WHEN IT COMES TO ETHICS,
THERE ARE NO GRAY AREAS

"I don't know that I ever faced a difficult problem that wasn't easily resolved in the end by asking, 'What is the right thing to do?'"

– P. Roy Vagelos, MD

Chairman of the Board, Regeneron

We have a highly ethical and engaged culture, which we work hard to preserve and nurture as we grow.

We encourage our people to thrive personally and professionally, work together to create positive change and promote a culture of diversity and inclusion.

In 2015, we were proud to be named one of the two top employers in the global biopharmaceutical industry by Science Top Employers survey for the fifth consecutive year, the third most innovative company in the world by Forbes and one of Fortune's 100 best companies to work for.

We take responsibility for ensuring that our colleagues, vendors and business partners are acting in accordance with all applicable laws, rules and regulations. Our comprehensive Compliance Program aligns with the key elements defined by the Office of Inspector General of the U.S. Department of Health and Human Services, and our Code of Business Conduct and Ethics provides the ethical framework for the manner in which we make decisions and operate our business.

95%
of employees say, "I'm proud to tell others I work here."

Great Place to Work® Survey

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Written policies and procedures

Regeneron maintains written policies governing a wide variety of legal, regulatory and policy matters. All such policies are made available to employees on the corporate intranet and are updated frequently.

Regeneron Code of Business Conduct and Ethics

Healthcare Law Compliance Guide


Designated Compliance Officer and Compliance Committee

Beth F. Levine serves as the Company's Chief Compliance Officer and chairs the Compliance Committee. The Compliance Committee is made up of senior leaders of all the major functions in the company and meets at least quarterly to oversee the Compliance Program.

In addition, the Corporate Governance and Compliance Committee of the Board of Directors has oversight responsibility for all non-financial compliance matters. The Chief Compliance Officer provides a report to the Corporate Governance and Compliance Committee on the status of the corporate compliance program at each Board of Directors meeting.

Effective training and education

Training resources include live training and online compliance education, as well as online access to policies. There are also new-hire and annual online training programs that support compliance education.

Effective lines of communication

Critical to the success of any compliance program is maintaining and fostering an environment where employees and others feel comfortable asking questions, raising concerns or offering ideas. Regeneron has an open door policy that encourages employees to offer up ideas and solutions and allows employees to raise concerns to any supervisor, manager, human resources or the compliance department without fear of retaliation. Regeneron maintains an anonymous and confidential 24-hour helpline at 1-877-RGN-ETHX (1-877-746-3849) that provides individuals, whether employed by Regeneron or not, the means to raise concerns over any Regeneron activity that may be inconsistent with any law, regulation, company policy or our Code of Business Conduct and Ethics.

In addition to the confidential helpline, individuals may also make an anonymous report to our compliance website www.ethicspoint.com. After entering the website, select File a Report to submit a question or concern.

These tools help promote an environment of compliance, integrity and trust amongst employees and our stakeholders.

Internal monitoring and auditing

Internal monitoring and auditing are integral parts of the Regeneron comprehensive Compliance Program. Effective monitoring and auditing can detect and prevent compliance concerns. Regeneron conducts a variety of monitoring activities in an effort to detect and respond to potential non-compliance.

Enforcement of standards through well-publicized disciplinary guidelines

Regeneron's Code of Business Conduct and Ethics includes a clear description of disciplinary standards, including the potential for termination as a result of non-compliance. Regeneron publishes its policies on progressive discipline and other disciplinary matters on its corporate intranet site.

Prompt response to detected problems through corrective actions

Any reports of suspected non-compliance that are raised to the attention of the Compliance department are promptly investigated. Any corrective action will take place in a timely fashion and where necessary, offenses shall be reported to relevant governmental authorities.

A written copy of the Comprehensive Compliance Program may be obtained by calling 877-REGN-7777.

Regeneron is committed to conducting its business in accordance with the highest ethical and moral standards in all of our operations, including the supply chain. We maintain a comprehensive Compliance Program that not only applies to our internal operations but also directly applies to relationships with the supply chain. We take responsibility for ensuring that our vendors, contract manufacturers and business partners all act with the same standards of integrity as Regeneron, and we utilize many of the tools encompassed in our Compliance Program to ensure we meet that responsibility.

Our procurement function regularly evaluates suppliers against certain criteria including financial performance and compliance with applicable statutory and regulatory environments. Given the nature of our business, this risk-based supplier assessment is concentrated on the provision of goods and services that meet or exceed current Good Manufacturing Practice and comply with regulatory requirements of the U.S. Food and Drug Administration and other similar international regulatory authorities. Of course, although we concentrate our due diligence of suppliers against the quality backdrop, any potential issues that might be uncovered regarding violations of any laws, including human rights and labor laws, would be thoroughly investigated and resolved prior to engaging that supplier.

