08/06/2023
The French Anti-Corruption Agency publishes a Compendium of practical information on indexes for measuring a geographical area's exposure to the risk of corruption.
The Sapin 2 Law requires the managers of companies with more than 500 employees and a turnover greater than €100 million, as well as their subsidiaries and managers, to implement measures to prevent and detect breaches of probity in France or abroad.
This anti-corruption compliance system shall include, among other measures:
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a regularly updated risk map designed to identify, analyze and prioritize the risks of the company's exposure to external corruption-related solicitations, based among other criteria on the geographical areas in which the company operates;
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procedures for assessing the situation of clients, first-tier suppliers and intermediaries with regard to risk mapping.
These two measures therefore require knowledge of the risk of committing acts of corruption inherent in each geographical area.
Geographical location is not the only factor in assessing the risk of corruption, but it is nonetheless a central criterion.
In this context, the AFA published a compendium of indexes elaborated by international organizations, governments, financial institutions, private entities, NGOs...
The AFA refers to two categories of indexes:
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indexes measuring the risk of corruption in a given geographical area;
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indexes which, while not all having the primary objective of assessing the risk of corruption, integrate this risk.
In addition to these indexes, the AFA lists a number of documentary resources useful for assessing the risk of corruption:
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state evaluation reports on the risk of corruption drawn up by international organizations (UN, OECD...), academic institutions or leading NGOs;
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additional tools (list of non-cooperative states and territories, list of individuals and states subject to international sanctions, etc.).
Although they do not constitute a "turnkey" tool for establishing a risk map or assessing the situation of third parties in relation with the organization, these indexes and documentary resources contribute to the assessment of a geographical area's exposure to the risk of corruption.
Isn't it time to review your risk map and submit it to our Probity team's stress test?
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