Sanofi

Composition of the Board and its committees

Information required under ESRS 2 paragraphs 20 and 21 can be found on Sanofi's website. One of these directors holds an executive position at Sanofi (Sanofi's CEO), while 16 are non-executives. Sanofi has two directors representing employees on its Board of Directors.

Responsibilities of the Board and its members for IROs, as depicted in the terms of reference or Board mandates

The Board of Directors shall lay down the orientations of the Company's activities and ensure that they are implemented, paying due consideration to social and environmental issues. The Board is committed to a long-term value creation approach while considering the social and environmental impacts, risks and opportunities of the Company's operations.

The Appointments, Governance and CSR (AGC) Committee of the Board addresses CSR-related topics at least four times per year and reports to the Board. On CSR matters, the Committee: • examines and monitors the Company's commitments and policy orientations in terms of social, environmental and societal responsibility (collectively referred to as Corporate Social Responsibility or "CSR") and the extent to which they meet stakeholder expectations, and more generally ensure that CSR issues are taken into account in developing and implementing corporate strategy; • ensures that on climate-related issues the Company's strategy is accompanied by precise objectives defined for different time frames, and reviews annually the results achieved. The Committee may review the presentation to the shareholders' meeting of the climate strategy; • examines draft reports by the Company on governance (including the sections dealing with the diversity policy applied to members of the Board) and CSR matters (especially the sustainability information), and more generally ensure that all information required by applicable legislation on such matters is prepared; • ensures that regular exchanges take place with shareholders on corporate governance and CSR issues and determine how such exchanges take place, while making sure that the principles of equal treatment of all shareholders and the collegiate nature of the Board are not undermined; • identifies and discuss emerging trends in governance and CSR, and ensure that the Company is preparing as well as possible to deal with those trends in light of issues specific to its operations and objectives; and • where applicable, participates in the determination, in conjunction with the Compensation Committee, of the extra-financial criteria included in the Company's remuneration policies.

The Committee does not include any executive corporate officers and is composed primarily of independent directors. The non-executive Chairman is a member of this Committee. While not a member of the committee, the Chief Executive Officer is involved in its work.

As of 2024, the Audit Committee (AC) has a formal oversight role on sustainability reporting. It can challenge the adequacy of such reporting, especially on the materiality assessment and the information to be provided with respect to material impacts, risks and opportunities in accordance with the CSRD and related methodology established by EC, EFRAG and other guidance (refer to the CSRD Disclaimer and Explanatory Note).

Role of the administrative, management and supervisory bodies related to business conduct

As part of its duties, the Audit Committee must obtain assurance that the Chief Executive Officer has sufficient resources to identify and manage the risks, and in particular risks of an economic, financial and legal nature, to which the Company is exposed in the course of routine and exceptional transactions (see article VI B. of Sanofi's Board Charter). In this respect, the Ethics & Business Integrity (E&BI) department is heard regularly by the Audit Committee and provides updates on its roadmap.

The Audit Committee meets at least six times a year and reports to the Board of Directors and informs the Board immediately of any difficulties encountered. Business integrity topics are discussed at least once a year.

Responsibilities of the CEO and the Executive Committee for IROs

The Executive Committee regularly monitors Sanofi's impacts, risks and opportunities, as well as the work carried out by the sub-committees described hereafter. Some members of the Executive Committee are also appointed as owners or sponsors of a given CSR topic within the broader CSR strategy outlined previously.

The Risk Committee is chaired by the Group General Counsel and gathers executives from Global Business Units (GBUs) and functions (GFs). It consolidates the risks and impacts identified by the sub-committees and focuses on those that are high priority for Sanofi. The group Risk Committee then assigns each identified risk or impact to the relevant Executive Committee member and reports regularly to the Audit Committee. The group Risk Committee reports on a quarterly basis to the Executive Committee on the progress of the mitigation plans.

The Executive Compliance Committee (ECC) ensures the effectiveness of Sanofi's Ethics & Business Integrity program and monitors the corresponding impacts, risks and opportunities. The ECC is chaired by the CEO with senior representatives from all key functions and GBUs. The ECC meets every quarter.

Other operational governance bodies responsible for overseeing IROs

The CSR Committee comprises the senior leaders of Sanofi's Global Business Units and global functions. It meets on a quarterly basis to discuss key CSR topics. As part of Sanofi's double materiality assessment, the CSR Committee was given formal oversight of the identification of social and governance impacts, risks and opportunities in accordance with the CSRD and related methodology established by EC, EFRAG and other guidance (refer to the CSRD Disclaimer and Explanatory Note).

The Planet Care Impact Steering Committee oversees the Planet Care pillar of Sanofi's CSR strategy and therefore monitors its efforts towards its environmental transition. The Committee chaired by the Head of Manufacturing & Supply (also an Executive Committee member) includes senior executives from Environment, CSR, Procurement and R&D functions along with senior representatives from Sanofi's GBUs and other activities. It submits strategic orientations and the company's commitments to managing its environmental (climate, pollution, biodiversity and waste) impacts, risks and opportunities to the Executive Committee, which reviews these proposals with respect to their operational implementation.

The Climate-related Risk & Opportunities Committee (CROC) oversees Sanofi's climate change adaptation efforts. It works closely with the Planet Care Impact Steering Committee to ensure that the Task-force for Climate-related Disclosure (TCFD) recommendations are applied at all levels of organization and that systems are in place to manage climate-related risks and opportunities. This group, which meets monthly, includes senior executives from CSR, HSE, Environment, Risk Management and Insurance, along with senior representatives from Strategy, Finance, Legal, CSR, Procurement, Supply Chain and HSE.

Engagement of the Board with Committees and working groups on (i) material IROs; (ii) implementation of due diligence; and (iii) results and effectiveness of policies, actions, metrics and targets

The Board of Directors validates the Company's overall strategy, scrutinizes its implementation and regularly monitors delivery. As part of this role, it is informed of all material CSR impacts, risks and opportunities and directly engages with the committees in charge of implementing the relevant policies and action plans, monitoring their effectiveness, as well as Sanofi's progress towards meeting its targets.

Regarding environmental IROs, the Board is kept up to date on the progress on Sanofi's Planet Care program and reviews the climate transition plan at least once a year. This oversight role is supported by the Appointments, Governance and CSR Committee within the Board of Directors, which meets every quarter with the Global Head of CSR.

The Planet Care Impact Steering Committee oversees Sanofi's transition efforts. It presents to the Executive Committee the Company's strategic priorities and commitments related to environmental risks, impacts and opportunities. The Executive Committee approves and ratifies these proposals for implementation.

For climate-related IROs, the Climate-related Risk & Opportunities Committee (CROC) oversees Sanofi's adaptation efforts, which are quarterly monitored at Executive Committee level via the Head of Corporate Affairs (member of the Sanofi Executive Committee). The Global Head of CSR informs the Board and its committees of the implementation of policies and action plans, and of progress towards meeting their targets for managing material IROs.

Regarding social and societal IROs, the Chief People Officer, a member of the Executive Committee, meets the Board regularly to discuss the People & Culture agenda, particularly when co-creation, review and decisions are needed to move forward.

The Ethics & Business Integrity function forms the cornerstone of Sanofi's efforts to promote and instill ethics and integrity in all of its activities. It works closely with other departments such as Internal Control and Processes, Internal Audit and Risk Management, Global Quality, Procurement, People & Culture, HSE, and CSR. The Head of Ethics & Business Integrity has a double reporting line — to the General Counsel and to the CEO — and meets periodically with the Audit Committee and/or the Board and external auditors.

How the Board and its committees take into account IROs when overseeing the strategy, major transactions and the risk management process

The Board and its committees reviewed several material IROs during the period. The Board and the Executive Committee engage regularly with the Global Heads of CSR, HSE, Ethics & Business Integrity and with the Chief People Officer. The Executive Committee also gives consideration to the reports and proposals from the Planet Care Committee and the CROC. Below is a list of material IROs addressed between January 1, 2024 and December 31, 2024:

Sanofi conducted its double materiality assessment at group-level in accordance with the CSRD and related methodology established by EC, EFRAG and other guidance - refer to the CSRD Disclaimer and Explanatory Note.

Incentives schemes contingent on ESG criteria

There are two incentive schemes which include ESG performance criteria: • the Chief Executive Officer's variable compensation policy (short-term incentive, STI); and • the performance shares plan (long-term incentives, LTI).

The individual performance criterion based on CSR accounts for 10% of the CEO's annual variable compensation.

Furthermore, 20% of the variable compensation of the Executive Committee members is contingent upon achieving targets regarding human capital and climate-related issues.

The compensation policy for the CEO is established by the Board of Directors.

Since 2023, performance share plans — Sanofi's long-term incentive scheme awarded to senior employees — have incorporated two CSR performance criteria, accounting for 10% in the current plan. The performance criterion equates to the achievement over a three-year period of annual targets linked to the following pillars of Sanofi's CSR strategy: • Affordable Access (5%) – providing essential medicines to non-communicable disease patients through Sanofi Global Health; • Planet Care (5%) – Carbon footprint reduction, Scope 1 & 2 emissions (% GHG reduction versus the 2019 baseline).

Details on the annual targets are reported in the plan's brochure made available to the beneficiaries. At the end of the period, the Board will determine the allocation rate corresponding to the CSR targets met.

Mapping of core elements of due diligence

Mapping of core elements of due diligence, for impacts on people and the environment, to the relevant disclosures in Sanofi's sustainability statement:

Risk management and internal controls process for sustainability data

Description of scope, main features and components of risk management and internal control processes and systems in relation to sustainability reporting

Sanofi applies the Internal Control - Integrated Framework issued in 2013 by the Committee of Sponsoring Organizations of the Treadway Commission (COSO), reflecting its listing on the US market and in light of obligations under the Sarbanes-Oxley Act. The COSO framework is considered equivalent to the reference framework of the Autorité des Marchés Financiers (AMF, the French Financial Markets Regulator). Internal Control is a process, performed out by an entity's Board of Directors, management and other personnel, and is designed to provide reasonable assurance regarding the achievement of objectives related to: • the effectiveness and efficiency of operations; • the reliability of reporting, particularly with regard to accounting and financial information; and • compliance with applicable laws and regulations.

Sanofi's Internal Control system has adopted the COSO guidance "Achieving Effective Internal Control Over Sustainability Reporting (ICSR): Building Trust and Confidence through the COSO Internal Control – Integrated Framework (2023)" as the foundation for establishing and maintaining an effective system of internal control over sustainability reporting.

Approach to the assessment of reporting risks

Description of risk assessment approach

During the first year of the CSRD rollout, the Internal Control function focused on review processes impacted by the European directive using a risk-based approach to identify main metrics to focus on. Priority was given to document quantitative data across the impacted processes, collected through interviews with multiple data points owners.

Additionally, the Internal Control function used the "List of ESRS Data Points — Implementation Guidance" released by EFRAG to collect, at data point granularity, the information (policies, systems used, scope of applicability, operational risks, etc.) pertaining to the quantitative and qualitative data to be disclosed under the CSRD.

At the end of this financial year, the Internal Control function delivered a mapping of the IROs by end-to-end process, as well as a systems and risks inventory, the first step in rolling out the internal control system.

Risks identified and strategies implemented in the sustainability reporting process to mitigate these risks

Activities that seek to mitigate identified risks are in progress and being rolled out over time by corporate support functions as part of their operational remit. The main mitigating activities in place are mainly consistency checks, gap analysis, variance analysis versus prior year, and reconciliations. As part of the mitigating activities implemented across the processes impacted by the CSRD, a similar review process is implemented using the "four eyes" principles. When the global team performs consistency checks, variations are investigated and explanations sought from local contributors; if corrections are needed, actions are taken either at local or global level.

Those mitigating activities were not part of an established internal control process. Further mitigating activities and formalization might be necessary and will be assessed by the Internal Control function as part of the deployment process.

The Internal Control function is developing a risk management strategy for sustainability reporting that will continue to draw on a training program for functions impacted by the CSRD. In July 2024, the Internal Control function delivered an introduction training for data point owners, addressing key concepts around risks and how to design and implement mitigating actions.

The Internal Control function already worked on a multi-year plan to develop and deploy a control environment to cover the CSRD-related material topics. The multi-year plan includes a training program to educate certain relevant contributors (globally and locally) in risk management and the control environment required in the context of audited sustainability reporting.

Integration of risk assessment findings and internal controls into sustainability reporting processes, with periodic updates to the Board or its Committees

Starting from 2025, the Internal Control function will integrate findings reporting and monitoring related to sustainability reporting into its standard process, in a similar way to the process used for its Severe Impact Controls & Sarbanes-Oxley controls.

At present, the Audit Committee, whose remit includes assessing the effectiveness of internal control, works with the Appointments, Governance and CSR Committee on monitoring the rolling out the ongoing program and processes to improve the reliability of and control over our ESG data and reporting processes.

Sustainability goals for our products, services, customers and geographical areas

Sanofi's goals cover four areas of sustainability:

Access to healthcare

In 2024, two billion people around the world still lacked access to quality medicine and healthcare. We aim to change this by offering affordable access to medicines for underserved communities, while helping to build sustainable healthcare systems. • We are using our expertise to provide affordable access to quality care for the deprived populations who need it the most. We have created the Sanofi Global Health Unit (GHU), a non-profit business unit that operates in some of the poorest countries where it initially offers 30 of its essential medicines in therapeutic areas including cardiovascular diseases, diabetes, and cancer. The GHU aims to provide care to two million people with non-communicable diseases (NCDs) in 40 countries by 2030. • We are also helping 1,000 patients with rare diseases who lack access to treatments by donating 100,000 vials of medicine each year. This fulfills a commitment of over 30 years to patients with rare diseases, such as Fabry, Gaucher or Pompe disease. • For many people, the affordability of our medicines is not the only barrier to access – availability is a further barrier. That is why we are developing a global access plan to make all new products available in selected markets with unmet needs, within two years of initial launch.

R&D for unmet medical needs

As part of our commitment to society, we believe it is essential to determine how our science can benefit vulnerable communities: • we continue to contribute to efforts led by the World Health Organization (WHO) to eradicate poliomyelitis and eliminate sleeping sickness – two diseases that affect marginalized communities – with vaccines and new therapeutics; and • we have identified significant disparities in treatment for children with cancer. Our R&D teams of world-renowned researchers have a deep understanding of the specific challenges of pediatric oncology and are keenly aware of the need for appropriate treatments. We have therefore devoted our teams to this cause.

A healthy planet

We are mindful of our ambition to support initiatives to protect the planet. Planet Care is our environmental program that seeks to reduce the direct and indirect impacts of our operations and products on the environment. It covers the entire life cycle of our products — from raw materials to their potential end-of-life impact. We commit to: • on climate change mitigation (i) reducing our greenhouse gas (GHG) emissions (Scopes 1 & 2) by 55% and our Scope 3 emissions by 30% by 2030 (versus 2019), and our emissions across all Scopes by 90% by 2045 (targets validated by the SBTi – Science Based Target initiative), (ii) supplying all of our sites with 100% renewably-sourced electricity by 2030, (iii) establishing an eco-fleet by 2030, (iv) committing the supply chain to reduce its Scope 3 emissions; and • on products, improving the environmental profile of our products by eco-designing all new products by 2025. By 2027, we will no longer use plastic in our vaccine syringe blister packs. This truly complex industrial task will address the problem of plastic waste in the environment and help to minimize our climate impact.

Inclusion and diversity of employees and communities

We are driven to make our workplace and communities inclusive and diverse by: • achieving gender representation in senior leadership; • fostering sustainability and inclusion in the ecosystems where we operate, serving communities through volunteering; and • making our commitment to society an integral part of our leaders' career development paths, thus strengthening the social impact of their decisions. The Leaders to Citizens program was launched in 2022 to encourage the Company's senior leaders to actively advocate CSR efforts and continue embedding these principles in all of its operations.

Elements of Sanofi's CSR Strategy that relate to or impact sustainability matters

Incorporating the CSR strategy, Sanofi's Play to Win core business strategy outlines our ambition to become a leading immunology company. This shift in portfolio focus has implications for our CSR strategy regarding our impact on people and the environment. There may be positive impacts on environmental sustainability matters: most immunology products are biologics, meaning fewer pharmaceuticals are released in the environment via patient use, and fewer chemicals are required for production. There may also be implications for our access to healthcare strategy, as immunology products are generally more expensive and produced at lower volumes. Furthermore, acquisitions made to fuel Sanofi's R&D pipeline may further challenge our ability to meet our access to healthcare commitments, such as access planning for products developed or commercialized under strategic external partnerships.

Description of products, services, markets, customers

Sanofi's activities are organized around the following categories: Immunology, Rare Diseases, Neurology, Oncology, Other pharma, Vaccines, and Opella (divestment process in-progress).

We have business operations in approximately 63 countries and our products are available in more than 160 countries. Sanofi is the tenth largest pharmaceutical company globally by sales. Our main markets in terms of net sales are the United States, followed by the European region, and other markets such as China and Japan.

We work with regulatory bodies who approve our medicines and vaccines for safety and efficacy, health authorities who valuate our products, healthcare practitioners who prescribe treatments and patients who benefit from our medicines and vaccines.

Sanofi employees around the world

Sanofi's workforce comprises 82,878 employees — see section 3.3.1. Own workforce (ESRS S1). The company operates through 52 manufacturing sites and has 13 research and development (R&D) facilities in countries across the globe.

Description of the business model and value chain

Our business model is centered on pharmaceutical innovation, with research and development (R&D) as the primary input. We gather inputs from a global network of suppliers and partnerships with research institutions. Inputs are secured by investing in R&D, maintaining quality control measures, and seeking to ensuring compliance with regulations. We also actively participate in collaborations and alliances on cutting-edge technologies and compounds to enhance our product pipeline.

Our outputs include a diverse portfolio of pharmaceutical products and vaccines to address a wide range of therapeutic areas, benefiting various stakeholders: • patients (end-users), through access to innovative and effective treatments that improve their health and quality of life; • other stakeholders, with healthcare providers gaining access to advanced medical solutions, and communities benefiting from our commitment to corporate social responsibility and public health initiatives.

Investors may benefit from Sanofi's financial performance and growth potential, driven by a steady stream of new product launches and expanding market share.

