French Sapin II Law (Law No. 2016-1691)
Sapin II: Pillars 7+8 - Disciplinary Regime and Internal Monitoring and Continuous Improvement

French Sapin II Law (Law No. 2016-1691) Pillar7-Disciplinary-Regime: Pillar 7 - Disciplinary Regime for Anti-Corruption Violations

Sapin II Pillar 7 - Disciplinary Regime (Regime disciplinaire). REQUIREMENTS: a documented disciplinary regime in the Internal Regulations (Reglement interieur per French Labour Code Art. L. 1321-1) covering: (a) PROHIBITED CONDUCT - active + passive corruption + facilitation payments + influence peddling + gifts above thresholds + retaliation against whistleblowers + obstruction of investigations + failure to cooperate with AFA inspection; (b) SANCTIONS LADDER from verbal warning to dismissal for serious misconduct (faute grave) + dismissal for very serious misconduct (faute lourde); (c) INVESTIGATION PROTOCOL with HR + legal + compliance involvement + due process + employee defense rights per French Labour Code; (d) DOCUMENTATION + chain-of-command + decision rationale + sanction proportionality; (e) APPEALS to employer representatives + Conseil des Prud'hommes (labour court); (f) APPLICATION to all personnel including senior management + directors. KEY CONSTRAINT: must comply with French Labour Code procedural requirements + collective agreements + the SAFI II + AFA expectations of consistent + proportionate + documented application across the organization.

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