Head of Ethics and Business Integrity at Sanofi

Sanofi is a global life sciences company committed to improving access to healthcare and supporting the people we serve throughout the continuum of care. From prevention to treatment, Sanofi transforms scientific innovation into healthcare solutions, in human vaccines, rare diseases, multiple sclerosis, oncology, immunology, infectious diseases, diabetes and cardiovascular solutions and consumer healthcare. More than 110,000 people at Sanofi are dedicated to make a difference on patients’ daily life, wherever they live and enable them to enjoy a healthier life.

JOB PURPOSE

1. Enable the effective implementation of Sanofi Global compliance program in English and French Speaking Africa, across different global business units (General Medicine, Specialty Care, Sanofi Pasteur and CHC) operating in the markets directly or through third parties.
2.  Ethics and Business Integrity Officer WESA is a strategic business partner, he/she will have an overview of all English-speaking Africa (including Angola and Mozambique) businesses, working in partnership with Management to ensure a sustainable business growth while ensuring proper Third-party risk management.

KEY ACCOUNTABILITIES

General

1.  Demonstrate risk awareness in Ethics and Business Integrity and understands their impact on patients, reputation, and business. Evaluates courses of action against such risks and proactively seeks to prevent and mitigate them
2. Act as Trade and Revenue function compliance business partner, including advice on compliance part of commercial policy of interaction with Sanofi customers
3. Proactively monitor and maintain up-to-date knowledge about global and local compliance best practices developments/changes, relevant legislation changes to follow in everyday professional activity
4. Contribute to the Sanofi E&BI and cross-functional knowledge sharing
5. Identify business and compliance risk areas, inefficient or ineffective business processes and work with management in a cross-functional approach to streamline such processes in a fully compliant manner
6. In a collaborative manner, implement, monitor, and augment the global Sanofi E&BI program and policies, while embedding compliance into everyday business practices
7. Participate or lead special projects in E&BI, or adjacent area
8. Act as a catalyst for corporate initiatives in the Global E&BI Organization, and lead and oversee projects as necessary, such as business process improvement efforts
9. Actively participate and coordinate activities as necessary in business integrity audits. This could include, for example, pre-audit correspondence, risk assessments, acting as key contact during the audit, ensuring that audit points are valid, and verifying that corrective actions are implemented as committed by management
10. Work with global compliance organization in leading and/or participating in special compliance projects as well as temporary assignments assisting other markets
11. Conduct or assist in internal investigations in alignment with E&BI function colleagues

NBM (countries in scope listed in Appendix 1)

1. Appropriate and regular trainings are delivered regarding Sanofi code of conduct to third party
2. Adequate review and follow-up (monitoring and audit reports) on third party actions done for Sanofi products (as per contract/ including Audit clause)
3. Appropriate segregation of activities between Sanofi and other companies represented by the third party
4. Assessment of percentage of remuneration to be done regularly by Sanofi in line with cost of doing business for Sanofi (no success fees, necessary reports to support remuneration)
5. Be a pro-active business partner in supporting and advising the management and distributor management teams on Sanofi expectations
6. Conduct periodic reviews with the management and distributor management teams
7. Keep track of new and changing legislation and regulations; assess their impact on Sanofi liability
8. Establish an inventory of distributors of the geographic area (and sub-distributors, if applicable), which should be kept up to date
9. Regular Audits (outsourced) with CAPAs follow-up
10. Review of Compliance indicators to identify areas of risk. Develop mitigation plan where needed
11. During the transition period monitor the deliverables and milestones according to the Distributor EBI action plan; ensure effective implementation of their compliance program by providing support to ensure risk mapping is done, processes are developed and implemented to address risk, all employees are trained
12. Perform regular assessments of the design and implementation of the program