Sanofi operates within a complex value chain that spans upstream and downstream activities and stakeholders. • Upstream operations include: – sourcing raw materials and active pharmaceutical ingredients (APIs) from a network of key suppliers who are selected based on pre-established criteria; – partnering with contract manufacturers for production; – partnering with clinical sites and research institutions to advance scientific research and clinical trials; and – purchasing/using capital goods and using financial services to fund its operations. • Downstream operations and stakeholders include: – transportation and distribution — we use both direct sales and partnerships with distributors, and work with service providers to transport products to their destination; – customers — health authorities, hospitals and healthcare professionals that prescribe and administer our Sanofi products; and – patients (end-users) who use Sanofi products and dispose of packaging and unused products (end-of-life).

The description above has considered the following: a. Key operations, resources, distribution channels and customer segments: Sanofi's key operations include R&D, manufacturing and marketing of pharmaceuticals and vaccines. Its key considerations are skilled personnel, state-of-the-art research facilities, and a global supply chain network. Distribution channels are diversified to include direct sales and working with wholesalers and pharmacies. b. Key business relationships and their characteristics: Sanofi's relationships with customers and suppliers are long-term collaborations that adhere to standards of quality and foster mutual commitment to innovation and public health. c. Cost structure and revenue: Sanofi's cost structure comprises substantial investment in R&D, production costs and marketing expenses. Revenue streams are primarily derived from the sale of pharmaceuticals and vaccines, with a focus on high-growth therapeutic areas. d. Potential impacts, risks and opportunities: Sanofi has in place a process to identify potential impacts, risks and opportunities within its sector, including regulatory changes, market competition and advancements in medical technology.

Key stakeholder groups and engagement

Below is a list of our key stakeholder groups. The overall goal of our engagement process is to build relationships, advance Sanofi's objectives and sustainability commitments and obtain outside views. We consider the outcomes of this dialogue in our CSR strategy. The examples provided in the table are not exhaustive.

The sustainability report was presented to the Bureau of the Comité de Groupe France on February 13, 2025.

Amendments to strategy and business model to address the views and interests of stakeholders

In 2021, Sanofi built its CSR strategy based on the perspectives of internal and external stakeholders via a materiality assessment and in alignment with its business priorities. The identified topics were used to design the CSR strategy — built into Sanofi's core strategy and business model — thereby addressing stakeholders' views and interests.

We regularly engage with our patients to ensure that their key concerns and expectations are included in our strategy, especially regarding products and geographical markets. We are also involved in several health and pharmaceutical trade associations that address various CSR topics. This gives us further insight into sector trends and stakeholder interests with respect to products and geographical markets in particular.

The table below indicates some of the key shareholder views and interests, as identified through ongoing dialogue, which influence our corporate and CSR strategies in the years ahead.

Plans for continuously improving stakeholder engagement

In 2024, we launched the Sanofi Patient Promise to further strengthen our engagement with patient organizations. We will report back on its effectiveness in 2025. Through ongoing dialogue, we are deepening our commitment to patients to better understand and serve their needs. For more information, see section 3.3.3.3. Patient Engagement.

How administrative, management and supervisory bodies are informed of views and interests of affected stakeholders with regards to impacts

The CSR strategy and its performance is presented to the Board of Directors at least once a year. The presentation includes new insights and views gathered from stakeholders. The quarterly presentations to the Appointments, Governance and CSR (AGC) Committee also address stakeholder views and interests in light of Sanofi's CSR strategy and proposed adjustments. The Audit Committee oversees the Double Materiality Assessment process and outcomes performed in 2024 in accordance with the CSRD and related methodology established by EC, EFRAG and other guidance - refer to the CSRD Disclaimer and Explanatory Note. and thereby seeks to be well informed of Sanofi's analysis of its impacts on affected stakeholders.

The executive leadership team is also regularly informed of views and interests of affected stakeholders via the communication of results of key stakeholder surveys, such as One Voice (employee survey) and an annual ESG investor perception study. Key functions in contact with stakeholders, such as CSR, Public Affairs and Media Relations, report directly to Sanofi's Head of Corporate Affairs who is a member of the Executive Committee.

Material impacts, risks and opportunities

The tables below list the impacts, risks and opportunities (IROs) identified as material to Sanofi following the double materiality assessment (DMA) performed in 2024 in accordance with the CSRD and related methodology established by EC, EFRAG and other guidance - refer to the CSRD Disclaimer and Explanatory Note. The full descriptions and all disclosures in accordance with ESRS 2 - SBM-3 can be found under the relevant topical standard.

Next to each (sub) topic in the tables it is specified: • whether it has a positive impact (IP) or negative impact (IN), or is a risk (R) or an opportunity (O); and • where the topic is located in Sanofi's value chain, i.e. upstream, own operations, or downstream.

All IROs have been scored regardless of the mitigation measures implemented by Sanofi. The materiality assessment was conducted based on gross impacts, risks and opportunities in accordance with the CSRD and related methodology established by EC, EFRAG and other guidance. For more information on the methodology, see section 3.1.4.1. IRO-1: Description of the process to identify and score IROs.

ENVIRONMENT

SOCIAL

GOVERNANCE

*The following IROs are entity-specific and not explicitly covered by the ESRS: • Medical and Bioethics (I) • Supply Chain Continuity (I)

Sanofi conducted its double materiality assessment at group-level in accordance with the CSRD and related methodology established by EC, EFRAG and other guidance - refer to the CSRD Disclaimer and Explanatory Note.

Current and anticipated effect of its material IROs on Sanofi's business model, value chain, strategy and decision-making

Sanofi has longstanding experience in identifying material topics. It published its first materiality assessment in 2010, and has performed an update approximately every two years based on a formalized stakeholder engagement process. The main goal of our legacy materiality assessments was to ensure the appropriateness and relevance of our CSR strategies in addressing key business and stakeholder concerns.

The material IROs identified in the DMA are intended to generally align with the CSRD methodology, as described in ESRS 1, and previous materiality assessments results. We believe that our CSR strategy already addresses aspects of the most material impacts and risks identified in the DMA:

The IROs with lower materiality are addressed in dedicated policies and approaches to ensure adequate focus and resource allocation.

Linking material impacts to Sanofi's strategy and business model

Our impacts originate from, and are connected to, our strategy and business model. • As a pharmaceutical company with a diversified product portfolio, we are contributing to better healthcare outcomes through our medicines and vaccines and, therefore, have positive impacts on patients. • We serve patients worldwide: medical innovation seeks to balance benefits and risks to improve patients' lives, making patient safety a priority. • We have a large international industrial footprint: the production, distribution and use of Sanofi's product has environmental impacts. • Sanofi's international upstream and downstream value chain to support our efforts can create negative environmental and social impacts, such as environmental pollution and labor rights issues. • We operate in a highly regulated environment: the pharmaceutical sector has a strong focus on medical ethics and business conduct requirements.

Financial effects of Sanofi's material risks

The material risks identified in the DMA as per the CSRD methodology are already included in our risk management framework. These identified material risks are gross risks in accordance with the CSRD and related methodology established by EC, EFRAG and other guidance and do not take into account mitigation measures in place. The level of control over those risks is monitored by our risk management governance process. We therefore do not expect a material adjustment to the financial statements due to those material risks.

Resilience of Sanofi's strategy and business model regarding its material impacts and risks

Key gross resilience-related risks identified during the DMA process in accordance with the CSRD methodology are: • climate adaptation — the risk that we do not anticipate and prepare for the adverse effects of climate change by taking appropriate action to prevent or minimize the damage they can cause to our business (includes transition and physical risks); • impacts and dependencies on ecosystem services, i.e. provisioning and supporting services — the risk that we or our suppliers are unable to secure the natural resources needed to produce and package its medicines and vaccines (e.g. plant materials, animal raw materials, materials used in packaging) and the risk that the prices of such natural resources increase significantly due to scarcity and competition for dwindling resources, leading to financial risk; • talent attraction — the risk that we will be unable to attract and/or retain people with the necessary skills and experience, which could adversely affect our ability to implement our strategy and attain our objectives (financial risk); and • supply chain continuity — the risk of supply chain interruptions or loss of inventories due to unforeseen events, which could lead to loss of revenue.

The above resilience issues are monitored by Sanofi's risk management governance.

Description of the process to identify and score IROs

Sanofi developed its DMA methodology in early 2024 in accordance with EFRAG's ESRS 1 guidance "IG 1 Materiality Assessment Implementation Guidance" and "IG 2 Value Chain Implementation Guidance" (December 23, 2023 versions). Sanofi consulted the final versions of the IG (May 2024). Sanofi's DMA methodology seeks to account for EFRAG's guidance with Sanofi's existing risk processes and thresholds established at Company level. Sanofi's DMA was conducted top-down at Company-level.

Identification of IROs to be assessed and their definition

Sanofi created a list of potential IROs, pre-filled with the IROs derived from the sustainability matters covered in the relevant topical ESRS as per ESRS 1, Appendix A, AR 16, up to the sub-sub-topic level for the DMA, where sub-sub topics are defined in the Standard. Some sub-sub-topics were merged into the same IRO when no difference in materiality scoring was identified. In biodiversity, for example, land degradation, desertification and soil sealing IROs were bundled under impacts on the extent and condition of ecosystems. Where no sub-sub-topics are defined in ESRS 1 AR 16, materiality was assessed at the sub-topic level.

Sanofi then added to the list other potential IROs relevant to Sanofi (e.g. Medical and Bioethics) that are not covered or not explicit enough under the sustainability matters described in ESRS 1 AR 16. These IROs were already identified in the previous materiality assessment conducted by Sanofi in 2022 (based on available guidelines at the time, for more information on the previous assessment, see our Statement of Extra-Financial Performance for 2023, Section 3.2.3. Double Materiality Assessment).

To identify additional risks not listed in the ESRS, Sanofi compared the list of potential IROs with entity-specific risk profiles (assessments updated annually) and added potential risks where necessary, identified pursuant to the DMA and the CSRD process, in accordance with the CSRD and related methodology established by EC, EFRAG and other guidance - refer to the CSRD Disclaimer and Explanatory Note.

Consideration of operational and regional specificities

Prior to the identification of IROs, Sanofi completed a context analysis as recommended under EFRAG IG 1. It identified its key products and activities, geographical regions, affected stakeholders and value chain participants, as specified in SBM-1. Sanofi is a multinational company with a broad geographical and industrial footprint, serving patients worldwide. For more context see "Evaluation of gross versus net impacts, risks and opportunities" below.

Sanofi considered that business relationships in lower-income countries are higher risk, in both human rights and environmental matters, due to less stringent national regulations in place. To identify human rights-related adverse impacts, for example, Sanofi assessed the presence of upstream and downstream business relationships in non-OECD countries.

Use of Sanofi's due diligence process for the identification of negative impacts

Sanofi is subject to the French duty of vigilance law of March 27, 2017 for parent and ordering companies. Sanofi's Vigilance Plan covers the Company's activities, those of its fully consolidated companies, and the activities of tier-one suppliers and subcontractors. The previous Vigilance Plan's salient issues — as identified and managed using Sanofi's methodology for identifying and prioritizing major risks to people and the environment — were considered when identifying IROs. Impacts identified pursuant to the DMA, from the CSRD perspective have then been used to define the Vigilance Plan salient issues, moving forward.

IRO description

For each IRO identified pursuant to the DMA in accordance with the CSRD and related methodology established by EC, EFRAG and other guidance - refer to the CSRD Disclaimer and Explanatory Note, Sanofi prepared a description of the impact, risk or opportunity as it manifests for Sanofi. It is therefore the company-specific definition, which could nonetheless be applicable to several companies. The descriptions were reviewed together with the owners of the topical ESRS.

External stakeholder consultation

Sanofi did not directly involve external stakeholders for the CSRD-specific DMA due to the short period for conducting the first analysis and because stakeholders had been consulted relatively recently, in the previous financial year (second half of 2022), and their input was still considered relevant. Sanofi may consider further involvement of external stakeholders in the DMA process in the future. Sanofi engaged with external stakeholders during its materiality analysis in 2022. In this exercise, external stakeholders were consulted on the 16 material topics that had been defined. The topics were grouped into bundles, and each stakeholder was assigned to one bundle, associated with his or her area of expertise. Stakeholders were asked their views on the IROs for Sanofi regarding the topics in their assigned bundle. The outputs of the interviews were aggregated for all interviewees and summarized in factsheets, one for each topic.

Value chain and own operations

For each IRO, it was defined whether the impact, risk or opportunity occurred in Sanofi's own operations, or its upstream or downstream value chain. An impact can occur at several levels for the same IRO. Below are the definitions of the three areas which also apply to impact and financial materiality.

Evaluation of gross versus net impacts, risks and opportunities

For the materiality assessment, Sanofi assessed gross impacts, risks and opportunities in accordance with the CSRD and related methodology established by EC, EFRAG and other guidance - refer to the CSRD Disclaimer and Explanatory Note. The gross approach evaluates impacts, risks and opportunities without taking into account measures put in place by the company to prevent, mitigate or correct impacts or risks, hence without considering the level of control on impacts or risks. However, Sanofi did consider context when assessing gross impacts, risks and opportunities. The context considered includes (but is not limited to): • that Sanofi is a pharmaceutical company; • that Sanofi is a European company, subject to European (and specifically French) regulations; • Sanofi's industrial footprint; • Sanofi's product portfolio; and • that Sanofi serves patients worldwide.

Examples of "measures" or "levels of control" that were not taken into account are for instance the Planet Care program and Sanofi's anti-corruption and anti-bribery program.

This gross approach, in accordance with the CSRD methodology, does not enable any direct comparison with risk factors disclosed as part of financial disclosures which also take into account mitigation measures and level of control.

Assessment and scoring of IROs

The final materiality score was calculated as follows: • Impact Materiality = Severity² x Likelihood • Financial Materiality = Size of Financial effect² x Likelihood

Severity and financial effect were squared to give further emphasis to the severity over the likelihood of the impact, risk, or opportunity. This practice is aligned with Sanofi's risk methodology and ensures that the most severe risks and impacts are adequately captured and reflected by the methodology.

The following materiality rating matrix was obtained using this methodology:

Materiality thresholds (risk methodology)

Each identified IRO is rated between 1 and 100 — 100 being the highest score possible (Severity at 5² x Likelihood at 4). The threshold for the materiality of an issue was set at 18 and above by Sanofi's leadership.

An existing in-depth scenario analysis has been leveraged to assess climate related IROs.

Severity

In line with ESRS 1, for impact materiality, severity was assessed using three sub-criteria: Scale, Scope and Remediability. Any of the three characteristics of severity can make an impact severe. For the ratings, Sanofi selected those of its risk methodology where issues are rated as 1, 2, 3, or 5 for the equivalent of "severity". Sanofi put in place and applied a process to determine the correspondence of each rating number with the double materiality sub-criteria. Judgements on the ratings are based on available studies, existing function risk profiles and expert opinions, and are therefore subjective and subject to ongoing review and change in accordance with the CSRD and related methodology established by EC, EFRAG and other guidance - refer to the CSRD Disclaimer and Explanatory Note.

For any particular IRO under evaluation, the highest rating of the three severity sub-criteria is used as the final severity score. For example, if an IRO has a severity scale rating of 2, a scope of 5 and a remediability of 1, the final severity score is set at 5.

Decision-making process and internal control procedures

General validation process

In general terms, Sanofi performed the double materiality assessment as follows:

1. The ESG team completed the evaluations based on internal studies and documentation or external scientific reports. The team also considered the previous materiality assessment constructed with internal and external stakeholder views.
2. The evaluations, were then discussed, adjusted, and approved with the subject-matter experts. The evaluations were also compared to the function-specific risk profile where available (risk profiles are updated annually).
3. The finalized file was submitted to and reviewed by Sanofi's Risk Management Team.
4. The CSRD-related materiality ratings, determined in accordance with CSRD, were approved by Sanofi's Senior Leadership, via presentation to the relevant Committees:
   1. the Planet Care Steering Committee for Environmental IROs;
   2. the CSR Committee for Social and Governance IROs.

Integration of the identification, assessment and management of IROs in the overall risk management process

Sanofi has historically integrated risk management in its processes at the highest decision-making level. The Risk department was initially created within the CSR function, linked to the Executive Committee, to facilitate collaboration between the audit, risk and CSR functions. Initially, three areas were included in the risk analysis: • the impact on Sanofi's business which is now clarified as the impact on Sanofi's profit and growth; • the impact on patients which has since been extended to employees; and • the impact on Sanofi's reputation.

The latter, reputational risk, has undergone the most changes to become the overall impact on stakeholders. This includes Sanofi's impact on society as well as the legal risk in terms of responsibility which now goes far beyond our legal responsibility to shareholders. Given the early integration of risk assessment and management into Sanofi's strategy and business model, impacts such as those on human rights and animal welfare have been assessed for several years, independent of their financial materiality to the Company.

The finalized double materiality assessment was submitted to Sanofi's Risk Management team. The risk team performed an alignment check to ensure consistency with Sanofi Group risk ratings. Inconsistencies were discussed and adjustments were made to the double materiality assessment. Each IRO was reviewed individually, as sometimes calculated ratings do not accurately reflect the prevalence of a risk or impact.

This years' CSRD DMA was reviewed by the Risk Committee followed by the Audit Committee.

All disclosures related to IRO-2 can be found in the appendix of the sustainability statement, page 127.

Sanofi's commitment to Net Zero

Our updated commitment towards Net Zero by 2045 was validated by the SBTi on January 19, 2023.

The SBTi's Target Validation Team has assessed Sanofi's corporate science-based targets and determined that the 2030 Scope 1 & 2 target and the 2045 Net Zero target are in line with a 1.5 °C trajectory.

To address Sanofi's corporate emissions, a 2045 Scope 3 target was set for a 'net zero' aligned 93.9% of base-year Scope 3 GHG emissions. Under the target, modeled using the Absolute Contraction approach, absolute Scope 3 emissions would be reduced by 30.0% by FY2030 from the FY2019 base. Our 2030 target meets the minimum ambition for the 2 °C pathway under the Absolute Contraction Approach.

Main GHG reduction targets

The main GHG reduction targets versus the 2019 baseline are described in the table below:

Additional supporting goals

1. Increase our annual supply of renewable electricity to 80% in 2025 and then 100% in 2030;
2. Invest in carbon offset projects that combine a positive impact on both communities and the environment to offset residual emissions from 2030, on top of a science-based emission reduction trajectory;

For Sanofi to reach these ambitious commitments, the company has defined an emissions reduction program and has set up several action plans across its own activities (Scopes 1 & 2) and full value chain (Scope 3).

