Ethics & Business Integrity

The E&BI department operates globally under the Global Compliance Officer with teams at corporate, regional, and local levels. It consists of:

Global Teams:

• Global Operations: Manages Code of Conduct, Learning and training, Culture of Ethics & Engagement, and Digital transformation and data analytics, Organizational justice & Smart Assurance, Ethics for Society and Responsible Innovation.
• Organizational Justice & Smart Assurance: Handles anti-fraud programs and investigations.
• Third-Party Risk Management.
• Compliance Business Partners: Support business units in implementing ethical standards

Regional & Local Structure:

• Regional Compliance Officers ensure consistency across countries.
• Approximately 90 country level leaders responsible for implementing core E&BI programs locally.
• Over 2000 "E&BI Champions" serve as ambassadors promoting ethical culture.

Specialized Ethics Domains:

• Data Privacy: Led by Chief Data Privacy Officer with global and local officers.
• Bioethics: Governance continuously enhanced to reflect evolving stakeholder expectations, reinforce patient-centricity and promote transparency. This includes regular reviews and updates to ensure ethical alignment in biomedical innovation and research.

Sanofi’s Code of Conduct applies to all employees and business partners, guiding behaviours and ensuring high ethical standards.

Sanofi adheres to international rules and contributes to cross-industry initiatives to promote business integrity and governance. Sanofi also prohibits any conduct that may negatively affect a person’s dignity. Sanofi does not condone or support any form of harassment (physical, sexual, psychological, verbal or any other form) or discrimination. These behaviours are fundamentally incompatible with our core values and are subject to a zero-tolerance approach across all our operations globally, as defined in our Concerns Management global operating procedure.

Sanofi has a zero-tolerance for bribery and corruption. The company has implemented comprehensive principles and procedures to prevent corruption in interactions with business partners. This includes risk-based due diligence and monitoring of business partners to ensure compliance with ethical standards.

Sanofi engages with various business partners, including suppliers, customers, and third-party intermediaries, expecting them to uphold the highest ethical standards. The company conducts risk-based anti-bribery due diligence on partners before and during engagements, using criteria such as the third party’s business profile and the nature of their business. Any potential issues identified are reviewed and assessed to determine if a risk mitigation plan is needed, including termination if required.

Sanofi ensures that no value is exchanged to influence behavior or decisions, particularly involving healthcare professionals, patient organizations, government officials, and state organizations.

Sanofi provides annual, mandatory compliance training for all employees. Non-completion of global compliance learning modules negatively impacts bonus payouts. New employees are assigned a global compliance learning curriculum as part of their onboarding program.

Prior to joining Sanofi, contractors are trained by their company on its own compliance program as part of its contractual obligations with Sanofi. They receive a copy of the Sanofi Code of Conduct and are being made aware of the existence of our 24/7 whistleblowing helpline (in local language). In addition, the manager receiving a contractor on his/her team ensures proper training on all operational procedures the contractor needs to master to execute their tasks in compliance with Sanofi’s principles and procedures.

In 2024, 81,058 Sanofi employees completed at least one global compliance learning module for a total of 411,419 modules completed.

We promote “Speak Up” and communication between employees, managers, and customers. Allowing for a better understanding of the issues and concerns of all stakeholders. Outside the United States, a secured compliance helpline is available 24/7 with a dedicated web page and a toll-free number offering 28 languages for ex-US Sanofi employees. In the United States, a dedicated toll-free external compliance helpline has been set up for Sanofi employees in accordance with local regulations and practices. These helplines are operated by an independent third party. Any Sanofi employee can report breaches to the Code of Ethics and/or any concern about potential wrongdoings.

A new helpline platform was implemented in 2023 to streamline investigations and improve reporting processes. All reports are investigated confidentially, and corrective actions are taken if necessary.

Employees who raised concerns will not be subject to discipline or discrimination, if they act in good faith and with no malicious intent, even if the facts reported prove to be inaccurate or no further action is taken. Sanofi permits anonymous reporting, but anonymity is subject to local law reporting provisions.

It is important to note that the use of our compliance helplines is clearly described in the Code of Conduct. All Sanofi employees, contractors and everyone conducting business on behalf of Sanofi do receive a copy of our Code of Conduct.

In 2024, the E&BI department received 900 alerts. A total of 396 cases were substantiated and resulted in 141 dismissals or resignations related to misconduct. Other corrective actions were also implemented as per Sanofi’s Corrective & Disciplinary Actions policy, such as additional training, process improvement steps, remuneration impacts, and verbal or written warnings.

AI holds immense promise in our industry. We recognize the importance of exploring this in a responsible manner to balance innovation with the right level of risk management. To address these concerns, we have defined and implemented a robust Responsible AI governance and accountability framework to drive responsibility across the entire AI lifecycle, from design through use, and adopted a thoughtful risk-taking approach to bring it to life.

Responsible AI at Sanofi is guided by five key principles:

• Accountable to outcomes
• Fair & Ethical
• Robust & Safe
• Transparent & Explainable
• Eco-Responsible

To mitigate risks, Sanofi employs a risk-based approach to AI regulation. Our approach includes the thorough assessment of AI risk through our Sanofi AI Risk Assessment procedures, the identification of appropriate controls depending on assigned risk level, and governance to oversee the assignment, execution and enforcement of controls.