As a member company of the European Federation of Pharmaceutical Industries and Associations (EFPIA), Sanofi discloses details of its collaborations with healthcare professionals (HCPs) and healthcare organisations across Europe. The disclosures include transfers of value, whether in cash, in kind or otherwise that Sanofi makes to HCPs and healthcare organisations. Transfers of value could relate to a wide range of activities, such as research and educational grants to healthcare organisations and could include transfers of value that Sanofi makes to individual HCPs, such as in sponsoring them to attend educational meetings, paying speaker fees, paying expenses, and remunerating them for consultancy activities and participating on advisory boards.

HCPs should be fairly compensated for the expertise and services they provide to the industry. At the same time, Sanofi acknowledges concerns that such transactions should be transparent. For this reason, Sanofi believes that the publication of transfer of value data, particularly on a named basis, serves important legitimate interests because it serves to:

• protect and instil public confidence in the integrity of the relationship between the pharmaceutical industry and HCPs;
• represent a step towards fostering greater transparency and building greater trust between the pharmaceutical industry, the medical community and society;
• safeguard public health by promoting HCP’s accountability to patients for decisions about their treatment;
• demonstrate commitment to continual education and development of HCPs to provide better care to patients; and
• enable Sanofi to most fully comply with its disclosure obligations, for instance under the Association of the British Pharmaceutical Industry (ABPI) Code of Practice.

All transfers of value by Sanofi to HCPs and healthcare organisations are published on the ABPI website. If a HCP does not object to Sanofi processing and disclosing his/her personal data, then the total sum of all transfers of value made by Sanofi to that HCP will be disclosed on an individual named basis. However, if a HCP does object to Sanofi processing and disclosing his/her personal data, then Sanofi will aggregate their data with other transfer of value data, so that the disclosed data does not identify them as an individual.

Effective from 1 January 2020, Sanofi switched from relying on written consent from HCPs to legitimate interests as the legal basis of processing and disclosing transfers of value data under the applicable data protection legislation (the EU General Data Protection Regulation, as supplemented in the UK by the UK Data Protection Act 2018).

To balance the legitimate interests described above against the interests, rights and freedoms of the relevant individual HCPs, Sanofi provides HCPs with information about how and why their personal data will be processed and disclosed, with specific instructions to contact GB-Transparency@sanofi.com  if they wish to exercise their right to “opt out” of disclosure on an identifiable basis.

View the support, including the nature and value we have given to patient organisations, and the methodological note summarising the methodology used in preparing our disclosure report on Transfers of Value to Patient Organisations, in accordance with the ABPI Code of Practice: