'CODE OF ETHICS PRACTICES' MANAGEMENT APPROACH
Sanofi Turkey carries out its activities in line with ethical principles and related policies declared by Sanofi Global. Sanofi Turkey, which regulates and conducts all operations in accordance with applicable laws and regulations of the region where it operates, is also committed to adhering to the principles of the United Nations Declaration of Human Rights, International Labor Organization and Economic Cooperation and Development Organization.
Sanofi Turkey Ethical Principles and Code of Ethical Conduct define Sanofi’s expectations regarding ethical processes from all employees and business partners while carrying out activities.
Sanofi's Code of Ethical Conduct is an integral part of Company culture and working principles. Sanofi Turkey regards implementing the Code of Ethics Principles, which Sanofi has set out in line with universal rules as a whole and informing all stakeholders in this respect as part of its key responsibilities.
A. Business Ethics
Adopting the right behaviors is a commitment that Sanofi has made to the community. In this respect, Sanofi Turkey acts with integrity in every situation it encounters and engages in ethical business practices. All business processes are carried out in accordance with the ‘Sanofi Turkey Code of Ethics,’ ‘Sanofi Financial Code of Ethics’ and ‘Procurement Ethics Regulation.' Moreover, all decisions regarding community support made under the name of philanthropy, including the events to be sponsored, are taken within the framework of the established ethical rules.
We act in accordance with all relevant regulations and rules in our company, chiefly among them the Code of Ethics booklet, in order to avoid conflict of interest and to fight against corruption, and each process is controlled periodically in accordance with these rules. There is also a Compliance Helpline, which all employees may call anonymously if they experience any problems in this area within the company. Detailed information on the subject is communicated during orientation of new recruits.
Sanofi Turkey Business Ethics Practices
Doing ethical business and full compliance with the Code of Ethics are the top priorities of Sanofi.
Sanofi Code of Ethics: The “Welcome Pack” prepared by Human Resources Department to be presented to all new recruits of the company includes the “Code of Ethics” booklet. The new recruit signs a document upon receipt of the “Welcome Package,” which includes the Sanofi Code of Ethics along with other guidelines, stating that they agree, declare and undertake to adhere to these rules and that they will be personally liable for any breach of these rules. The Code of Ethics booklet in the Welcome Pack has also been distributed to all employees.
Every new recruit is also provided with “Code of Ethics – Orientation Training” on the general scope of Ethical Principles as part of the Orientation Training (Head Office) and Journey to Excellence Training (field team). Moreover, “Ethics and Business Integrity in the Recruitment Processes” training is provided through Sanofi's online training platform iLearn for new recruits. All employees are obliged to follow the procedures and must repeat the training on the Code of Ethics each year. The Compliance Department oversees whether or not the employees uphold these rules.
The Compliance Department also trains all our employees in ethical principles once a year. All employees are obligated to adhere to the procedures and required to take the ethical principles trainings every year. The Compliance Department oversees whether or not the employees uphold these rules. All required trainings have been taken 100% by all Sanofi employees.
Financial Code of Ethics: Financial Code of Ethics ensures that the executives avoid conflicts of interest in their personal and professional relationships, act in accordance with the principle of integrity, address any conflicts of interest in their personal or professional lives in accordance with the highest ethical standards and notify the Country Council immediately of any such conflicts or any material procedures or transactions that may lead to such conflicts. The Code also ensures that reports issued by the organization are complete, fair, objective and comprehensible, comply with local and international policies and regulations of the Company as well as principles of good faith, responsibility, due diligence, competence and objectivity, respect confidentiality of the business and that employees adopt to ethical principles. Financial Code of Ethics is read and undersigned each year by the Country Chair, General Manager of Sanofi Pasteur, General Manager of Consumer Health, Director of Industrial Operations and Director of Finance and Administration.
Procurement Ethics Regulation: Sanofi’s Ethics Regulation on Procurement sets out the principles of integrity and transparency between the employees of Sanofi purchasing department and suppliers, relationships and behaviors with suppliers, potential conflicts of interest, relationships with government employees and civil servants, limits of foreign travel and imports and competition laws with the aim of helping to make decisions when faced with sensitive situations. This regulation is read and signed each year by the employees in the Procurement Department and the Congress and Event Department.
