Since 2014, SNCF has been working hard to prevent and fight corruption. To support this effort, our Ethics and Deontology unit launched a programme outlined in a March 2015 memo from our Chairman and Deputy Chairman.

This voluntary effort became a legal obligation on 9 December 2016, when France adopted its Transparency, Anti-Corruption and Economic Modernization Act. Under Article 17 of the law known as the Sapin II Act, once an EPIC (a state-owned industrial and commercial enterprise) reaches a certain size, it must take 8 actions to prevent and detect corruption and influence-peddling in France and abroad.

1. Code of conduct

Adopt a code of conduct that fights corruption¹ by defining and illustrating the various types of prohibited behaviour usually associated with corruption and influence-peddling.
The code expands on these points in areas with the highest risk of corruption: contracts, tenders, facilitation payments, corporate sponsorships and partnerships, conflicts of interest and use of agents.

2. Whistleblowing system

Set up a whistleblowing system that employees can use to report situations that violate our code of conduct.

3. Risk mapping system

Develop a risk-mapping system to identify, analyse and prioritize risks exposing the company to situations involving corruption, with special emphasis on the industries and regions in which the company does business.

4. Due diligence procedures

Conduct due diligence procedures to assess the positions of customers, lead suppliers and agents based on the risk-mapping system.

5. Control procedures

Adopt internal or external accounting control procedures to ensure that none of the books, ledgers or accounts are used to cover up corruption or influence-peddling.

6. Training

Deploy a training programme for employees with the highest exposure to corruption and influence-peddling risks.

7. Enforcement

Create an enforcement system to sanction employees who violate the code of conduct.

8. Internal monitoring

Set up an internal monitoring and assessment system to evaluate measures adopted by the company.

France’s Anti-Corruption Agency (AFA) is tasked with ensuring that companies comply with these 8 requirements. If AFA finds that a business has failed to properly deploy an anti-corruption programme, it can impose financial penalties of up to €200,000 for individuals and €1,000,000 for legal entities.
We have already launched a number of compliance efforts, but we still have work to do, especially in the areas of risk-mapping and accounting control procedures.