Sapin 2 Act: What are the obligations? Who is affected?

by | Apr 2, 2024 | Identity check

The Sapin 2 law represents a major turning point in the fight against corruption in France. Since 2016, it has strengthened transparency and integrity in economic practices. It establishes a more rigorous framework for preventing acts of corruption, influence peddling and other financial crimes.

In concrete terms, what does the Sapin 2 law require? What are the resulting obligations? Who is affected?


What is the Sapin 2 law?


The Sapin 2 law represents an ambitious response to the challenges posed by corruption and fraud. Its aim is to establish companies as bulwarks against these practices. To achieve this, the regulations establish a robust legal framework based on 8 fundamental pillars.


Focus on the 8 pillars of the Sapin 2 law


A code of conduct

A code of conduct sets out the ethical principles and standards of behavior to be respected. This helps to standardize anti-corruption measures. This code of conduct must be made available to all employees.


Internal alert procedure

An internal whistle-blowing procedure must be set up to collect reports of suspicious behavior. This guarantees confidentiality and the protection of whistle-blowers.


Corruption risk mapping

Corruption risk mapping is used to identify potentially exposed areas.


Third-party risk assessment

Companies need to assess the probity of their business partners. In this way, they can put in place appropriate verification procedures.


Accounting controls

Accounting controls help detect and prevent all forms of corruption and embezzlement.


Training and awareness-raising on the Sapin 2 law

Training and awareness-raising are necessary to recognize and prevent illicit practices. They are particularly necessary for employees who are most exposed to the risks of corruption.



Failure to comply with the code of conduct is subject to administrative and criminal penalties. They ensure the effective implementation of the planned measures.


Internal assessment

Companies must regularly assess the effectiveness of their anti-corruption measures and adjust them if necessary.


Who does the Sapin 2 Act apply to?


The law sets out 2 specific criteria, which define the French companies covered by the law.

  • The headcount criterion: Only companies with over 500 employees are concerned.
  • And the sales criterion: consolidated sales must exceed 100 million euros.


This obligation also extends to subsidiaries attached to any company that meets the above criteria.


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