This post was written by Daniel Kadar.

A significant difference between the French and U.S. and UK legal systems is in the understanding of legal privilege: it does not exist for in-house counsel in France. The French approach is in line with the 2010 Akzo decision, in which the Grand Chamber of the European Court of Justice (ECJ) ruled that the requirement of independence means the absence of any employment relationship between the lawyer and his client, so that legal professional privilege does not cover exchanges within a company or group with in-house lawyers.

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