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Sanofi-aventis Internet rules
Version 2.1 - Simplified process


Last updated: July, 2010




                                   1

Internet Rules 2.1 – July 2010
Foreword: Why a simplified version of the Internet rules?



             5 fields are now reviewed instead of 8
             In a justified emergency, the web site can be validated before it goes on-line in 72 hours
            (Fast-Track process)
             An ad hoc process can be set up enabling the site to be validated after it goes on-line (on
            request by the subsidiary and after approval by the Internet Validation Committee)
             The e-PSF becomes optional. On the other hand, centralised management of the domain
            names remains mandatory.




Web use in the Group is growing and it has become an essential medium.

More than 580 web sites were listed in the Group at end 2009, which is a 40% increase in 4 years. The
Internet Validation Committee has validated about a hundred projects a year since 2005 (own sites, in
partnership, web 2.0), which demonstrates the growing importance of the web for our business.
More than ever, the Internet is supplementing other media traditionally used in our marketing mix. It is a
channel with very great potential for promoting our products and activities, as well as informing our
patients about our main therapeutic fields.


But being on the Internet also has risks.

Being on the Internet is not risk-free for a group like ours. So precautions must be taken to limit potential
risks so that serious damage is not suffered (such as legal risks, non-compliance with regulations, hacking
of our sites, unauthorised access to or retrieval of confidential data, alteration or inconsistency of our
image or messages). Note that 74% of sites reviewed in 2008 and 46% in 2009 did not comply with the
Group’s Internet standards (out of a total of 294 projects reviewed in 2 years).


This is why there have to be Internet rules – which keep pace with evolving
needs.

It is inconceivable for sanofi-aventis to be on the Internet unless some principles are abided by. As
regards changes in our internal organisation and the limitations of our environment, we believe it is
necessary to free up the process of validating web sites, so we have simplified it by altering the points
mentioned in the introduction above.




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Internet Rules 2.1 – July 2010
The Internet rules and forms mentioned in this document can be
                                 downloaded at Is@ Group:


                        http://internet.sanofi-aventis.com




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Internet Rules 2.1 – July 2010
CONTENTS

1. Scope ............................................................................. 5

2. The validation procedure ............................................... 6
  2.1 Phase 1 : The site project...................................................................................................6
  2.2 Phase 2 : Building the site .................................................................................................8
  2.3 Phase 3 : Launching the site .............................................................................................9


3. Validation components ................................................ 11
  3.1 Domain names ..................................................................................................................11

  3.2 Legal affairs.......................................................................................................................11
     3.2.1 Formalise contractual relations and comply with the legislation in every country....................... 11
     3.2.2 Terms and conditions .................................................................................................................. 12
     3.2.3 Site exit pop-up ........................................................................................................................... 12
     3.2.4 Copyright and intellectual property rights.................................................................................... 13

  3.3 Regulatory Affairs.............................................................................................................13
     3.3.1 General principles ....................................................................................................................... 13
     3.3.2 Transparency .............................................................................................................................. 14
     3.3.3 Access to the site ........................................................................................................................ 14
     3.3.4 Specific questions related to the type of information .................................................................. 14

  3.4 Communication.................................................................................................................16
     3.4.1 Graphic charter............................................................................................................................ 16
     3.4.2 Content management.................................................................................................................. 17

  3.5 IS security..........................................................................................................................17
     3.5.1 Hosting facilities .......................................................................................................................... 17
     3.5.2 Applications ................................................................................................................................. 18
     3.5.3 Sending information .................................................................................................................... 18

  3.6 Accessibility......................................................................................................................19


4. Appendices .................................................................. 20
  Glossary ................................................................................................................................................... 20
  The e-PSF................................................................................................................................................ 21
  The e-PAF................................................................................................................................................ 23
  DN registration request form.................................................................................................................... 27
  DN pointing request form ......................................................................................................................... 28
  Check-list for contracts ............................................................................................................................ 29
  The consent request email for links ......................................................................................................... 32
  Site exit pop-up ........................................................................................................................................ 33
  Example of terms and conditions............................................................................................................. 35
  The Contact Us page ............................................................................................................................... 40
  The graphic charter applicable to all sanofi-aventis product and/or theme sites..................................... 42




                                                                                                                                                               4

Internet Rules 2.1 – July 2010
1. Scope

Version 2.1 of the Internet rules covers Internet projects intended for external targets (outside
                                                sanofi-aventis).


