Sapin II Pillar 2 - Internal Whistleblowing System AS REVISED BY THE WASERMAN LAW (Loi 2022-401 du 21 mars 2022) transposing EU Whistleblower Directive 2019/1937. REQUIREMENTS: (a) DEDICATED CHANNEL for employee + temporary + contractor + alumni + suppliers + applicants to report concerns about prohibited conduct + violations of law + fundamental ethical principles; (b) CONFIDENTIAL HANDLING with anonymous option; (c) DEDICATED HANDLER (referent or compliance officer) with adequate independence + authority + resources; (d) ACKNOWLEDGEMENT within 7 DAYS of receipt + INVESTIGATION within reasonable time + RESPONSE within 3 MONTHS (extendable for complex cases); (e) PROTECTIONS for whistleblowers - no retaliation + reverse burden of proof in retaliation cases (employer must prove decision not motivated by report) + provisional measures + interim suspension reversal + statutory civil + criminal sanctions for retaliation; (f) EXTERNAL CHANNELS to public authorities (Defenseur des Droits + AFA + Procureur de la Republique + EU institutions); (g) ANTI-RETALIATION TRAINING for all managers. APPLICABILITY: all employers with AT LEAST 50 EMPLOYEES (Waserman extended this from Sapin II's original threshold). SUPPORTING INFRASTRUCTURE: typically web portal + phone hotline + email + face-to-face options.
The graph holds this control, the 0 it maps to, and the evidence behind each claim, over MCP and REST.