1
Understand the challenges of the fight against corruption
- Identify the issues of corruption on an international scale.
- Consider corruption as a risk for a company: sanctions, reputation, stock market losses.
- Understand the international regulatory framework and the American and British legislation (FCPA, UK bribery).
- Identify the objectives, scope and principles of the SAPIN II law.
Example
Examples of U.S. FCPA corruption cases. Example of concrete application of the SAPIN II law.
2
Understanding different patterns of corruption
- Case study: Corruption in an international buying and selling process.
- Case study: Corruption in a public-sector subcontracting process.
- The link between corruption, money laundering, and terrorist financing.
- Case study: Corruption related to personnel management.
- Case study: Corruption in expense management.
Storyboarding workshops
Telling apart lobbying and corruption.
3
Overview of the measures of the Sapin II law
- The 8 measures of the law.
- Focusing on the alert system.
- Focusing on the design of the corruption risk map.
- Creation of the French Anti-Corruption Agency and its mechanisms of action.
- Obligation for companies to prevent corruption risks.
- Compliance enforcement and penalties associated with the SAPIN II law.
Group discussion
Identify the types of companies most affected by the SAPIN II law.
4
Implementing the Sapin 2 anti-corruption compliance program
- Developing and adopting a code of conduct.
- Mapping risks and assessing third party risks.
- Implementing accounting control procedures.
- Organizing in-company training for the most exposed managers and staff.
- Organizing a system for monitoring and evaluating the measures taken.
- Setting up an internal alert system.
Example
Key elements of the code of conduct. Key risk indicators and formalization of risk mapping. Parts of the procurement policy that limit the risk of corruption. Whistleblowing if the ethical compliance system is violated.