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Responding department: Excellence in CSR Direction

Stock Exchange Symbol: (SAN:FP)

Does your company have a publicly available commitment to respect human rights?

Yes,

A stand-alone "human rights policy": [link] Using a collaborative and sectorial approach targeted at human rights in the pharmaceutical industry and in the workplace, in 2013 the Group produced a guide, Human Rights in our Activities, to provide a practical tool that reflects the reality of our day-to-day business activity. This guide includes the SANOFI HUMAN RIGHTS STATEMENT, from Gilles Lhernould page 3, and SANOFI’S COMMITMENT TO HUMAN RIGHTS, page 5. Because Sanofi’s core business is the development and commercialization of medicines and vaccines, we have designed this guide to follow the four steps in the life cycle of a drug, listing the key human rights principles expected from stakeholders and illustrations of best practice along the way. This document also includes a section dedicated to human rights at work across various functions, which outlines the best practices a responsible employer should put in place all along the value chain.

Please find the link to: Our Human Rights Guide: [link] and especially the SANOFI HUMAN RIGHTS STATEMENT, from Gilles Lhernould page 3, and SANOFI’S COMMITMENT TO HUMAN RIGHTS, page 5. Our Human Rights Mini Site: [link] Our Human Rights Fact Sheet for more information: [link] 

Also, concerning our commitment to the Global Compact, please find the direct link to our 2014 Communication on Progress report in the download center: [link]

Please also find the link to: The Sanofi Code of Ethics: [link]

The Sanofi Social Charter: [link] 

The Sanofi Suppliers Code of Conduct: [link]

How are human rights governed in your company?

- How are human rights governed in your company?

Our commitment to respect human rights is the foundation of our CSR approach. It provides Sanofi with an inspirational framework and guide for analysis and action towards continuous improvement. We are committed to following this approach because we are convinced that the principles of human rights apply to people, to nations and, by extension, to businesses. In particular, we support each person’s fundamental human right to health, through our daily efforts to improve access to healthcare for patients everywhere.

Corporate Social Responsibility is embedded into Sanofi’s core business strategy, focused on the patient at the center of our activity, or patient centricity. Our ambition is to play a wider role in delivering effective care to patients by innovating and developing patient-oriented solutions, and by seeking to improve business performance and remain global leaders in our sector. Our CSR strategy is built on four key areas: Patient (Improving access to healthcare), Ethics (acting ethically), People (working together) and Planet (preserving the environment).

- Where is the lead responsibility for human rights located, and why?

Ensuring the respect of human rights is currently under the responsibility of our CSR organization as it is a transversal issue that requires coordination and insight.

- Does any board member or board committee have oversight of human rights issues? No, but the Senior Vice-President of CSR, Gilles Lhernould reports directly to the CEO. In addition, the Senior VP CSR is the chairman of the Risk Committee and a member of the Executive Compliance Committee, the Bioethics Committee, and the France Strategic Committee. The CSR perspective is thus represented on three of five strategic committees that report formally to the CEO. The CSR Direction provides a broad, cross-company view of the risks and opportunities that Sanofi must address, in particular those related to CSR.

- What is the relevance of human rights considerations to the company’s business model and strategy? CSR is strongly embedded into Sanofi’s business strategy and our commitment to respect human rights is the foundation of our CSR approach. Sanofi expressly recognizes the importance of all internationally agreed upon Human rights. However, we grants a heightened attention to the right to health, and all human rights related to, or constitutive of, this right; See answer above

How are human rights managed within your company?

- How are human rights managed within your company?

From pilot programs to robust management systems, Sanofi deploys targeted actions to avoid causing adverse human rights impacts on patients, employees, clinical trial participants, local communities or the general public, and to protect their interests at best in the limit of its leverage and resources. Human rights are an integrated criteria in the design, implementation, monitoring and evaluation of the policies, procedures and actions deployed for each of our CSR priorities.

- How are actual and potential human rights impacts identified and assessed?

Self-assessments are performed and monitored using internal dedicated tools to evaluate in-house practices at global and country levels. Self- assessments have also been conducted by Sanofi since 2007 to evaluate the labour practices of Sanofi suppliers, monitor specific topics linked to Human Rights at work and ensure that the Sanofi Suppliers Code of Conduct rules are respected. In 2012, Sanofi implemented a new Procurement Risk Assessment Model which includes CSR and Human Rights criteria. For more information: Human Rights Fact Sheet: [link]

Sanofi also adopts a proactive strategy for managing risks related to our business. To implement this strategy, and to address all risks we may be exposed to in connection with our activities, we rely on a dedicated risk-management organization, which includes a Risk Committee chaired by the Senior Vice-President of CSR, a Risk Co-ordination Direction that is part of the CSR Direction, and Risk Cocoordinators responsible for risk assessment within their area of responsibility. In 2013 a working group was established, co-ordinated by the Group Risk Management Direction, to provide a risk profile on social and human rights within Sanofi and its suppliers, in order to propose actions plans when relevant and monitor critical risks. For each of the following human rights risks assessed, the analysis will determine its severity (level of impact), its likelihood, and the level of control currently in place at Sanofi.

