Compliance and monitoring Sapin II law

The SAPIN II law on transparency, fight against corruption and modernization of economic life has made due diligence a major issue for French companies.
Our experts support you to ensure compliance with your legal obligations.

An obligation to fight against corruption and influence-pedding

Promulgated in December 2016, the SAPIN II law requires companies to set up internal measures to prevent and detect the risks of corruption or trafficking. These obligations are made for French and foreign companies carrying out an activity in France.

The SAPIN II law notably requires companies to set up:

  • A code of conduct
  • An ethical alert system
  • Risk mapping
  • Business partner audit procedures
  • Accounting audit procedures
  • Employee training and awareness programs
  • Disciplinary sanctions
  • Monitoring and evaluation of their political implementation

Three steps to protect the company

Detecting, investigating and documenting are the main actions involved in protecting the company from the consequences of an accusation of corruption. If it is a substantial fine, the issue of business management or criminal reputation could be problematic and could have serious consequences

Your company will have to justify the management of alerts by investigating to identify fraudulent models, roles and responsibilities, and what could impact on your organization.

Beyond the prevention stage, the company must acquire an internal or external device as a “safe channel”. This involves reporting alerts to deal with allegations of corruption and non-compliant behaviors. 


Corpguard Intelligence Solutions teams support you in implementing these obligations through the iterative processing path. 

1. Risks  assesment

Assess your environnement and the threats you may encounter in order to decrease the risks exposure. Identify the stakeholders and map the actors around you.

2. Removing doubts

Verify legal declarations, shareholding and financial holdings, the reputation and integrity of managers and partners in order to limit the risk of corruption, money laundering or financing of terrorism. To conclude this step, a report will document your compliance process.

3.Setting up a “safe channel” mechanism

A “safe channel” enables any incident reports submitted to be dealt with. This solution guarantees protection for whistleblowers.

4.Investigations when an alert is raised

Each report received via the “safe channel” is assessed and documented, to gather the information submitted (email, phone call, interview, etc.). Further investigations are conducted if necessary.

This stage enables you to react promptly when faced with cases or allegations of corruption, embezzlement of assets, financial fraud, money-laundering, breaches of specific legislation, cyber attacks or other types of inappropriate behaviour, such as sexual harassment.

5.Forensics – Digital investigations

Our staff is able to conduct investigations into your digital media, for the purpose of adducing evidence. Corpguard will extract and analyse the data gathered, using a procedure that will ensure that this data is not compromised. This work is undertaken in accordance with the requisite legal procedures.

Development at the international level or prior to a merger

The requirements of the Sapin 2 Law in terms of transparency and combatting corruption also apply to any plans to set up businesses abroad, to mergers and company takeovers. To safeguard your investments, due diligence will also enable you to prepare the comprehensive and complete mapping of a company and to verify its good governance.