timeline


Does Sapin II apply to you?

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

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500 or more

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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.


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

We can help bring your compliance programme into alignment with the AFA’s guidelines through targeted compliance solutions that meet the requirements of Sapin II legislation.

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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.

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

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

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

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

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

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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

Our comprehensive suite of integrated solutions is built to evolve and grow alongside the needs of your business, industry best practices, and changing regulations including Sapin II. See how one or more Convercent solutions can help you build a compliance program that keeps your organisation ahead of the evolving regulatory landscape.

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