Sapin II Pillar 6 - Anti-Corruption Training (Programmes de formation). REQUIREMENTS: (a) GENERAL AWARENESS training for ALL employees (typically online + 30-60 minutes + annual refresh); (b) ROLE-SPECIFIC training for high-risk positions (Sales + Procurement + Finance + Government Affairs + HR + Senior Management) with case studies + decision exercises; (c) BOARD-LEVEL briefing on legal regime + AFA expectations + corruption-incident response; (d) ENHANCED training for high-risk geographies + business lines; (e) NEW-HIRE training within reasonable onboarding window; (f) POST-INCIDENT + post-AFA-inspection refreshers; (g) METRICS - completion rates + knowledge-check pass rates + manager attestations + correlation with risk-event frequency. CONTENT FRAMEWORK: integrate Code of Conduct + risk mapping outputs + whistleblowing channel + third-party DD + accounting controls + sanctions regime + sector + jurisdictional updates + emerging risks (e.g. AI bribery + cryptocurrency + influencer marketing). DELIVERY MODES: e-learning + classroom + workshops + scenario role-play + executive briefings; mandatory completion within deadlines + escalation for non-completion.
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