Regeneron strives to include representations in all of its procurement agreements and purchase order terms that verify suppliers adhere to all local and international laws, which would include laws regarding human rights and labor practices. Our direct suppliers also represent in their quality agreements that they will manufacture product in accordance with Good Manufacturing Practice and in compliance with all applicable laws, which would include prohibitions on forced labor and human trafficking.

Regeneron products are manufactured to the highest standards of quality, and we ensure that our supply chain maintains the same level of quality. Suppliers are routinely subject to quality audits, including written audits and on-site inspections. These audits, in concert with personal engagement of management and in-person meetings during routine business operations, would allow us to identify any violations of law or conflicts with our Compliance Program. We maintain effective lines of communication in our Compliance Program to ensure prompt reporting of any violations of our policies. Any supplier found to use forced labor or human trafficking would be terminated from the Regeneron supply chain.

Regeneron operates in an environment that embraces continuous improvement. We are committed to continually reviewing and revising our supplier arrangements to help ensure that our suppliers' products fully comply with all laws, including human rights laws. We are committed to continuing to provide effective training and education to our employees on all compliance matters, including training for our supply chain professionals regarding human trafficking and slavery.

Our partnership and collaboration with members of the scientific community are integral to our goal of transforming lives through science. We fully support efforts to increase transparency around interactions with healthcare professionals and healthcare organizations. We comply with all applicable requirements to disclose payments made to healthcare professionals, including the Physician Payment Program (a.k.a. "The Sunshine Act") in the United States.

U.S.

The Sunshine Act, passed in 2010, is a healthcare law designed to increase transparency around financial relationships between healthcare providers and pharmaceutical manufacturers. The Act requires manufacturers of drugs, medical devices and biologicals that participate in U.S. federal healthcare programs to report certain payments and items of value given to physicians and teaching hospitals.

The Centers for Medicare & Medicaid Services (CMS) has been charged with implementing the Sunshine Act, and has called it the Open Payments Program.

CMS Physician Fact Sheet
CMS website
AMA website

California

Annual Declaration of Compliance

Regeneron Pharmaceuticals, Inc. is a biopharmaceutical company that is dedicated to discovering, developing, and commercializing pharmaceutical products for the treatment of serious medical conditions. Regeneron conducts its activities in accordance with all applicable laws and regulations and is committed to establishing a corporate culture of compliance, honesty, integrity, and fair dealing. Regeneron has established and maintains a comprehensive Compliance Program that is consistent with the requirements of California Health and Safety Code sections 119400 and 119402. This program has been developed in accordance with the laws applicable to the biopharmaceutical industry, the Compliance Program Guidance for Pharmaceutical Manufacturers published by the Office of the Inspector General of the U.S. Department of Health and Human Services in April 2003, and the PhRMA Code on Interactions with Health Care Professionals (PhRMA Code) as revised in July 2008. Regeneron certifies annually to PhRMA that it has policies, procedures or guidelines in place to foster compliance with the PhRMA Code. As required by California Health and Safety Code section 119402, with specific reference to the provision of gifts, promotional material, or items or activities that a pharmaceutical company may provide to an individual medical or healthcare professional, Regeneron has established an aggregate, annual dollar limit of $2,500 on promotional items and/or meals directed to an individual medical or healthcare professional who resides or practices in California. The dollar limit is a maximum only. Regeneron declares that, to the best of our knowledge, and based on our good faith understanding of the statutory requirements of the California Health & Safety Code sections 119400 and 119402, we are in compliance with our comprehensive Compliance Program. We also declare that the structure of our comprehensive Compliance Program incorporates the principles articulated in the Compliance Program Guidance for Pharmaceutical Manufacturers published by the Office of the Inspector General of the United States Department of Health and Human Services in April 2003, and the Code on Interactions with Healthcare Professionals as revised in July 2008 adopted by the Pharmaceutical Research and Manufacturers of America.

Dated: July 1, 2016

A written declaration of compliance may be obtained by calling 877-REGN-7777.

France

In accordance with the Loi Bertrand Act in France, Regeneron Pharmaceuticals Inc. has included disclosures for 2012 and the 1st Semester of 2013 below. All subsequent disclosures have been made directly to the centralized reporting website.

France 2012
France 2013 Semester 1

Les informations ci-dessus sont publiées conformément aux exigences de l'Article 3 du décret 2013-414 du 21 mai 2013 relatif à la transparence des avantages accordés par les entreprises produisant ou commercialisant des produits à finalité sanitaire et cosmétique destinés à l'homme. En conséquence, et conformément à l'Article R1453-7 du Code de la santé publique, le droit d'opposition des individus à la collecte et au traitement de leurs données n'est pas d'application. Toute demande d'accès et de rectification des données ci-dessus et toute demande d'information doit être adressée à l'adresse e-mail suivante: aggspend@regeneron.com.