An Internet project can be a web site, of course, but can also be an e-crf system, an e-purchasing system
involving suppliers, an e-recruitment system, etc.
External targets can be customers, patients, doctors, health authorities, payers, shareholders, suppliers,
partners (patients’ associations, universities, hospitals, etc.), job applicants, etc.


The Group’s Internet rules 2.1 apply to:
       Internet projects that sanofi-aventis owns and is solely responsible for
       Internet projects that sanofi-aventis sponsors (partnership with a site owned by a third
        party)


So any site, although it uses Internet technologies and is accessible on the Internet, that only concerns
sanofi-aventis employees is not covered by these rules. For example, web sites for sales forces are not
within the scope of the Internet rules 2.1.




                       Web 2.0 initiatives (using social networking for example) are covered
                       in a document supplementing the Internet rules: the Web 2.0 Guide.
                       Please refer to it (downloadable on the intranet).


                       Projects that sanofi-aventis sponsors are covered in an ancillary
                       document to the Internet rules: Internet partnerships. Please refer to it
                       if your project comes under this heading.




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Internet Rules 2.1 – July 2010
2. The validation procedure




       IDEA                      PROJECT DEVELOPMENT                        LAUNCHING / RUNNING


               STAGE 1                                            STAGE 2

                Registering the Domain name                       Validating the project
                       Domain Name Registration Form                      e-Project Assessment Form
                                                                          or Web 2.0 Checklist (depending
                                                                          on the project)
                OPTIONAL: project monitoring
                                                                  Activating the domain name
                       e- Project Study Form
                                                                           Domain Name Pointing Form




                All forms mentioned in this section are given in the appendix and are
                available on the intranet at http://internet.sanofi-aventis.com




2.1 PHASE 1: THE SITE PROJECT

Registering the domain name and presenting the Internet project


    a) How do I register my domain name?


When you begin an Internet project, and once you have chosen your project’s domain name(s), send your
request to the e-mail address DN-Domain-names-management@sanofi-aventis.com, using the “DN
Registration Form” (see appendix).


The management of all sanofi-aventis domain names is based on the following principles:
               Centralised administrative registration of domain names
               Centralised technical management of domain names (on sanofi-aventis DNS
                servers)




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Internet Rules 2.1 – July 2010
b) Who do I present my project to, when and how?


AT LOCAL LEVEL


Firstly, your project must have been validated at local level (Internet website or web 2.0 project).
The following steps are absolutely necessary in the strategic validation of your project and must be
respected before the presentation of your project at global level:
    1- Know the global digital strategy
    2- Define your website and project objectives
            a. Why and how a website is the right tool to achieve your objectives?
            b. What are the objectives of the website itself?
    3- Define how your website is innovative in comparison with existing tools
    4- Define your audience targeted
            a. Profile (from general public to Healthcare Specialists)
            b. Characteristics
            c.   Geographical localization
    5- Define your messages and publishing frequency
            a. Contents, services and functionalities
            b. Customer loyalty and added-value services enhancement
             Think as if you were in visitor’s shoes!
    6- Include medical, regulatory, legal and IT local correspondents the soonest, in order to get
        their validation at the very beginning of the project
    7- Define how the website will be promoted (set up a promotion plan)
    8- Define the success and profitability indicators (ROI)
            a. Website frequentation
            b. Visitor’s behaviour on the website
            c.   Impact of the website in terms of product notoriety, image or sales
    9- Manage the lifecycle of your website
            a. Updates frequency (mandatory to maintain your website attractive)
            b. Contents creation
            c.   Allocated resources (for updates, promotion…)


AT GLOBAL LEVEL


In parallel, you must inform the Internet coordination team that you are initiating an Internet project, before
starting the building of the website.
To do so, please be sure to complete correctly the section “project description” in the domain name
registration form.