Decarbonization levers for reducing Scope 1 & 2 GHG emissions and progress to date

The figures below detail the levers to achieve the Scope 1 & 2 target to reduce GHG emissions by -55% by 2030 from a 2019 baseline, as well as progress to date.

Scopes 1 & 2 (GHG protocol): 2019 GHGs emissions to 2024 (-47%)

Scope 1 & 2 emissions are linked to energy consumption, leakage of refrigerants and Sanofi's vehicle fleet: Sanofi has adopted an approach that combines energy efficiency (consume less, consume smarter) with decarbonization of energy supplies (consume differently).

Reduced consumption and improved energy efficiency

• Sanofi's energy efficiency approach extends to relevant activities, buildings, processes and utilities. It takes in the design of new buildings, and the medical representative vehicle fleets. Energy saving programs are in place at all relevant sites. Sanofi's Energy efficiency program is managed via a management system that covers all relevant operations, includes a reference framework, an internal audit and performance review program. – The Energy management system of Sanofi has been assessed and certified as meeting the requirements of ISO 50001:2018 for the following activities: research, development, manufacturing, distribution centers and related support functions performed in the Business Units. • Various levers are being activated (depending on the activity carried on at the site), with a specific focus on air treatment systems that ensure high-quality environments in manufacturing and R&D buildings, which can account for up to 70% of the energy consumption of these buildings. However, these systems are important for the quality and safety of Sanofi's medicines, and any alterations must be validated. The Company therefore plans to reduce its energy consumption at existing facilities by 15% in 2025, compared to 2021. • Internal standards have been issued, requiring energy efficiency to be built into the design and selection of plant and equipment that use energy. Sanofi's Sustainable Buildings Charter also helps promote sustainable and energy-efficient buildings that are, in many cases, certified to LEED (Leadership in Energy and Environmental Design), BREEAM (Building Research Establishment Environmental Assessment Method) or HQE (Haute Qualité Environnementale) standards.

Decarbonization of energy

Sanofi also operates a low-carbon energy policy, favoring the use of lower-carbon energies for projects and buying in electricity from certified renewable sources. In September 2020, the Company made a public pledge that by 2030, 100% of the consumed electricity will come from renewable sources, by joining the RE100 initiative. Transition to renewables relies on the following strategies: • installation of solar panels; Sanofi can self generates up to 25 GWh per year. The largest plant, which will produce 11.5 GWh per year, is located on the Sisteron site. Progress to date: the output from the solar panels installed rose from 0.5 GWh at the end of 2021 to 18.8 GWh at the end of 2024, representing between 5% and 20% of consumption on the nine largest project sites located in France, India, Italy, China, Spain & Brazil; • guaranteed certified origin energy contracts; • a renewable electricity Power Purchase Agreement (PPA) is in place in Mexico to supply energy to Sanofi's two Mexican sites. Plans to extend this model to Europe and the United States is in progress; we notably signed 11 Power Purchase Agreements (PPA) in 2024 for a maximum of 20 years for an annual volume of 238.5 GWh per year, representing 50% of electricity needs in France; • transition to renewable thermal energy to meet heating needs by increasing the use of biomethane and biomass. A long-term biomethane supply contract (2024-2030) has been signed in France for 210 GWh per year.

As a result, the use of renewables has been raised from 16% of electricity consumption in 2019 to 85% in 2024.

Refrigerant control

Regarding emissions linked to the leakage of refrigerants, Sanofi has put policies in place to manage the use of carbon-intensive refrigerants like HFC & HCFC. These include switching to substitute refrigerants with a lower global warming impact, improving leak prevention, and systematically analyzing accidental discharges so that lessons can be learned and shared across sites. Progress to date: since 2019, Sanofi has reduced the impact of refrigerant discharges by 41%, avoiding 9,300 tons of CO2e emissions.

Sustainable vehicle fleet

We have also pledged to optimize our vehicle fleet (subject to availability of suitable models in the regions where we operate), to reduce greenhouse gas emissions from our fleet. Our aim is for our eco-car fleet to reach 80% of total fleet by 2030. An eco-car fleet as defined by internal criteria combines hybrid, electric and biofuel vehicles.

Regarding emissions from Sanofi's vehicle fleet, the global car fleet policy was reviewed in 2023 so as to cover the cost of installing EV charging points at home for employees who opt for an electric vehicle. A policy for sales representative travel was also introduced to implement an eco-driving policy and culture (e.g., with eco-driving courses), improve fuel efficiency, reduce travel and convert Sanofi's car fleet to an eco-fleet criteria (biofuel, hybrid and electric vehicles). Progress to date: already 50% of Sanofi's fleet meets the eco-fleet criteria and CO2e emissions from the sales forces were cut by 50% versus a 2019 baseline.

Decarbonization levers for reducing Scope 3 GHG emissions and progress to date

Scope 3 emissions account for 91% of Sanofi's total emissions. The figures below detail the levers to achieve the Scope 3 target to reduce GHG emissions by -30% by 2030 from a 2019 baseline, as well as progress to date.

Scope 3 (GHG protocol): 2019 GHGs emissions to 2024 (-10%)

Decarbonization of inputs and raw materials

In terms of decarbonization, we are actively working to reduce the use of virgin resources and reuse materials more efficiently in order to mitigate the impact of our products' GHG emissions. Emissions from the purchase of raw materials and subcontracting represent half of Sanofi's emissions (51% for in 2024), making them the primary lever for decarbonization. To reduce the impact of our products, we are reviewing our manufacturing processes and seeking to replace the most carbon-intensive raw materials with more environmentally sustainable alternatives. The use of alternative supplies for certain carbon-intensive raw materials will improve our level of emissions from 2024 onwards. We are identifying less carbon-intensive suppliers for our main raw materials. The country of manufacture and origin of our raw materials has become a key element of decision-making when choosing suppliers. For example, the emissions linked to one of our most carbon-intensive raw materials has been significantly reduced since 2019 by moving sourcing to less carbon intensive suppliers in Europe (Spain and France).

Supplier engagement

Purchased goods and services and capital goods represent 67% of Sanofi's total emissions. We are therefore engaging with suppliers to work towards their improving their environmental footprint and fighting climate change. Sanofi's Supplier Engagement Program: • sets clear environmental expectations on activities to be completed; • provides guidance on how to complete activities; and • supports suppliers less advanced/mature on sustainability matters.

As part of the program, those suppliers need to commit to: • calculate their Scope 1+2+3 emissions and report them publicly; • get a CDP Climate score of A or B; • engage with their own supply chain; • set SBTi (Science Based Targets initiative) targets; and • sets a target for 100% renewable electricity by 2030.

In 2024, there were 205 suppliers engaged in the Supplier Engagement Program, covering 75% of supplier-related emissions and representing 50% of our procurement spend.

Moreover, through the Energize Program, a collaborative effort within the pharmaceutical industry, we help our shared supply chains convert to renewable energy. We are also a member of the Pharmaceutical Supply Chain Initiative where, among other efforts, a decarbonization maturity model has been developed to help suppliers evaluate how responsible their current practices are toward Net Zero, as well as provide corresponding content to help them proceed to the next level.

In 2023, the Sanofi CEO signed an Open Letter to Suppliers published by members of the Sustainable Markets Initiative Health Systems Task Force to set out minimum targets for supplier decarbonization.

Reducing air cargo shipments in favor of more sustainable modes of transportation

To decrease emissions related to the distribution of pharmaceuticals within our international transport network, we are using less air transport and more sea shipment, road and rail shipment, which are less carbon-intensive. Our other decarbonization efforts include: • increasing the fill levels of trucks and sea containers; • developing rail for intra-European deliveries and France-China deliveries; • experimenting with electric and natural gas vehicles for in-town deliveries and for pre-carriage shipments; • designing packaging to reduce volume and optimize transport; • grouping product shipments and pooling transport to reduce the number of trucks on the road; • starting analysis of new sea shipment with hybrid or renewable propulsion; • developing multimodal transports solutions.

Since 2023, we continued to reduce our carbon footprint by maximizing sea transport for vaccines shipments (excluding flu vaccines) from France to 13 countries (Australia, Japan, Malaysia, South Korea and Brazil for instance). Potential new sea routes are under assessment or validation for the transport of vaccines.

Reducing other downstream emissions

Downstream emissions will be impacted by packaging and device improvements, such as Sanofi's commitment to PVC-free blister packaging for its vaccine syringes. Such actions contribute to the decarbonization of downstream emission categories such as 'transportation and distribution' and 'end of life treatment of sold products'.

Investments planned to support the climate transition roadmap

Sanofi has estimated the costs of its climate transition roadmap for its whole scope until 2030. The Executive Committee, through the annual strategic planning process, has validated the funding needed to meet 2030 public climate commitments. The investment represents between €300 million and €400 million annually on average.

Alignment of the transition plan with the overall business strategy and financial planning

The Planet Care roadmap is embedded in our strategic financial planning processes. We work on the integration of our climate change mitigation and adaptation projects, into our short and long-term strategic financial planning process. This is an annual process culminating in executive endorsement of key strategic investments over a ten-year horizon.

Approval of the transition plan by supervisory bodies

Sanofi's Board of Directors validates the Company's overall strategy, oversees its implementation, and regularly monitors delivery. As part of this role, the Board monitors Planet Care (Sanofi's environmental program), including the climate commitments, and reviews the climate transition plan at least once a year.

With regard to the Sanofi's climate change mitigation transition plan, it aims to provide an understanding of the Company's past, present and future mitigation efforts, to ensure that its strategy and business model are compatible with the transition to a sustainable economy. It is understood, however, that to date there is no consensus on targets or trajectories for reducing greenhouse gas emissions at company level (the objectives being set at national level), which would make it possible to guarantee the compatibility of a strategy with a scenario limiting global warming to 1.5 °C, in accordance with the Paris Agreement.

Policies related to climate change mitigation and adaptation

The full description and objectives of our CSR strategy may be found in ESRS 2 and our Road to Net Zero is presented in detail in our transition plan disclosure.

Aligned with the Task Force on Climate-related Financial Disclosures (TCFD) framework, reflecting key financial stakeholders concerns, our Climate-related Financial Disclosures & Risks and Opportunities program aims to identify climate risks and opportunities and develop and implement adaptation plans to address climate risks and opportunities.

Most of the sub-topics identified in the Climate Transition and Physical Impact risk category are monitored in dedicated working groups. Short-, medium- and long-term mitigation plans have been defined and are being implemented. Monthly reporting is escalated to the Climate Risk and Opportunities Committee (CROC) and progress is presented quarterly to the Executive Committee Climate Risk Owner by the Global Heads of Risk Management, CSR and the CROC leader.

Targets and actions related to the Climate Change — Road to Net Zero

The main targets and progress against targets are presented in the following sections: 3.2.1.4.2. GHG emissions for targets related to GHG emission reductions and 3.2.1.2. Transition plan for climate change mitigation (E1-1) for targets related to decarbonization levers. Please refer to section 3.2.1.2. Transition plan for climate change mitigation (E1-1) for actions and resources related to the Climate Change – Road to Net Zero sub-program of the CSR policy.

Targets and actions for the Climate-related Financial Disclosures & Risks and Opportunities

We are working to identify targets to drive our adaptation policies and actions. We aim to define these targets by the end of the 2026 fiscal year. The internal targets are set by each working group in accordance with their adaptation plans and internal stakeholders, who monitor the actions, and are validated by the Climate Risks & Opportunities Committee (CROC).

The table below outlines the high-level actions corresponding to each of the identified climate-related risks and opportunities, as well as the resources currently assigned to these actions:

The main targets and progress against targets are presented in the following sections: 3.2.1.4.2. GHG emissions for targets related to GHG emission reductions and 3.2.1.2. Transition plan for climate change mitigation (E1-1) for targets related to decarbonization levers. Please refer to section 3.2.1.2. Transition plan for climate change mitigation (E1-1) for actions and resources related to the Climate Change – Road to Net Zero sub-program of the CSR policy.

Climate-related targets and progress

Main GHG reduction targets versus the 2019 baseline:

Additional supporting goals:

1. Increase our annual supply of renewable electricity to 80% in 2025 and then 100% in 2030;
2. Invest in carbon offset projects that combine a positive impact on both communities and the environment to offset residual emissions from 2030, on top of a science-based emission reduction trajectory;

Progress to date on key targets:

Scope 1 & 2 emissions reduction:

• 47% reduction achieved by 2024 (versus 2019 baseline)
• From 708 ktCO2eq in 2019 to 374 ktCO2eq in 2024
• Target: 55% reduction by 2030

Scope 3 emissions reduction:

• 10% reduction achieved by 2024 (versus 2019 baseline)
• From 4,265 ktCO2eq in 2019 to 3,823 ktCO2eq in 2024
• Target: 30% reduction by 2030

Renewable electricity:

• 85% of electricity consumption from renewables in 2024 (versus 16% in 2019)
• Target: 100% by 2030

Vehicle fleet:

• 50% of Sanofi's fleet meets eco-fleet criteria
• CO2e emissions from sales forces cut by 50% versus 2019 baseline
• Target: 80% eco-fleet by 2030

Supplier engagement:

• 205 suppliers engaged in the Supplier Engagement Program in 2024
• Covering 75% of supplier-related emissions
• Representing 50% of procurement spend

Other achievements:

• 41% reduction in refrigerant discharge impact since 2019, avoiding 9,300 tons of CO2e emissions
• 18.8 GWh generated from solar panels at the end of 2024 (versus 0.5 GWh in 2021)
• 11 Power Purchase Agreements signed in 2024 for 238.5 GWh per year
• 210 GWh per year biomethane supply contract signed for France (2024-2030)

Energy consumption and mix

Energy consumption by source (2024, 2023, 2022, 2019 baseline)

Energy consumption is reported in MWh, by energy type, calculated on a like-for-like basis (historical values recalculated to align with Sanofi's 2024 reporting scope).

Scope: The reporting scope covers all Sanofi sites other than tertiary and logistics sites for certain indicators. Values are calculated on a like-for-like basis; 2019, 2022, and 2023 values have been recalculated to align with Sanofi's 2024 reporting scope.

Nuclear calculation methodology: Nuclear power consumption is calculated by multiplying non-renewable electricity consumption at each site by the publicly available percentage of local grid electricity from nuclear plants.

Energy intensity (high climate impact sector)

As a high climate impact sector, Sanofi reports energy intensity based on net revenue:

• 2024 energy intensity: 0.065 MWh/k€

Energy production, consumption, and sales breakdown

Note on steam: Detail on purchased vs self-generated steam is not available. Figures include purchased, sold, and consumed steam.

Contractual instruments for renewable energy

Methodology: Sanofi uses Power Purchase Agreements (PPAs), Renewable Energy Certificates (RECs), Guarantees of Origin (GO), Energy Attribute Certificates (EACs), International RECs (I-RECs), J-Credit (Japan), and Renewable Gas Guarantees of Origin (RGGO) for biomethane. On-site photovoltaic solar energy is for self-consumption only without sale. In countries where Sanofi does not directly own solar panels, contractual instruments are used.

Energy reduction and renewable electricity progress

• 2024 renewable electricity share: 85% of total electricity consumption (vs 16% in 2019).
• Energy consumption reduction 2024 vs 2023: 4%, driven by enhanced energy-efficiency programs and facility optimization.
• Renewable electricity target: 80% by 2025, 100% by 2030 (RE100 initiative).

Energy efficiency system: Sanofi's Energy Management System is certified to ISO 50001:2018, covering research, development, manufacturing, distribution centers, and related support functions across Business Units.

Gross Scopes 1, 2, 3 and Total GHG emissions

Summary table (2024 vs. baseline and targets)

The following table displays Sanofi's 2024 GHG emissions results, with comparison to past years and to the 2019 baseline. Corresponding milestones and target years are displayed on the right side of the table. The SBTi emission reduction targets for 2030 cover Scope 1, 2, and 3 emissions within the boundaries defined.

Notes: (a) The following sites are involved in regulated emissions trading schemes: Marcy l'Etoile, Vitry sur Seine, Aramon, Waterford. The Val de Reuil site was involved until 2022 (emissions included in the % calculated in 2019 and 2022). (b) Emission categories as per the GHG Protocol. Categories 8 and 13 (upstream and downstream leased assets) and 14 (franchises) are not material for Sanofi.

Regulated emissions

In 2024, 12.0% of Scope 1 GHG emissions came from sites involved in regulated emissions trading schemes (primarily EU ETS). Sites include Marcy l'Etoile, Vitry sur Seine, Aramon and Waterford. Val de Reuil site was involved until 2022.

Biogenic CO₂ emissions (reported separately from Scope 1)

In compliance with the GHG Protocol and the CSRD, Sanofi reports biogenic CO₂ (CO₂b) outside of scopes (i.e. outside of its Scopes 1, 2 and 3), while all other GHGs from biomass production, transformation, and transport are included in Scope 1, 2, or 3 as appropriate.

GHG intensity per net revenue

The calculation of Sanofi's GHG intensity is based on annual Scope 1, 2, 3 emissions (location-based and market-based) in relation to Sanofi's annual net sales (for the calendar year, i.e. from January 1 to December 31).

Methodology and scope notes

Baseline year: Baseline year 2019 is used for Environmental performance monitoring. This year was chosen as it is representative of activities included in reporting scope and free from exceptional external factors (e.g. pandemic 2020–2022). Baseline restatement is maintained in line with GHG Protocol and SBTi requirements.

Scope 1 direct emissions: Scope 1 emissions include emissions from Sanofi's facilities (stationary combustion, process emissions) and vehicles owned or leased by Sanofi and used by medical sales representatives (mobile combustion), as well as refrigerant leakage (fugitive emissions). Emission factors used to calculate Scope 1 emissions include those of the GHG Protocol, the Department for Business, Energy & Industrial Strategy (UK) and cross-sector tools (e.g. ecoinvent).

Scope 2 indirect emissions: Scope 2 emissions result from energy purchased externally. Two methodologies are used:

• Location-based: Emission factors taken from data published by the International Energy Agency OECD/IEA, which set emission factors for year N-2 and estimate emission factors for year N-1 and N. Emission factors are updated annually.
• Market-based: Reflects the contractual instruments (Power Purchase Agreements, Energy Attribute Certificates, Renewable Energy Certificates) used by Sanofi to purchase renewable electricity.

Emissions from steam production are calculated on the basis of site-specific factors or estimates defined in company standards. Emissions from vehicles owned or leased by Sanofi and used by medical sales representatives are included in Scope 1. Emissions from personal vehicles of medical sales representatives are included in Scope 3.

