Sanofi Newsletter Jan-Apr 2021

INDIA EBI Newsletter Jan - Apr 2021

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India Ethics & Business Integrity Newsletter January – April 2021 We are Sanofi Our patients inspire us to pioneer

INDIA EBI Newsletter Jan - Apr 2021

ETHICS & BUSINESS INTEGRITY Building A Culture To Support Our Future Success

Play to Win Responsibly ENCOURAGE stretching, risk taking within the boundaries set by our Principles and Values

INSPIRE instill belief and confidence into teams to win responsibly for the patients

LIFT STANDARDS by encouraging adherence to Code of Ethics, SOPs and its underlying principles

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INDIA EBI Newsletter Jan - Apr 2021

Key communications from EBI & Management in January – April 2021 Year Beginning Message from Ethics & Business Integrity • •

Expressing company’s expectation from all its employees and providing link to key policies Email dated 4th Jan 2021 from Bratin.Bag@Sanofi.com

Inviting employees to submit their Conflict of Interest (COI) disclosures • •

Email dated 1st Mar 2021 from Arjun.Thakkar@sanofi.com Click here to check the awareness video on Yammer

Compliance Helpline and Framework for Corrective and/or Disciplinary Actions •

Email dated 31st March 2021 from Narayanan.Rajaram@sanofi.com

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INDIA EBI Newsletter Jan - Apr 2021

OBJECTIVES In Q4 2020, Sanofi India Management launched Compass with an objective to:

• Reinforce compliance to Sanofi Global policies • Ultimately ensure Sanofi is best-in-class when organizing Events

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WHAT Compass involves an independent third party consultant silently attending Sanofi Events, noting their observations, discussing them with Sanofi Employee organizing the said event, and then submitting the same the report to Sanofi Management, with intent to find areas of improvement, gaps to be filled and enhancing impact of our events

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• Strengthen the monitoring of Sanofi events, and provide quantitative and qualitative feedback to Sanofi

EXEMPLARY COLLABORATION • The initiative which bore a risk of being perceived as policing exercise, was embraced with above the line mindset and passion to do what’s right for the company.

• Calling it as one of the smoothest launch of such initiative in industry wouldn’t be an overstatement • Hats off to entire Field Force, Sales Management team to make it happen

INDIA EBI Newsletter Jan - Apr 2021

LEARNINGS • The Project tasted its initial success in the quarter it was launched, generating powerful leads to enhance the execution of our events, plug gaps for ineffectiveness and compliance risks.

• First Compass report to Senior Management for Q4 – 2020 was made in Jan 2021

STEERING FOR BETTER IMPACT • A cross functional team under leadership of Rupendra Sachdeva (BU Head – CHC Rx) and K Lakshminarayan (National Sales Manager - Cardio Diabetes) worked swiftly and rigorously to take input from all senior sales and functional leaders, EBI Committee members to plot impactful and pragmatic solutions to steer our events towards better and risk averse execution • Training conducted for Sales Area Managers and above, Medical and Finance functions on implementation of said solutions in March 2021 by Rupendra Sachdeva, Lakshminarayan, K (National Sales Manager - Cardio Diabetes), Kedar Chandrachuli (National Sales Manager – Diabetes and Compliance Champion), Medical and EBI teams

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INDIA EBI Newsletter Jan - Apr 2021

Actions from recent Investigations in India • Termination of employment of a Sales Personnel for submitting fraudulent invoices for Internet and Telephone expenses • Termination of an employee for submitting fraudulent inflated invoices for Medical insurance claim • Termination of an employee for False Call Reporting • Blacklisting of a vendor for submission of fraudulent invoice

What to report & How to report • Corruption • Fraud • Conflict of Interest • Improper Promotion of Sales Practice • Protection of Confidential and Senstitive Information • Anti-Competitive Behaviour • Privacy Breach • Insider Trading • Misuse of Company’s Assets • Harassment, Discrimination and Work-place Violence Compliance Helpline 28 Languages 24 X 7 000 800 440 1286 Connect to: https://wrs.expolink.co.uk/ Password: sanofi Email to: Chairman.SILauditcommittee@sanofi.com” You can write to your Compliance Officers

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INDIA EBI Newsletter Jan - Apr 2021

I am not sure confidentiality will be guaranteed

TRUTH

I need to have enough information and/or be certain it is a violation

TRUTH

I will face retaliation if I raise a concern

TRUTH

I will get somebody fired

TRUTH

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Unconscious biases on raising concerns

The fact that the internal investigations are managed under the strict supervision of Ethics & Business Integrity (EBI) guarantees the confidentiality of the whistleblower. In addition, any whistleblower could report anonymously through the Compliance helpline You do not need to have full information or be certain it is a violation. You can report as soon as you believe, in good faith, that a law, regulation, provision of an industry code, Sanofi policy or standard or one of the principles of the Sanofi Code of Ethics has been or is about to be violated.