- What steps are taken to prevent or manage negative human rights impacts?

Firstly the Group defined a reference framework and tools for all our organizations: Sanofi has translated its commitment for Human Rights into internal reference tools and policies, to be considered as the minimum applicable standards should the local regulation be less stringent in any of the Group’s countries of operation such as Code of Ethics, Social Charter and Suppliers Code of Conduct. In addition, Sanofi has set up dedicated management processes and systems such as Quality, HSE, Compliance, Drug Safety Monitoring, Internal Audit & Control and Risk Management) to answer patients’ rights (right to health, right to access to information, etc.), employees’ rights (right to work under equitable conditions, right to freedom from discrimination, etc.) and compliance with all internal reference tools and policies in place. In addition, since 2006, a warning system has been in place to allow early detection and handling of non-compliant behaviors. Trainings and self-assessments are also conducted to prevent or manage negative human rights impact (see more detail below)

-How is the importance of human rights signalled to business partners?

The supplier’s code of conduct was developed to ensure that all suppliers are aware of the Group’s CSR principles. Based on the Global Compact, ILO Conventions and our own Code of Ethics, it sets out the standards to apply with respect to human rights and labor practices, health and safety, the environment and the ethics;

- What training is conducted for staff and business partners?

To prevent negative human rights impacts, senior executives and heads of a range of functions at Sanofi have attended training sessions on Human Rights tailored specifically to the pharmaceutical industry. In addition, in order to bring HR issues to the attention of as many employees as possible, the Human Rights guide will gradually deployed in all Sanofi organizations, at both corporate and local level. Since 2010, more than 100 managers and senior executives representing more than 25 functions have participated in a one-day training session on human rights in the workplace, organised with the support of outside experts

- How does the company track the effectiveness of its actions on human rights?

To manage negative human rights impacts identified, the recommendations made by the working group will be evaluated in 2014 by the Group Risk Committee, for further implementation of relevant actions. Other measures taken to track the effectiveness of our actions are the Number of training participants, the human rights guide deployment and follow-up of actions plans.

What is the company’s approach to the engagement of stakeholders (including workers, and local communities impacted by the company’s activities), on human rights issues?

Representatives from all areas of our business interact on an ongoing basis with stakeholders from many different walks of life. Our Research & Development (R&D) and industrial activities, corporate functions and marketing teams all engage stakeholders, particularly in the healthcare field, for numerous projects through dedicated Sanofi organizations. The CSR listen to their concerns and expectations and solicit their input to develop our CSR strategy and action plans. In our relations with stakeholders, Sanofi seek to involve them to varying degrees – from simply monitoring actions and targeting messages to soliciting their feedback. The highest degree of involvement consists of partnering with stakeholders to pursue common objectives, which creates the greatest value for businesses. To develop a deeper understanding of the challenges and expectations of patients, healthcare professionals, policy makers, NGOs, communities and many others, Sanofi seeks to maintain close relations with our stakeholders. In addition, the human rights guide was developed in a bottom-up and collaborative approach managed by the CSR Excellence. In order to take into account the extent and nature of Human Rights issues faced by Sanofi, this document was built in two steps using a cross-functional and participative approach including 37 representatives from more than 12 internal functions. This human rights guide was developed to follow the four steps in the life cycle of a drug and the human right at work, lists the key human rights principles and taking into account the expectations from various internal and external stakeholders.

For more information, please find the link to our human rights guide: [link]

Priority human rights issues: What are some of the priority human rights issues for your company?

The company selected the following from a check list:

  • Health (including environmental health, workplace health & safety)
  • Workplace diversity / non-discrimination
  • Forced labour and human trafficking (including in supply chains)
  • Freedom of association and trade union rights
  • Transparency in payments to governments / responsible tax practices
  • Product Misuse
  • Women
  • Children (including child labour)
  • Other Issues

Actions on 'other' issues

Sanofi grants a heightened attention to:

- The right to health, and all human rights related to, or constitutive of, this right;

- The whole spectrum of human rights of patients and clinical trial participants, going beyond access to healthcare to encompass for instance the right to access information or the right to privacy;

- Human Rights at work, whether for Sanofi employees or those of the Group’s suppliers

- In line with the United Nations Guiding Principles, Sanofi pays a particular attention to the rights and needs of, as well as the challenges faced by, groups or populations that may be at heightened risk of becoming vulnerable or marginalized.