Scope 3 indirect emissions: Indirect Scope 3 emissions are calculated in accordance with the GHG Protocol's Technical Guidance for Calculating Scope 3 emissions (version 1.0). Emission factors come from published databases (e.g. ecoinvent or the French Environment and Energy Management Agency (ADEME)), or from other standard calculation approaches such as Life Cycle Assessment or recognized product carbon footprinting.

• Category 1 (Purchased goods and services): Based on actual volumes. Digital calculation tool provides detailed figures. Scope covers production sites, R&D sites, tertiary sites and medical sales representatives' vehicle fleets. Data source: 72% primary activity data, 19% monetary proxy, 9% estimate (includes Opella due to divestment in progress). GHG calculation: 80% cross-industry emission factors, 20% internal PCF / LCA.
• Category 2 (Capital goods): Calculated on a purchase basis (in €). Data source: 100% monetary proxy. GHG calculation: 100% cross-industry emission factors.
• Category 3 (Upstream fuel & energy): Upstream emissions from the production of energy. Calculated by the SHERPA reporting tool for safety and environmental data. Data source: 100% modelled using Sherpa primary consumption data. GHG calculation: 100% cross-industry emission factors.
• Category 4 (Upstream transport): Includes transport from Tier 1 supplier to Sanofi sites, among Sanofi sites, from Sanofi sites to distribution centers, and distribution centers to customers. Calculated on the basis of freight forwarders' data and the quantity of products purchased. Data source: 73% primary activity data, 7% monetary proxy, 11% modelled based on average distance for transport of purchased goods. GHG calculation: 100% cross-industry emission factors.
• Category 5 (Waste): GHG emissions related to Sanofi waste treatment. Calculated by the SHERPA reporting tool: waste volumes and treatments. Data source: 100% primary activity data. GHG calculation: 100% cross-industry emission factors.
• Category 6 (Business travel): Includes business travel (train, air, car rental, hotel night) and sales representatives commuting by their own means. Calculated on the basis of transport and business travel data, and distances travelled. Data source: 100% primary activity data. GHG calculation: 100% cross-industry emission factors.
• Category 7 (Employee commuting): Calculated by the SHERPA reporting tool for safety and environmental data. Data source: 100% modelled based on employees commuting surveys. GHG calculation: 100% cross-industry emission factors.
• Category 9 (Downstream transportation): Impact of sold product refrigeration at pharmacies and in distribution centers. Calculated on the basis of the energy required for refrigeration of certain products sold. Data source: 100% modelled based on finished goods sold. GHG calculation: 100% cross-industry emission factors.
• Category 10 (Processing of sold products): Impact of formulation of APIs sold and packaging services of semi-finished products. Calculated on the basis of quantities of APIs present in products sold. Data source: 100% modelled based on API & semi-finished goods sold. GHG calculation: 100% cross-industry emission factors.
• Category 11 (Use of sold products): Refrigeration of products at patient's home (considered a necessity and the most impactful). The use of propellant gas is also estimated. Calculated on the basis of products sold containing propellant gas. Data source: 100% modelled based on finished goods sold. GHG calculation: 100% cross-industry emission factors.
• Category 12 (End-of-life): Impact of packaging disposal (waste treatment) and unused medicine disposal (specific collection or waste treatment). Calculated on the basis of (i) the share of unused medicinal products in products sold, and (ii) the recycling phase of packaging purchased. Data source: 50% modelled on primary data and assumed waste treatment, 50% modelled based on unused medicinal products study. GHG calculation: 100% cross-industry emission factors.
• Category 15 (Investments): Impact of Sanofi investments in external companies. Estimated on the basis of Scope 1 & 2 emissions for the year preceding Sanofi's acquisition in EUROAPI (30% of EUROAPI's Scopes 1 & 2 emissions). Data source: emissions data supplied by the supplier. GHG calculation: assume > 98% cross-industry emission factors.

Note on Opella: Due to the Opella business divestment currently in progress and the associated separation of IT systems, a monetary-based factor was used for Opella purchased goods emissions in 2024. Opella monetary contribution represents 21% of scope 3 category 1 Purchase of goods and services, and 14% of total Scope 3. For 2024, Opella was excluded from the eligibility and alignment analyses for revenue and OPEX. For CAPEX, the entity was taken into account for the full 2024 financial year.

Estimation for Q4 2024: To facilitate calendar year reporting, the last quarter (Q4) has been estimated for some indicators. For Scope 1 and Scope 2, previous years' seasonal trend (2022 & 2023) was used to estimate Q4 vs Q1, Q2, Q3 actual data. For Scope 3 category 3, the same method was used. For category 4, actual data for October and November were used, with December estimated. For categories 5, 6 and 7, previous years' seasonal trend was used. Total estimated emissions for Q4 represent 6.3% of total GHG emissions.

Scope 3 level of accuracy: Scope 3 data quality and modelling are assessed on eight criteria ranked from 1 to 5, evaluating data integrality, frequency of data capture, quality of data sources, completeness, method used, emissions factor scope, assumptions, and reliability of emissions factor source. Maturity grades range from 2.3 (category 12 End-of-life) to 4.8 (categories 3 and 5). Sanofi works continuously on improving Scope 3 GHG emissions calculation, especially focusing on improvements in the use of primary data and on purchase of goods, services and capital goods that represent 74% of Scope 3 emissions.

SBTi commitments: Sanofi commits to reduce absolute Scope 1 + 2 GHG emissions 55% by 2030 from a 2019 base year. On Scope 3, Sanofi commits to reduce absolute Purchased Goods and Services (3.1), Capital Goods (3.2), Fuel and Energy related activities not included in Scope 1+2 (3.3), Upstream Transportation and Distribution (3.4), Waste generated in operations (3.5), Business Travel (3.6) and Employee Commuting (3.7) GHG emissions 30% by 2030 from a 2019 base year. To achieve Net Zero target, Sanofi commits to reduce absolute Scope 1+2 and Scope 3 categories 3.1, 3.2, 3.3, 3.4, 3.5, 3.6, 3.7 and 3.12 (End-of-Life treatment of sold products) GHG emissions 90% by 2045.

Biogenic emissions methodology: In accordance with the GHG Protocol, Sanofi reports biogenic emissions separately from other Scope 1 and Scope 2 GHG emissions. The use of biomass entails various GHG emissions: (1) Biogenic CO₂ (CO₂b) during its combustion or biodegradation; (2) CH₄ and N₂O during its combustion or biodegradation; (3) CO₂, CH₄, N₂O, and other GHGs during its production, transformation, and transportation. Item (1) is not incorporated in Scope 1, but rather disclosed in a separate table. Items (2) and (3) are incorporated in Scope 1, 2, or 3 depending on where the biomass consumption occurs. For Scope 1, Sanofi calculates emissions from biomass it consumes in machines, vehicles, and buildings by applying appropriate emission factors to the quantity of biomass consumed. This calculation is performed only for very specific sites where Sanofi sources heat through local networks (India) and for biogas certificates purchased. For Scope 2, Sanofi calculates emissions from biomass consumed through heat generation suppliers by applying appropriate emission factors. This calculation is performed only for very specific sites where Sanofi sources heat through local networks (France). Source of emissions factors is ecoinvent 3.11. For remainder of carbon footprint, average biomass consumption of Sanofi's suppliers is considered very low at global level and included in associated average EFs used by Sanofi to calculate Scope 2 and 3. Consequently, biogenic CO₂ included in average EFs is not deemed material for CSRD reporting. Items (2) and (3) are calculated as part of EFs and incorporated in Sanofi's Scope 2 and 3; item (1) is not calculated in a separate inventory. If new information were to emerge on bioenergy consumption by Sanofi's electricity, heat or steam suppliers, or on other purchases, activities or processes that use a significant quantity of biomass, a reassessment would be made.

Sanofi's Climate risks scenario analysis

In 2023, Sanofi updated and published the results of its climate risk analysis performed in 2021. Sanofi used scenario analysis to perform a physical and transition risk assessment based on three of the IPCC climate change scenarios under two different time horizons (2030 and 2050): • a 1.5 °C scenario (RCP2.6) which assumes aggressive mitigation measures leading to transitional constraints; • a 4 °C scenario (RCP8.5) which reflects limited climate action, resulting in more pronounced physical impacts; and • a "most-likely" scenario based on a 2.8 °C warming projection (RCP4.5) to complement the analysis, providing a balanced view of potential risks and opportunities.

We did not use the short-term (2025) time horizon in our analysis, considering the short timeframe and the ongoing roadmaps to address short-term risks.

For transition risks, Sanofi also used IEA transition scenarios (IEA Net Zero Emissions and IEA Sustainable Development Scenario). In particular, IEA assumptions for energy prices and carbon costs in 2030 are used to estimate financial impacts: • IEA NZE 2050 scenario which is ambitious and requires significant changes in policy, technology, and behavior; and • IEA STEPS (Stated Policies Scenario) which is more reflective of the current trajectory without additional interventions.

Climate-related scenarios used by Sanofi

Anticipated financial effects from material physical and transition risks

This climate-scenario analysis was used to assess (i) the resilience of each aspect of Sanofi's own operations and value chain (upstream, downstream) to climate change scenarios, (ii) the materiality of climate-related risks, and (iii) the scale of potential opportunities for the business to capitalize on prospects from the transition to a low-carbon future. Sanofi conducted an assessment covering all climate areas to determine which climate change adaptation sub-risks and opportunities could have a financial impact in the medium term (2030) and the long term (2050), along with an approximate scale of impact.

Four sub-risks (Carbon Costs, Raw Material Scarcity, Stakeholder Pressure, Natural Disasters) were evaluated as material for Sanofi according to our DMA and its specific thresholds. These four sub-risks were aggregated into the Climate change adaptation risk of the DMA.

As discussed elsewhere in this chapter, risks that are "material" from a CSRD perspective are not necessarily "material" from a securities law or financial statements perspective in accordance with the CSRD and related methodology established by EC, EFRAG and other guidance - refer to the CSRD Disclaimer and Explanatory Note. Climate scenarios used are compatible with the climate-related assumptions made in Sanofi financial statements.

Financial impact assessment of material climate risks

The table below describes the financial impact of each risk identified. All financial effects assessed as part of the analysis are potential estimates, not exact financial effects to be expected, and include assumptions about Sanofi's operations in the future. The actions undertaken to support the adaptation of Sanofi's strategy to those sub-risks are described in the Actions section hereafter.

Policies related to pollution

Sanofi addresses pollution through its overarching Health, Safety and Environment (HSE) policy and management system, complemented by specific commitments and frameworks related to pharmaceutical substances in the environment.

Health, Safety and Environment (HSE) Policy

Scope:

• All industrial, research & development and commercial activities
• Research, development, manufacturing, distribution centers and related support functions performed in the Business Units

Governance:

• Defined by the company's HSE Department
• Validated by Sanofi's management
• Signed by the CEO

Key content:

• Protection of the environment by addressing impacts of activities and products
• Conserving water and energy
• Reducing emissions, effluents and waste from all operations
• Wastewater management
• Waste management
• Air emissions control
• Spill and release prevention
• Environmental impact assessment
• Preventing and mitigating negative impacts related to potential emissions of chemicals to the environment (air/water/soil)
• Preventing incidents and emergencies

Public availability: Not specified in the excerpts

Link to international standards:

• The HSE management system has been assessed and certified as meeting the requirements of ISO 14001:2015

Implementation monitoring:

• HSE management system covers all relevant operations
• Includes a reference framework
• Internal audit program for all sites
• Performance review program for all sites
• All sites monitor compliance with emissions limits set in their respective operating permits

Planet Care Program

Sanofi's strategic approach to prevent and reduce the environmental impact of pharmaceutical substances (including antibiotics) through actions across the entire life cycle of products:

Key content:

• Evaluating and seeking to minimize emissions to the environment from manufacturing
• Assessing the environmental impacts related to the use of products
• Promoting responsible use and proper disposal of unused medicines

Antimicrobial Resistance (AMR) Roadmap

Scope:

• Antibiotics manufacturing sites of signatories or their suppliers

Key content:

• Defines and implements a common framework for assessing and managing antibiotic discharge
• Promotes responsible production of antibiotics worldwide

Link to international standards:

• Sanofi is a signatory to the AMR roadmap

Substances of Very High Concern (SVHC) Management

Scope:

• All countries where Sanofi has business operations
• Applies to laboratory and manufacturing activities

Key content:

• Compliance with applicable regulations regarding use of SVHC under EU REACH regulation
• All sites monitor compliance with emissions limits set in respective operating permits
• Eco-design approach to reduce, minimize or replace use of SVHC by less hazardous substances when available and feasible, without compromising patients' access to medicines

Implementation monitoring:

• Task force ensures monitoring of SVHC-related regulatory developments
• Regular assessments of impacts on activities
• Development of plans to mitigate or prevent impacts
• Scientific and regulatory tracking on pollution-related aspects
• Consideration of new scientific developments and stakeholders' concerns & interests when revising policies and action plans

Biodiversity and Biopiracy Prevention

Scope:

• Use of genetic resources for R&D purposes
• All Sanofi entities

Governance:

• Company Nagoya Taskforce, reporting to Bioethics Committee

Key content:

• Respect for human rights in relation to protecting the environment and local communities
• Environmental policies reflect compliance with conventions on protection of biodiversity and fight against biopiracy
• Respect of intellectual property rights of indigenous peoples
• Due diligence processes when investigating use of new products from natural sources for R&D purposes

Link to international standards:

• Compliance with Convention on Biological Diversity (CBD) and Nagoya Protocol

Implementation monitoring:

• Company Nagoya Taskforce maintains appropriate level of knowledge through regular training
• Works on issues arising from internal implementation of the protocol
• Assists teams to ensure compliant use of genetic resources
• Follows international implementation in signatory states

Actions and resources related to pollution

Overview

All relevant manufacturing sites monitor compliance with air emissions limits set in their respective operating permits. Sites must comply with HSE requirements and related standards in line with the HSE management system. HSE requirements cover air emissions control including volatile organic compounds (VOCs). Action plans with specific targets are being developed at local level to further prevent and control air emissions, where needed. No specific target has been set at global level regarding air emissions.

WASTEWATER DISCHARGES

Action: Implementing environmental impact management programs

• Description: Characterizing and monitoring emissions of pollutants, conducting impact assessments, managing emission reduction strategies
• Topic: Pollution of water
• Scope: Manufacturing sites
• Time horizon: Already in place
• Progress: Already implemented at local level

Action: Environmental risk management program targeting pharmaceuticals in wastewater

• Topic: Pollution of water PIE (from manufacturing)
• Scope: Manufacturing sites
• Time horizon: 2025
• Progress: Programs already implemented at local level to monitor, manage and reduce emissions. Emissions reduction measures implemented on a case by case basis where needed through specific projects/timelines

Action: Joining the Industry Roadmap for Progress on Combating Antimicrobial Resistance

• Description: To protect aquatic species against the adverse effects and spread of antimicrobial resistance
• Topic: Pollution of water
• Scope: Company level
• Time horizon: Already in place
• Progress: In place

VOC EMISSIONS AND OPTIMIZING SOLVENTS USE

Action: Reducing emissions at source by optimizing solvent use in chemical processes

• Topics: Pollution of air; Pollution of water; SVHC
• Scope: Manufacturing site
• Time horizon: Already in place
• Progress: Already implemented

Action: Capturing and treating residual volatile organic compound (VOC) emissions

• Description: At special treatment facilities using the best available techniques for the specific physicochemical properties of the VOCs emitted (cryogenic capture, gas scrubbers, thermal oxidizers, activated carbon)
• Topic: Pollution of air
• Scope: Manufacturing sites
• Time horizon: Already in place
• Progress: Already implemented

Action: Promoting the use of less hazardous solvents when developing new chemical synthesis or optimizing existing ones

• Description: Using the solvent selection guide
• Topics: Pollution of air; Pollution of water; SVHC
• Scope: Manufacturing sites and R&D
• Time horizon: Already in place
• Progress: Already implemented

REDUCING FINAL PRODUCTS' IMPACT

Action: Implementing the eco-design strategy and monitoring performance with Life Cycle Assessments (LCA)

• Description: For all new products and top marketed products
• Topics: Pollution of water; Pollution of air
• Scope: R&D and Manufacturing and Supply chain
• Time horizon: 2025 new products; 2030 top 20 marketed products
• Progress: 27 LCAs completed

Action: Identifying, assessing and mitigating potential risks to responsibly manage substances of very high concern

• Description: In line with the eco-design approach
• Topic: SVHC
• Scope: New products
• Time horizon: Long-term
• Progress: 2024 new HSE standard on eco-design. Development of an eco-design concern substance list including SVHCs. From 2025 progressive implementation in all projects.

Action: Conducting environmental hazard and risk assessments on our products

• Topic: Pollution of Water PIE (from patients)
• Scope: New medicines and Top-100 selling medicines
• Time horizon: 2025
• Progress: Already implemented for new medicines. Top-selling medicines progressively assessed.

Action: Developing and implementing pilot projects to promote the proper collection and disposal of unused or expired medicines

• Topic: Pollution of water PIE (from patients)
• Scope: Not specified
• Time horizon: 2025
• Progress: Pilot projects launched at local level

Resources Allocated

No specific quantified financial resources (capex/opex amounts) or non-financial resources (dedicated personnel, partnerships) are disclosed for these pollution-related actions.

Targets related to pollution

Wastewater emissions

Water emissions (excluding pharmaceuticals): No specific target has been set at global level regarding emissions into water excluding pharmaceuticals. All relevant sites monitor compliance with wastewater emissions limits set in their respective operating permits or local regulation. Action plans with specific targets are implemented at local level to improve wastewater quality, where needed.

Pharmaceuticals in wastewater (Planet Care program)

Target year: 2025

Target metric: All manufacturing sites will implement a plan to monitor, manage and reduce emissions of pharmaceuticals in wastewater to reduce their potential impacts on ecosystems.

Scope: Manufacturing sites

Progress to date: Programs already implemented at local level to monitor, manage and reduce emissions. Emissions reduction measures implemented on a case by case basis where needed through specific projects/timelines.

Environmental impact assessment of medicines (Planet Care program)

Target year: By 2025

Target metric: The environmental impact of Sanofi's 100 best-selling medicines will be evaluated, as well as all new medicines on the market, regardless of regulatory requirements.

Scope: Product portfolio

Sustainable use and disposal (Planet Care program)

Target year: By 2025

Target metric: Pilot projects will be implemented to further promote the sustainable use and responsible disposal of unused medicines, devices and packaging.

