Want to create interactive content? It’s easy in Genially!

Get started free

Copie - Anti-Corruption Training I

SII

Created on March 18, 2026

Start designing with a free template

Discover more than 1500 professional designs like these:

Essential Business Proposal

Project Roadmap Timeline

Step-by-Step Timeline: How to Develop an Idea

Artificial Intelligence History Timeline

Microlearning: When to Use Chat, Meetings or Email

Magazine dossier

Microlearning: Graphic Design

Transcript

Anti-Corruption Training I

Corruption

© SII Group | SII Internal Use

8 rue des Pirogues de Bercy, CS 42112 75580 PARIS CEDEX 12

Document exclusive property of SII, communication, reproduction and use are prohibited without prior written authorization of SII

Hello !

SII

This presentation is interative

You can make it full screen, switch from one part to another, or return to the home page at any time. Click to see which elements are interactive

Why an Anti-Corruption Training ?

Better Management of Relationships with Third Parties

Ethics at the Core of Our Professional Practices

Prevention and Protection

Compliance with Regulations

Implement reasonable due diligence procedures

Anti-corruption code of conduct, Ethics Charter

SAPIN II Law United Nations Global Compact

Prevent risks Avoid sanctions

© SII Group | SII Internal Use

Commitment from the Management Team

Integrity and responsibility must guide our business conduct wherever we operate, within the Group and in our relationships with third parties.

Eric MATTEUCCI (Chairman of the Management Board)

Charles MAUCLAIR (Regional Director France West)

François GOLABRE (Regional Director France North & East)

Didier BONNET (Regional Director International Zone 3)

Grégoire NITOT (International Director Zone 1)

Antoine LECLERCQ (Regional Director International Zone 2)

© SII Group | SII Internal Use

What is corruption

Examples

Definitions

Main forms of corruption

SII Group Ethics Policy

Legal framework

© SII Group | SII Internal Use

Legal Framework

SAPIN II

Aims to strengthen transparency, the fight against corruption, and the protection of whistleblowers. It imposes compliance obligations on companies, including the implementation of a corruption risk prevention plan.

United Nations

UN Global Compact - Principle 10: "Business should work against corruption in all its forms, including extorsion and bribery." United Nations Convention against Corruption.

The SII Group is a signatory to the Global Compact

Corruption is a criminal offense in all countries where the SII Group operates.

© SII Group | SII Internal Use

Legal Framework

Sanctions

Criminal Sanctions: Example from France

Passive bribery = active bribery: both forms are equally punishable.

Natural person :

  • Up to 10 years of imprisonment
  • Up to €1 million in fines, or twice the amount of the illicit gain
  • Ban from carrying out certain professional activities (e.g., banking, real estate, credit, insurance)
  • Civil lawsuits may also be brought

Legal person :

  • For the SII Group, the fine can be up to five times the amount applicable to a natural person

Disciplinary Action:

Corruption may also lead to disciplinary sanctions, including dismissal or a ban on carrying out certain professional activities.

© SII Group | SII Internal Use

Definitions

Influence peddling

Corruption

© SII Group | SII Internal Use

ZERO TOLERANCE FOR CORRUPTION

SII Group Ethics Policy

SII GROUP ETHICS COMMITTEE

Eric MATTEUCCI

Chairman of the Management Board

Bénédicte QUERENET-HAHN

Lawyer- GGV Law Firm

External and independant member

Romain LE BESNERAIS

Head of Internal Audit

The Group Ethics Committee is the same as that of SII France and is responsible for:

Its duties

© SII Group | SII Internal Use

SII Group Ethics Policy

Ethics within Subsidiaries with more than 250 Employees

Local Ethics Committees are established in all subsidiaries with more than 250 employees. Under the supervision of the Group Ethics Committee, they only handle matters specific to their own subsidiary.

Group Ethics Committee

A local Ethics Committee is in place in each subsidiary with more than 250 employees, to address matters specific to the subsidiary.

Its duties

An Ethics Officer is appointed in subsidiaries with fewer than 250 employees, with responsibilities similar to those of local Ethics Committees. To prevent any conflict of interest, reports made within these subsidiaries are handled exclusively by the Group Ethics Committee, under conditions that ensure confidentiality.

© SII Group | SII Internal Use

MAIN FORMS OF CORRUPTION

Click on each card to reveal the practices related to the forms of corruption presented.

Invitations, gifts, sponsorships, donations, etc. Examples include:
  • An all-expenses-paid vacation offered to a sales representative under the pretext of a business trip
  • A payment made for the benefit of an intermediary

Fake invoices Consultancy fees with no actual service rendered Payments routed through a third party Amounts paid to speed up a process

Appointing someone to a position not based on merit or qualifications, but because they are a friend, relative, or personal connection.

DISGUISED AS COMMON BUSINESS OR SOCIAL PRACTICES

NEPOTISM AND FAVORITISM

BRIBE/ FACILITATION PAYMENT

© SII Group | SII Internal Use

Example (1): Suggesting

You are a Business Manager at a company within the SII Group

A well-known company in the digital sector (Numerix) launches a call for tenders for a major contract worth several thousand euros over three years. You are participating in this tender, and one of your sales representatives suggests offering a "GOLD Package" to one of the decision-makers at Numerix to attend the CES Congress in Las Vegas. This package includes a business class flight and accommodation in a 5-star hotel, with the aim of increasing SII Group’s chances of winning the contract.

© SII Group | SII Internal Use

Example (1): Suggesting

What should you do?

You explain to your sales colleague that such a practice would constitute a case of corruption and is contrary to the SII Group’s integrity rules.

You invite your sales colleague to consult the SII Group’s anti-corruption Code of Conduct, in order to always follow the business conduct rules it sets out.

© SII Group | SII Internal Use

Example (2) - Accepting the offer

You work in the IT Department

For several years, you have been purchasing computers for the SII Group from a supplier you are satisfied with. One day, your manager asks you to compare different suppliers in order to identify potential cost savings.

You inform your supplier about this initiative and invite them to take part in the tender process. The supplier then invites you to a VIP hospitality event at a sports venue. During the event, they emphasize their long-standing relationship with the SII Group and the trust between you. They then make you an offer: in exchange for an all-expenses-paid leisure trip for you and your family, they ask you to share a copy of the lowest bid so they can match the price.

© SII Group | SII Internal Use

Example (2) - Accepting the offer

© SII Group | SII Internal Use

Example (2) - Accepting the offer

What should you do?

Refuse gifts and invitations during tender processes.

You may communicate your expectations to your suppliers, but you must refuse to share competitors’ data.

© SII Group | SII Internal Use

Summary

Ask yourself the following questions before making any decision:

Could the offer influence a choice or decision, either for me or for someone else?

OBJECTIVITY

If my decision were made public, would I feel comfortable explaining and justifying it?

TRANSPARENCY

If I were the one facing the consequences of my decision, would I still consider it the right one?

RECIPROCITY

Somos seres visuales

Could my decision serve as a positive example in a similar situation?

LEADING BY EXAMPLE

© SII Group | SII Internal Use

Be careful, it's not over yet!
The next module is a Quiz

To access the next course, click on "Exit course" and then on continue.

To access the next course, click on "Exit course" and then on continue.

100%

Be careful, it's not over yet!
The next module is a Quiz

To access the next course, click on exit the course and then on continue.

To access the next course, click on exit the course and then on continue.

100%

1. Legal Framework

2. Definitions

3. SII Group Ethics Policy

4. Main Forms of Corruption

5. Examples

"At SII Poland, we act with honesty and integrity."

1. Legal Framework

2. Definitions

3. SII Group Ethics Policy

4. Main Forms of Corruption

5. Examples

1. Legal Framework

2. Definitions

3. SII Group Ethics Policy

4. Main Forms of Corruption

5. Examples

1. Legal Framework

2. Definitions

3. SII Group Ethics Policy

4. Main Forms of Corruption

5. Examples

The legal framework consists of both national and international regulations. The Sapin II Law, adopted in 2016, requires companies such as SII to implement an anti-corruption prevention system and a whistleblowing mechanism. At the international level, as a signatory to the United Nations Global Compact, SII is committed to upholding its principles, particularly Principle 10, which calls on businesses to work against corruption in all its forms. This commitment also falls within the broader scope of the United Nations Convention against Corruption, which encourages the implementation of effective measures to prevent and combat corruption. Accordingly, SII takes a proactive approach by integrating awareness and prevention actions to ensure ethical and responsible business practices.

Monitor regulatory and case law developments. Ensure the SII Group’s Ethics Policy is effectively disseminated across all entities. Oversee the implementation of the Ethics Policy (e.g., Gifts and Hospitality Policy). Support subsidiaries in complying with ethical principles and implementing the Ethics Policy. Ensure that employees are aware of the ethics-related documentation. Review and handle reports submitted by employees, contractors, or other stakeholders, in conditions that ensure confidentiality.

Influence peddling

Undue advantage

Intermediary

Beneficiary

Decision maker

Favorable decision

"We firmly believe that a well-functioning economy relies on fair exchange within a framework of free competition, and we strongly uphold all laws designed to ensure compliance with competition rules."

Imagine you work in the IT Department. For several years, you have been purchasing computers for the SII Group from a supplier you are satisfied with. One day, your manager asks you to compare several suppliers in order to assess potential cost savings. You inform your long-standing supplier about the initiative and invite them to take part in the tender process. The supplier then invites you to a VIP hospitality event at a sports venue. During the event, they express their strong commitment to the SII Group and highlight the trust you have built over time. They then make you an offer: in exchange for an all-expenses-paid leisure trip for you and your family, they ask you to share a copy of the lowest bid so they can match the price. How should you respond?

1. Legal Framework

2. Definitions

3. SII Group Ethics Policy

4. Main Forms of Corruption

5. Examples

1. Legal Framework

2. Definitions

3. SII Group Ethics Policy

4. Main Forms of Corruption

5. Examples

Local Ethics Committees, under the supervision of the Group Ethics Committee, are responsible for handling matters specific to their subsidiary and for:

Monitoring regulatory and case law developments. Ensuring the dissemination of the SII Group’s Ethics Policy. Monitoring the implementation of the Ethics Policy (e.g., the Gifts and Invitations Policy). Ensuring compliance with ethical principles and the implementation of the SII Group’s Ethics Policy. Ensuring that employees are aware of the ethics-related documentation. Reviewing and handling reports submitted by employees, service providers, and other stakeholders within the subsidiaries, under conditions that ensure confidentiality.

"Our professional ethics, a core value of the SII Group, must be reflected in all our interactions — whether with colleagues or third parties."

Corruption can take many forms, and the individuals involved may use various mechanisms to offer, solicit, or accept undue advantages.The main forms of corruption are:

  • Bribes: This refers to a secret payment made in addition to the price of a transaction, in order to obtain a contract or an advantage. The payment methods are often concealed, for example through fake invoices, fictitious consultancy fees, or payments routed through a third party.
  • Facilitation payments: These are payments or gifts offered to public officials or individuals with decision-making power to speed up a decision or action to which the person is normally entitled.
  • Misuse of business or social practices: Corruption is disguised through invitations, gifts, sponsorships, or donations. For example: an all-expenses-paid vacation offered to a sales representative under the pretext of a business trip, or a payment made for the benefit of an intermediary.
  • Favoritism: Appointing someone to a position not based on competence, but due to personal ties (friendship or family), in exchange for a favorable decision.

Anti-corruption training is essential to ensure compliance with applicable regulations, which require companies to prevent corruption—particularly by raising employee awareness. It enables everyone to understand what corruption is, to identify associated risks, and to adopt the right reflexes in business conduct. Beyond legal obligations, this training strengthens the ethical culture within the SII Group and helps foster a climate of trust, both among employees and with external stakeholders.

1. Legal Framework

2. Definitions

3. SII Group Ethics Policy

4. Main Forms of Corruption

5. Examples

"Business ethics is not optional — it is a daily commitment. In a complex international environment, it is our ethical compass, guiding our decisions, strengthening partner trust, and ensuring the long-term sustainability of our growth."

1. Legal Framework

2. Definitions

3. SII Group Ethics Policy

4. Main Forms of Corruption

5. Examples

"The professional relationships we build and maintain with our clients and suppliers always uphold the integrity of those business relationships."

1. Legal Framework

2. Definitions

3. SII Group Ethics Policy

4. Main Forms of Corruption

5. Examples

1. Legal Framework

2. Definitions

3. SII Group Ethics Policy

4. Main Forms of Corruption

5. Examples

How to act with integrity? Ask yourself the following questions before making any decision:

  • Could the offer influence a choice or decision, either for me or for someone else?
  • If my decision were made public, would I feel comfortable explaining and justifying it?
  • If I were the one facing the consequences of my decision, would I still consider it the right one?
  • Could my decision serve as a positive example in a similar situation?

The fight against corruption and fraud, along with integrity and loyalty in our relationships with third parties, are part of the ethical commitments on which the SII Group bases its business conduct.

"We select our partners independently, based on clear criteria: quality of service, professionalism, and fair pricing. No other consideration guides our choices — ethics is our compass."

1. Legal Framework

2. Definitions

3. SII Group Ethics Policy

4. Main Forms of Corruption

5. Examples

The act of offering, promising, or giving a benefit in exchange for the performance or non-performance of an act by a person holding a position of responsibility.

Active corruption

Corruptor

Corrupted person

The act of soliciting or accepting an undue advantage by a person holding a position, in exchange for performing or refraining from performing an act related to their duties.

Passive Corruption

1. Legal Framework

2. Definitions

3. SII Group Ethics Policy

4. Main Forms of Corruption

5. Examples

1. Legal Framework

2. Definitions

3. SII Group Ethics Policy

4. Main Forms of Corruption

5. Examples