Sapin II (French Corruption Law) in Hotel RFPs (Plain English Definition + Examples)

Definition

Sapin II is the 2016 French anti-corruption law (Loi Sapin II) that requires French companies with 500+ employees and €100M+ revenue to implement an anti-corruption programme covering risk mapping, third-party due diligence, gifts and hospitality policy, accounting controls, and a whistleblower channel.

In European MICE sourcing, sapin ii (french corruption law) sits inside a broader workflow that includes the brief, the longlist, the shortlist, the contract negotiation, and the post-event reconciliation. Understanding it in isolation is not enough — what matters is how it interacts with the other levers a planner can pull. The definition above is the textbook version; the sections below explain how it actually behaves in real RFPs.

Why Sapin II (French Corruption Law) matters

Sapin II reaches MICE through hospitality policy. Any French corporate (or any company with French operations meeting the threshold) must vet venues, gifts, and entertainment against the anti-corruption programme. A €120 dinner is fine; the same dinner labelled 'hospitality for a French public official' is a compliance event. Always document business purpose and attendee role.

Example

French pharma corporate hosts a 200-attendee European launch in Lyon. Among attendees: 4 doctors from public hospitals (French public officials under Sapin II). Hospitality cap per the programme: €60 per meal, business purpose documented, attendee list logged in compliance system. Without documentation, the same meals trigger Sapin II flags.

Where Sapin II (French Corruption Law) appears in contracts

Sapin II compliance is internal to the planner organization, not the hotel contract — but hotels with French corporate clients should expect detailed attendee-data and itemization requests on invoices.

Related terms

Deeper reading