French Sapin II Law (Law No. 2016-1691)
Article 17 II 2° and Articles 8 and 9: internal alert and whistleblowing procedures – French Sapin II Law (Law No. 2016-1691)

French Sapin II Law (Law No. 2016-1691) 17.II.2: Article 17 II 2°: an internal alert system for reports of conduct contrary to the code

What does 17.II.2 require?

The company must have an internal alert system to collect reports from employees about conduct or situations contrary to its code of conduct. The AFA recommends a single technical reporting channel for all legal alert regimes, open to external and occasional staff, deployed across all controlled entities, presented to new joiners and in the code, secured with access limited to authorised handlers, allowing anonymous reports with continued dialogue, naming the referent who receives and the one who treats reports, guaranteeing confidentiality with disciplinary consequences for breaches, acknowledging receipt promptly, informing the reporter of closure, and reporting indicators (reports received, closed, handled, time taken) to the governing body; outsourced handling is allowed with regular checks (paragraphs 251 to 269 and 280).

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