Sapin II Pillar 1 - Anti-Corruption Code of Conduct (Code de conduite). REQUIREMENTS: a documented + formally-adopted Code of Conduct articulating: (a) prohibited behaviour (active + passive corruption + influence peddling + facilitation payments + foreign-official bribery + gifts + hospitality + sponsorship + political contributions thresholds); (b) the company's commitment to anti-corruption + ethical conduct; (c) the consequences of breach (disciplinary regime); (d) the whistleblowing channels + protections; (e) decision-making authority + escalation; (f) integration into employment contracts + Internal Regulations (Reglement interieur per French Labour Code Art. L. 1321-1) via Article 17 II.1 explicit reference. ADOPTION + COMMUNICATION: must be communicated to ALL EMPLOYEES + acknowledged + posted prominently; must be translated into local languages for foreign subsidiaries; must be reviewed + updated at least annually + after major events (corruption incidents + regulatory developments + AFA inspections). AFA-PREFERRED FEATURES: tone-from-the-top message; concrete examples + decision trees; sector-specific risk awareness; integration with sanctions screening + due diligence; alignment with parent group code if applicable.
The graph holds this control, the 0 it maps to, and the evidence behind each claim, over MCP and REST.