- Children’s health is an important recognized business and CSR priority for the Group: our “Healthy children, happy children” program aims to offer children the most innovative and adapted medicines and to improve access to these products worldwide, especially in emerging countries;

- Sanofi is engaged in several programs aiming at strengthening patient care in mental illness in emerging countries, where inadequate medical resources and stigma contribute to the neglect of these patients. Sanofi has set up tailored programs based on collaborations with stakeholders from different sectors, efforts to combat stigmatization by educating communities, training front-line healthcare professionals in diagnosis and treatment, and tiered pricing policy.

How are human rights commitments and information about how the company addresses its human rights impacts communicated, internally and externally?

Sanofi communicates its human rights performance through the intranet with the support of the Communication Direction and our CSR Reports. Through the support of the Communication Direction, the Human Rights guide and a minisite was published and made available to all Sanofi employees in the end of 2013. In 2014, the Communication Direction published the Business and Human Rights video, which was elaborated with the support of the Global Compact France and translated by the Association Entreprises pour les Droits de l’Homme, where Sanofi is a founding member alongside eight other French International Groups. Within the scope of the Global Compact commitment, the Group is required to issue an annual Communication on Progress (COP), which is signed by the Senior VP of CSR and the CEO, to report the Group’s progress in human rights to the Secretary-General of the United Nations. In addition, the Group discloses the performance indicators on human rights, including those developed by the Global Reporting Initiative (GRI), through our CSR reports. Tracking performance on human rights is also communicated with regard to the value chain and other business partners in responsible procurement.

Please find the link to: Our 2013 CSR Report, page 8: [link]

Our 2013 Doc de Ref translated in English- page 36: [link] 

Our Human Rights Guide:[link] and especially the SANOFI HUMAN RIGHTS STATEMENT, from Gilles Lhernould page 3, and SANOFI’S COMMITMENT TO HUMAN RIGHTS, page 5.

Our Human Rights Mini Site: [link]

Our Human Rights Fact Sheet for more information: [link]

Also, concerning our commitment to the Global Compact, please find the direct link to our 2014 Communication on Progress report in the download center: [link]

What provisions does your company have in place to ensure that grievances from workers and affected communities or individuals are heard, and can you provide examples of remedies provided?

Regarding our Code of Ethics, a warning system has been in place to allow early detection and handing of noncompliant behaviors since 2006; the Code of Ethics invites employees to inform their superior of any concerns regarding possible illegal practices, ethical or human rights violations if they believe in good faith that a rule or one of the principles laid down in the Code of Ethics has been or is about to be violated.

Which external and collaborative human rights initiatives does your company participate in, and what is the nature of your involvement?

Sanofi is proud to be a founding member of EDH, a not-for-profit association launched in 2003 to provide companies with practical solutions for implementing the Universal Declaration of Human Rights in business. It is inspired by the work of BLIHR. Current EDH members include international groups and CAC40 companies such as BNP Paribas, Casino, EDF, Lafarge, Orange, STMicroelectronics, and GDF SUEZ, which together represent over one million employees. As a member of EDH, in 2013 Sanofi participated in the development of several tools, including:

  • a guide to help managers understand human rights due diligence, as set out in the UN Guiding Principles by John Ruggie, UN Special Representative on Business and Human Rights; and
  • an e-learning module on business for human rights
  • a Business and Human Rights video, which was elaborated with the support of the Global Compact France and translated by the Association EDH: [link] In addition, we work with other pharmaceutical companies to improve global health outcomes and address the right to health. The guiding principles on Access to Healthcare were developed by BSR’s Healthcare Working Group and have secured signatures from the CEOs of 13 companies, including Sanofi. These guiding principles provide the framework for working together to develop new approaches to expanding access to healthcare together. For more information: www.bsr.org

Which are the key one, two or three elements of your approach to human rights that been developed or amended since June 2011? Please indicate if these actions were in response to the UN Guiding Principles.

Since June 2011 we developed our Human Rights Guide to bring human rights issues to the attention of as many employees as possible and to be in line with the UN Guiding Principles on business and human rights. This guide was developed to be a valuable tool for all Sanofi managers as we make progress towards the goal of ensuring that human rights are soundly integrated into all our operations worldwide.

What are some of the obstacles and challenges that your company encounters in implementing its human rights commitments?

Among the obstacles disclosed to implement our human rights commitments we can note that this subject remains a complex issue: The huge number of topics makes priorisation essential yet existing guidance is poor. The link with CSR is hard to communicate internally. Implementing the human rights approach especially along political and social rights is a challenge in somes geographies.