Supplier Code of Conduct
Our focus on responsible procurement is underpinned by our Supplier Code of Conduct to which all (100%) of our suppliers are required to agree to as part of their onboarding in our Third Party Risk Management system. Accordingly, they are expected to comply with:
- Labor regulations — adherence to regulations against child labor, forced labor, violence and discrimination, as per the ILO fundamental conventions;
- Working conditions — provision of decent working conditions that include reasonable working hours, fair wages and benefits, and freedom of association;
- Health & Safety — ensuring the protection of workers' health and safety, providing training and information on hazards as well as emergency preparedness arrangements; and,
- Environment — regulatory compliance, mitigating climate change, minimizing environmental releases, reducing energy and water usage and protecting biodiversity.
The Supplier Code of Conduct is incorporated into our electronic ordering systems and is also referenced in both the global procurement policy and global procurement operating standard. During onboarding, suppliers must acknowledge and agree to comply with our Supplier Code of Conduct.
Supplier Selection and Onboarding
Since 2022, all new suppliers bidding for Sanofi tenders must undergo a compulsory sustainability assessment (ESGiT), which includes questions on human rights and environmental policies. The assessment represents up to 20% of a supplier’s scorecard in the tender process. Suppliers that don’t have explicit measures against forced labor, child labor and discrimination are monitored carefully. Suppliers evaluated as high-risk by the ESGiT tool are asked to commit to undergoing a third-party assessment if not already in place.
As part of their onboarding process, suppliers considered risky from a sustainability standpoint are systematically requested to complete a dedicated third-party assessment with our company specific risk experts to determine action plans to remediate the risky vendor and or blockage of the vendor for use within Sanofi prior to being activated into the Sanofi systems.
Supplier Risk Mapping
We profile each supplier by domain, subcategory, and country in alignment with our legal and risk expert teams. We analyze subcategories to identify inherent risks by country, supplier profile and economic indicator. This profiling helps us detect risks before fully onboarding a supplier for use in the Sanofi system and triggers additional assessments in third-party tools or with risk experts to assist in addressing potential issues, allowing a positive and measurable impact on value chain workers linked to our suppliers.
The above process aims to ensure that human rights and health & safety risks are reviewed for all procurement sub-categories. Suppliers are assessed based on inherent risks related to health & safety, the environment, and human rights as defined below:
-
health & safety — number of people affected and severity of consequences;
-
environment — extent of the negative consequences (pollution, use of natural resources), communities and biodiversity (whether or not limited to the site), and their irreversibility; and
-
human rights — workforce characteristics (qualification level, number, temporary or permanent status) and sector-specific labor rights risks. Sustainability Statement
An internal compound rating, found in the subcategory risk matrix, identifies 47 procurement subcategories as high-risk. Specific management practices are applied to suppliers in these 47 subcategories based on their classification through audits or third-party risk assessments.
Supplier Assessment
We have established a risk-based approach, focusing assessments on the high-risk categories identified in the subcategory risk matrix defined above. Our buyers and risk experts can also recommend ad hoc assessments based on the information captured in the general questionnaire during onboarding.
The assessment must be completed upon supplier onboarding and renewed at least every three years. This assessment covers the following areas:
- environment
- labor practices and human rights
- fair business practices
- responsible supply chain
Suppliers with poor performance are requested to implement corrective action plans. In case of significant and/or non-remediated deviations, Procurement may decide to conduct on-site audits or terminate the relationship.
Supplier Audits
Supplier audits, focusing primarily on Health, Safety and Environment (HSE) performance and labor rights issues, where relevant, are conducted by our HSE function or external auditors.
In 2024, we focused on essential and antibiotics suppliers, continuing audits of high-risk API providers and contract manufacturing organizations.
Sanofi can take actions such as contract termination if an audit reveals critical non-compliance. Action plans following an audit are verified through re-assessment or specific follow-up audits. Between 2020 and the end of 2025, Sanofi removed 82% of third parties creating potential HSE risks. By discontinuing business partnerships, and through performance improvement plans, the number of Sanofi suppliers/CMOs ranked critical decreased from 129 to only 27. All 27 remaining third parties are subject to continuous specific monitoring and improvement plans.
References
- In 2024, revised evaluation rules resulted in assessments being triggered at local company level rather than at parent company level. This has led to a significant increase in assessment numbers.
- Includes PSCI shared audits