Analysis of the 2nd hearing of the Sanctions Commission of the French Anti-Corruption Agency

Will the decision, which will be issued in a month at the latest, allow other businesses to understand what the authorities expect of them in implementing their compliance program? Moreover, this is what the public present expected, as was recalled, at the end of the hearing, by the board of the company Imerys controlled on 22 January.

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As with the first company that was subject to controls in 2019, the company that was referred to the Sanctions Committee by the AFA Director had more than 2 years to improve its compliance program. Therefore, out of the seven shortcomings identified at the time of the report, only three remained at the time of the Commission's referral letter in September 2019: non-compliance with the risk mapping, the code of conduct and accounting controls. From the outset, Imerys alleged that the statement of objections was inaccurate, but nevertheless answered point by point.

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The point with our partner Maria Lancri for Editions Législatives.