Introduction
This statement is made in accordance with section 54 of the Modern Slavery Act 2015, on behalf of Aventis Pharma Limited (“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
At Sanofi UK, our teams are guided by one purpose: we chase the miracles of science to improve people’s lives. This inspires us to drive progress and deliver positive impact for our people and the communities we serve, by addressing the most urgent healthcare, environmental, and societal challenges of our time.
Sanofi UK is organised into three business units: General Medicines; Vaccines and Specialty Care.
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 integrated into Sanofi's corporate strategy at every level of the company. In 2025, Sanofi introduced its updated AIR sustainability strategy, focused on the critical nexus between health and the environment, across three dimensions: Sustainable and Equitable Access to Healthcare, Environmental Impact, Resilience of Healthcare Systems. These commitments reflect Sanofi's broader dedication to ethical business conduct and responsible supply chain management, which are fundamental to our approach to identifying and mitigating modern slavery risks.
Sanofi UK is integrated into a global supply chain involved in the manufacturing of active pharmaceutical ingredients and finished goods, 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.
Our Policies
Sanofi UK is required to comply with all Sanofi policies including our Code of Conduct which outline our commitment to complying with national laws and regulations in the areas of human rights and labour law. In particular:
- Championing Diversity, Equity and Inclusion – Sanofi wants to reflect the diversity of our communities, unleashing our whole selves every day to transform the practice of medicine. We want to make an impact in the world through who we are, what we do, and the way we do it, and we recognize that the only way to really do this is to do it together and by being “All In”
- Fighting Bribery and Corruption – Sanofi does not tolerate any form of bribery or abuse of power for personal gain, both among our employees and business partners, as well as among stakeholders involved in chasing the miracles of science to improve patients’ lives;
- Competing Freely and Fairly – Sanofi strives to deliver better outcomes for patients, communities, and stakeholders by providing ground-breaking therapies at the right time and for the right reasons. We support a level playing field in which companies freely and fairly chase the miracles of science without undue advantage; and
- Speak Up - Sanofi maintains confidential reporting mechanisms available to employees and others working in our supply chains to report any wrongdoing, including human rights violations. Any reports are fully investigated and appropriate remedial actions taken. (See Reporting Mechanisms below for further details.)
Sanofi's commitment to combating modern slavery and human trafficking is further reinforced by our Human Rights Position Statement, published in 2025 and publicly available on our corporate website. This statement sets out Sanofi's commitment to respecting human rights across our entire value chain, in accordance with the United Nations Guiding Principles on Business and Human Rights (UNGPs), the OECD Guidelines for Multinational Enterprises, and the ILO Core Labour Rights Conventions, including the explicit prohibition of all forms of forced labour, modern slavery, and human trafficking (ILO Conventions 29 and 105). As a signatory to the United Nations Global Compact, Sanofi is also committed to its ten principles, which include the elimination of all forms of forced and compulsory labour.
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.
Reporting Mechanisms: Speak Up Portal and Ombuds Office
Sanofi is committed to maintaining a culture of integrity and transparency, in which all individuals whether employees, contractors, suppliers, or other third parties feel safe and empowered to raise concerns without fear of retaliation. These reporting mechanisms play a crucial role in the prevention and early detection of modern slavery, human trafficking, and other human rights violations across our operations and supply chain. To this end, Sanofi operates two complementary and confidential reporting mechanisms:
- Speak Up Portal
In 2024, Sanofi launched a dedicated internal Speak Up Portal, providing employees with a centralized, user-friendly platform to access all available reporting channels, guidance on how and when to raise concerns, peer stories, and resources on Sanofi's culture of integrity. The Portal reinforces Sanofi's commitment to making it as easy as possible for employees to speak up when they witness or suspect wrongdoing, including any form of modern slavery or human rights abuse.
