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Loi Sapin II - offrir une invitation à ses clients
Sapin II law
Tuesday 23 August 2022

Sapin II Law: can I offer an invitation to Stade de France to my customers?

"Can I invite a customer to a VIP event?". Since the Sapin II law came into force, this is a legitimate question that some companies ask themselves before sending an invitation, for example, to a box for an event at Stade de France.
To help you answer this question, Stade de France invites you to consult the practical guides published for the occasion, so you can ask yourself the right questions to remove any doubts and finally to implement a series of practical tools within your company.

Guides to help you make your decision (AFA, White Paper)

As part of the second part of the Sapin law, the government decided to create the French Anti-Corruption Agency (AFA), whose mission is to assist economic actors in preventing and detecting corruption.

To facilitate this process, the AFA published a practical guide in 2020 that governs gifts and invitations in companies and warns of the risks of non-compliance with the Sapin II law. The agency specifies that "inviting a partner to an event does not in itself constitute an attempt at corruption, but an ordinary act of business life".

Stade de France, which is affected by this new regulation, has also decided to help companies to make their decisions in full knowledge of the facts and to help them with their questions about business invitations in the context of the Sapin II law. Stade de France therefore published a white paper in 2021 that sheds light on preventing acts of corruption and on the steps to follow for a successful Hospitality programme.

These two documents are complementary. They will certainly help you to carry out worry-free, profitable, dynamic and ethical public relations operations.

Questions to ask yourself before offering an invitation

Even if an invitation to an event at Stade de France cannot, according to the AFA, be considered as an act of corruption as such, it could constitute a risk if it takes place in a sensitive context or if it is not part of a global and transparent public relations strategy defined by the inviting company.

Let's take the example of a call for tenders or a contract renewal. It is clear that inviting a business contact involved in this contract before its signature could present a higher risk.

To go further and guide you in your thinking, the AFA invites those making invitations to consider 3 aspects of the invitation:

  • the purpose: do you expect something in return for your invitation? Could your customer feel embarrassed by accepting?
  • the frequency: haven’t you invited this customer too many times?
  • its value: is this invitation excessive compared to what is usually done in your sector?

If you answered "yes" to any of these questions, it is advisable to review the context of your invitation so that it unambiguously complies with the Sapin II law.

The right tools to put in place within your company

If you still have doubts, there are several internal warning systems and other tools to help you see things clearly and move forward comfortably:

  • designate an anti-corruption contact person in line with the Sapin II law;
  • create approval mechanisms for invitations ;
  • fill in an internal register to record;
  • determine key indicators and evaluating the Return on Objectives for each event...

On the other side of the Atlantic, American regulations set out the 4Rs rule which can also help you in your thinking:

  • comply with Regulation: comply with the laws and the company’s internal processes;
  • be Reasonablebe reasonable, act in a measured way;
  • be Responsable: use your common sense;
  • keep Record: keep track of gifts in a register.

Some companies go further to ensure that their policy complies with the Sapin II law by following the ISO 37001 (anti-corruption management systems) international standard.

In short: practical guides, a list of questions to ask yourself and numerous tools are available to help you secure your business invitations policy, while making it more efficient.

Stade de France, an expert in the implementation of public relations programmes for over 20 years, is here to support you in this process and allow you to continue to experience memorable moments with your customers and partners, in exceptional and transparent conditions!

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