TRANSPARENT MANAGEMENT APPROACH

Sanofi Turkey manages all its operations openly and transparently in line with sectoral business ethics and ensures direct, dialogue-focused and informative communication with employees while promoting open communication with other stakeholders as well.

Sanofi Turkey adopts maintaining constant dialogue with both internal and external stakeholders through various communication channels. It aims to be a company where information can be directly accessed by employees and communicated accurately, swiftly and securely with a Transparent Management Approach. 

A. Governance

Sanofi Turkey carries out commercial and industrial activities under the Country Council and Management Committee led by the Country Chair. Sanofi Turkey Country Council consists of the General Managers of Sanofi companies and the directors of support functions. Senior executives of Business Operations, Commercial Operations and Revenue Management, Finance, Legal, Public Affairs, Human Resources, Corporate Communications, Market Access, Digital and Multi-Channels, Medical and Compliance departments are permanent members of the Country Council. The Country Council meets quarterly. 

Sanofi Turkey Management Committee, which meets on a monthly basis, consist of the senior executives of Sales and Marketing, Public Affairs, Finance, Market Access, Corporate Communications, Commercial Operations and Revenue Management, Human Resources, Medical Business Operations, Digital and Multi-Channels and Supply Management.

Sanofi Turkey Country Chair reports to the Sanofi Eurasia and the Middle East Regional Head. Local Compliance Committee and other steering committees established for various projects within the company, operate within their own areas of responsibility. Sanofi Turkey Country Chair, the chair of the highest governance body, also holds an executive position. As of 2018 year-end, the Country Council and the Management Committee are composed of 25 and 15 members, respectively. Remuneration of the Management Committee members is determined after careful consideration of market data available in pharmaceutical industry wage studies. The company also has in place an annual performance appraisal system and performance bonuses are paid. The performance of the group is evaluated and overseen based on the monthly reports submitted to the international division to which the Company reports, as well as through reports and analyses during annual budget preparations and quarterly forecasts for the year.

Sustainability performance is an important key performance indicator that is particularly emphasized by Sanofi. Sanofi Turkey Country Council is responsible for all performance indicators, including the company's sustainability performance. 

B. Risk Management

Sanofi continuously fosters risk management to identify and address potential threats and opportunities that may impact our commitment to:  

  • protect employees, patients and local communities, 
  • launch and market safe and innovative products to patients and healthcare professionals, and satisfy unmet medical needs;  
  • create value while delivering trust and transparency for all stakeholders  

As an important player in the Turkish pharmaceuticals sector, Sanofi Turkey identifies, assesses and mitigates key risks both at global and local level in order to ensure the integrity of its value chain. 
Within the scope of our risk assessment mechanism, the relevant risks are managed, and the necessary controls and inspections are carried out under the leadership of the ‘Internal Control’ and ‘Risk and Audit’ Committees.

Managing Risks

Risk Assessment 
In order to maintain risks at reasonable levels, Sarbanes-Oxley reports are prepared in the periods identified by the Sanofi Group. Furthermore, necessary controls across all companies and processes and risk control analysis through self-assessment procedures are conducted; risky areas or areas with insufficient controls are identified and action plans are developed. The findings identified during these activities are shared with the relevant departments, areas of improvement are identified, and the related processes and results are closely monitored by the Internal Control and Processes Department. In addition, end-to-end reviews are carried out on a process basis in order to optimize processes, and the implementation of action plans is also overseen by local and global senior executives.  

Internal Control 
The Internal Control and Processes Department of Sanofi Turkey is responsible for establishing an internal control environment and ensuring its continuity, conducting risk analyses, complying with applicable legislation and internal rules related to operations, organizing process improvement activities or supporting existing practices. The Department is responsible for carrying out annual risk control analyses and self-assessments for the entire the company, as well as planning Internal Control Process Audit / Review activities based on risk analyses, organizing detailed audits or process tests for the processes identified, and taking necessary actions to mitigate the risk of fraud. Immediate solutions can be developed and implemented for the risks identified during the year. The findings identified during these activities are shared with the relevant departments, action plans are created, the results of which are closely monitored by the Internal Control and Processes Department.

Additionally, affiliates are audited by the Global Internal Audit Unit during certain periods. Roadmaps are defined for all findings reported as a result of the findings of the audit and whether or not these plans have been implemented is monitored and reported to senior management. In addition, the Compliance Manager plans Review Activities every four months. Detailed audits or process tests are organized for the processes identified and necessary measures are taken to reduce the risk of fraud. The findings from the processes are evaluated and plans are prepared in collaboration with the members of the Country Compliance Committee, held every two months. The relevant process owner is responsible for making the necessary process improvements in accordance with the timeline set out in the Compliance Committee.