Employees who raise concerns, anonymously or not, WILL NOT be disciplined, discriminated or retaliated if acting in good faith and with no malicious intent, even if the facts reported prove to be inaccurate or no further action is taken

Depending on the results of the investigation and the severity of the case, the GDPOL-013848 : Corrective and/or Disciplinary actions policy will apply CLICK HERE TO ACCESS GDPOL -013848

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INDIA EBI Newsletter Jan - Apr 2021

The Company will not do anything or nothing will happen as the person concerned is senior

TRUTH

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Unconscious biases on raising concerns

According to the GDPOL-012575: Alerts Management policy EBI has the duty to log all the alerts received. Any logged alert triggers an investigation.

CLICK HERE TO ACCESS GDPOL -012571

I am not concerned, so I do not want to become involved

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It is not worth reporting as the company already knows

TRUTH

As soon as you have a concern or believe a law, regulation, provision of an industry Code, Sanofi policy or standard or one of the principles of the Sanofi Code of Ethics has been or is about to be violated, you should report it. Your report will trigger an investigation by EBI. By raising concerns you contribute to protect Sanofi.

Never assume that a report has already been made. Several reports on the same case may help the investigation.

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INDIA EBI Newsletter Jan - Apr 2021

COMPLIANCE CHAMPIONS Do you know Sanofi India has a network of Compliance Champions that increase the reach and impact of Sanofi’s Ethics & Business Integrity Program?

Compliance Champions, who come from various areas of company like Sales & Marketing, Industrial Affairs, Enabling and Support functions propagate the culture of Ethics & Business Integrity in company by: • Relaying and reinforcing compliance messages.

• Answering questions on policies which do not requiring the input of the Compliance Officer).

• Promoting employees « comfort » in speaking up.

• Acting as a layer between EBI Department and employees to facilitate exchange of ideas, feedback.

To avoid any real or perception of conflict of interest, Compliance Champions do not do formal Risk Assessment of Projects, Monitoring or Investigations.

• Identifying issues, gaps in SOPs, policies, trainings and communications.

• Providing ground level feedback to EBI department for better understanding of culture, perception of employees about culture, issues, strengths and areas of improvement in organization.

• Conducting Trainings, assisting in special projects, survey as required.

INDIA EBI Newsletter Jan - Apr 2021

COMPLIANCE CHAMPIONS

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INDIA EBI Newsletter Jan - Apr 2021

You can reach out to Compliance Champions for • Seeking any clarification regarding SOP requirement concerning HCP Interactions/ EBI department • Seeking clarity on reporting Concerns, what type of issues to report, Compliance Helpline etc.

• Getting support for conducting a refresher training for your team on areas concerning EBI • Relaying any feedback to EBI Department • As your next point of contact when you are not able to reach out to Compliance Officer

CLICK HERE TO LOCATE COMPLIANCE CHAMPION CLOSE TO YOU

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INDIA EBI Newsletter Jan - Apr 2021

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JUST FOR FUN

Find 18 Words that relate to Ethics & Business Integrity

KEY

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INDIA EBI Newsletter Jan - Apr 2021

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Ethics and Business Integrity is a real game changer for us. It is real force of good, it sets us apart from our competitors. Just imagine a situation where you pick a news paper and find a report that Sanofi is flouting some rules and regulations. How would we feel, how would our family think of us, how would our interactions with our customers change.

Nikhilesh Kalra General Manager Established Product & CHC Business

The role of EBI, SOPs that we have is to protect ourselves and to protect our company from that type of situation happening. Ethics and Business Integrity is incredibly important to company that we all have built up over years.

Know your Compliance Officers

Bratin Bag Senior Director & Head of Ethics & Business Integrity, South Asia +91 9920778885 Bratin.Bag@sanofi.com

Arjun Thakkar Head – Compliance Operations, India +91 7769060600 Arjun.Thakkar@sanofi.com

Maulik Shah Compliance Business Parter +91 9820116838 Maulik.Shah@sanofi.com