Decisions to work with charitable organizations, health care organizations and medical or scientific associations are always based on Sanofi Group's ethical standards, anti-corruption and anti-bribery policies, all applicable laws and regulations in effect, and all the national and international codes of practice applicable to the pharmaceutical industry. Sanofi Turkey may provide financial support to charitable organizations, health care organizations and medical or scientific associations as long as they operate in the fields of health, science (not related to Sanofi products), public services, education, arts, and athletic performance.
The trustworthiness of any organization in its compliance with anti-corruption laws is the main criterion in offering financial support and due diligence is performed before a decision to that effect is to be given concerning any organization. Financial support is always based on a written request. The process is further strengthened by a duly written contract setting out the purpose of the support, and the obligations of the recipient.
Faced with a request or offer for financial support, Sanofi evaluates the impact of the organization concerned on the society, and the purposes of the financial support request, while also evaluating whether the members of the Board of Directors of the requesting organization are government officials, and the ultimate beneficiaries of the request. In this context, an appropriate due diligence process is carried out to comply with the general rule that individual healthcare professionals and/or government officials should be excluded from the scope of such financial benefits.
The designated employee of Sanofi begins the due diligence process on the potential recipient by completing Internal Due Diligence in-house as well as filling out the External Due Diligence Questionnaire with information to be provided by the recipient. Potential "red flag" situations and corrective actions are also evaluated with this scope.
COMPLIANCE, ANTI- BRIBERY AND ANTI-CORRUPTION
Avoiding Conflicts of Interest
All our employees are responsible for avoiding any conflict of interest within the Company. If Sanofi employees become aware of any current or potential conflict of interest, they must report to the relevant authorities the transaction, activity or relationship that is causing the situation. Sanofi employees fill out and submit a Conflict of Interest Form to report the situation.
Every year from January to April, conflict of interest statements are obtained from all employees (affected employees) working in departments that may face the risk of bribery and corruption and Country Council members in particular, via electronic software and any conflicts of interest, which these employees may be exposed to, are evaluated by the Compliance Department. Checks to ensure healthy functioning of the process are carried out in the first quarter of every year after conflict of interest statements are collected and relevant action plans are implemented in case of any actual or potential conflict of interest. Furthermore, all new recruits fill out the conflict of interest form included in their “Welcome Package” and submit it to the Human Resources Department. The forms collected by the Human Resources are then sent for review to the Compliance Department, which takes necessary actions and retains the forms.
Additionally, the Sanofi Code of Ethics includes a chapter on “Avoiding Conflicts of Interest”. Conflicts of interest are briefly explained in this chapter, which also provides information about the issues that the employees should avoid. All employees are required to comply with these principles set out in the Code of Ethics.
Risk Management Mechanisms for Anti-Corruption
Fighting Against Corruption is of utmost importance for Sanofi; therefore, types of corruption and identification methods, sanctions and penalties for bribery and corruption and how to act in such cases are explained in the “Fight Against Bribery and Corruption” section of the Code of Ethics booklet. In addition, new recruits attend the obligatory training on “Fight against Bribery and Corruption”, provided by the Compliance Department as part of their Orientation Program.
Minimizing fraud and corruption risks is part of Sanofi's audit and risk management plans. Internal Control and Processes Department conducts annual risk analyses and self-assessments for all units within the organization, organizes detailed audits or process tests over the defined processes to minimize the risk of fraud and corruption and cooperates with the Compliance Department when necessary to conduct the said audits.
Sanofi Turkey has a local Compliance Committee to support these efforts. The mission of the Local Compliance Committee is to oversee compliance at Sanofi Turkey with the Sanofi Group's Code of Ethics, policies and procedures, applicable legal and regulatory requirements, industry standards and particularly ethical interactions with healthcare professionals and government officials established directly or through intermediaries. The committee meets every other month to carry out its work. At these meetings, the Compliance Committee assesses current risks and may request audits in areas considered risky.
