How the Sapin II Law Influences How Companies Must Manage Their Relationships with Third Parties

La Loi Sapin II

The Sapin II law, enacted in 2018, has strengthened the mechanisms to combat corruption in France. This legislation has significant implications for businesses, especially in how they manage their relationships with third parties.

Here is an analysis of these implications and their impact on the French entrepreneurial landscape.

  1. Obligation to Implement an Anti-Corruption Program: The Sapin II law requires large companies and corporate groups with more than 500 employees and a turnover of more than 100 million euros to establish internal procedures to prevent and detect acts of corruption. This includes a regular assessment of third parties they work with, such as suppliers, subcontractors, and business partners.
  2. Risk Mapping: Affected companies must develop a regularly updated risk map to identify, analyze, and prioritize their exposure to external corruption risks. This directly influences how companies select and collaborate with third parties.
  3. Third-Party Evaluation: The law strongly encourages companies to assess the status of third parties with whom they intend to do business. This involves conducting compliance audits, examining the reputation and financial structure of the third party, and assessing associated risks.
  4. Contracts with Anti-Corruption Clauses: Sapin II law encourages companies to include specific anti-corruption-related clauses in their contracts with third parties. These clauses may stipulate compliance obligations, regular audits, and sanctions in case of breaches.
  5. Training and Awareness: Companies are required to organize training sessions for their employees most exposed to corruption risks. This often includes teams in charge of procurement, sales, and those in direct contact with third parties.
  6. The Role of Whistleblowers: The Sapin II law has also strengthened the status and protection of whistleblowers. Companies must establish internal mechanisms to allow employees to report acts of corruption involving third parties.
  7. Enhanced Sanctions: In case of non-compliance, companies face severe financial penalties, as well as reputational damage. This encourages them to be particularly vigilant in managing their relationships with third parties.


The Sapin II law has established a robust regulatory framework that compels companies to rethink and strengthen how they manage their relationships with third parties. In a world where business transparency and ethics have become central, adapting to this law is not only a legal obligation but also a sign of trust and sustainability for companies.