Modern Slavery Act 2021
This statement is made in accordance with section 54 of the Modern Slavery Act 2015, on behalf of the Sanofi group of companies operating and carrying on business within the UK (“Sanofi UK”).
It sets out the steps we have taken to ensure there is no modern slavery or human trafficking within our business and supply chains.
Sanofi UK’s Structure, Business and Supply Chains
Sanofi UK is part of a global biopharmaceutical company focused on human health and dedicated to supporting people through their health challenges. We prevent illness with vaccines, provide innovative treatments to fight pain and ease suffering. We stand by the few who suffer from rare diseases and the millions with long-term chronic conditions.
With more than 100,000 people in 100 countries, Sanofi is transforming scientific innovation into healthcare solutions around the globe.
Sanofi UK is organised into four business units: General Medicines including diabetes, cardiovascular and our established medicines; Vaccines; Speciality Care, including immunology, neurology and multiple sclerosis, oncology, and rare blood disorders and diseases; and Consumer Healthcare.
We ensure the way we contribute to improving health is one which is both sustainable and responsible. We are convinced that each of us has an obligation to leave the world a better place for the next generation.
Corporate Social Responsibility (“CSR”) is built into our corporate strategy and the CSR function is responsible for managing and integrating our New Contract with Society at every level of the company – locally, regionally, and globally. Beyond the coordination, sustainability is fully embedded in our CSR strategy through four flagship programmes; affordable access to our medicines, R&D for unmet needs enabling the support of vulnerable communities, efficiency & sustainability through our commitment toward a healthy planet and working on a more inclusive workplace.
Sanofi UK consists of the following Sanofi companies operating and carrying on business within the UK:
- AVENTIS PHARMA LIMITED
- GENZYME LIMITED
Sanofi UK is integrated into a global supply chain involved in the manufacturing of active pharmaceutical ingredients, finished goods, devices and packaging through a global network of manufacturing sites and distribution centres. This network includes the procurement of goods and services from a large number of external contractors.
Sanofi UK understands the global challenges related to slavery and human trafficking and works to ensure that this is not present in any part of our business, including all suppliers and the supply chain.
Sanofi UK is required to comply with all Sanofi policies including our Code of Ethics which outline our commitment to complying with national laws and regulations in the areas of human rights and labour law. In particular:
- Respect for the Individual – fostering a workplace environment for our partners where personal dignity is respected;
- Fighting Bribery and Corruption – committing to fighting all forms or corruption;
- Security in dealings with contractors – ensuring that our contractors adhere to the fundamental principles of the International Labour Organisation, in particular those relating to child labour, working hours, pay, freedom of expression and equality of opportunity; and
- Compliance Helpline - aimed principally at our employees but also available to others working in our supply chains which encourages employees to report any wrongdoing which extends to human rights violations. Any reports are fully investigated and appropriate remedial actions taken.
The applicable Sanofi policies confirm that we will not tolerate or condone abuse of human rights within any part of our business or supply chains.
Sanofi UK Employees
All employees who work for Sanofi UK are background checked, having their identity, qualifications and previous work history verified as a condition of employment. We abide by the requirements of the UK Border Agency and verify employees’ right to live and work in the UK. Regular audits are made of employees who have only a temporary right to remain.
Sanofi ensures that all employees are paid at minimum in accordance with National Minimum Wage legislation.
Sanofi UK Suppliers
Sanofi UK conducts due diligence on its suppliers. The standard Request for Proposals used by Sanofi UK attaches the Sanofi Suppliers Code of Conduct as well as a questionnaire that includes enquiries pertaining to potential suppliers’ economic, social and environmental performance and a statement advising potential suppliers that they are expected to be compliant with the Sanofi Supplier Code of Conduct (which includes adherence to the fundamental principles of the International Labor Organization such as prohibitions on child and forced labour). In addition, Sanofi’s UK’s Standard Services Agreement that may be provided to potential suppliers includes a warranty from such potential supplier that it will carry out any services in full compliance with (and ensure that all its personnel comply with) all applicable legislation, regulations, codes of practice, guidance notes and other requirements of any relevant government or governmental agency as these may be amended, implemented, modified or supplemented from time to time. In each case Sanofi UK reserves the right to audit to ensure compliance to our high standards on quality and ethical behaviour.
Sanofi UK assesses the extent to which its supplier can be considered a business or procurement risk. This assessment depends on various factors including, for example, the nature of the goods and/or services supplied and/or their country of origin). Suppliers who fall into the business or procurement risk category can be asked to complete specific supplier assessment questionnaires. The questionnaires include enquiries pertaining to the suppliers’ economic, social and environmental performance, including questions aimed at ensuring respect for human rights. Depending on the response to the questionnaire, representatives of Sanofi may ask the suppliers for more information and their participation in a face-to-face interview. Additionally, based on the quality of the responses, Sanofi may choose to conduct a third party supplier audit. In cases where potential issues as to particular suppliers have been identified, the company has taken appropriate action dependent on the circumstances presented, including, for example, working with the supplier to develop an improvement plan, or declining to continue the supplier relationship. In addition, Sanofi UK conducts continued monitoring of new supplier creation requests including the re-assessment of existing suppliers.
Review of Performance
An overview of Sanofi UK’s effectiveness in preventing and detecting non-compliance with local laws and regulations and violations of its Code of Ethics (including breaches of human rights such as forced labour and human trafficking) is presented at the UK Ethics & Business Integrity Committee held three times a year. Results in the areas of investigations (including those arising from reports received via the Compliance Helpline), due diligence on third parties and training have been discussed with the local management team and the appropriate remedial actions taken.
Training and Capacity Building
As part of their employment conditions, all Sanofi UK employees must agree to uphold Sanofi’s Code of Ethics and training is provided as part of on-boarding and throughout employment on topics relating to business ethics.
On an annual basis ethical topics for training purposes are identified by the Executive Compliance Committee. Such requirements are cascaded through Sanofi for active participation by all Sanofi personnel. Such topics have included fighting bribery and corruption, conflicts of interest and ethical decision-making.
For more information, please visit our homepage at www.sanofi.co.uk
Director & General Manager Sanofi UK
Director & CFO Sanofi UK
Job bag number MAT-GB-2102428(v1.0)
Date of Preparation June 2021