Scope: Medicines, devices and packaging

Air emissions

Air emissions: No specific target has been set at global level regarding air emissions. All relevant manufacturing sites monitor compliance with air emissions limits set in their respective operating permits. Action plans with specific targets are being developed at local level to further prevent and control air emissions, where needed.

Substances of very high concern (SVHC)

SVHC: No specific target has been set at global level. Substitution plans are engaged on a case by case basis in line with applicable regulations. The company strives to reduce, minimize or replace the use of substances of very high concern by less hazardous substances when available and feasible.

Pollution of air, water and soil

Emissions to Air

Refrigerant Emissions (HFC and HCFC)

Methodology note: Data is presented in terms of Carbon Dioxide equivalent to best reflect impact to atmosphere. Sanofi monitors HFC and HCFC refrigerant emissions by tracking refrigerant losses through site-level data.

Volatile Organic Compounds (VOCs)

Methodology note: Sanofi developed a Solvent Management Plan (SMP) to calculate the volume of VOC emissions into the atmosphere based on an annual solvent mass balance. The SMP is applicable to all sites or operations using more than one ton of organic solvents per year. Dichloromethane was identified as a new metric based on 2023 data reported by sites as per E-PRTR regulation.

Emissions to Water

Methodology note: Chemical oxygen demand (COD) and total organic carbon (TOC) are the most relevant parameters for assessing the quality of wastewater discharges. COD loads relate to analyses performed on samples collected at the boundaries of sites. The COD load is converted into TOC load using the E-PRTR ratio. Dichloromethane releases reported above are related to 2 sites for which the applicable E-PRTR reporting threshold was exceeded. Dichloromethane releases are calculated from wastewater analysis performed on samples collected at the discharge point of sites.

Emissions to Soil

Assessments of the risk of soil and groundwater contamination have been carried out at current and former Sanofi sites. In cooperation with national and local authorities, Sanofi evaluates the rehabilitation work required and carries out such work when appropriate. Provisions have been established for the sites already identified and to cover contractual guarantees for environmental liabilities for sites that have been divested. Potential environmental contingencies arising from certain business divestitures are described in the consolidated financial statements.

E-PRTR Reference

A preliminary review of air and water pollutant indicators was performed based on 2023 data reported by most EU-based sites as per the application of the European Pollutant Release and Transfer Register (E-PRTR) at national level. The review was extended to data collected from other EU or non-EU based sites selected based on the likelihood of exceeding E-PRTR reporting thresholds. E-PRTR-listed pollutants for which applicable E-PRTR reporting thresholds were exceeded for at least two sites were included in air and water pollution monitoring indicators.

Scope and Coverage

Data covers all Sanofi sites other than tertiary and logistics sites, which contribute only marginally to releases. The reporting period for environmental indicators runs from January 1 to December 31. For some indicators collected quarterly, actual data was collected for the first 3 quarters, with Q4 estimated due to closing deadlines.

Substances of concern and substances of very high concern

Policy and Management Approach

Our laboratory and manufacturing activities may require using some substances placed on the candidate list of substances of very high concern (SVHC) under the EU REACH regulation. All sites monitor compliance with emissions limits set in their respective operating permits. In all countries where we have business operations, we also seek to comply with applicable regulations regarding the use of these substances. A task force ensures a monitoring of SVHC-related regulatory developments, regular assessments of their impacts on our activities and develops plans to mitigate or prevent impacts. In line with our eco-design approach, we strive to reduce, minimize or replace the use of substances of very high concern by less hazardous substances when available and feasible, without compromising patients' access to medicines.

Targets

In line with our eco-design approach, we strive to reduce, minimize or replace the use of substances of very high concern by less hazardous substances when available and feasible, without compromising patients' access to medicines. No specific target has been set at global level. Substitution plans are engaged on a case by case basis in line with applicable regulations.

Quantitative Data

SVHC data reported here relate to our manufacturing operations and related activities and cover a list of 53 substances placed on the candidate list of substances of very high concern under the REACH regulation.

Methodology

A preliminary review of the candidate list of SVHC for authorization under the REACH regulation was done to identify those are the most likely used in Sanofi manufacturing activities. A list of 53 SVHCs was established based on the above mentioned review and was used as a basis for collecting and consolidating data from Sanofi manufacturing sites worldwide.

Amounts of SVHC procured and used cover SVHCs as such or in pre-identified mixtures in manufacturing operations and related activities (cleaning, quality control). Amounts of SVHC leaving facilities as part of products cover products for which the SVHC content is >0.1% (w/w). Amounts of SVHC that leave facilities as emissions (air / water) were calculated from regulatory monitoring data when applicable, or determined by mass-balance based on worst-case assumptions. For each category a reporting threshold of 1kg/y was applied.

For 2023, total amounts were consolidated from yearly figures provided by sites. For 2024, total amounts were determined from a consolidation of Q1 to Q3 figures provided by sites and an estimate of Q4 calculated as an average quarterly value from Q1 to Q3 data.

Anticipated financial effects from pollution-related impacts, risks and opportunities

This disclosure requirement has been omitted in 2024 due to phase-in provisions under CSRD.

As stated in the ESRS index:

Transition plan and consideration of biodiversity and ecosystems in strategy and business model

Integration of biodiversity into strategy and business model

In 2023, Sanofi updated the assessment of its biodiversity footprint and dependencies to ecosystem services as well as associated risks covering the entire value chain. This assessment enabled the identification and analysis of Sanofi main impacts and dependencies on biodiversity based on a methodology and tools that rely on:

• the scientific framework provided by the IPBES 2019 Global Assessment Report;
• the recommendations of the Science Based Targets Network (SBTN) methodology, which is a framework to set science-based targets on nature-related issues. In particular, the requirements of step 1a) on materiality screening have been followed;
• the guidance and recommendations provided by the Taskforce on Nature-related Financial Disclosure (TNFD) framework, a market-led, science-based and government-backed initiative providing organizations with the tools to act on evolving nature-related issues;
• the recommendations of the Corporate Sustainability Reporting Directive (CSRD) and the European Sustainability Reporting Standards (ESRS).

Main impacts and dependencies

The results of this assessment suggest that Sanofi's main potential impacts are found primarily in the upstream value chain, for instance due to the pressure on horseshoe crab populations for their blood, used for quality testing applications. Additionally, the pressures of pollution and climate change affect both the upstream processes and Sanofi's direct operations. Finally, the potential downstream impacts of the value chain are likely to come from pollution from product use (pharmaceuticals in the environment).

The dependencies were narrowed down as follows: Sanofi's supply chain is dependent on ecosystems for provisioning and support services. These services support Sanofi's supply of raw materials used in products (direct input from nature for plant-based and animal-based materials, minerals, petroleum, etc.) and for packaging (paper, cardboard, plastics, etc.), as well as the availability of molecules used in chemicals.

Resilience assessment

To understand Sanofi's resilience to biodiversity loss, we conducted an assessment focused on dependencies and impacts related to nature-based products. This extensive, ongoing work involves mapping key ingredients and identifying high-risk commodities as identified in the Science Based Targets Network (SBTN) list and other programs. The resilience analysis covered our entire upstream value chain. Our assessment considered two time horizons: 2030 and 2050, to capture both near-term and long-term risks.

We have identified a potential dependency to timber derivatives, which are key for packaging applications. New deforestation regulations and consequences of climate change (extreme weather, water scarcity, wildfires, etc.) affect the costs, quality and availability of this material which could have a negative impact on our business and operations.

Current status of transition plan

Currently, there is no direct involvement of stakeholders in this assessment. However, we are taking steps to adapt to climate and nature-related risks, although a formal transition plan has yet to be established.

Sites in or near biodiversity-sensitive areas

The biodiversity risk assessment of our sites was developed with the support of an external consultant and using the database of the Integrated Biodiversity Assessment Tool (IBAT).

The results of the assessment showed that our own operations involve 13 sites located near biodiversity-sensitive areas, considering conservative buffer zones up to 15 km. These sites are located in France, Hungary, Germany, Mexico, Spain and the USA.

These priority sites are required as a company HSE rule to implement a Biodiversity Management Plan (BMP) by 2025.

Framework alignment

Alignment with the TNFD framework is noted in stakeholder engagement with shareholders and investors, with expectations regarding "Alignment with new ESG standards and frameworks (such as TNFD)".

Policies related to biodiversity and ecosystems

Sanofi does not yet have comprehensive policies specifically addressing biodiversity and ecosystems. The company explicitly states that work is in progress for material biodiversity-related impacts, risks and opportunities that were recently identified.

Sanofi CSR strategy

Status: Work in progress. The company has not yet adopted policies related to:

• Impacts on the state of species (recently identified as material under ESRS 2-62)
• Dependencies on provisioning and support services (recently identified as material under ESRS 2-62)

Scope: Upstream, own operations, downstream (depending on the specific impact/risk)

Standard procedures and templates for materials management

Sanofi has established standard procedures and templates for managing the quality and safety of materials used in manufacturing.

Key content:

• Details the level of information required from suppliers to clarify the animal, mineral or vegetal origin of materials
• Ensures traceability of materials
• Prohibition: Materials of animal or vegetal origin from species recognized in the CITES list as endangered or protected are not authorized in Sanofi products

Scope: Materials used to manufacture Sanofi products

Limitations acknowledged:

• Biodiversity-related policies do not address the management of ecosystems from which the company produces, sources or consumes in a way that maintains or enhances conditions for biodiversity
• No regular monitoring or reporting of biodiversity status and gains or losses for these ecosystems

Commitments to international frameworks

Nagoya Protocol and Convention for Biological Diversity (CBD):

• Sanofi recognizes the Nagoya Protocol and CBD for obtaining and using natural resources
• Addresses social consequences of impacts on biodiversity and ecosystems through commitment to fair and equitable sharing of benefits arising from utilization of genetic resources
• Requires prior informed consent for access to genetic resources
• Collaboration contracts set out conditions for sharing benefits arising from use of genetic resources

Act4Nature international commitment

Sanofi renewed its commitment to Act4Nature international in November 2021.

Description: International collaboration bringing together companies, public authorities, scientists and environmental associations to step up concrete business action in favor of biodiversity protection

Key content:

• Common commitments signed
• Individual commitments defined based on SMART objectives (Specific, Measurable, Attainable, Relevant and Time-bound)
• Aligned with Sanofi's Planet Care program

Site-level biodiversity management commitments (Planet Care program)

As part of the Planet Care program, Sanofi has set dedicated commitments to manage biodiversity at sites, updated following biodiversity risk mapping completed in 2022.

Key commitments:

• By 2025: All priority sites with the highest potential impacts will have implemented specific biodiversity management plans aligned with local initiatives
• By 2025: All sites will have implemented at least one local initiative for biodiversity
• By 2030: All sites located near sensitive areas will have implemented specific biodiversity management plans aligned with local initiatives

Scope: All Sanofi sites, with priority sites identified based on potential impacts

Implementation status (2024):

• Biodiversity management plans now cover 60% of priority sites
• More than 60% of sites have implemented a local initiative on biodiversity
• Assessments initiated by priority sites in 2024 will conclude by end of 2025

Actions and resources related to biodiversity

Summary of E4-3 disclosure status

Sanofi has not yet adopted actions specifically related to biodiversity and ecosystems under ESRS E4-3. The company provides the following status for each material biodiversity IRO:

Climate change and Pollution

• Scope: Upstream, own operations (and downstream for pollution)
• Status: Actions related to climate change and pollution are covered in ESRS E1 and E2 respectively
• Note: There are no actions in ESRS E1 and E2 that specifically address biodiversity and ecosystems, and therefore no incorporation of local and indigenous knowledge and nature-based solutions

State of species

• Scope: Upstream
• Status: Work in progress - Sanofi has not yet adopted actions related to its impacts on the state of species, as this impact has only recently been identified as material for Sanofi (ESRS 2 – 62)

Provisioning and support services

• Scope: Upstream, own operations
• Status: Work in progress - Sanofi has not yet adopted actions related to its dependencies to provisioning and support services, as this impact has only recently been identified as material for Sanofi (ESRS 2 – 62)

Additional disclosure

• Sanofi has not used biodiversity offsets in its action plans
• No biodiversity metrics have yet been developed (E4-5)

Targets related to biodiversity and ecosystems

Sanofi has not yet adopted targets related to biodiversity and ecosystems.

Summary of E4-4 disclosure

Status

• No biodiversity-specific targets have been established
• Climate change and pollution targets are covered under ESRS E1 and E2
• State of species impacts were recently identified as material; target-setting is work in progress
• Provisioning and support services dependencies were recently identified as material; target-setting is work in progress
• No biodiversity metrics have yet been developed (E4-5)

Impact metrics related to biodiversity and ecosystems change

E4-5 Disclosure

No biodiversity metrics have yet been developed.

Sites in or near biodiversity-sensitive areas

The biodiversity risk assessment of sites was developed with the support of an external consultant using the Integrated Biodiversity Assessment Tool (IBAT).

The results showed that own operations involve 13 sites located near biodiversity-sensitive areas, considering conservative buffer zones up to 15 km. These sites are located in France, Hungary, Germany, Mexico, Spain and the USA.

Sensitive areas definition: Regulated or non-regulated areas of high biodiversity value, including International protected areas, Man and Biosphere protected areas, RAMSAR sites, IUCN I-IV Protected areas, Regional protected areas, Natura 2000, other regional protected areas, UNESCO World Heritage Sites, Alliance for Zero Extinction sites (AZE), Important Bird and Biodiversity Areas (IBA), IFC Critical Habitat, Key Biodiversity Areas (KBA) and ZNIEFF.

Species impacts (qualitative)

Impacts on threatened species: Sanofi uses horseshoe crab blood to produce Limulus Amebocyte Lysate, essential for testing the sterility of medical products. This practice leads to the harvest of individuals from the wild, disrupting their reproductive cycle and increasing their mortality. Two of the four species of horseshoe crab, potentially used by Sanofi, are listed on the IUCN Red List of Endangered Species.

Biodiversity Management Plans

Priority sites (13 sites near biodiversity-sensitive areas) are required as a company HSE rule to implement a Biodiversity Management Plan (BMP) by 2025.

Methodology notes

Estimation accuracy: The biodiversity footprint assessment used the Global Biodiversity Score (GBS) methodology. Proxies with the chemical sector were considered as the GBS methodology is not specific to the pharmaceutical industry. Estimated level of accuracy is difficult to define, as no pharmaceutical sectoral benchmark was available. A conservative approach was taken expecting to overestimate the real footprint.

Planned improvements: Sanofi will enhance and update in 2025 the assessment of biodiversity footprint and dependencies to ecosystem services as well as associated risks covering the entire value chain. This effort will be led jointly by CSR and HSE teams.

Policies related to resource use and circular economy

Sanofi sees the circular economy as a model inspired by nature that advocates for more restrained and efficient use of resources and limited generation of waste. It is a production and consumption model involving sharing, leasing, reusing, repairing, remanufacturing, and recycling existing materials and products to extend product life cycles. The circular economy is based on three principles driven by design: eliminating waste and pollution, keeping products and materials in use, and regenerating natural systems to decouple economic growth from the consumption of finite resources.

Sanofi's "Eco-design & Circular Economy" team manages a set of standards and guidelines:

Sanofi Standard on Waste Management

• Key content: Manages waste-related processes across Sanofi operations
• Scope: Applies to all R&D and manufacturing sites where both non-hazardous and hazardous waste is handled and tracked

Sanofi Standard on Eco-design Management

• Key content: Provides guidance on eco-design principles across the organization

Sanofi Standard on Eco-design guide for Packaging

• Key content: Promotes the use of Post-Consumer Recycled (PCR) material and Post-Industrial Recycled (PIR) material in packaging. PCR content comes from products that have reached end of life and would otherwise end up in landfills. PIR content is made from manufacturer waste that never reached consumers. PCR waste reuse is preferable to PIR as it is less likely to end up in landfills.

Sanofi Standard on Official List of Materials or Substances

• Key content: Manages approved materials and substances for use in operations

Sanofi Standard on Single Use Components & Assemblies

• Key content: Establishes requirements for single-use components and assemblies

Sanofi Global HSE Guide "HSE requirements for the selection of solvents used in new processes"

• Key content: The solvent selection guide identifies the best organic solvent in terms of safety, quality and environmental impact based on physical and chemical properties. It seeks to allow appropriate use and reuse of solvents for the design of drug-manufacturing processes.

Procurement Global Operating Standard

• Key content: Establishes procurement requirements related to circular economy principles

Implementation approach

• Double Materiality Assessment (DMA): Site-level information on waste flows and quantities is used in Sanofi's DMA to assess the scale, scope and remediability of risks and impacts related to hazardous waste, in accordance with CSRD and related methodology established by EC, EFRAG and other guidance
• Waste hierarchy: Sanofi applies a waste hierarchy with zero-waste at the top, followed by reduction at source, systematic examination of reuse and recycling before resorting to other disposal forms (such as incineration with or without energy recovery). Landfill is only used as a last resort and must be subject to audit.
• 9R applicability: Sanofi studied the applicability of 9R (Refuse, Rethink, Reduce, Reuse, Repair, Refurbish, Remanufacture, Repurpose, Recycle and Recover) to its business, but because patient safety is the highest priority, refurbish, remanufacture, or repurpose are currently not applicable to drug products

Targets related to circular economy

Solvent Regeneration and Reuse Target

Target metric: Percentage of solvents regenerated and reintroduced into industrial process

Target description: The company discloses that "every year we disclose the percentage of solvents that is regenerated and reintroduced into our industrial process" and that this is "directly linked to our circular material use rate."

Progress to date (2024): 58% of solvents were regenerated and reintroduced into industrial process

Scope: Own operations (industrial sites)

Type: This appears to be an ongoing disclosure metric tracked under the 3R (Reduce, Reuse, Recycle) waste program

Waste Reduction Progress (under Planet Care program)

While specific quantified future targets are not explicitly stated in the excerpts, the company reports progress on waste management under its 3R program with 2019 as baseline:

Baseline year: 2019

Scope: Own operations (industrial sites)

Note: The document states that "Waste management, including preparing waste for proper treatment, is directly addressed by two targets under our Planet Care program" but the specific quantified future target values and target years are not disclosed in the provided excerpts.

Waste

Waste Management Targets:

• By 2025: Reuse, Recycle or Recover at least 90% of waste (3R program)
• By 2025: Reduce landfill rate to less than 1%
• By 2030: Reduce waste index by -30% versus 2019

Waste Hierarchy: Sanofi applies a five-layer waste hierarchy with "zero waste" at the top, followed by reduction at source, reuse, recycle/compost, incineration with energy recovery, and landfill as last resort.

