You want to carry out a periodic evaluation of the tools put in place by the Sapin II law and communicate internally on the practical implications of a possible AFA inspection (availability of teams, documents, need to avoid any obstacle to the inspection)
You want to prepare in advance all the answers and documents that must be sent to the AFA in the event of an inspection (within an imperative period of only 15 days)
You want to document each action of the company relating to the mechanisms and tools put in place (meetings, changes made, alerts, etc.) and to centralise the storage of all relevant data and documents.
What is SAPIN II ?
Sapin II is the French legal framework to fight corruption. Sapin II is named after the SAPIN I 1993 and was enacted in 2016.
The main additional provisions of the Sapin II law are the establishment of a French Anti-Corruption Agency (“AFA”), as well as the compulsory implementation of an anti-corruption compliance programme for French companies of a certain size. Companies may be penalized for failure to comply. Moreover, SAPIN II introduced the establishment of a criminal settlement procedure, the extension of the extraterritorial application of French criminal law in international corruption matters and the increased protection of whistleblower status.
Sapin II applies to companies and corporate groups that are incorporated or headquartered in France and have at least 500 employees and have annual revenues or consolidated revenues of at least 100 Million Euro.
Penalties for violations reach up to 20000 Euro for individuals and 1 Million for companies. In order to prevent SAPIN II violations, a solid set of compliance procedures is required.
This solution will provide you guidance with the adoption of SAPIN II compliance procedures and moreover, it will advice you how to stay compliant.
Smart Global Governance is the operational software solution to automate key processes in Ethics, Compliance and Controls. It can be used for implementation and compliance management with all local and international regulations as well as internal controls and procedures.