SEC Comment Letter 0000000000-24-003917 to Sanofi (SNY, SNYNF) (CIK 0001121404) (SNY)
Sanofi (SNY, SNYNF) (CIK 0001121404)
Date: April 11, 2024 · CIK: 0001121404 · Accession: 0000000000-24-003917
AI Filing Summary & Sentiment
File numbers found in text: 001-31368
Letter
United States securities and exchange commission logo April 11, 2024 Francois Roger Chief Financial Officer Sanofi 46, avenue de la Grande Armée 75017 Paris, France Re:Sanofi Form 20-F for the Fiscal Year Ended December 31, 2023 Filed February 23, 2024 File No. 001-31368 Dear Francois Roger: We have limited our review of your filing to the financial statements and related disclosures and have the following comment. Please respond to this letter within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Form 20-F for the Fiscal Year Ended December 31, 2023 Item 5. Operating and financial review and prospects A.1.5 Segment information and Business net income 3/ Business net income (non-IFRS measure), page 58 1.We note that your presentation of Business net income on a non-IFRS basis includes an adjustment - income from out-licensing - which excludes upfront payments and regulatory milestone payments. We believe that non-IFRS financial measures that exclude upfront and milestone payments would not comply with the guidance provided in Rule 100(b) of Reg. G. Please confirm to us that you will no longer include these adjustments in any non- IFRS financial measure presented in accordance with Item 10(e) of Regulation S-K or Rule 100(b) of Regulation G.
In closing, we remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
FirstName LastNameFrancois Roger Comapany NameSanofi April 11, 2024 Page 2 FirstName LastName Francois Roger Sanofi April 11, 2024 Page 2 absence of action by the staff. Please contact Ibolya Ignat at 202-551-3636 or Angela Connell at 202-551-3426 with any questions. Sincerely, Division of Corporation Finance Office of Life Sciences
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United States securities and exchange commission logo
April 11, 2024
Francois Roger
Chief Financial Officer
Sanofi
46, avenue de la Grande Armée
75017 Paris, France
Re:Sanofi
Form 20-F for the Fiscal Year Ended December 31, 2023
Filed February 23, 2024
File No. 001-31368
Dear Francois Roger:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment.
Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments.
Form 20-F for the Fiscal Year Ended December 31, 2023
Item 5. Operating and financial review and prospects
A.1.5 Segment information and Business net income
3/ Business net income (non-IFRS measure), page 58
1.We note that your presentation of Business net income on a non-IFRS basis includes an
adjustment - income from out-licensing - which excludes upfront payments and regulatory
milestone payments. We believe that non-IFRS financial measures that exclude upfront
and milestone payments would not comply with the guidance provided in Rule 100(b) of
Reg. G. Please confirm to us that you will no longer include these adjustments in any non-
IFRS financial measure presented in accordance with Item 10(e) of Regulation S-K or
Rule 100(b) of Regulation G.
In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
FirstName LastNameFrancois Roger
Comapany NameSanofi
April 11, 2024 Page 2
FirstName LastName
Francois Roger
Sanofi
April 11, 2024
Page 2
absence of action by the staff.
Please contact Ibolya Ignat at 202-551-3636 or Angela Connell at 202-551-3426 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences