Sapin 2 Act – Prevention of corruption


The Sapin 2 Act (2016) requires companies to implement eight measures and procedures to prevent corruption. The aim of these measures and procedures is to form a prevention system of corruption within companies, that’s why Nexity established internal and external warning to report unethical behaviour, with:

  • a Code of Conduct, reminding the legal and ethical framework of the Group. The Code of Conduct was updated in 2018 and disseminated to all employees;
  • a Whistleblowing procedure, The whistleblowing procedure provides that any employee who witnesses a situation of non-compliance with the Code of Conduct can notify his line manager or the Compliance Officer using the address provided for this purpose. The whistleblowing procedure is described in the Code of Conduct and on the Group’s intranet. It has been the subject of a number of internal communications to employees. The person using the whistleblowing procedure benefits from the guarantee of confidentiality in doing so and from protection against any discriminatory practice or disciplinary measure for having raised an alert in accordance with the conditions set out in the law.;
  • the risk mapping pertaining to corruption and influence peddling, initiated in 2017, was updated in the fourth quarter of 2019. On that occasion, the scope of the concerned subsidiaries was broadened. Based on interviews with the executives of the subsidiaries, it led to an update of the risks of corruption and influence peddling.
  • a Supplier Ethics charter, stating the values that Nexity’s suppliers and providers must respect. Since 2018, this charter is signed when entering into contracts with our service providers.


Duty of care – Risk identification and prevention (environment, liberties, health and safety)


The Duty of care Act (2017) recommends the implementation of a duty of care plan in order to identify and prevent the risks of serious damage to the environment, fundamental liberties, and the health and safety of individuals that may result from the activities of the Group, its subsidiaries and its service providers.

In response to this obligation, Nexity has undertaken the risks identification and evaluation and takes into account their frequency and severity, as well as the associated control procedures.

Nexity believes that the risks are limited. The Group’s activities are mainly based in France (just 2% of revenue 2018 was generated in other countries - Belgium, Italy, Switzerland and Poland).



The identification of risks and control measures put in place for this duty of care plan enabled Nexity to identify areas for improvement. The 2018-2020 multi-year internal audit plan provides for verification that action plans have been implemented effectively.


>> For more information, refer to pages 101 to 106 of the Universal Registration Document.