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 for the reporting period from
January 1, 2020 to December 31, 2020 (the “Reporting Period”).
Rule
13p-1, through Form SD, requires the 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 included in 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”).
The results of the Company’s RCOI
regarding the Subject Minerals are set out below.
The Company’s global supply chain is complex. In the course of its business
operations, the Company may purchase materials and components containing conflict 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. As a result, the Company relies on its direct suppliers of materials to provide information
regarding the origin of any conflict minerals that are included in their products.
The Company’s procurement and industrial affairs
departments worked together to search the Company’s data base to identify where Subject Minerals were used in its products. As a result of this process, the Company identified a small number of 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 to confirm whether the Subject Minerals contained in the materials or components
come from Covered Countries. The Company inventoried the responses received from the Covered Suppliers.
No evidence of Covered Country
origin has resulted from the RCOI process described above. The Company has no reason to believe that the Subject Minerals contained in its products during the Reporting Period may have originated in the Covered Countries.
As required by Form SD, the disclosure contained in this Form SD regarding the Company’s RCOI is available on the Company’s website
located at http://www.sanofi.com. The content on, or accessible through, any web site referred to in this Form SD is not incorporated by reference into this Form SD unless expressly noted.