Sapin II Pillar 4 - Third-Party Due Diligence (Evaluations integrite des tiers). REQUIREMENTS: a risk-based due-diligence procedure for THIRD PARTIES including: (a) CLIENTS (especially government clients + politically-exposed persons + high-risk jurisdictions); (b) SUPPLIERS + VENDORS; (c) INTERMEDIARIES + agents + consultants + distributors; (d) JOINT VENTURE partners; (e) M&A targets (acquired entities); (f) AGENTS + CONSULTANTS providing introductions or advocacy services. METHODOLOGY: per-third-party RISK SCORING (geography + sector + transaction nature + counterparty type + government-touchpoints); SANCTIONS + WATCHLIST screening (OFAC + EU + UN + UK HMT + France DGT + sectoral lists); ADVERSE MEDIA screening; ULTIMATE BENEFICIAL OWNER (UBO) verification; INTERVIEWS + questionnaires; SIGNED ANTI-CORRUPTION CERTIFICATIONS in contracts; PERIODIC REFRESH (annual for high-risk + 3-year for low-risk); RED-FLAG escalation + management review + decision documentation. M&A: integrity due diligence as part of buyer's deal-evaluation + post-close integration assessment + indemnification + remediation under SAPIN II + FCPA-equivalent standards.
The graph holds this control, the 0 it maps to, and the evidence behind each claim, over MCP and REST.