Sanofi’s activities are governed by a global procedure on lobbying, updated in 2024 considering the highest international codes and standards and the evolving external transparency requirements. One of the 16 fundamental principles of Sanofi’s Code of Conduct is “Interacting with stakeholders”, which includes all trade associations, public authorities, governments, universities and research.
Our global procedure on Responsible Lobbying and Interaction with Public Officials stipulates that Sanofi must perform lobbying with ethical standards and due consideration of patients, in addition to compliance with Sanofi’s Code of Conduct and with the applicable lobbying and advocacy laws and regulations where Sanofi does business. The key principles of the procedure include (but are not limited to):
-
only Sanofi-authorized employees and consultants may engage in lobbying activities and political interactions on Sanofi’s behalf, and must comply with applicable laws and regulations;
-
lobbying activities are done with the purpose of advancing Sanofi’s interests and are performed with transparency;
-
anti-bribery and due diligence are performed for organizations or third parties (e.g., research institutes or think tanks, paid media) conducting lobbying activities on behalf of Sanofi;
-
in-house or consultant lobbyists that have previously held a public official post must respect cooling-off periods or transition rules imposed by their former organizations;
-
any misalignment with trade associations on topics related to our own social and environmental commitments is publicly announced;
-
lobbying and advocacy activities (including key topics we advocate and the corresponding resources) are reported on an annual basis.
Our lobbying activities are coordinated and driven by our employees working in public affairs in the countries where we operate, with clear accountabilities to the executive committee (CEO and Executive Vice Presidents), and are primarily overseen by the Executive Vice President of Corporate Affairs. Our lobbying activities are mainly focused on innovation, healthcare, access to healthcare and environment. Sanofi is involved in several trade and industry groups that represent the pharmaceutical sector and our business interests. Sanofi closely monitors our engagement with trade associations through our representatives.
Our Actions
Throughout the year, Sanofi's Public Affairs Department maintains a list of employees authorized for lobbying, as well as a list of trade association memberships and members, and provides guidance on contracting consultants for lobbying activities. The department strives to ensure that direct or indirect lobbying activities, are consistent with Sanofi’s social and environmental goals. Sanofi employees authorized to engage with public officials receive mandatory training on the Lobbying global procedure and on relevant global and local policies, as advised by the relevant global or local Public Affairs Department. Additional training, support platforms and enforcement mechanisms may be determined on a case-by-case basis, at global and/or local level. Sanofi is committed to providing timely and complete information to government-led transparency registries or commonly used voluntary databases for lobbying and corporate political contributions.
To enhance transparency and integrity, a risk-based internal control system supports the implementation and monitoring of lobbying activities, including biannual internal audits of public affairs activities.