Compliance program for French "Sapin 2 Law" : prevention of corruption plan

To assist companies build their compliance program according to the anti-corruption requirements of the French Sapin 2 Law, and follow the French anti-corruption Agency guidelines (AFA - Agence Française Anti-corruption)


Adopted in June 2017, the French Sapin 2 Law requires that companies settled in France implement a corruption prevention plan applicable to the company’s national and international activities. This plan shall be scaled to the level of corruption exposure. 

The Law applies to  companies settled in France with over 500 employees  (in France and abroad) and with a revenue over 100 million euro (in France and abroad).

The French anti-corruption Agency (AFA -Agence Française Anticorruption) is the controlling body.



  • Meet the legal requirements of the anticorruption French law
  • Reduce exposure to corruption risks in your activities in France and abroad
  • Implement a corruption prevention plan in line with your CSR and ethical commitments
  • Reduce financial, legal, penal and reputational risks 
  • Be assisted by multidisciplinary experts for corruption risk mapping and creation/implementation of appropriate prevention measures


Our comprehensive program for compliance with the Sapin 2 Law:
  1. Preparatory step
    1. Presentation to the steering committee to raise awareness of governance bodies
    2. Training of the project team and presentation in detail of Sapin 2 Law anticorruption requirements 
    3. Documentation review and compliance evaluation of existing policies, processes, procedures related to anti-corruption, integrity and/or ethics
  2. Corruption Risk Mapping
    1. Gap Analysis with Sapin 2 Law requirements
    2. Corruption risk mapping of each process and/or department and/or business unit, and global conlidation
  3. Creation / implementation of the "corruption prevention plan" required by Sapin 2 Law 
    1. Technical Assistance for the creation and / or improvement of policies, procedures, processes, legal, commercial and contractual documents
    2. Brainstom and consulting for an appropriate internal and external communication of the anticorruption policy
    3. Expertise for the choice of performance indicators, and continuous improvement monitoring tools
  4. Training / Awareness raising
    1. Design / animate a specific training program for exposed employees
    2. Provide e-learning tools and monitor the awareness program (including an LMS Platform)
    3. Report on progress and effecticiency level of the training plogram 
  5. Support or manage the international implementation in subsidiaries / entities abroad

Our strengths

  • ACTE International is an ISO 37001 certified company
  • Our references and international experience in various sectors
  • Our expertise in international trade and global supply chain management
  • A team of multidisciplinary and multicultural experts working as project groups
  • Operational methodology based on workshops and immediate appropriation by employees
  • Risk evaluation and mapping tools validated during our own ISO37001 certification process 
  • Proven and long lasting training skills, supported by our accredited professional training centre.
  • customized scale of your prevention plan
  • Our services are available in Europe and abroad (including Maghreb/Africa)