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Sapin 2 Act: implementing an operational anti-corruption framework
Corruption prevention must be reflected in everyday decisions and practices. Understand the requirements of the Sapin 2 Act, identify sensitive situations and clarify responsibilities. Develop a practical understanding of how to contribute to a coherent framework and its implementation.
- Duration
- 3 days 21 hours
- Code
- GRC002FR Code
Presentation
As transparency requirements continue to increase, the Sapin 2 Act has become a key benchmark for managing business ethics within organisations. This course will enable you to understand, structure and implement a compliant anti-corruption framework, drawing on the recommendations of the French Anti-Corruption Agency (AFA) and international best practices.
The course offers a progressive, practical approach to building a compliance programme suited to your company's circumstances. You will explore essential prevention mechanisms, such as codes of conduct and training, while mastering detection tools, including risk mapping and third-party assessments. Emphasis is placed on senior management commitment and coordination with internal control to ensure the framework is effective.
By the end of the course, your newly acquired expertise will enable you to initiate or strengthen a comprehensive anti-corruption framework within your organisation. You will have a clear understanding of how to manage internal whistleblowing, conduct investigations and implement consistent corrective and disciplinary measures.
Objectives
By the end of this course, you will be able to:
- analyse compliance challenges by interpreting the Sapin 2 legal framework and its convergence with international standards (FCPA, UK Bribery Act);
- apply AFA recommendations to structure the 8 mandatory pillars of your organisation's anti-corruption framework;
- design a robust risk map by mastering the identification, analysis and prioritisation of corruption scenarios;
- structure an effective due diligence procedure to assess the integrity of third parties (suppliers, partners and intermediaries);
- secure the collection and handling of reports by deploying an internal whistleblowing mechanism that meets confidentiality requirements;
- conduct an internal investigation methodically to establish the facts and prepare corrective measures;
- integrate accounting and operational controls within the three lines of defence to prevent attempted corruption;
- govern the compliance programme by defining a consistent disciplinary system and ensuring continuous improvement.
Program
Module 1: mastering the legal framework and risk mapping
- Fundamental anti-corruption issues and the role of the AFA.
- Analysing the Sapin 2 legal framework and its convergence with international standards (FCPA, UK Bribery Act).
- Understanding the pillars of senior management commitment.
- The complete risk mapping methodology: identifying, analysing and prioritising corruption scenarios.
Practical exercises
- Create a risk map for a fictional company to learn how to prioritise threats.
Module 2: implementing prevention tools and internal control
- Structuring the anti-corruption code of conduct and training arrangements.
- Implementing third-party assessment procedures (due diligence).
- Applying the three lines of defence principle to the anti-corruption framework.
- Deploying accounting controls and first-, second- and third-level controls.
- Methodology for auditing the effectiveness of an existing framework.
Practical exercises
- Analyse sample documents (codes of conduct and third-party questionnaires) and resolve practical internal control cases.
Module 3: managing whistleblowing, investigations and framework oversight
- Technical and legal implementation of the reporting mechanism (internal whistleblowing).
- Methodical conduct of an internal investigation following a report.
- Defining the disciplinary system and necessary corrective measures.
- Organising coordination between compliance and internal control.
- Managing the overall framework and continuous improvement strategies.
Case studies
- Handle a report in a realistic situation and participate in a group debrief of the practical exercises.
Audience
This course is intended for professionals responsible for business ethics and regulatory compliance within their organisations, including:
- executives and corporate officers seeking to understand the scope of their criminal liability and secure lasting management commitment to protecting the organisation;
- operational managers and directors who need to identify areas requiring vigilance in their daily work and respond appropriately to risky solicitations;
- HR, finance and accounting managers responsible for integrating ethics and compliance into third-party management and financial flow controls;
- legal professionals and support functions seeking a practical interpretation of legal obligations to safeguard business processes and internal contracts;
- anyone involved in compliance or internal control seeking to master the fundamentals of the Sapin 2 Act and detect early warning signs in their work.
Prerequisites
No specific prerequisites are required for this course.
Teaching and assessment methods
- Initial skills assessment
- Training materials provided to participants
- Continuous assessment throughout the course
- End-of-course feedback questionnaire
- Combination of theory and practical application
- Attendance records
- Post-course follow-up evaluation
- Practical exercises
- Case study
Course highlights
- Operational approach: methodological guidance combined with tools you can reuse directly in your organisation.
- Comprehensive toolkit: take away risk mapping, code of conduct and third-party assessment templates, plus an AFA checklist.
- Standards expertise: a programme aligned with AFA recommendations and ISO 37001/37002 standards.
- Flexibility: available as public or in-company training, with possible adaptation to your industry.
Dates and sessions
Choose the date and delivery format that suit you.
No upcoming sessions are currently available.
The AFA (French Anti-Corruption Agency) is a French national government agency. Its framework is used here for educational purposes.