If you want, you can get the support of the Internet coordination team when undertaking your
project. To get their help, send an e-PSF (e-Project Study Form in the appendix or available on the


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Internet Rules 2.1 – July 2010
intranet) to Internet-Committee@sanofi-aventis.com. You will have the benefit of regular support, and
can ask the team for advice while running your Internet project.
The E-PSF stage is optional.


2.2 PHASE 2: BUILDING THE SITE

Validation of the Internet project with the Internet Validation Committee


    a) When does this phase take place?
This second phase takes place when the Internet project has been developed, and is ready to go on line.
The site should be completed, installed on its permanent hosting platform, and not accessible to web
users (protected by HT Access).


    b) What is the Internet Validation Committee and what does it do?
The Internet Validation Committee validates all Internet projects before or after they go on line, according
to the procedure set in the Internet rules.
It is a multi-disciplinary body, tasked with setting and ensuring application of the Group Internet rules in
sanofi-aventis. Local validations of the project remain primordial, and the IVC does not substitute for the
local validation process (in terms of medical and regulatory contents validation for example).


It consists of global representatives from the following sectors:


Corporate Communication                                 Thierry Le Magny, Géraldine Gorgol
Legal Affairs                                           Isabelle Cadiau, Anne-Sophie Nibert
Medical and Regulatory Affairs                          Cécile Gousset, Françoise Rey, Sylvie Pujol, Peggy
(Promotional Material Excellence team)                  Dolin-Brunel
Information System Security                             Jérôme Lahalle, Olivier Fourmaux
Accessibility                                           Tanguy Lohéac
Marketing                                               Céline Degand
Information System Technologies                         Dominique Lacan
Coordination                                            Caroline Debuire, Frédéric Dimur


It meets fortnightly on a Friday morning. A schedule of meetings is available on the intranet at
http://internet.sanofi-aventis.com


    c) The traditional validation procedure


To have your Internet project validated by the Internet Committee, you should send an e-PAF (e-Project
Assessment Form in the appendix or available on the intranet) to Internet-Committee@sanofi-
aventis.com at the latest by the Tuesday before the Internet Validation Committee meeting.


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Internet Rules 2.1 – July 2010
At the end of the assessment, which takes up to two working days, the Internet Validation Committee
gives an answer to the person in charge of the web site, who may be asked to make changes before the
site goes on line, if it does not comply with the Internet rules 2.1.


Exception: the emergency validation procedure (Fast-Track process)
Sometimes the dates of the Internet Validation Committee meeting may not fit in with the date scheduled
for your web site to go on line.
If and only if the site launch date is linked to a major event (such as a product launch, marketing
authorisation announcement, crisis on a product, international congress, etc.) an exceptional review
between two meetings of the Internet Committee can be arranged.


    d) The Ad Hoc procedure assigned per subsidiary


Depending on the number of sites already validated by the Internet Committee, and especially
depending on the degree of compliance of sites previously presented, some teams/subsidiaries have
acquired certain expertise in the Internet rules.
It is possible to set up a simpler procedure, to speed up reviews by the Internet Committee. Each case will
be looked at individually, and depending on the conclusions of the analysis by the Committee with the
team/subsidiary concerned, a Ad Hoc procedure may be implemented, which may even include the
possibility of accepting sites after they go on line if necessary. In which case, the domain name will be
pointed before validation.
Nonetheless, if there are repeated breaches of the Internet rules reported during the use of the Ad Hoc
stage, the subsidiary will be required to go back to the traditional procedure.


2.3 PHASE 3: LAUNCHING THE SITE

Putting your Internet project on line


    a) How is the web site activated?
Once the site has been validated by the Internet Validation Committee and any changes requested have
been made, the Internet project can then be put on line.
To do so, the domain name should be pointed to your web site’s IP address.
To request pointing, the pointing request form “DN Pointing Form” (see appendix) should be completely
filled in and sent to the address DN-Domain-names-management@sanofi-aventis.com.
The domain name pointing will be confirmed in the days following the request.


    b) What happens once the site is launched?
The project manager is responsible for the site and in particular must ensure compliance with the Internet
rules 2.1 throughout the life of the site. If necessary, he/she must ask the Committee if there is a question
or problem.
In addition, every web site may be checked to ensure it complies with the Internet rules.

