Code of conduct

Article 17 II 1° of the Sapin 2 Law stipulates that the chairs/presidents, chief executive officers, general managers and managers of companies targeted by said Law must implement:

“a code of conduct that defines and illustrates the various types of proscribed conduct that could constitute bribery or influence peddling.”

The code of conduct, whatever is may be called, is a document that expresses the company’s commitment to bribery prevention and detection.

In order to be adapted to the specificities of the company, its activities, its culture and its values, the code must be drawn up on the basis of the information gathered during the preparation of the risk map. It must be clear, straightforward, unequivocal, written in layman’s terms and accessible to non-specialists.

Soulier Avocats assists companies and corporate groups operating in a wide range of industries in the preparation of a code of conduct defining and illustrating, by means of practical cases, the different types of risk situation and proscribed conduct in order to protect the company and its employees from any practice likely to characterize corruption, influence peddling and breaches of probity.

Our dedicated team provides guidance and assistance at every stage of the preparation process:

• Presentation of the issues at stake and identification of the objectives,

• Determination of the scope of the code of conduct and internal means of communication (in particular consultation with the staff representatives as required under Article L.1321-4 of the French Labor Code),

• Definition of the internal/external drafting and approval process,

• Insights on the interaction of the code of conduct with other documents (operational fact sheet, processes, procedures, etc.),

• Coordination of the code of conduct with the company’ internal rules and regulations,

• Determination of the content (in particular proscribed conduct, relevant illustration of actual cases, presentation of the internal whistleblowing system, designation of the person(s) responsible for answering questions from staff members, etc.),

• Updates to the code of conduct.