Main Risks and their Mitigation

Sanofi Turkey has grouped its relevant risks under ‘Financial Risks,’ ‘Product Risks,' 'New Product Development and Operational Planning Risks,’ ‘Clinical Research and Medical Risks’, ‘Risks related to Investment Environment,' ‘Natural Disasters,’ and ‘Climate Change.'

Financial Risks
Ensuring continuous liquidity for affiliated companies, managing financial risks and optimizing the financial structure are among the objectives of Sanofi's Department of Finance and Treasury. For this purpose, forecasts are prepared and reported in close contact with all relevant departments (marketing, sales, financial control, accounting, tax, etc.), in order to obtain healthy information about the affiliate's operations, and anticipate any risks due to exchange rates. In case through regular reporting an exposure to any risk is identified, the strategy for protecting against financial risk is adapted accordingly. The purpose is to reduce commercial and financial risks arising from foreign exchange rate fluctuations. Credit risks and customer accounts are managed through a credit management policy, where risks concerning receivables are also clearly defined. With this policy risk coverage tools are applied based on the rating of any given customer, bearing in mind economic developments and potential impacts.

Product Risks
Quality issues have important implications for both patient health and company reputation. To ensure the highest level of quality and fulfill the requirements of all relevant laws and regulations, Sanofi applies all the required standards to ensure the quality of all its current and innovative products throughout their life cycle from research to production and development. These standards are constantly reviewed and all sites of the company are regularly inspected by authorities. 

Pharmacovigilance Department, alongside other relevant functions, plays an important role in obtaining, coordinating and following through the approval of Ministry of Health for risk management plans that may be needed to identify, prevent or at least minimize the risks that may arise from Sanofi Turkey products. Pharmacovigilance Department also organizes routine annual pharmacovigilance trainings to ensure that Sanofi Turkey employees understand and adapt to their roles and responsibilities better regarding product safety. 

Risks Related to New Product Development and Operational Planning 
In new product development and operational planning, the entire process is defined according to a specific time frame. The risks, if any, are identified for each step of the process. The likelihood of the risks is calculated and if a risk occurs, the effects are identified according to the consumer/sector/business results and listed. Findings of the risk analyses are shared with all necessary internal and external stakeholders and three main topics are formed in agreement with all stakeholders:
1. Preventive actions against risks 
2. Actions for mitigating or reducing the effects of risks, should they occur 
3. Second action plan to implement in case a risk occurs

Recurrence of risk within the scope of the above-mentioned plans is evaluated by the management team and relevant stakeholders and a decision is reached on whether or not to take such a risk. 

Clinical Research and Medical Risks
Potential risks are determined through teleconferences and meetings by global and local working groups as part of the feasibility stage of clinical and medical research, followed by monthly meetings and follow-up of these risks. 

Risks Related to Investment Environment
The national and international political and economic developments and the key topics related to the investment environment in the pharmaceutical industry are regularly monitored, and potential risks are thus anticipated. The necessary information and announcements are made to the internal stakeholders, the possible impacts of the existing situation on Sanofi are analyzed together with the relevant departments, and appropriate roadmaps are created.  

Natural Disasters
Our company has in place a defined process that is included in the joint crisis communication plan. This mainly ensures that volunteers have access to medications in case of natural disasters, etc., so that patients do not miss their treatments. The plan is ready to be implemented in the occurrence of any risky situation. In the event of a crisis, responsible people have been determined and a communication chain has been established. 

Climate Change
One of the risky issues identified by Sanofi Turkey is climate change. Climate change is among Sanofi's global priorities. The Sanofi Climate Change Committee has been established in 2005 to carry out activities in this field under the steering of senior management. In addition to determining the strategy, the Committee also coordinates energy efficiency programs in global operations.  

Sanofi Turkey, within the scope of its global sustainability approach, works toward minimizing its environmental impact at every stage of its business processes with the aim of protecting public health and fighting against climate change and also strives to ensure that employees act with this awareness. Energy efficiency projects and methods applied to avoid any risks arising from chemical waste at the Sanofi Turkey's Lüleburgaz plant in particular are examples in this area. 

Business Continuity Plan involves ensuring continuity of the pharmaceuticals supply process as well as production in unforeseen circumstances including risks caused by climate change, thus ensuring patients’ access to pharmaceuticals. Business Continuity Plan is included under risk management topics. Sanofi Turkey’s business continuity and relevant risk management mechanisms are reviewed annually and necessary assignments are made in job descriptions.