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Internet Rules 2.1 – July 2010
Where applicable, a summary of any requests for changes will be sent to the person in charge of the site.
Lastly, if major changes are made to the Internet project (such as a change of positioning of a site, new
design, new service, new web 2.0 tool, etc.), they must be reported to the Internet Validation Committee.


    c) What should I do if a site is on-line but has not been validated?
There are two possibilities:


     The site has never been reviewed by the Internet Committee, and has been on-line for a long
       time
This can be the case for example with sites on the Internet before the Internet rules were published, or
web sites from mergers or acquisitions.
Every site owner concerned must send an e-PAF to the Internet Validation Committee at the following
address Internet-committee@sanofi-aventis.com.
The site will then be assessed by the Committee and an assessment report will be sent to the person
responsible for the site, detailing any changes to be made.


     The site has been reviewed by the Internet Committee, or has been put on-line without
       making the requested changes
The Internet Validation Committee may decide to close a site put on-line without the Committee’s
authorisation, notified by e-mail to the person in charge of the site.
It must be closed as soon as possible after notification is sent:
   1 Either by the project manager, by any means available (e.g. HT Access, redirection)
   2 Or by disabling the domain name pointing if necessary.




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Internet Rules 2.1 – July 2010
3. Validation components

These mandatory components determine whether or not a web site is validated.
The components concern six separate fields: domain names, legal affairs, regulatory affairs,
communication, computer security and accessibility.


                  3.1 Domain names

All domain names should:
          comply with the sanofi-aventis naming policy
          be bought directly by sanofi-aventis and not by a any third party
          be hosted on sanofi-aventis DNS servers


Any pointing enabling a site to be put on-line is done by sanofi-aventis in-house staff, and can be done in
only two cases:
          either before the site is put on-line, provided that an HT Access is set up
          or after approval by the Internet Committee


Important information:
For legal liability reasons, when sanofi-aventis partners or sponsors a site, the domain name must not be
registered by sanofi-aventis.


                     Registration and pointing forms for domain names are available in the
                     appendix.



             All DN requests should be sent to the following e-mail address:
                    DN-Domain-names-management@sanofi-aventis.com




3.2 Legal affairs

       3.2.1 Formalise contractual relations and comply with the legislation
       in every country

You should have the following points validated by your Legal Department:


   Validation and verification of contractual relations (see checklist in the appendix):
                  Web site design agreement
                  Maintenance agreement

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Internet Rules 2.1 – July 2010
Internet access and hosting agreement
                 Site promotion related agreements
                 Partnership agreement


   Checking the legislation applicable in each country:
                 National and international legal provisions: the laws in each country, as well as
          international agreements (such as Community law for the EU), should be taken into account
                 Recommendations, codes of conduct and practices on the Internet: personal data
          should be collected and processed in accordance with the specific laws in each country.
                 Current regulations: check that information given on the site is aimed at the right
          audience (patients/doctors), is not unlawful and does not create offence; does not mention third
          parties’ products or services; information should not defame or denigrate; it should respect
          customs and practices in countries where it is disclosed.


So it is essential, before going on-line and even before the e-PAF is sent to the Internet Validation
Committee, for you to check with your legal department that the web site complies with all the
requirements that apply to it.


        3.2.2 Terms and conditions

     Terms and conditions should be shown on all Group sites.
    The terms and conditions should be tailored to take account of legislation in the country concerned and
    should also cover legal information, limitation of liability, a statement relative to privacy and the
    protection of intellectual property rights (e.g. copyright), the publisher of the site, and the name
    of the Head of publication.
     Legal information on privacy and the processing of personal data should also be provided.
     This information should be easy to consult from all pages on the site.
     An example of terms and conditions is available in the appendix. We strongly recommend that you
       use it and have it checked by your legal department.


