International CSR & Corruption Prevention

Sapin 2 law compliance plan: How To Prevent Corruption Abroad

A programme for assisting companies with their compliance plan for the anti-corruption section of the French Sapin II law and requirements of the French anti-corruption agency: Agence Française Anti-corruption (AFA).


Adopted on 30 June 2017, the Sapin 2 law requires that French companies deploy a corruption prevention plan suited to the company’s national and international activities and adjusted for the company’s exposure to risks.

The law applies to French companies with over 500 employees  (in France and abroad) and with revenue of over 100 million euro (in France and abroad).

The French anti-corruption (AFA) is the controlling body.


  • Meet the legal requirements of the Sapin law
  • Reduce exposure to corruption risks in your activities in France and abroad
  • Deploy a corruption prevention system in line with your CSR and ethical commitments
  • Reduce financial, legal, penal and reputation risks 
  • Receive assistance from multidisciplinary experts for mapping risks and the creation of adequate prevention measures


Our comprehensive programme for compliance with the Sapin 2 law:
  1. Organize an executive committee to raise awareness amongst management teams
  2. Training for the project team and assistance with decrypting the Sapin II law in real terms
  3. Guide/assist the internal officer/project team
  4. Sapin II law benchmarking exercise with different operational directions
  5. Document review of existing processes/procedures for anti-corruption/ethics/deontology
  6. Employee and third-party interviews to evaluate how existing measures are implemented
  7. Corruption risk mapping for each manager/business unit and global entity
  8. Calculate the objective and operational risks: gross, real and theoretical residual risks)
  9. Workshops for identifying exposed trade partners and roles
  10. Assistance for creating corruption schemas and evaluate control systems
  11. Assistance for compliant Anti-Corruption Management System (ACMS) procedures and documents
  12. Advice for the deployment/communication of corruption preventions internally and externally
  13. Assistance in choosing indicators for performance and continued improvement
  14. Conception/organization of a specific training programme for exposed employees
  15. Creation/distribution of e-learning tools for raising general awareness
  16. Guide the progress and effectiveness of the  training plan (LMS platform)
  17. Conformity audit
  18. Assist or organize the  deployment of agencies/entities abroad
 Average period for application by the company: 6 months

Our strengths

  • ACTE International has had the ETHIC Intelligence certification since 2014.
  • Many references and our international experience in diverse sectors
  • Expertise in international trade and global supply chain management.
  • A team of multidisciplinary and multicultural experts who can work with you on projects
  • Operational methodology based on workshops and immediate appropriation by employees
  • Evaluation tools developed internally: benchmark, mapping, identification, control systems, etc.
  • Proven training skills, supported by our accredited professional training centre.
  • A personalized approach to a suitable prevention plan, and optimal competency in operational corruption risk systems.
  • Activities possible in our head office in France and/or in our international branches.