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. The Code is structured around 16 fundamental principles that guide employees in their daily work and interactions with all stakeholders. 

In 2025, the Code was updated to include a new chapter on Health & Safety, introducing programs that foster a proactive safety culture for everyone, everywhere, every day. Updated chapters also reflect Sanofi's strengthened commitments to inclusion, sustainability, and intellectual property protection. 

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 behaviors 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’s anti-corruption program is a global, risk-based compliance framework embedded within its Ethics & Business Integrity (E&BI) system, designed to prevent, detect, and remediate bribery and corruption across all operations. The program is anchored in the Code of Conduct and applies to all employees as well as third parties acting on Sanofi’s behalf. It is structured around three core pillars:  

1. Prevention: through clear policies, mandatory training, risk assessments, and third-party due diligence,  

2. Detection: through monitoring, audits, data analytics, and speak‑up channels, and 

3. Remediation: through investigations, disciplinary measures, and continuous improvement of controls.  

The program targets key risk areas such as interactions with healthcare professionals, gifts and hospitality, donations, public sector engagement, procurement, and third-party relationships, and reflects a zero‑tolerance approach to bribery and corruption. 

A core component of this framework is the management of conflicts of interest, which are recognized as a significant corruption risk. Employees and third parties are required to avoid, disclose, and properly manage any actual, potential, or perceived conflicts to ensure objectivity, transparency, and decisions made in the best interest of the company.  

At its core, the program is supported by strong governance, leadership commitment, and a culture of integrity and transparency, reinforced through training, communication, and accountability. Sanofi explicitly prohibits offering, promising, or giving anything of value to improperly influence decisions or obtain an unfair business advantage, ensuring alignment with global anti-corruption laws and the protection of patient trust and corporate reputation.  

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 2025, 74,295 Sanofi employees completed at least one global compliance learning module, and a total of 486,416 modules were 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, we have a secured compliance helpline, available 24/7 and in 27 languages, with a dedicated web page. The helpline is operated by an independent third party. 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.

All Sanofi employees, contractors, and third parties conducting business on behalf of Sanofi receive a copy of the Code of Conduct, which clearly outlines the use of the Speak Up helpline. 

In 2025, the E&BI department received 1095 alerts. A total of 333 cases were substantiated and resulted in 201 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.