This document (the “Chart”), issued by Sanofi Oy, a company registered under the business identity number 1048723-8 and having its registered office located at Revontulenkuja 1, 02100 Espoo, Finland (hereinafter referred to as “Sanofi”), describes Sanofi’s policy regarding invitation of healthcare professionals (Guests) to scientific and/or medical information events (“Event”).
- Ethic Codes. According to the applicable laws and in accordance with: (i) the EFPIA code for healthcare professionals of the European Union or (ii) the IFPMA code for healthcare professionals from outside of the European Union, related to the promotion of drugs, Sanofi’s coverage of invitations’ costs is strictly limited to event registration fees, travel and accommodation costs. No personal expenses will therefore be reimbursed, nor costs related to individuals accompanying the Guest.
- Transparency. As requested by codes of ethics and/or laws and/or regulations applicable to the pharmaceutical industry, Sanofi and/or its Affiliates have to disclose the existence, the scope and the financial transfers provided for the purposes of the invitation. In accordance with applicable data privacy laws, the Guest can consent to such disclosure in the Data Privacy Consent form that will be sent separately. For the purpose hereof, “Affiliate(s)" shall mean Sanofi parent company “Sanofi” (registered in PARIS, France under the n°395 030 844, hereinafter "Sanofi SA") and any legal entity which is controlled by Sanofi SA or under common control with Sanofi SA or controlling Sanofi SA. For the purpose hereof, “Control” shall mean the direct or indirect ownership of at least fifty per cent (50%) of the share capital or the voting rights of such entity.
- Data Privacy. Sanofi will process all personal data obtained for the invitation in accordance with applicable data protection laws. Sanofi will process any personal data received from the Guest, including – but not limited to – Guest’s name, profession, address, contact details (“Personal Data”), for purposes linked to the invitation, to fulfil legal, regulatory and compliance requirements applicable to Sanofi - including, without limitation, anti-bribery laws, audit, tax records, reporting requirements and for the purpose of the Event (“Purposes”). Sanofi may disclose the Personal Data to its Affiliates and to any third party providing services to Sanofi (“Recipients”), for the Purposes described herein and for storage purposes. Except as set forth herein, the Personal Data will be kept confidential. Personal Data may therefore be stored, processed or transferred for the Purposes to Recipients possibly located in third countries that do not necessarily ensure the data protection level of the EEA member countries. Sanofi shall take all appropriate measures to safeguard and prevent access to Personal Data. Sanofi stores and processes the Personal Data for a period reasonably determined by business necessity to meet the Purposes. Objection to the processing or request (i) to access or (ii) to rectify the Personal Data, or (iii) to obtain Personal Data in a structured and machine-readable format may be done by contacting the “Data Privacy Officer” at Sanofi’s address. Filling complaint about the processing is also possible before the local Data Protection Authority.
- Guest responsibilities. Guest guarantees that his acceptance of any benefits under the invitation has been approved by relevant persons where this is necessary according to law, collective industry standard agreements which apply to the relationship between Sanofi and Guest, and its employer's regulations. Guest will not be considered as a Sanofi employee, agent or partner, nor as a participant in any programs, insurance or other benefits extended to employees of Sanofi.
- Tax. Guest shall bear all taxes and social benefit contribution which could be payable due to the benefits received under the invitation. If necessary due to reporting requirements to authorities, Guest further agrees to provide to Sanofi such information as is reasonably required in relation to the receipt of such benefits.
- Anti-Bribery. The arrangements set out in this Chart do not take effect and are not intended to take effect as an incentive or reward for a person’s past, present or future willingness to prescribe, administer, recommend (including formal recommendations), purchase, pay for, reimburse, authorize, approve or supply any product or service sold or provided by Sanofi or as an incentive to grant an interview for any sales or marketing purposes. Guest acknowledges that any support and/or payments provided by Sanofi will remain independent of all decisions relating to drug choice made by any healthcare professionals which the Guest engages.
Guest shall comply with the requirements of all applicable anti-bribery regulations, codes and/or sanctions, both national and foreign, including but not limited to the US Foreign Corrupt Practices Act, the UK Bribery Act and the OECD Convention dated 17th December 1997 (the “Anti-Bribery Laws”) and; therefore that Guest shall not make, promise or offer to make any payment or transfer anything of value (directly or indirectly) to (i) any individual, (ii) corporation, (iii) association, (iv) partnership, or (v) public body, (including but not limited to any officer or employee of any of the foregoing) who, acting in their official capacity or of their own accord, are in a position to influence, secure or retain any business for (and/or provide any financial or other advantage to) Sanofi by improperly performing a function of a public nature or a business activity with the purpose or effect of public or commercial bribery, acceptance of or acquiescence in extortion, kickbacks or other unlawful or improper means of obtaining or retaining business. Guest shall immediately notify Sanofi if, at any time, the circumstances, knowledge or awareness changes such that Guest would not be able to repeat the warranties set out above at the relevant time.
- Binding Agreement. By accepting the invitation the Guest agrees to be bound by the terms of the Chart.