The Portal provides direct access to the Speak Up Helpline, a confidential reporting channel operated by an independent third-party provider, available 24 hours a day, 7 days a week, in multiple languages (currently available in 27 languages). It can be accessed via a web form or a toll-free telephone number. Reports may be made anonymously if preferred. The Helpline is available not only to Sanofi employees but also to individuals working within our supply chains, including contractors and business partners. Any concern raised in good faith — including concerns related to modern slavery, forced labour, human trafficking, or other human rights violations will be fully investigated and appropriate remedial action taken. Sanofi has a strict non-retaliation policy to protect those who raise concerns. All reporters are notified of the safe receipt of their report within seven days of submission, and updates are provided while the report is being processed and at closure.
- Ombuds Office
Established in 2024, the Ombuds Office is a confidential, informal, independent, and impartial resource available to all Sanofi employees. Unlike the Speak Up Helpline which is a formal reporting channel that triggers an investigation, the Ombuds Office provides a safe space for employees to discuss workplace concerns, conflicts, or ethical dilemmas informally, without triggering a formal investigation. This includes concerns about potential modern slavery risks or human rights issues that employees may observe in their work environment or supply chain interactions. The Ombuds Office can assist employees through active listening, helping to identify options and navigate complex situations, facilitating informal resolution, and referring individuals to appropriate formal channels where necessary. The Ombuds Office operates under strict principles of confidentiality and does not advocate any individual or outcome, but rather for fair processes and ethical conduct.
Together, these two mechanisms ensure that Sanofi UK employees and supply chain workers have multiple accessible avenues to raise concerns related to modern slavery, human trafficking, or any other human rights violation, and that all such concerns are taken seriously and addressed appropriately. These reporting channels serve as critical tools in our proactive approach to preventing modern slavery and protecting vulnerable workers throughout our value chain.
Sanofi UK Employees
All employees who work for Sanofi UK are background checked, having their identity 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
The standard Request for Proposals (RFP) 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 Labour 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 suppliers 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 applies a structured, risk-based due diligence process to assess and manage the risks of modern slavery and human trafficking across its supply chain and third-party relationships.
All suppliers are required to acknowledge and comply with the Sanofi Supplier Code of Conduct, which is integrated into Sanofi's electronic ordering systems (Coupa) and must be agreed upon at the point of onboarding.
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. This assessment draws on internationally recognized standards. Sanofi also uses third-party risk assessment service providers, including EcoVadis, to evaluate suppliers' commitment to workforce safety, compliance with human rights policies (including prohibitions on child labour and forced labour), and alignment with Sanofi's standards.
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.
Sanofi UK recognises that modern slavery risks may exist beyond our direct (Tier 1) supplier relationships. While our primary due diligence focus is on direct suppliers, we encourage and, where appropriate, require our key suppliers to:
- Apply similar due diligence standards to their own suppliers (Tier 2+)
- Provide transparency into their supply chains for high-risk categories
- Report any identified concerns in their extended supply networks.
We acknowledge that achieving full visibility into complex, multi-tier supply chains remains an industry-wide challenge. Sanofi UK continues to explore innovative approaches, including technology solutions and industry collaboration, to enhance transparency across deeper supply chain tiers.
Sanofi UK manages supplier risks through appropriate contract clauses and ongoing monitoring. Based on the quality of supplier responses, Sanofi UK may also conduct third-party audits. When potential issues with suppliers are identified, Sanofi UK takes appropriate actions based on the specific circumstances. This may include working with the supplier to develop an improvement plan or deciding to discontinue the supplier relationship. Additionally, Sanofi UK continuously monitors new supplier creation requests and reassesses existing suppliers. For more details, please refer to the Sanofi Supplier Standards available via the Sanofi Supplier Portal.
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 Conduct (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. Failure to complete mandatory training on time has an impact on employee performance ratings and bonuses.
Training and Capacity Building
As part of their employment conditions, all Sanofi UK employees must agree to uphold Sanofi’s Code of Conduct 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 respect for human rights, prohibition of forced labour and modern slavery, fighting bribery and corruption and ethical decision-making.
For more information, please visit our homepage at www.sanofi.co.uk.
