Section 1 – Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
Conflict Minerals Disclosure
Sanofi
(including its consolidated subsidiaries, the “Company”) is filing this Form SD pursuant to Rule 13p-1 under the Securities Exchange Act of 1934 (“Rule 13p-1”) for the reporting period from January 1, 2022 to December 31, 2022 (the “Reporting Period”).
Rule 13p-1, through Form SD, requires disclosure of certain information if a company manufactures or
contracts to manufacture products for which certain “conflict minerals” (as defined below) are necessary to the functionality or production of such products. Form SD defines “conflict minerals” as: (i)
(a) columbite-tantalite, (b) cassiterite, (c) gold and (d) wolframite, or their derivatives, which are currently limited to tantalum, tin and tungsten; or (ii) any other mineral or its derivatives determined by the U.S.
Secretary of State to be financing conflict in the Democratic Republic of the Congo or an “adjoining country,” as such term is defined in Form SD (collectively, the “Covered Countries”).
The Company’s operations may at times manufacture, or contract to manufacture, products for which conflict minerals are necessary to the
functionality or production of those products (collectively, the “products”).
Reasonable Country of Origin Inquiry
As required by Form SD, the Company has conducted a good faith reasonable country of origin inquiry (“RCOI”) regarding
the conflict minerals that are necessary to the functionality or production of its products during the Reporting Period, which the Company refers to as the “Subject Minerals,” to determine whether any such Subject Minerals
originated in the Covered Countries and/or whether any of the Subject Minerals were from recycled or scrap sources, in accordance with Form SD and related guidance provided by the Securities and Exchange Commission (“SEC”).
In accordance with SEC Staff Guidance with respect to Rule 13p-1, the Company excluded packaging materials from this review.
The Company’s global supply chain is complex. In the course of its business operations, the Company may purchase materials and components
containing Subject Minerals. These materials and components may, in turn, be included in the Company’s products. Because the Company does not purchase conflict minerals directly from mines, smelters or refiners, there are many third parties in
the supply chain between the Company and the original sources of conflict minerals. The Company’s immediate suppliers, in turn, typically are also downstream in the minerals supply chain and have similar challenges in achieving supply chain
transparency. As a result, the Company relies on its direct suppliers of materials, with which the Company has business relationships, to provide information regarding the origin of any conflict minerals that are included in their products.
The Company’s RCOI process and results regarding the Subject Minerals include as described below.
| |
• |
|
The Company’s procurement and manufacturing and supply departments worked together to search the
Company’s database to identify where Subject Minerals were used in its products. As a result of this process, the Company identified certain of its immediate, potentially in-scope suppliers of materials
that provided materials or components containing Subject Minerals (collectively, the “Covered Suppliers”). |
| |
• |
|
The Company put in place a consultation of the Covered Suppliers, with the assistance of a third-party service
vendor (the “Vendor”) with expertise in supply chain due diligence, to assist in data collection and identifying risks of the presence of Subject Minerals originating from Covered Countries in the Company’s products,
using the Conflict Minerals Reporting Template (“CMRT”) published by the Responsible Materials Initiative. The Company, with the assistance of the Vendor, inventoried the responses received from the Covered Suppliers.
|