         3.2.3 Site exit pop-up

     It is recommended that the limitation of liability clause be displayed on entering and leaving
       the site, especially for hyperlinks to third party web sites. Examples of site exit pop-ups are
       available in the appendix.
     Any link to an external partner’s site should not be installed without the prior agreement of the third
       party and sanofi-aventis.


The terms and conditions and site exit pop-up should be validated by your legal department.




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Internet Rules 2.1 – July 2010
3.2.4 Copyright and intellectual property rights

    Sanofi-aventis should hold the intellectual property rights on content used on sites (including text,
      photos, videos, animations and logos).
    A copyright symbol should be inserted with the name of the company owning the site and the
      date at the bottom of every page of the site.


                  Examples available in the appendix: checklist for agreements/
                  contracts, letter requesting consent for links to third party sites, site
                  exit pop-ups, terms and conditions.


                        All requests to legal affairs should be sent to:
                                 isabelle.cadiau@sanofi-aventis.com




3.3 Regulatory Affairs

      3.3.1. General principles

    The website must imperatively be validated by the structure in charge of the project (affiliate,
      region or global) before being sent to the Internet Validation Committee. The regulatory and
      medical representatives of the structure are responsible for the contents validation.

    These principles are the minimal standards that everyone in the Group should meet worldwide.

    They do not cancel or replace stricter local regulations.

    Information specific to a given country should comply with local rules.

    Promotional information (full page or banner advertising) and medical information given on web
      sites should be validated, in compliance with the process of promotional document validation, well
      before it is put on-line on web sites and then after it is put on-line whenever any promotional
      information is changed.

    Remember that information on the Internet is subject to the same rules and regulations on
      medical information as it is in all other media.




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Internet Rules 2.1 – July 2010
3.3.2 Transparency

    The identity of the Group should be clearly stated on the first page as well as the nature of the
      partnership if there is one (cooperation or simple financial support, educational grant).

    The target audience should be clearly identified (country of residence, general public, health
      professional, shareholder or journalist) and clearly specified on the site (in general at the top of the
      site page).

    The content should be suited to the target audience and the purpose of the site should be clearly
      stated.

    Links should be appropriate and clearly highlighted for the target audience with site exit pop-ups.
      Examples of pop-ups are available in the appendix.
          if the site belongs to sanofi-aventis and complies with the same rules and regulations (same
          country), there is no need to add the pop-up;
          if the external site belongs to sanofi-aventis and complies with different rules and
          regulations (different countries), a pop-up should be added stating that the web site cannot
          comply with regulatory criteria that apply to the audience in question;
          if the external site does not belong to sanofi-aventis, it is necessary to add a pop-up
          warning users that they are leaving the sanofi-aventis web site;
          if a page provides several links, a clearly visible message at the top of the page can replace
          the pop-up. This solution applies if it complies with local regulations.

     The sources of any information given on the site and its date of publication should be stated on the
       site.

     The date of the last update of the various information given should be stated on every page and be
       specific to each item of the content.



      3.3.3 Access to the site

     Site open to the general public: information on prescription products (excluding the US) should
       not be put on-line.

     Information for health professionals: a password is required to access this page, or a clause
       limiting access in the form of a pop-up with confirmation click, in accordance with local regulations.

     Information for patients given a prescription medicine: proof of prescription should be provided
       or access should be granted by the prescribing doctor.



          3.3.4 Specific questions related to the type of information

    Product information: depending on the target audience, the Patient Information sheet / the
      Summary of Product Characteristics or any other official Product Information required by the local
      authorities should be easily accessible by means of a clear, easy-access link.

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Internet Rules 2.1 – July 2010
 General information on health: free. Web sites that provide information on health should always
      advise web users to consult a health professional for any further information. Drugs can be alluded
      to provided that they are presented in an exhaustive and objective way. Generally, only therapeutic
      classes are mentioned; if the law allows, the international non-proprietary name (INN) should be
      preferred to the brand name. If brand names are used, they should be accompanied by the INN, for
      reasons of clarity.

