Welcome back to the podcast, bribes, swindle, or steel. I'm Alexander Ragi. Today I'm speaking with Olivier

Caterine. Olivier has both French and American law degrees and has been the Group General

Council of Sonapar in Paris since April of last year. Sonapar, of course, is an electrical

equipment distribution company and was the first company audited by the French Anti-Corruption

Agency, the AFA, under the 2016 Sapins de Law. Olivier, thank you for joining me.

Oh, it's a pleasure. Perhaps you can begin by describing the AFA investigation into Sona Part, leading up to

the July 4th decision by the Sanctions Committee.

I think it's still new enough that a lot of listeners won't be familiar with it.

The Sapins-Due law is quite recent.

It was enacted in late 2016 and actually it became effective as of June 1st, 2017.

And actually, Sonepa was one of the first, you know, six companies ever to be audited by the AFA.

And this is what we call in France the first wave that actually started in mid-October 2017. So it's very important to note

because it means that these first audits started just a few months after the effective date

of the Sapins de Law. So that was a key challenge for all those six entities, including

of course, Sunniper. How do companies learn of these audits?

How does the process unfold?

You receive a letter from the AFA director, and that informs you that the audit is actually starting,

and you only have two weeks to provide a lot of documents.

And the good thing is that since pretty much early

2018, the standard questionnaire used by the AFA is available on site on the website of the

AFA. So that helps companies these days to actually prepare for the audit. But the main challenge,

you know, in terms of logistics, I should say, that actually Sonepaar faced, you know, back in the fall 2017, is that this standard questionnaire was not available.

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