Ireland

In accordance with the Irish Pharmaceutical Healthcare Association Code on Disclosure of Transfers of Value from companies to Healthcare Professionals and Healthcare Organisations, Regeneron Pharmaceuticals Inc. has included disclosures as applicable below:

Ireland 2015

  • Written policies and procedures

    Regeneron maintains written policies governing a wide variety of legal, regulatory and policy matters. All such policies are made available to employees on the corporate intranet and are updated frequently.

    Regeneron Code of Business Conduct and Ethics

    Healthcare Law Compliance Guide


    Designated Compliance Officer and Compliance Committee

    Beth F. Levine serves as the Company's Chief Compliance Officer and chairs the Compliance Committee. The Compliance Committee is made up of senior leaders of all the major functions in the company and meets at least quarterly to oversee the Compliance Program.

    In addition, the Corporate Governance and Compliance Committee of the Board of Directors has oversight responsibility for all non-financial compliance matters. The Chief Compliance Officer provides a report to the Corporate Governance and Compliance Committee on the status of the corporate compliance program at each Board of Directors meeting.

    Effective training and education

    Training resources include live training and online compliance education, as well as online access to policies. There are also new-hire and annual online training programs that support compliance education.

    Effective lines of communication

    Critical to the success of any compliance program is maintaining and fostering an environment where employees and others feel comfortable asking questions, raising concerns or offering ideas. Regeneron has an open door policy that encourages employees to offer up ideas and solutions and allows employees to raise concerns to any supervisor, manager, human resources or the compliance department without fear of retaliation. Regeneron maintains an anonymous and confidential 24-hour helpline at 1-877-RGN-ETHX (1-877-746-3849) that provides individuals, whether employed by Regeneron or not, the means to raise concerns over any Regeneron activity that may be inconsistent with any law, regulation, company policy or our Code of Business Conduct and Ethics.

    In addition to the confidential helpline, individuals may also make an anonymous report to our compliance website www.ethicspoint.com. After entering the website, select File a Report to submit a question or concern.

    These tools help promote an environment of compliance, integrity and trust amongst employees and our stakeholders.

    Internal monitoring and auditing

    Internal monitoring and auditing are integral parts of the Regeneron comprehensive Compliance Program. Effective monitoring and auditing can detect and prevent compliance concerns. Regeneron conducts a variety of monitoring activities in an effort to detect and respond to potential non-compliance.

    Enforcement of standards through well-publicized disciplinary guidelines

    Regeneron's Code of Business Conduct and Ethics includes a clear description of disciplinary standards, including the potential for termination as a result of non-compliance. Regeneron publishes its policies on progressive discipline and other disciplinary matters on its corporate intranet site.

    Prompt response to detected problems through corrective actions

    Any reports of suspected non-compliance that are raised to the attention of the Compliance department are promptly investigated. Any corrective action will take place in a timely fashion and where necessary, offenses shall be reported to relevant governmental authorities.

    A written copy of the Comprehensive Compliance Program may be obtained by calling 877-REGN-7777.

  • Regeneron is committed to conducting its business in accordance with the highest ethical and moral standards in all of our operations, including the supply chain. We maintain a comprehensive Compliance Program that not only applies to our internal operations but also directly applies to relationships with the supply chain. We take responsibility for ensuring that our vendors, contract manufacturers and business partners all act with the same standards of integrity as Regeneron, and we utilize many of the tools encompassed in our Compliance Program to ensure we meet that responsibility.

    Our procurement function regularly evaluates suppliers against certain criteria including financial performance and compliance with applicable statutory and regulatory environments. Given the nature of our business, this risk-based supplier assessment is concentrated on the provision of goods and services that meet or exceed current Good Manufacturing Practice and comply with regulatory requirements of the U.S. Food and Drug Administration and other similar international regulatory authorities. Of course, although we concentrate our due diligence of suppliers against the quality backdrop, any potential issues that might be uncovered regarding violations of any laws, including human rights and labor laws, would be thoroughly investigated and resolved prior to engaging that supplier.

    Regeneron strives to include representations in all of its procurement agreements and purchase order terms that verify suppliers adhere to all local and international laws, which would include laws regarding human rights and labor practices. Our direct suppliers also represent in their quality agreements that they will manufacture product in accordance with Good Manufacturing Practice and in compliance with all applicable laws, which would include prohibitions on forced labor and human trafficking.