Nigeria

1. Responsible for managing the process of ensuring that the core elements of an effective compliance program are implemented and maintained
2. Compliance standards, policies, procedures, and processes are designed, implemented, and updated. Training and communication occurs as required. Compliance activities are monitored periodically. Enforcement of compliancerelated disciplinary actions occurs properly
3. Actively participate in local management team / Compliance committee and contribute to various business projects from compliance perspective.
4. Help embed business integrity and compliance behaviour into the local business using a risk-based approach
5. Provide assistance and cross-functional coordination with other Sanofi control functions (for example, Legal, Audit, Internal Control, etc)
6. Support and monitor the implementation of CHC specific policies, ensure processes are implemented to address risk
7. Execute comprehensive and holistic risk management approach towards business development deals (including, but not limited to, outsourced promotion partners, gross-to-net collaboration, licensing deals, localization partners, etc. – hereinafter BD partners) and Third parties risk management meaning
8. Understanding the business need and goals of the deals, identify the Ethics and business integrity risks related to the business goals achievement. Work collaboratively within the E&BI function and Sanofi involved project team
9. Assist Sanofi project team in developing the design of the deal, including advise on the Third-party selection criteria and advising on the deal KPI design to ensure that all relevant E&BI/compliance risks are mitigated to the accepted risk level while the legitimate business goals are met
10. Participate in the Third-party selection and periodic reviews helping the team to assess compliance-related areas (includes Due Diligence review)
11. Develop risk mitigation plan for the deals in coordination with Head of E&BI and BD project team
12. Develop and conduct tailored training and communication for Sanofi employees and for Third party Senior management and compliance personnel, including leading without authority with positive influence on third party compliance system enhancement
13. Ensure BD partners and other risky third parties’ personnel awareness on Sanofi rules and Sanofi compliance speak up channels
14. Establish working relationships with BD partners as well as other Third-party management and compliance responsible employees
15. Maintain effective communication and information exchange in Sanofi with all departments for relevant topics, e.g., emerging risks of business development deals or similar transactions with third parties
16. Audit (by him/herself or by supervision of a vendor auditing service provider on Sanofi’s behalf) and monitor the Third-party compliance program in respect to Sanofi standards
17. Enable timely alignment of the Third-party risk management plan in accordance with Sanofi global and regional benchmarks, as well as industry best practices, and ensure consistent approach
18. Ensure proper coordination and adequate reporting of any identified or suspected violation of Sanofi rules and procedures

South Africa

1. Provide support across the different global business units (General Medicine, Specialty Care, Sanofi Pasteur and CHC) in ensuring that all employees are trained on the Sanofi’s Code of Ethics, corporate requirements, and relevant SOPs. Assist in the development, organization and implementation of local training programs and content as well as measuring the effectiveness of these programs
2. Support Anti bribery and other relevant training for the outsourced promotion partner/s in CHC, Diabetes and Established products
3. Assist with Tri-mester monitoring across the different global business units, including HCP and Patient interactions, PSP, donations, and other high- risk areas. Develop and implement corrective action plan where required. Monitor to ensure implementation done

Requirements

Competencies

1. Act for change
2. Cooperate Transversally
3. Develop People Self/Other
4. Strategic thinking – Identifies new information in order to develop clear understanding on industry trends, emerging technology, market opportunities, stakeholder focus. Thinks strategically by proposing solutions tailor-made to the organization environment, challenges, and objectives
5. Negotiation skills
6. Resilience
7. Able to work in cross-cultural environment and respect cultural differences
8. Able to build Value-added relationship in cross-functional and cross-cultural environment
9. Presentation skills, active listening and effective communication skills, effective relations building abilities
10. Change Management Skills
11. Take responsibility and leads in the correct direction. Has a positive impact on others, inspires and motivates the team. Self-awareness and demonstration of situational leadership skills
12. Company Value’s Advocate
13. Planning, organizing, project management skills
14. Analytical thinking and ability to draw conclusions
15. The ability to advise management on complex issues

MINIMUM SKILLS REQUIRED

1. Higher Education (Finance, Auditing, legal, pharmacist, medical) Work experience
2. Minimum 5-year experience in pharmaceutical industry preferably within compliance or compliance-related area with an international company Skills and knowledges
3. In depth knowledge of the global and domestic pharmaceutical industry
4. Knowledge of global and local anti-corruption requirements and best practices, knowledge of pharmaceutical industry self-regulation, Data Privacy regulations etc
5. Expertise in compliance controls: Contributes to the processes and procedures that regulate, guide, and protect the organization
6. General understanding of accounting and finance data, being able to draw conclusions out of it
7. Commitment up to 30% of time spent in business trips
8. Experienced computer user, including data analytics tools, presentation tools

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