Sanofi Turkey has in place the following internal audit mechanisms for anti-corruption:
Segregation of Duties Principle: Authorizations in systems assessed as financially critical at Sanofi Turkey are given in line with the principle of “segregation of duties” to prevent corruption. Authorizations in the system are reviewed for compliance with the “segregation of duties” principle and corrective actions are taken where authorities overlap, if any.
Delegating Internal Authority: The internal (approving expenses) and external (representing the company before third parties) conditions where employees are authorized to act on behalf of the Company are defined in the “Authority Delegation Policy” according employees’ roles, responsibilities and competencies and approved in the systems.
Compliance Helpline: When employees believe in good faith that a law, regulation or a principle in the Code of Ethics is or will be violated, or when they have concerns about such issues, they are encouraged to notify the Compliance Department or their own superiors. There is also a Compliance Helpline, which all employees may call anonymously when faced with an issue. Detailed information about the subject is given to each new recruit during the “Compliance and Business Integrity” training in their orientation program.
Due Diligence: For all agreements to be signed, concerning procurement of all goods and services, works and activities that fall within the scope defined by the Company, the relevant party is subjected to due diligence to avoid corruption and bribery. Agreements with third parties can only be signed after the information obtained during the due diligence process is reviewed by company experts.
Gifts and Gratuities: During the term of their service, employees cannot accept the proposals, gifts and gratuities from public officials, politicians, political parties or any person or organization in return for performing or not performing certain acts using their position or the benefits of their position directly or indirectly, or cannot propose such gifts or gratuities to such persons or organizations. This topic is addressed in the Code of Ethics.
Supplier Agreements: In supplier agreements, obligations of parties to the agreement should clearly be stated. Terms and conditions about rebates, advance payments and invoices, which should specify the services provided in detail and compliance with the policies and procedures of the Company and regulatory bodies are all checked. This topic is addressed in the Code of Ethics.
All practices are valid for all units of the Company.
B. Ethical Marketing
All marketing activities in Sanofi Turkey are carried out according to the relevant rules and regulations. Promotional activities for healthcare professionals are regulated by laws and regulations, namely, the Ministry of Health Regulation on the Promotional Activities of Medicinal Products for Human Use, and the Ministry of Food, Agriculture and Livestock regulation on labeling. Marketing communication activities aimed at consumers are carried out in accordance with the relevant regulations of the Ministry of Food, Agriculture and Livestock, as well as regulations related to advertising. Other marketing activities of the Company are carried out in accordance with the Ministry of Health Regulation on Promotional Activities, AIFD good practices and recommendations, Company compliance policies and standard operating procedures. Compliance with the global principles of Sanofi is also ensured. The Company acts in full compliance with all rules and regulations set out for this purpose and adheres to competition law. All trainings are updated upon an amendment of the procedures and regulations. In the context of marketing generic pharmaceuticals, all promotional activities are carried out similar to the original products.
At Sanofi, promotion, sponsorship and donation activities are carried out within the scope of the applicable standards operating procedures and in line with the regulations and Code of Ethics, by which all these processes are approved. In order to raise our quality standards, the Regulatory Affairs Department has started to take part in the evaluation and validation process of promotional materials as of 2017 and 2 procedures related to the process have been revised and published under the Department's leadership. The evaluation and validation of the promotional materials consist of checking the compliance of the materials with the relevant Company procedures, regulations and Good Promotion and Good Communication principles.
Our Company also uses a platform called ZINC in order to prevent errors during product and service information and labeling processes. ZINC is a global electronic platform where all promotional materials, promotional activities and training materials used for promoting products are approved. This program is in use since 2011 to confirm that all the promotional materials and activities and trainings prepared are in compliance with the regulations and principles of promotional activities prior to introduction/presentation to internal and external customers.
Sanofi Turkey has a separate department to monitor and assess any complaints which may arise out of its activities carried out within the scope of the Ministry of Health Regulations on Promotional Activities, AIFD rules and Company compliance policies, as well as standard operating procedures.