Sapin II Article 17. SCOPE + APPLICABILITY: applies to (a) French companies + groups (including French subsidiaries of foreign groups) with AT LEAST 500 EMPLOYEES + AT LEAST EUR 100 MILLION ANNUAL TURNOVER (consolidated for groups); (b) public officials + appointees of state-owned enterprises; (c) elected officials per HATVP. 8-PILLAR MANDATORY PROGRAM: (1) Code of Conduct; (2) Internal Whistleblowing System; (3) Corruption Risk Mapping (cartographie); (4) Third-Party Due Diligence; (5) Accounting Control Procedures; (6) Anti-Corruption Training; (7) Disciplinary Regime; (8) Internal Monitoring + Assessment. PROGRAM OWNERSHIP: must be approved by + reported to the Board of Directors + the chief executive; the chief executive bears personal responsibility for the program implementation + the AFA may impose individual sanctions. AFA RECOMMENDATIONS: detailed guidance on each pillar (most recent revision December 2021 + ongoing updates 2024-2025). EXTRATERRITORIAL APPLICATION: may catch foreign parent companies of French subsidiaries even when activities occur outside France (mirrors FCPA + UK Bribery Act).
The graph holds this control, the 0 it maps to, and the evidence behind each claim, over MCP and REST.