French Sapin II Law (Law No. 2016-1691)
Article 17 II 1°, 6° and 7°: code of conduct, training and disciplinary regime – French Sapin II Law (Law No. 2016-1691)

French Sapin II Law (Law No. 2016-1691) 17.II.1: Article 17 II 1°: a code of conduct integrated into the internal rules

The company must have a code of conduct that defines and illustrates the kinds of behaviour to be prohibited as likely to amount to corruption or influence peddling; it is integrated into the règlement intérieur and so goes through the staff representative consultation of article L. 1321-4 of the code du travail. The AFA expects it to be written after the risk map, structured by type of prohibited behaviour with concrete illustrations (gifts and hospitality, facilitation payments, conflicts of interest, patronage, sponsorship, lobbying, representation costs), to present the internal alert system, to state that breaches lead to disciplinary sanctions, to name the function answering questions, to be clear and unequivocal, prefaced and validated by the governing body, applicable everywhere the company operates (with local versions where needed), communicated to third parties with a contractual clause where useful, and reviewed after each risk map update with an effective date (paragraphs 156 to 178).

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