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A Range of Possibilities

Head of Ethics & Business Integrity M/F

date posted 10/22/2021
contract type Full time
job id R2583709
location Antony, France

Le contenu du poste est libellé en anglais car il nécessite de nombreuses interactions avec nos filiales à l’international, l'anglais étant la langue de travail.

Context

Sanofi plans to create a major leading European company dedicated to the production and marketing to third parties of active pharmaceutical ingredients (API), which are the essential molecules responsible for the beneficial effects used in the composition of any drug. The project consists of creating a standalone company which would combine Sanofi’s API commercial and development activities with six of its European API production sites (based in Italy, Germany, UK, France and Hungary) within a new company. The headquarter would be in France and a planned IPO on Euronext Paris would be evaluated with a decision expected by 2022, subject to market conditions.

This recruitment is in a project mode and is subject to social and legal process applicable to this new organization. - The position is based in the southern suburb of Paris (RER B).

Global Objectives

Under the direct reporting of the General Counsel, the Head of EBI.

Contributes to the definition and implementation of the Legal, Ethics & Business Integrity (EBI) strategy by

  • Designing and deploying the EuroAPI organization and the EBI program (see below)

  • Ensuring that EBI objectives, priorities and principles are clearly communicated and understood throughout the EuroAPI organization (from mindset, develop skills and raise awareness)

  • Monitoring the respect and the effectiveness of the EBI policies

  • AS a Business Partner, supporting EuroAPI operations in their daily activities in answering ad-hoc questions and/or giving tailored advice within the framework of specific projects / initiatives

Is responsible for the reporting of Transparency data to Health Authorities, in compliance with the local legal requirements applicable in France and in the countries of the affiliates (e.g.: “Loi Bertrand” in France, Sunshine Act in the USA …)

Ensures that EuroAPI is compliant with the General Data Protection Regulation (GRPR) standards standards in France and with local data protection laws in the countries of the affiliates

Main missions & Responsibilities

ORGANIZATION

  • Define the best organization to successfully implement the mission of EBI

  • Lead/manage the EBI interfaces in foreign countries and ensure a relevant and consistent implementation of the EBI program within the whole perimeter

  • Develop a network of “Compliance champions” within the wider EuroAPI organization

IMPLEMENTATION OF A COMPLIANCE PROGRAM

  • Identify the risks areas and domains of potential vulnerabilities, inefficient or ineffective processes in connection with other departments such as Finance, Internal Control, Audit, RSE, HR, Communication departments, in order to optimize the processes in compliance with EUROAPI’s values and general E&BI principles

  • Develop a relevant Code of Conduct and related policies 

  • Ensure the training all the employees to such policies in local languages

  • Ensure the anti-bribery anti-corruption assessment of third parties (customers, suppliers, agents, subcontractors…) through Due Diligence performance in liaison with other functions (Procurement,

  • Commercial, HR…)

  • Develop strategic tools allowing an effective implementation of the Compliance Program (conflict of interest identification, third parties assessment, activity monitoring...)

  • Perform internal monitoring to ensure that the implementation of the global & local policies/ standards/best practices are done timely and appropriately in compliance with local regulations and Sanofi EBI standards

  • Set-up an internal alert system (process and tools) Run investigations on the posted alerts 

ORGANIZATION

  • Define the best organization to successfully implement the mission of EBI

  • Lead/manage the EBI interfaces in foreign countries and ensure a relevant and consistent implementation of the EBI program within the whole perimeter

  • Develop a network of “Compliance champions” within the wider EuroAPI organization

IMPLEMENTATION OF A COMPLIANCE PROGRAM

  • Identify the risks areas and domains of potential vulnerabilities, inefficient or ineffective processes in connection with other departments such as Finance, Internal Control, Audit, RSE, HR, Communication departments, in order to optimize the processes in compliance with EUROAPI’s values and general E&BI principles

  • Develop a relevant Code of Conduct and related policies 

  • Ensure the training all the employees to such policies in local languages

  • Ensure the anti-bribery anti-corruption assessment of third parties (customers, suppliers, agents, subcontractors…) through Due Diligence performance in liaison with other functions (Procurement,

  • Commercial, HR…)

  • Develop strategic tools allowing an effective implementation of the Compliance Program (conflict of interest identification, third parties assessment, activity monitoring...)

  • Perform internal monitoring to ensure that the implementation of the global & local policies/ standards/best practices are done timely and appropriately in compliance with local regulations and Sanofi EBI standards

  • Set-up an internal alert system (process and tools) Run investigations on the posted alerts 

TRANSPARENCY REPORTING

  • Ensure complete and accurate Transparency disclosure on local Healthcare Authorities websites for all relevant EuroAPI Legal entities (network and processes)

DATA PRIVACY

  • Be the point of contact with supervisory authorities and internal teams (coordination of the internal network), 

  • Identify and evaluate company’s data processing activities

  • Establish policies, systems and procedures to enforce compliance

  • Deliver GDPR trainings to increase awareness of data protection measures

  • Provide advice and instructions on Data Protection Impact assessments (DPIAs) Perform audits

BUSINESS PARTNERING

  • Work in close collaboration with Legal, Finance, Audit, RSE, and HR departments to ensure effective implementation of the E&BI program under the responsibility of these functions

  • Support operational and corporate departments in daily activities, by providing tailored advice

BUDGET & COST MANAGEMENT

  • Define, manage and optimize the annual E&BI Budget

Education, knowledge

  • Master’s degree level in a business school, law or other

  • Ideally, 5 years of experience in a similar position (compliance, audit, internal control) of which a past experience in a pharmaceutical or a chemical company

  • Knowledge in Compliance, Data Privacy, Transparency

  • Significant experience in leadership and project management

  • Exposure to diverse and complex environments

  • Objective-driven and self-motivated

  • Experienced in using IT technology and tools supporting processes

Skills

  • Exercising initiative, adaptability, autonomy, flexibility, agility and open to new ways of working, team player

  • Ability to network and exercise influence

  • Demonstrate good empathy and communication skills, ability to interact with all levels of the organization, Analytical and organizational skills

  • Intercultural savvy

  • Master verbal and written communication in English (ideally in French)

  • Keen to help colleagues in other functions with activities in areas outside of his/her areas of responsibility as needed to contribute to a collegial and collaborative atmosphere

  • Sense of discretion and confidentiality

  • Can do”-attitude

At Sanofi diversity and inclusion is foundational to how we operate and embedded in our Core Values. We recognize to truly tap into the richness diversity brings we must lead with inclusion and have a workplace where those differences can thrive and be leveraged to empower the lives of our colleagues, patients and customers. We respect and celebrate the diversity of our people, their backgrounds and experiences and provide equal opportunity for all.

As part of its diversity commitment, Sanofi is welcoming and integrating people with disabilities.

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