2024 Waste Performance:

Radioactive Waste (2024): 2.71 tonnes

Key Waste Streams:

• Used solvents: 23% of total waste (58% regenerated and reintroduced into industrial process in 2024)
• Heparin production biowaste: Over 99% recovered through biomethane production
• Egg waste from flu vaccine production: Composted or used for methanization
• Radioactive waste from R&D activities: Declared to authorities per local regulations

Waste Management Programs:

1. Landfill-Free program: Target less than 1% waste to landfill by 2025
2. 3R program: Target more than 90% reused, recycled or recovered by 2025
3. Performance & Digitalization program: Standardize processes, leverage partnerships, implement digital tracking

Significant Achievements:

• One US facility switched from landfill to composting for egg waste (June 2022), reducing landfill by nearly 4,000 tons annually
• One French site started selling 1,800-3,000 tons/year of material previously treated as hazardous waste to another company for reuse (late 2023)

Methodology Notes:

• Distinction between hazardous/non-hazardous follows EU Decision 2000/532/EC for EU countries and local regulations elsewhere
• Waste from soil decontamination operations excluded
• Recovery rate = waste recycled + incinerated with energy recovery
• 3R rate = (recycled waste + waste with energy recovery) / (total waste + solvents recycled on-site)
• Site considered landfill-free when disposal rate < 1%

Policies related to own workforce

Sanofi has established multiple policies addressing its own workforce, aligned with international labor standards and human rights frameworks.

Code of Conduct

Scope: Applies to all employees and anyone who works for or on behalf of Sanofi (including healthcare professionals and providers, governments, research institutions, and patient organizations).

Governance and oversight: Established by the Ethics & Business Integrity department, approved by Senior Management and signed off by the CEO. The Code is validated by the Sanofi Board of Directors. It is overseen by the Office of Inspector General's (OIG's) seven fundamental elements of an effective compliance program.

Key content/principles: The Code encompasses 16 fundamental principles including:

• Acting with integrity, respect, legitimate intent, transparency, and accountability
• Prohibiting discrimination, defined as any form of unequal treatment on grounds of race, ancestry, place of origin, color, sex, pregnancy, sexual orientation, gender identity or expression, civil status, age, religion, political convictions, language, social condition, disability or family status
• Safeguarding data privacy and protecting information
• Fighting bribery and corruption
• Respecting human rights
• Promoting psychological safety and wellbeing
• Championing diversity, equity & inclusion
• Requiring completion of mandatory training for all employees

Public availability: Publicly available at https://www.codeofconduct.sanofi and available to all Sanofi employees on the Sanofi intranet.

Links to international standards: References to United Nations Guiding Principles on Business and Human Rights (UNGPs), OECD Guidelines, and alignment with minimum safeguards on human rights.

Monitoring implementation: All employees complete mandatory annual training on the Code of Conduct. Failure to complete global compliance learning impacts employee bonuses. In 2024, 81,058 Sanofi employees completed at least one global compliance learning module for a total of 411,419 modules completed.

Freedom of Association Global Policy

Scope: Applies to all corporate functions, regions, countries and divisions worldwide.

Governance and oversight: Adopted in 2015. In 2024, a Global Social Relations Office was established within the People & Culture organization, reporting directly to the Chief People Officer, responsible for developing global standards on freedom of association and collective bargaining.

Key content/principles:

• Observes ILO conventions 87 and 98 on freedom of association and the right to collective bargaining
• Recognizes that all employees are free to form and/or join a workers' organization of their own choice
• Prohibits intimidation, harassment, punishment or discrimination against employees due to trade union activities
• Respects the right to collective bargaining
• Commits to bargaining in good faith
• Provides access to grievance mechanisms

Public availability: Available to all Sanofi employees in the central documents repository. Listed in the Code of Conduct.

Links to international standards: Observes ILO conventions 87 and 98 on freedom of association and the right to collective bargaining.

Monitoring implementation: Global voluntary freedom of association self-assessment implemented. In 2024, eight affiliates identified as at-risk from a human rights perspective (Algeria, Brazil, China, Egypt, India, Mexico, Russia and Turkey) were reviewed pursuant to internal procedures. These affiliates represent approximately a third of the Sanofi workforce.

Global Disciplinary Policy

Key content/principles: States that discrimination is subject to a zero-tolerance approach. Prohibits discrimination against employees engaged in union activities.

HSE (Health, Safety & Environment) Policy

Scope: Applies to all Sanofi entities and departments. Targets 100% of employees covered by health and safety management system based on legal requirements and/or recognized standards or guidelines.

Governance and oversight: Formulated by the HSE department and endorsed by senior management. HSE results are monitored on an ongoing basis and regular management reviews are performed. A monthly report is issued to operational managers, and a quarterly report is sent to the CEO and Executive Committee members.

Key content/principles:

• Establishes framework for actions for employees, temporary workers and external partners
• Includes a Leading Safety Program with dedicated training programs
• Focuses on zero-tolerance approach: 0-SIF (Serious Injuries & Fatalities) target for 2024
• Regular management reviews to ensure achievement of targets
• Audits performed to evaluate system effectiveness

Links to international standards: Internal HSE management system aligned with risk analysis and stakeholder expectations.

Monitoring implementation: Real-time monitoring tool alerts management when accidents occur and tracks frequency rates. Corrective and preventive actions implemented to contribute to continuous HSE performance improvement. In 2024, 100% of employees were covered by the health and safety management system.

Diversity Edge (DE&I Strategy)

Scope: Applies to all employees globally, subject to local laws and regulations.

Governance and oversight: The Chief Diversity Officer sits on the Catalyst Advisory Board. Progress reports are presented to Sanofi's Board of Directors and to the Diversity, Equity & Inclusion Board.

Key content/principles:

• Reflects the diversity of communities
• Different diversity strands mapped and recognized: gender, race + ethnicity, faith, LGBTQIA+, age, and disability
• Ensures under-represented employees have equal chances to succeed
• Locally defined under-represented groups have equal access to opportunities
• Recruitment, promotion and retention tracked using local scorecards
• Mandatory DE&I training for all employees

Public availability: Information available through internal communications and mandatory training modules.

Monitoring implementation: Demographic data captured annually on voluntary basis through employee surveys. Comprehensive dashboard available to Top 500 leaders and all Talent and DE&I professionals.

Global Pay Equity Action Plan

Scope: Applies to all direct employees across all countries of operation.

Governance and oversight: Overseen by the Group Chief People Officer. Annual progress reports presented to Sanofi's Board of Directors and to the Diversity, Equity & Inclusion Board. Local reviews conducted regularly in line with global guidelines and local regulations.

Key content/principles: Three global commitments:

1. Regularly monitor pay equity and develop action plans to remediate gaps
2. Promote equity in all pay decisions and develop a pay equity mindset
3. Review base salaries for employees returning from parental/family leave to prevent disparities and systemic bias

Monitoring implementation: Target to maintain alignment with living wage standards for all direct employees. In 2023, 104 living wage gaps were identified. In 2024, all identified gaps were addressed, achieving full alignment as of June 2024. As of December 2024, there are no employees paid below the applicable adequate wage benchmark.

Gender-Neutral Parental Leave Policy

Scope: Applies to all permanent employees globally, regardless of gender or sexual orientation, covering biological or non-biological parents, including adoption and surrogacy.

Key content/principles: Offers 14 weeks of paid parental leave to all employees globally, introduced in 2022.

Reporting and Non-Retaliation Policy

Scope: Applies to Sanofi employees, contractors, business partners, suppliers and value chain workers.

Key content/principles:

• Prohibits intimidation or retaliation against those who report concerns in good faith
• Permits anonymous reporting (subject to local laws)
• Individuals who retaliate are subject to disciplinary action up to and including termination
• Speak-Up Helpline available 24/7 in 28 languages

Public availability: Available in the Sanofi Code of Conduct (publicly available) and in the Global Operating Procedure on Global Reporting and Alert Management (available to all employees).

Monitoring implementation: In 2024, 900 alerts were raised through the Speak Up Helpline, resulting in two confirmed discrimination and 28 harassment cases. No severe human rights issues were reported via the Helpline in 2024.

Global Privacy Standard

Scope: Applies to all Sanofi companies worldwide.

Key content/principles: Implements "8 Golden Privacy Principles" for managing personal data, including employee data:

1. Know what personal data is
2. Process personal data only for clear and legitimate reasons
3. Retain personal data for a defined period
4. Limit the amount of personal data to be processed
5. Ensure personal data are secure and confidential
6. Be transparent and allow individuals to exercise their rights
7. Ensure legitimacy of transfers
8. Demonstrate compliance by assessing the data processing process

Links to international standards: Binding Corporate Rules (BCRs) approved by European Data Protection Authorities. Compliance with GDPR.

Public availability: Privacy commitments included in publicly available Code of Conduct. Global Privacy Standard available to all employees.

Anti-Bribery Policy

Scope: Applies to Sanofi worldwide, including all Sanofi employees and third parties engaged in activities with Sanofi.

Key content/principles:

• Zero-tolerance policy towards bribery
• Establishes clear guidance for employees and third parties on compliance with anti-corruption and anti-bribery laws
• Defines prohibited and permitted interactions
• Requires anti-bribery due diligence on third parties

Public availability: Available internally and externally via Sanofi website. Communicated through internal communication and mandatory training.

Links to international standards: References United Nations Convention against Corruption.

Monitoring implementation: Regular Ethics & Business Integrity risk assessments. All employees receive mandatory anti-corruption training as part of Code of Conduct training (100% of functions covered).

Taking action on material impacts on own workforce

Sanofi's S1-4 disclosure is cross-referenced to section 3.3.1.6 "Equal treatment and opportunities for all" (pages 74-82). The following actions are disclosed:

Diversity, Equity & Inclusion Training

• Action: Mandatory DE&I training for all employees, integrated into Global Code of Conduct training
• Scope: Own operations (all employees)
• Time horizon: Implemented since 2023
• Resources: Not quantified
• Expected outcomes: 100% employee coverage through mandatory training

Data-driven DE&I Decision-making

• Action: DE&I analytics strategy to inform global and local People & Culture decisions
• Scope: Own operations
• Activities: Rolling out new solutions and methodologies to support People & Culture Analytics function with use cases for recruiting, talent and wellbeing initiatives
• Resources: Not quantified

Workplace Accessibility Programme

• Action: Global accessibility initiatives for employees with disabilities
• Scope: Own operations (all Sanofi sites)
• Time horizon: Target completion by end of 2025
• Target: 100% of employees with disabilities to have workplace accessibility by end of 2025
• KPI: 100% of sites achieve at least bronze standard or higher by 2025
• Current performance: 95% of audited sites (office spaces) currently at bronze level or higher
• Resources: Bespoke assessment tool used across categories: Physical, Health & Safety, Informational, Sensorial, Organization & Operational, Labs, Manufacturing, Warehousing
• Classification system: Bronze (minimum level), silver, gold, platinum
• Owner: Workplace Experience team

Gender Representation Initiatives

Gender+ Employee Resource Groups (ERGs)

• Action: Global and local Gender+ ERGs
• Scope: Own operations
• Participation: More than 4,000 members
• Activities: Provide career development tools, visibility and advocacy for women at all professional levels
• Resources: Dedicated ERGs for female talents to encourage women in STEM careers

Gender+ Advocacy Initiative

• Action: In-house Gender+ advocacy initiative
• Scope: Own operations
• Time horizon: Developed in 2023
• Objective: Encourage gender allies to actively advocate for gender equality, raise awareness, and engage in dialogue
• Current participation: 130 advocates (split equally between men and women), of which 50% hold senior leadership positions
• Activities:
  • Sharing and explaining the Allyship Guide within teams and networks
  • Sponsoring, mentoring or coaching women through various programs facilitated by Gender+ ERGs
  • Engaging in external initiatives (mentoring programs, 90-minute Interview Coach, Capital Filles, Women in Tech)
  • Promoting uptake of parental leave
  • Sharing gender metrics for transparency and accountability

External Partnerships

• Action: Partnerships with major global gender equality organizations
• Scope: Own operations
• Resources: Partnership with:
  • Catalyst (CEO is full Board member, Chief Diversity Officer is Advisory Board member)
  • WIN (Women's International Networking)
  • The Boardroom
  • Healthcare Businesswomen's Association (150 members)
  • Global Summit of Women
  • Women's Forum
  • WeQual

Gender-neutral Paid Parental Leave

• Action: Gender-neutral paid parental leave
• Scope: All employees globally
• Time horizon: Introduced in 2022
• Benefit: 14 weeks of paid parental leave regardless of gender or family structure
• Link: See section 3.3.1.5.1. Employee wellbeing & work-life balance

Equal Pay for Work of Equal Value

Global Pay Equity Action Plan

• Action: Global Pay Equity Action Plan
• Scope: Own operations (all employees)
• Time horizon: Launched in 2021
• Oversight: Group Chief People Officer; annual progress reports to Board of Directors and DE&I Board
• Three global commitments:
  1. Regularly monitor pay equity and develop action plans to remediate gaps
  2. Promote equity in all pay decisions and develop a pay equity mindset
  3. Review base salaries for employees returning from parental/family leave to prevent disparities and systemic bias
• Activities: Geographies regularly monitor pay gaps and take remedial actions including pay adjustments
• Resources: Not quantified

Characteristics of the undertaking's employees

Total headcount and FTE

As of December 31, 2024:

• Total headcount: 82,878 employees
• Full-time equivalent (FTE): 82,182

Prior year (December 31, 2023):

• Total headcount: 86,088 employees
• Full-time equivalent (FTE): 85,348

Prior year (December 31, 2022):

• Total headcount: 89,824 employees
• Full-time equivalent (FTE): 89,116

Headcount by contract type and gender

Note: Sanofi does not hire employees on contracts with non-guaranteed hours. Employees on garden leave and Executive Committee management level are excluded from the data.

Headcount by region and gender

Note: Employees on garden leave and Executive Committee management level are excluded from the data.

Employees by commercial activity and function

Note: Employees on garden leave and at Executive Committee management level excluded from the data.

Employee turnover and new hires

New hires and departures by region

Notes:

• Employees on garden leave and Executive Committee management level excluded from the data.
• Data on movements (new hires and departures) cover more than 99% of the reporting scope. Internal transfers are not included.
• Change in calculation for 2024, refer to 3.5.1. Methodological note on data reporting.

Employee departures worldwide by reason for departure

Note: Mostly China, where most new hires are on fixed-term renewable contracts (78.1% of the total at the end of 2024).

Gender-neutral parental leave

Number and percentage of eligible employees by gender who took parental leave:

Methodological notes

Data are sourced from Sanofi's Workday HR management system, which serves as the single source of truth for all employees. The reporting scope covers more than 99% of the organization. Employees on garden leave in non-operational organizations and Executive Committee members are excluded from workforce metrics. The reference baseline is extracted at period end and reconciled with Finance for headcount consistency. Regional classifications are defined in the methodological note (page 134).

Characteristics of non-employees in the undertaking's own workforce

Disclosure Status

Sanofi has omitted disclosures related to ESRS S1-7 for the 2024 reporting year due to the phase-in provisions of the CSRD.

Definitions Provided

Sanofi defines non-employees as contractors hired by Sanofi to perform regular work that would otherwise be carried out by an employee (under NACE codes N78.1 and N78.2):

• Contingent workers: Offer temporary support to cover for employees on leave or to cope with high demand. Their scope is defined by a specific job description.
• Managed services: Offer temporary support to supplement Sanofi employees for a regular Sanofi activity, for example for equipment calibration, app development or a study report. Their scope is defined by a statement of work.

Important scope exclusions: This scope specifically excludes workers who provide outsourced services or professional services. These categories are defined and addressed separately in section 3.3.2 Workers in the value chain.

Methodology Note

Sanofi states: "Disclosures related to non-employees have been omitted for the 2024 reporting year due to the phase-in provisions of the CSRD."

For 2024 and previous years, Sanofi considers as own workforce employees with a direct contract with Sanofi, excluding third-party contracts, such as contingent workers or managed services. Also excluded are employees on specific garden leave linked to social plans, mainly in France, and members of the Executive Committee.

Collective bargaining coverage and social dialogue

Policies

Sanofi seeks to observe at a minimum the provisions of ILO conventions 87 and 98 on the freedom of association and the right to collective bargaining, without prejudice to more favorable national provisions. Our global policy on Freedom of Association, adopted in 2015, defines our commitments to observe ILO standards and describes the operational due diligence processes and grievance mechanisms. The policy applies to all of our corporate functions, regions, countries and divisions worldwide.

According to the Freedom of Association global policy, Sanofi:

• recognizes that all employees are free to form and/or join a workers' organization of their own choice and does not interfere with this right;
• prohibits any intimidation, harassment, punishment or discrimination against employees due to trade union activities and does not discourage any employee from joining organizations of their own choosing;
• respects the right to collective bargaining and the role of workers' organizations for the purpose of collective bargaining and commits to bargain in good faith;
• allows workers' organizations to act entirely independently, by giving them reasonable access to the information, resources and means necessary to accomplish their missions;
• in case of conflict between international standards and domestic laws, Sanofi aspires to international standards by finding alternative ways to respect these rights.

In 2024, we established a Global Social Relations Office within the People & Culture organization, reporting directly to the Chief People Officer. This office is responsible for developing global standards on freedom of association and collective bargaining to ensure consistent application of these principles across Sanofi markets.

Overall, 48% of our employees are covered by collective agreements. In countries where no collective agreements exist, other approaches are relied upon, such as Speak-Up events, Employee Resource Groups, or similar opportunities to ensure the ongoing involvement of employees at all levels.

Social dialogue structures

France: In France, employees are represented through the Works Council, the Employee Representatives Committee and trade unions. In addition, several employee representatives represent France in the European Works Council. The trade unions are affiliated with the pharmaceutical industry sector and the chemistry sectors. French employees are therefore covered by two collective agreements: either pharmaceutical or chemistry. Social dialogue in France is organized through different regular subject-matter specific committees and negotiations with representative unions. As a result, 22 collective agreements were signed with union representatives in 2024.

Germany: Employees are represented through the Works Council or the Employee Representatives Committee. Both bodies are affiliated with the German chemistry sector and delegates are elected by employees for a four-year term. Employee representative bodies exist in both legal entities that employ a workforce in Germany: Sanofi-Aventis Deutschland GmbH and Nattermann GmbH u. Cie. Both entities have employee representatives representing Germany in the European Works Council.