    Regeneron products are manufactured to the highest standards of quality, and we ensure that our supply chain maintains the same level of quality. Suppliers are routinely subject to quality audits, including written audits and on-site inspections. These audits, in concert with personal engagement of management and in-person meetings during routine business operations, would allow us to identify any violations of law or conflicts with our Compliance Program. We maintain effective lines of communication in our Compliance Program to ensure prompt reporting of any violations of our policies. Any supplier found to use forced labor or human trafficking would be terminated from the Regeneron supply chain.

    Regeneron operates in an environment that embraces continuous improvement. We are committed to continually reviewing and revising our supplier arrangements to help ensure that our suppliers' products fully comply with all laws, including human rights laws. We are committed to continuing to provide effective training and education to our employees on all compliance matters, including training for our supply chain professionals regarding human trafficking and slavery.

  • Our partnership and collaboration with members of the scientific community are integral to our goal of transforming lives through science. We fully support efforts to increase transparency around interactions with healthcare professionals and healthcare organizations. We comply with all applicable requirements to disclose payments made to healthcare professionals, including the Physician Payment Program (a.k.a. "The Sunshine Act") in the United States.

    U.S.

    The Sunshine Act, passed in 2010, is a healthcare law designed to increase transparency around financial relationships between healthcare providers and pharmaceutical manufacturers. The Act requires manufacturers of drugs, medical devices and biologicals that participate in U.S. federal healthcare programs to report certain payments and items of value given to physicians and teaching hospitals.

    The Centers for Medicare & Medicaid Services (CMS) has been charged with implementing the Sunshine Act, and has called it the Open Payments Program.

    CMS Physician Fact Sheet
    CMS website
    AMA website

    California

    Annual Declaration of Compliance

    Regeneron Pharmaceuticals, Inc. is a biopharmaceutical company that is dedicated to discovering, developing, and commercializing pharmaceutical products for the treatment of serious medical conditions. Regeneron conducts its activities in accordance with all applicable laws and regulations and is committed to establishing a corporate culture of compliance, honesty, integrity, and fair dealing. Regeneron has established and maintains a comprehensive Compliance Program that is consistent with the requirements of California Health and Safety Code sections 119400 and 119402. This program has been developed in accordance with the laws applicable to the biopharmaceutical industry, the Compliance Program Guidance for Pharmaceutical Manufacturers published by the Office of the Inspector General of the U.S. Department of Health and Human Services in April 2003, and the PhRMA Code on Interactions with Health Care Professionals (PhRMA Code) as revised in July 2008. Regeneron certifies annually to PhRMA that it has policies, procedures or guidelines in place to foster compliance with the PhRMA Code. As required by California Health and Safety Code section 119402, with specific reference to the provision of gifts, promotional material, or items or activities that a pharmaceutical company may provide to an individual medical or healthcare professional, Regeneron has established an aggregate, annual dollar limit of $2,500 on promotional items and/or meals directed to an individual medical or healthcare professional who resides or practices in California. The dollar limit is a maximum only. Regeneron declares that, to the best of our knowledge, and based on our good faith understanding of the statutory requirements of the California Health & Safety Code sections 119400 and 119402, we are in compliance with our comprehensive Compliance Program. We also declare that the structure of our comprehensive Compliance Program incorporates the principles articulated in the Compliance Program Guidance for Pharmaceutical Manufacturers published by the Office of the Inspector General of the United States Department of Health and Human Services in April 2003, and the Code on Interactions with Healthcare Professionals as revised in July 2008 adopted by the Pharmaceutical Research and Manufacturers of America.

    Dated: July 1, 2016

    A written declaration of compliance may be obtained by calling 877-REGN-7777.

    France

    In accordance with the Loi Bertrand Act in France, Regeneron Pharmaceuticals Inc. has included disclosures for 2012 and the 1st Semester of 2013 below. All subsequent disclosures have been made directly to the centralized reporting website.

    France 2012
    France 2013 Semester 1

    Les informations ci-dessus sont publiées conformément aux exigences de l'Article 3 du décret 2013-414 du 21 mai 2013 relatif à la transparence des avantages accordés par les entreprises produisant ou commercialisant des produits à finalité sanitaire et cosmétique destinés à l'homme. En conséquence, et conformément à l'Article R1453-7 du Code de la santé publique, le droit d'opposition des individus à la collecte et au traitement de leurs données n'est pas d'application. Toute demande d'accès et de rectification des données ci-dessus et toute demande d'information doit être adressée à l'adresse e-mail suivante: aggspend@regeneron.com.

    Ireland

    In accordance with the Irish Pharmaceutical Healthcare Association Code on Disclosure of Transfers of Value from companies to Healthcare Professionals and Healthcare Organisations, Regeneron Pharmaceuticals Inc. has included disclosures as applicable below:

    Ireland 2015