Sanofi European Works Council: Chaired by the Chief Executive Officer of Sanofi or his representative, and created by agreement in 2005, the Sanofi European Works Council (EWC) comprises 40 full members and 40 substitutes, appointed for four years, who represent Sanofi employees in the EU countries where Sanofi operates. In 2024, there were two EWC plenary meetings, one training session for all EWC members, and six selected committee meetings.

Metrics: Collective bargaining coverage and social dialogue

(a) Percentage of employees covered by collective bargaining agreements.

(b) Percentage of employees covered by workers representatives.

Diversity metrics

Employees by managerial role and gender

(a) Senior leaders are employees with management level 5 and above.

(b) Top management are employees in executive roles.

Employees by age and gender

Sanofi aims to have a balanced age pyramid including senior employees and early talents.

Adequate wages

Policy and commitment

Sanofi published a commitment in 2024 to pay a living wage for all employees. The company supports a living wage that enables workers and their families to meet their basic needs.

The policy:

• Monitors living wage standards in each country annually and takes remediation actions as needed
• Promotes transparency by measuring progress regularly and sharing with stakeholders
• Promotes Living Wage standards beyond Sanofi, advocating among strategic suppliers
• Applies to all direct employees of Sanofi
• Currently excludes contingent or temporary workers, though efforts are being made to extend living wage principles to more types of employment in the future
• Chief People Officer (CPO) is accountable for this policy

Benchmark used

Sanofi utilizes an internationally recognized living wage methodology developed by a reputable benchmark provider. Specifically, the company uses data from the Fair Wage Network, which covers family costs for:

• Basic food
• Water
• Housing
• Clothing
• Healthcare
• Transport & communication
• Education
• Leisure & other discretionary spending

Following the latest agreement on living wages by the International Labor Organization (ILO), Sanofi adheres to ILO principles by actively seeking living wage data providers that best meet the latest ILO standards.

Sanofi upholds its commitment to a living wage, aligns with the United Nations Global Compact's living wage ambition and supports the United Nations Sustainable Development Goals.

Coverage and assessment

2024 results:

• In 2023, 104 living wage gaps were identified
• In 2024, all identified gaps were addressed, achieving full alignment as of June 2024
• At Sanofi, there are no employees paid below the applicable adequate wage benchmark as of 2024
• 100% coverage: Annual reviews conducted for all direct employees across all countries

Methodology

Annual living wage review and adjustment:

• Conducted in Q4 each year, following the living-wage benchmark provider's database updates
• Involves benchmarking guaranteed cash against local living wage standards
• Any gaps identified are addressed in the upcoming compensation cycle or other events in line with local practices

Assessment process:

• Compensation data is collected annually from global payroll systems
• Benchmarked against respective living wage standards
• Differences between employee compensation and living wage standards are identified and addressed through a structured remediation process

Assumptions:

• Assumes relative economic stability in regions of operation, with living wage adjustments reflecting local economic conditions
• As living wage updates once per year, sudden changes or constant changes in economic situations (e.g., in hyperinflation countries) may not be captured through living wage data; Sanofi has a well-developed approach to address issues in employees' compensation caused by continuous hyperinflation
• Assumes accuracy and reliability of data provided by Fair Wage Network and internal payroll systems

Targets and commitments

Target: Maintain alignment with living wage standards for all direct employees across all countries of operation, in line with policy objectives.

Since this ambition has already been achieved, no baseline value or year-on-year comparisons are necessary. Regular assessments ensure continued adherence, with any gaps promptly addressed. This commitment applies universally to all direct employees, subject to local regulations.

Future plans:

• Advocacy for living wage principles with strategic suppliers (currently being planned by Global Procurement department)
• Efforts to extend living wage principles to contingent or temporary workers

Remediation approach

No extra budget was allocated to impacted countries, as their conventional local budgets (e.g., merit budget) were sufficient to address identified gaps. Continuous monitoring and adjustment processes are in place to ensure that any newly emerged gaps can be addressed in a timely manner.

Geographic scope

Global coverage across all countries of operation. Data sourced from 69 countries as of December 31, 2024.

Validation

External validation: Fair Wage Network provides the living wage benchmarks and validates Sanofi's methodologies for calculating and addressing living wage gaps.

Social protection

Medical coverage

Sanofi provides medical coverage to employees and their families (partners and children) who can benefit from Sanofi coverage when the employee chooses to enroll them, subject to country plan design.

Since 2023, for new employees and new contracts, whenever legally and technically possible, Sanofi aims to remove exclusions in benefits for pre-existing conditions. Specifically:

• No exclusions for conditions such as HIV, chronic conditions, cancer, pandemics, congenital defects, suicide
• No medical questionnaires or medical examinations for employees to obtain coverage except in cases where the employee is above a free cover limit defined in the local policy

Paid sick leave

In addition to medical coverage, Sanofi provides employees access to competitive paid sick leave so that they can take the time they need to heal without having to worry about their financial situation.

Disability and death coverage

As an employer of choice, Sanofi provides market competitive cover to employees around the world in case of unfortunate life events such as death and disability, in line with global standards of care.

Business travel insurance

Sanofi provides emergency medical assistance and evacuation to all Sanofi employees travelling for business purposes outside their country of employment. The assistance applies 24 hours a day, seven days a week.

Employee Assistance Program (EAP)

Since 2022, Sanofi provides a global Employee Assistance Program (EAP) which offers confidential 24/7 support to employees everywhere. Six counselling sessions per employee, per issue, per year are offered.

Retirement and financial wellbeing

Sanofi focuses on creating high-quality savings opportunities that can contribute to employees' future financial wellbeing and empowers employees to plan for their retirement and long-term financial projects.

Gender-neutral parental leave

In 2022, Sanofi launched gender-neutral parental leave, providing 14 weeks of paid parental leave to any colleague who has a new child no matter which country they are working in. This includes colleagues welcoming a child due to childbirth, adoption, surrogacy, irrespective of the gender or sexual orientation of the parent. All birthing and non-birthing parents who are permanent employees are eligible regardless of gender or sexual orientation.

Number and percentage of eligible employees by gender who took parental leave

Family-related leave

All employees are entitled to family-related leave. They may be paid or unpaid, regulated or company granted through social policy and/or through collective bargaining agreements. Family-related leaves include, depending on the countries: maternity leave, paternity leave, parental leave, death in family leave, sick-parent or sick-child leave.

Global program availability

Currently, 100% of global programs under the All Well global strategy are consistently available in all Sanofi markets and to all employees, subject to local regulations.

Persons with disabilities

Disclosure approach

Sanofi states in its ESRS disclosure index that S1-12: Persons with disabilities is "Not applicable to Sanofi" (page 139).

Qualitative information disclosed

Despite marking the disclosure requirement as not applicable, Sanofi provides the following qualitative information:

France-specific data:

• Employment rate of people with disabilities in France: 8.6%
• This rate is almost two points above the statutory minimum rate of 6% in France
• Described as one of the highest among CAC40 companies in France

Methodology / scope:

• No global percentage of employees with disabilities disclosed
• No indication of methodology (self-identification, official registration, etc.) for the France figure
• No country exclusions explicitly stated, though the demographic survey notes "except where local regulations exclude specific questions"

Targets:

• Target: 100% of employees with disabilities to have workplace accessibility by end of 2025
• Current metric: 95% of audited sites (office spaces) at bronze level or higher accessibility classification

Supporting initiatives:

• 35 sites conducted accessibility assessments in 2024
• Accessibility classification levels: Unclassified, Bronze (minimum), Silver, Gold, Platinum
• Assessment categories: Physical, Health & Safety, Informational, Sensorial, Organization & Operational, Labs, Manufacturing, Warehousing
• First Digital Accessibility Standard launched in 2024
• Training on accessible workplace practices and disability etiquette available to all employees
• Global demographics survey launched in 2024 (anonymous, voluntary)
• Network of 35 disability delegates at French sites

Multi-year comparison

No multi-year data provided.

Training and skills development metrics

Performance and career development review coverage

Year-end performance assessment (%) - 2024

Note: Year-end performance assessment figures exclude the following populations: employees hired after October 1, employees on leave, employees in production-related jobs, interns and apprentices.

Career development reviews at Sanofi are structured within the Performance Impact framework, which includes four check-ins annually. Of these, two check-ins are focused on career development.

Training hours and participation

Training performance indicators (based on the iLearn system) - 2024

Note: These figures do not include training programs followed by subcontractors. iLearn delivers all compulsory and support function training. Training hours by gender exclude employees for whom information on gender was not available or undisclosed.

100% of employees completed at least one training module.

Individual Development Plans (IDPs)

An IDP has been completed or is in progress for:

• 56% of all employees in scope
• 83% for high-potential (Accelerate) talents

Targets

Sanofi currently does not have a formal quantitative target set for corporate training and development.

Health and safety metrics

Coverage

100% of employees covered by health and safety management system based on legal requirements and/or recognized standards or guidelines.

Health and safety metrics table

Notes:

(a) Published figure only concerns fatalities as result of work-related injuries.

(b) The Total Reportable Injuries (TRI) frequency rate is the number of occupational injuries with or without lost time, per million hours worked. It is calculated over a 12-month rolling period.

(c) The Lost-Time Injury (LTI) frequency rate is the number of accidents resulting in one day or more of time lost within a 12-month period, per million hours worked.

(d) Reported by Sanofi on a voluntary basis, in addition to mandatory metrics as per CSRD requirements.

Methodological note

Due to the early time of disclosure, hours worked for December 2024 were not available from all sites. In these cases, hours worked from November were rolled-over to December to arrive at the full calendar year.

The lost-time injury frequency rate is the number of accidents resulting in lost time of one day or more within a 12-month period, per million hours worked. For employees working in a fixed location, accidents occurring during the home-workplace commute are not included in this indicator. However, they are included for travelling medical reps, in accordance with internal reporting rules. Since 2021, work accidents occurring when teleworking have been included in this indicator.

The Total Reportable Injuries (TRI) frequency rate is the number of occupational injuries with or without lost time, per million hours worked.

Sanofi's HSE management system is ISO 14001:2015 certified and covers all relevant operations, including research, development, manufacturing, distribution centers and related support functions.

Work-life balance metrics

Family-related leave

All employees are entitled to family-related leave. Family-related leaves may be paid or unpaid, regulated or company granted through Sanofi's social policy and/or through collective bargaining agreements. Family-related leaves include, depending on the countries: maternity leave, paternity leave, parental leave, death in family leave, sick-parent or sick-child leave.

Percentage of employees entitled to family-related leave: 100% of employees are entitled to family-related leave.

Gender-neutral parental leave

Since 2022, Sanofi provides 14-weeks of paid parental leave to any colleague who has a new child no matter which country they are working in. This includes colleagues who are welcoming a child due to childbirth, adoption, surrogacy, irrespective of the gender or sexual orientation of the parent, as long as the employee is recognized as the child's parent. All birthing and non-birthing parents who are permanent employees are eligible regardless of gender or sexual orientation.

Number and percentage of eligible employees by gender who took parental leave

Return to work after parental leave

As part of the Global Pay Equity Action Plan, Sanofi reviews base salaries for employees returning from parental/family leave to prevent disparities and systemic bias. In the French gender equality index, Sanofi reports the percentage of female employees receiving a pay raise on return from maternity leave.

Monitoring and utilization

Program utilization data are tracked either through vendor reports on utilization rates or sourced directly from the human resources information system. Data are aggregated into dashboards for People & Culture teams, enabling yearly comparisons of program usage and performance.

Compensation metrics

Pay gap

Annually Sanofi reports a pay gap, which expresses the difference between the average female base pay and the average male base pay, in % of average male base pay. As of December 2024, Sanofi has an average global pay gap of 5.5% in favor of women. The calculation of the gender pay gap is very sensitive to the evolutions of our headcount structure, geographical footprint and business model. Thus, the gender pay gap has its limits to adequately reflect the effectiveness of our fair pay policies. The ratio considers:

• all employees (including the Chief Executive Officer and members of the Executive Committee);
• located in 70 countries;
• excluded are all contingent workers and, in France, employees who have taken different pre-retirement plans and are no longer working for Sanofi.

Remuneration ratio

In 2024, the annual total remuneration ratio of the highest paid individual to the median annual total remuneration for all employees was 166.3.

The scope of the calculation includes permanent Sanofi employees with at least two financial years of uninterrupted employment. For all in scope employees, except for corporate officers and employees in France, the calculation takes into account benefits recorded in the global human resources information system (HRIS), including base salary, short-term incentives (STIs), and long-term incentives (LTIs). Additional local benefits, which are not centrally recorded, are not considered.

The calculation of the corporate officers' (CEO and Chairman) compensation, as a general rule, and the compensation of employees in France takes into account all existing compensation items.

Methodology

Sanofi operates in multiple, diverse markets. Different geographies have unique laws, regulations and even reporting requirements. Pay is also impacted by country, location and fluctuating market dynamics and many factors as diverse as, among others, complexity of job roles, skills and individual performance.

Sanofi currently tracks the effectiveness of its policies using an internal methodology, focusing on exempt populations and countries with 50 or more employees. The pay gap is adjusted for job grade. As EU countries will implement the EU Pay Transparency Directive, Sanofi plans to review its Board reporting methodology to avoid inconsistencies between global and local measurements.

Gender representation: In 2023, Sanofi designed a comprehensive dashboard to drive greater visibility and accountability across the organization. It is available to Sanofi's Top 500 leaders and all Talent and DE&I professionals across the organization.

Incidents, complaints and severe human rights impacts

Speak Up Helpline - 2024 Results

In 2024, 900 alerts were raised through the Speak Up Helpline (available to both Sanofi employees and external stakeholders), which resulted in:

• 2 confirmed discrimination cases
• 28 confirmed harassment cases
• No severe human rights issues were reported via the Helpline in 2024

Discrimination Policy

Aligned with the Code of Conduct, Sanofi does not condone or support any form of discrimination. The global disciplinary policy states that discrimination, defined as any form of unequal treatment on the grounds of, but not limited to, race, ancestry, place of origin, color, sex, pregnancy, sexual orientation, gender identity or expression, civil status, age, religion, political convictions, language, social condition, disability or family status, on the basis of actual or perceived group membership or affiliation, is subject to a zero-tolerance approach.

The global Freedom of Association policy prohibits discrimination against employees who are engaged in union activities.

Grievance Mechanisms

The Speak Up Helpline is available to both Sanofi employees and external stakeholders. In 2024, Sanofi launched a global Speak Up program and an internal Ombuds Office, which provides independent, impartial, confidential and informal support to employees to overcome disputes, conflicts and barriers.

Status and Remediation

No information disclosed on the status of complaints (open/resolved/under investigation), fines, penalties, or compensation related to incidents.

Policies related to value chain workers

Sanofi has disclosed three main policies related to value chain workers:

Supplier Code of Conduct

Scope:

• All suppliers and their respective suppliers are required to agree to this code as part of their onboarding

Key content and principles:

• Labor Regulations: Adherence to regulations against child labor, forced labor, violence and discrimination, as per the ILO fundamental conventions
• Working Conditions: Provision of decent working conditions that include reasonable working hours, fair wages and benefits, and freedom of association
• Health & Safety: Ensuring the protection of workers' health and safety, providing training and information on hazards as well as emergency preparedness arrangements

Public availability:

• Incorporated into electronic ordering systems
• Referenced in both the global procurement policy and global procurement operating standard
• Access links are available in the Supplier Code of Conduct

Monitoring implementation:

• During onboarding, suppliers must acknowledge and agree to comply with the Supplier Code of Conduct
• Awareness is provided through suppliers' acceptance during onboarding and through training

Human Rights Policy (for value chain workers)

Links to international standards:

• Adherence to ILO Fundamental Principles and Rights at Work, encompassing:
  • Freedom of association and recognition of the right to collective bargaining (ILO conventions 87 and 98)
  • Elimination of all forms of forced labor (ILO conventions 29 and 105)
  • Effective elimination of child labor (ILO conventions 138 and 182)
  • Elimination of discrimination in employment (ILO conventions 100 and 111)
  • Just and favorable working conditions (ILO conventions 1, 14, 106, 132 and 138)
• Support for international human rights standards, including the United Nations Guiding Principles on Business and Human Rights

Key content (for adequate wages, working time and social dialogue):

• Addresses matters of adequate wages, working time, and social dialogue in the Human Rights Policy Note
• Overtime work is voluntary, with consideration for business needs and the health and safety of workers
• Recognizes the importance of addressing violence and promotes safety within its value chain

HSE Policy

Governance:

• Formulated by the HSE department
• Endorsed by senior management

Scope:

• All employees and contractors
• Suppliers, co-contractors, and subcontractors are strongly encouraged to comply with HSE standards

Key content and principles:

• Seeks to maintain a safe and healthy workplace
• Compliance used as a key assessment criteria for suppliers, co-contractors, and subcontractors

Monitoring implementation:

• HSE management system implemented across all Sanofi sites
• Undergoes regular reviews
• Comprehensive reference manual delineating standards and methodologies aligned with risk analysis and stakeholder expectations
• Suppliers and subcontractors targeted by audits, concentrating on HSE performance and pertinent human rights issues
• Audits tracked through action plans to monitor continuous compliance and improvement
• Risk assessments for external parties reviewed every three years or during significant changes
• Consolidated annually in a risk matrix

Taking action on material impacts on value chain workers

1. Supplier Engagement Program

Description:
Engagement with suppliers to improve their environmental footprint and fight climate change. The program sets clear environmental expectations, provides guidance, and supports suppliers less advanced on sustainability matters.

Scope: Upstream value chain
Time horizon: Short to medium term (program ongoing in 2024)
Expected outcomes / KPIs:

• 205 suppliers engaged in 2024, covering 75% of supplier-related emissions and representing 50% of procurement spend
• Suppliers commit to:
  • Calculate their Scope 1+2+3 emissions and report them publicly
  • Get a CDP Climate score of A or B
  • Engage with their own supply chain
  • Set SBTi (Science Based Targets initiative) targets
  • Set a target for 100% renewable electricity by 2030

Links to policy: Sustainable Procurement policy

2. Pharmaceutical Supply Chain Initiative (PSCI) – Human Rights Sub-group

Description:
Engagement in the PSCI human rights sub-group focused on regions such as India and China, where supplier conferences are organized to raise awareness about labor and human rights issues. These conferences serve as a platform for dialogue and education on best practices.

Scope: Upstream value chain (workers from multiple sectors worldwide)
Responsible teams:

• People & Culture team leads dialogue with trade unions
• Procurement teams lead engagement via PSCI

Expected outcomes:

• Alignment with best practices in labor and human rights issues

Links to policy: Human rights policy, Supplier Code of Conduct

3. Supplier Risk Management Lifecycle

Description:
Comprehensive supplier risk assessment and continuous monitoring through three key areas: onboarding, risk assessment, and continuous monitoring.

Scope: Upstream value chain
Key components:

a) Sustainability Assessment during Tenders (ESGiT)

• Since 2022, all new suppliers bidding for Sanofi tenders must undergo a compulsory sustainability assessment
• Assessment includes human rights questions and represents up to 20% of a supplier's scorecard
• Suppliers evaluated as risky are asked to commit to undergoing third-party assessment

b) Digital Onboarding Platform (COUPA)

• Collects information on labor rights and health & safety policies
• Suppliers must complete risk assessments and sign Supplier Code of Conduct before transacting
• Deficiencies trigger mitigation action plans to be executed within one year

c) Third-party Risk Assessment (EcoVadis)

• Continuous supplier evaluation and monitoring
• Focus on 47 high-risk procurement subcategories
• Reassessments scheduled every two years
• Contract termination possible for critical non-compliance

Target:

• Evaluate 80% of suppliers requiring sustainability assessments by end of 2025
• Evaluate 100% by 2026

Links to policy: Supplier Code of Conduct, Sustainable Procurement policy

4. Supplier Health & Safety Audits

Description:
Regular audits conducted by Sanofi's HSE department or external auditors, focusing on HSE performance and labor rights issues where relevant.

Scope: Upstream value chain (suppliers, subcontractors, Contract Manufacturing Organizations)
Time horizon: Ongoing (2022-2024 data available)

Results:

Expected outcomes:

• Of 103 suppliers ranked critical in 2020: 39% have improved performance, 39% subject to business termination, 22% still under re-audits and CAPA
• Action plans verified through re-assessment or specific follow-up audits
• Audit frequency based on risk score (ranks 1-6), with systematic audits for rank 5 and 6 suppliers

Links to policy: HSE policy, Supplier Code of Conduct

5. Energize Program

Description:
Collaborative effort within the pharmaceutical industry to help shared supply chains convert to renewable energy.

Scope: Upstream value chain
Expected outcomes:

• Supplier decarbonization
• Conversion to renewable energy

Links to policy: Climate transition plan

6. Open Letter to Suppliers (Sustainable Markets Initiative)

Description:
In 2023, the Sanofi CEO signed an Open Letter to Suppliers published by members of the Sustainable Markets Initiative Health Systems Task Force to set out minimum targets for supplier decarbonization.

Scope: Upstream value chain
Time horizon: 2023 onwards
Links to policy: Climate transition plan

7. Supplier Code of Conduct Implementation

Description:
All suppliers required to agree to and comply with Sanofi's Supplier Code of Conduct during onboarding, covering:

• Labor Regulations (ILO fundamental conventions)
• Working Conditions (working hours, fair wages, freedom of association)
• Health & Safety (worker protection, training, emergency preparedness)

Scope: Upstream value chain
Expected outcomes:

• Adherence to regulations against child labor, forced labor, violence and discrimination
• Provision of decent working conditions
• Protection of workers' health and safety

Links to policy: Supplier Code of Conduct, global procurement policy, global procurement operating standard

8. IndustriALL Global Trade Union Engagement

Description:
Meetings with the IndustriALL global trade union to engage with workers from multiple sectors worldwide.

Scope: Upstream value chain
Responsible team: People & Culture team leads dialogue with trade unions

Expected outcomes:

• Alignment with best practices in labor and human rights issues

Links to policy: Human rights policy

Resources Allocated

Non-financial resources:

• HSE department conducting audits
• Procurement teams leading PSCI engagement
• People & Culture team leading trade union dialogue
• Risk management team overseeing Supplier Risk Governance Structure
• Monthly and quarterly meetings with internal stakeholders to address supplier risks

Digital infrastructure:

• COUPA digital onboarding platform
• EcoVadis third-party risk assessment service
• ESGiT sustainability assessment tool
• Provigis online platform for supplier documentation

No specific financial resources (capex/opex amounts) quantified for value chain worker actions.

Policies related to consumers and end-users

Sanofi's S4-1 disclosures are cross-referenced to pages 91-111 of the Universal Registration Document. The excerpts provided focus on the Medical Information function and related processes, but do not explicitly name a standalone policy document for S4-1.

Medical Information Policy

Scope:

• Applies to Sanofi's Medical Information function providing information to healthcare professionals (HCPs), patients, and consumers
• Covers all written and oral communication through various channels including phone, web-portal, and webform

Key content and principles:

• Provides accurate, unbiased, and balanced evidence-based product information to HCPs
• Information is for education purposes only and not intended to promote products
• Uses pre-approved scientific response documents (SRDs) to ensure quality of information
• SRDs are created, reviewed and approved by medically and scientifically qualified employees
• Maximum validity period of two years for SRDs with immediate review requirements for labeling or scientific updates
• Includes appropriate disclaimers in line with local regulations
• Secured access to off-label information according to local regulations

Public availability:

• Available to internal stakeholders on the Sanofi Quality Document repository
• Medical Information web-portal provides external access
• External stakeholders are notified orally of Data Privacy and Personal Data Protection Policy and directed to website for more information
• Notice available on Medical Information web-portal and webform

Monitoring and implementation:

• Medical Information is regularly audited by internal and third-party auditors
• Inspected by health authorities to assess processes and systems
• Target of "no critical findings" (0 critical findings achieved in 2024)
• Corrective and Preventive actions implemented for continuous performance improvement
• Service level metrics: 70% of calls answered within 30 seconds (81% achieved in 2024)
• Resolution time metrics: 90% of inquiries resolved same day (91% achieved in 2024)
• SRD creation, revision and approval performed in Global Medical Information system under GxP (good practice) environment
• Monthly reviews with vendors on service level metrics
• Quarterly reviews of resolution time metrics automatically calculated by CRM system

Data Privacy and Personal Data Protection Policy

Scope:

• Applies to external stakeholders contacting the Company

Public availability:

• Communicated orally to external stakeholders phoning the Company
• Available on Sanofi website
• Notice available on Medical Information web-portal and webform

The document cross-references S4-1 to pages 91-111 but the excerpts focus primarily on Medical Information processes and metrics rather than comprehensive policy disclosures aligned with international standards such as UNGPs or OECD Guidelines.

Incidents of corruption or bribery

Confirmed incidents

Sanofi reports that in 2024 the Ethics & Business Integrity (E&BI) department received 900 alerts through its Speak-Up Helpline and other reporting channels. Out of these alerts, 396 cases were substantiated, of which:

• 38 confirmed fraud cases (including conflicts of interest, expense fraud, asset misappropriation, non-financial fraud, and other types)
• The distribution included categories such as:
  • Unethical practices and breach of policies: 133 cases
  • Improper sales practices: 83 cases
  • Fraud: 38 cases
  • Discrimination or harassment: 30 cases
  • Customer data privacy: 12 cases
  • Money laundering and insider trading: 0 cases
  • Other: 98 cases

While Sanofi reports fraud cases, it does not explicitly separate or quantify corruption or bribery incidents specifically under the G1-4 definition.

Convictions and fines

Sanofi explicitly states:

• Number of convictions for violation of anti-corruption and anti-bribery laws: no convictions were reported in 2024
• Total amount of fines for violations of anti-corruption and anti-bribery laws: no fines were issued during the year 2024

Disciplinary actions

A total of 141 dismissals or resignations took place related to misconduct in 2024:

• 84 employees were terminated in connection with the 38 confirmed fraud cases
• 57 employees were terminated in connection with the 358 non-fraud substantiated cases

Other corrective actions implemented included additional training, process improvement steps, remuneration impacts, and verbal or written warnings, in accordance with Sanofi's Corrective & Disciplinary Actions policy.

Sanofi's Disciplinary Action Policy states zero tolerance of corruption and bribery cases, which result in termination of employment.

Contracts terminated

Not disclosed for corruption or bribery incidents specifically.

Investigation and speak-up procedures

Sanofi operates a 24/7 Speak-Up Helpline available in 28 languages, operated by an independent third party. The helpline is accessible to all employees, contractors, business partners, suppliers, and value chain workers.

Key features include:

• Anonymous and confidential reporting options
• All reporters notified of safe receipt within seven days
• Zero tolerance for retaliation policy
• Global Triage and Investigations team manages reports through a secure case management system
• Regular reporting to the Executive Compliance Committee and Audit Committee with metrics on cases by region, issue type, and outcomes
• In 2024, Sanofi launched a global Speak Up program and an internal Ombuds Office to provide independent, confidential support

The Ethics & Business Integrity (E&BI) function, under the Chief Compliance Officer, is responsible for receiving, assessing, handling and investigating reports. The Board and Executive Compliance Committee oversee implementation of anti-corruption and anti-bribery procedures.

Anti-corruption program

Sanofi maintains a comprehensive anti-corruption program including:

• Zero-tolerance policy towards bribery and corruption
• Mandatory Code of Conduct training for all employees including anti-bribery and anti-corruption modules
• Risk-based anti-bribery due diligence on third-party business partners
• Regular Ethics & Business Integrity risk assessments at country and global levels
• AI-powered monitoring for pattern detection and anomaly identification
• Third-party due diligence system (eGuard in the Coupa Module)

In 2024, 81,058 Sanofi employees completed at least one global compliance learning module for a total of 411,419 modules completed. The Code of Conduct training, including anti-bribery and corruption, is mandatory for all employees. Failure to complete training impacts employee bonuses.

Political influence and lobbying activities

Political engagement approach

Sanofi believes in carrying out lobbying and political engagement in a responsible manner. Sanofi's activities are governed by a global procedure on lobbying, updated in 2024 considering the highest international codes and standards and the evolving external transparency requirements. "Interacting with stakeholders", which includes all trade associations, public authorities, governments, universities and research, is one of the 16 fundamental principles from Sanofi's Code of Conduct.

Our Global Operating Procedure on Responsible Lobbying and Interaction with Public Officials stipulates that Sanofi must perform lobbying with ethical standards and due consideration of patients, in addition to compliance with Sanofi's Code of Conduct and with the applicable lobbying and advocacy laws and regulations where Sanofi does business.

Our lobbying activities contribute to discussions mainly around innovation, healthcare, access to healthcare, environment and climate change, and diversity, equity and inclusion. Sanofi's positions on these topics are published on our public website, including the key asks to specific governmental bodies. These issues are adapted based on the local context.

Ethical standards and guidelines

The key principles of the procedure include (but are not limited to):

• only Sanofi-authorized employees and consultants may engage in lobbying activities and political interactions on Sanofi's behalf, and must comply with applicable laws and regulations;
• lobbying activities are done with the purpose of advancing Sanofi's interests and are performed with transparency;
• anti-bribery and due diligence are performed for organizations or third parties (e.g., research institutes or think tanks, paid media) conducting lobbying activities on behalf of Sanofi;
• in-house or consultant lobbyists that have previously held a public official post must respect cooling-off periods or transition rules imposed by their former organizations;
• any misalignment with trade associations on topics related to our own social and environmental commitments is publicly announced;
• lobbying and advocacy activities (including key topics we advocate and the corresponding resources) are reported on an annual basis.

The policy applies to all Sanofi employees and consultant lobbyists hired by Sanofi around the world who perform lobbying activities or engage with Public Officials.

Our lobbying activities are coordinated and driven by our employees working in public affairs in the countries where we operate, with clear accountabilities to the executive board (CEO and Executive Vice Presidents), and are primarily overseen by the Executive Vice President of Corporate Affairs.

The OECD's Recommendation for Transparency and Integrity in Lobbying was used as a reference in the development of the Sanofi Global Operating Procedure on Lobbying and Interactions with Public Officials.

Actions and oversight

Below are ongoing actions carried out throughout the year:

• our Public Affairs Department maintains a list of employees authorized for lobbying, a list of trade association memberships and members, and provides guidance on contracting consultants for lobbying activities;
• our Public Affairs Department strives to ensure that direct or indirect lobbying activities are consistent with Sanofi's social and environmental goals;
• training/learning programs: Sanofi employees authorized to engage with public officials receive mandatory training on the Lobbying Global Operating Procedure and on relevant global and local policies, as advised by the relevant global or local Public Affairs Department. Additional training, support platforms and enforcement mechanisms may be determined on a case-by-case basis, at global and/or local level;
• disclosure: Sanofi is committed to providing timely and complete information to government-led transparency registries or commonly used voluntary databases for lobbying and corporate political contributions.

As part of our efforts to enhance transparency and integrity in our lobbying and advocacy activities, a risk-based internal control system is put in place to support the implementation and monitoring of our activities: twice a year, an internal audit is conducted on public affairs activities.

EU Transparency Register

In 2009, we joined the European Union's Transparency Register, which provides European citizens with direct access to information on different organizations' activities aimed at influencing the European Union's decision-making process, as well as the resources invested in these activities. Registrants are required to provide information about their lobbying and advocacy activities and sign the Transparency Register Code of Conduct. Sanofi's EU Transparency Register Number is 61291462764-77.

Our estimated annual costs related to activities covered by the register for the financial year 2023 is between EUR 1,750,000 and EUR 1,999,999.

Transparency registers

Country registers where Sanofi reports its lobbying and advocacy activities include: Australia, Canada, France, Germany, United States.

Political contributions

Sanofi's corporate contributions are financial and come directly from the Company. In the political arena, these contributions help foster dialogue with individual candidates seeking to champion our issues and groups of elected officials who understand our unique role in the healthcare sector. Such political contributions are only made in the United States. At the federal level, and in some states, corporate contributions are prohibited.

Past years political contributions (United States only)

Sanofi US PAC

The Sanofi US Employee's Political Action Committee (Sanofi US PAC) is a voluntary group of Sanofi employees with the mission to increase Sanofi's voice in the political arena. Sanofi US PAC supports federal and state candidates, on a nonpartisan basis, who champion Sanofi and its diverse portfolio. Additionally, Sanofi US PAC seeks to educate candidates who want to learn more about Sanofi's portfolio and subsequently champion our issues. Sanofi US PAC is governed by the PAC Board of Directors, a group of Sanofi employees covering a broad range of company functions and responsibilities. The Board decides which candidates to support, after incorporating important factors: positions on core industry issues and prevalence of Sanofi US employees or facilities in the state or district at hand.

Sanofi US PAC Spend

In-kind contributions

We do not provide any in-kind political contributions related to lobbying. Our Global Operating Procedure states that the provision of gifts, items, or services could be subject to public scrutiny. Accordingly, such contributions to Public Officials are strictly prohibited.

Trade association memberships

Our lobbying activities are mainly carried out through the trade associations we adhere to at global, regional and national level. Monetary contributions provided to trade associations are allocated to their internal operations and advocacy activities.

Most lobbying activities within Sanofi are carried out through trade and industry associations. Sanofi is involved in several trade and industry groups that represent the pharmaceutical sector and our business interests. Sanofi closely monitors our engagement with trade associations through our representatives. The Company has established clear accountability for the key priority topics driven by our executive board representatives in trade association boards and committees.

Sanofi engages in topics that are relevant to the business and recognizes that these organizations can engage in a broader range of topics that may be beyond the priorities of the company. We understand that our participation as a member of these associations might mean that they may not always be aligned with the positions of the broader organization and/or its members. In case of any misalignment with our own position, Sanofi representatives who serve on boards and committees convey these concerns as appropriate and seek to offer solutions to address them accordingly.

In-kind contributions may be provided from time to time to trade associations. These contributions are not quantified on account of their nature: individual speaker or expert engagements from Sanofi, provision of meeting venues, support for meeting organizations, provision of IT tools, etc.

We disclose our contributions to trade associations via Sanofi's website annually.

Board members and former public officials

As of 2024, no member of the Sanofi Board of Directors or the Executive Committee has held a comparable position in a public administration in the two years preceding their appointment. Sanofi's Global Operating procedure on lobbying outlines that former public officials that are to be hired by Sanofi must respect any cooling periods imposed by their former organizations.

Our Global Operating Procedure on Responsible Lobbying and Interaction with Public Officials states that individuals that have previously held a public official post and will be contracted by Sanofi as an in-house or consultant lobbyist must respect cooling-off periods or transition rules imposed by their former organization. Sanofi employees seeking to hire former Public Officials must seek prior clearance from the Public Affairs Department, Human Resources, and Legal before starting engagement discussions to determine appropriate cooling off or transition periods.

Payment practices

Standard payment terms

Sanofi tracks standard payment terms using the weighted average payment terms (WAPT) methodology for all vendors. The company strives to follow local legislation and proceeds on a case-by-case basis with suppliers depending on the contractual terms.

Main supplier categories (representing 58% of spend) and their respective WAPTs:

Overall payment terms:

• Overall Sanofi Biopharma WAPT: 71 days
• 50% of the spend is on target
• Biopharma WAPT for spend in the European Union: 62 days

By default, the payment terms reflected in the Supplier Master Data are those negotiated with the supplier. Payment terms are set from the date of receipt of the invoice unless applicable laws necessitate otherwise. The standard payment terms are mutually agreed with suppliers based on the current market practice and in compliance with local regulations.

Average time to pay invoices

At the end of 2024, Sanofi's global days payable outstanding (DPO), which is the number of days between invoice booking date and invoice payment date, was 42.5 days.

Legal proceedings for late payments

To date, Sanofi is aware of 1 legal proceeding due to late payment. Additionally, Sanofi is subject to regular audits/inspections from the French authorities, which are public.

Policy on late payments to SMEs

At present, there are no special terms at Sanofi for SMEs, except where required by law. Sanofi pays SMEs according to the vendor master data. The company acknowledges the definition of SMEs as set forth by respective countries and strives to adhere to the payment regulations established in each country. During the onboarding process, SMEs have the option to indicate their status.

Sanofi's ultimate goal is no late payments.

Actions on overdue payments

Sanofi does not have a company level action, but a case-by-case set of rules based upon local legislation and local supplier agreements. If a payment is overdue, suppliers can alert Sanofi business/procurement to request immediate payment. This change in payment would need approval from Sanofi Procurement before being released to supplier.

Prompt payment code participation

Not disclosed.

Verification

The metrics above are not validated by an external body.