    Public information on clinical trials: the sanofi-aventis Group is committed to transparency
      on clinical trials: information on clinical trials in progress and the results of clinical research can be
      accessed by the public firstly through records of clinical trials, and secondly on databases of clinical
      trial results. Sanofi-aventis has chosen to save its clinical trials to the www.clinicaltrials.gov web site
      and publishes the results of its clinical trials on the www.clinicalstudyresults.org web site. Useful
      link:

      http://www.sanofi-aventis.com/recherche_innovation/dev_clinique/engagements/engagements.asp

    Clinical trial results: this information should be validated by the Communication Department.

    Clinical trials in progress: secure site that can only be accessed by health professionals who are
      directly taking part in the trials. The decision to deploy this type of network should be validated by
      the department managing the trial (International Clinical Development or Global Medical Affairs
      and/or the Global Marketing Clinical Operations).

    Price list: possible at country level if validated. Information should be limited to the product name,
      its INN, presentation and price. Information should be dated.

    Bibliography or database of publications: it should be as complete as possible, up-to-date and
      not restricted to articles favourable to our products. The search and selection criteria should be
      clearly specified.

    Photographs: authorisation to use and pay for copyright should be obtained. Credits (name of the
      photographer/agency) should be stated.

    Interactive sessions (forums, webinars): refer to the web 2.0 document. Sessions should only
      be on a precise date for a predefined audience, and access should be by password.

    Contact page: Direct access to e-mail addresses or direct reference via “mail to” should be
      avoided. There should be a contact form that includes required fields (name, address, profession
      and electronic address) and a general statement advising members of the public against reporting
      undesirable effects or other drug monitoring events to this address. An example is available in the
      appendix.
    The mail box should be checked every day and reports of undesirable events should be sent to the
      drug monitoring department of the subsidiary concerned




              Examples available in the appendix: contact form and site exit pop-up.




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Internet Rules 2.1 – July 2010
For further information, refer to:
                    The FIIM’s Code of marketing practices for pharmaceuticals
                     The sanofi-aventis Principles of good promotion practices
                                                 Intranet
                            The Promotional Material Excellence intranet
                                                  Contact
                 Promotional-Material-Excellence-Team@sanofi-aventis.com




3.4 Communication

Three types of web site are identified:

            Group and Subsidiaries’ Corporate Communication
                        Corporate sites: sanofi-aventis.com, sanofi-aventis.tv and sanofipasteur.com.
                        Subsidiaries’ sites: sanofi-aventis.us, sanofi-aventis.de, etc.
            Internet initiatives
                        Product, pathology, environment and social media sites
            Partnerships with third parties

Information provided by sanofi-aventis and spokespersons on the Internet should comply with the
basic principles of respect for the Group’s identity, image and values. Every web site should
comply with the graphic charter and content management principles.




        3.4.1 Graphic charter

Every web site should comply with the Corporate Identity Guideline, as specified by the
Communication Department:

    The Group’s symbols, colours and logos should be used in compliance with the Group graphic
      charter.
    The Group logo block consists of the “sanofi-aventis” logo and the “Because health matters”
      signature. These two parts are indissociable.
    The Group logo should appear on all pages (home page and inside pages) of all Group web sites.
    The Corporate Identity Guidelines and especially rules concerning Internet electronic
      communication are available at IS@: Communication / Guidelines and Graphic Identity (the model
      is also available in the appendix to this document).
    When a web site is built in partnership with another company, a special graphic charter may be
      needed, in which case the Group Communication Department should be consulted. At the very
      least, the Group logo should appear on all pages on the site.

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Internet Rules 2.1 – July 2010
The graphic charter to be used for web sites is given in the appendix
           (example of a site).




        3.4.2 Content management

The content of web sites calls for special attention because it represents the image of the Group
and should always accord with Group values:

    Information on the Group should only be provided on the sanofi-aventis.com, sanofi-aventis.tv
      and sanofipasteur.com Group web sites. Local information provided by subsidiaries should be
      based on the example of the Group web site.
    People in charge of content management should be identified. They are responsible for the content
      and for updating it. A “contact” or “webmaster” link should also be provided on all Group web sites.
      Mail boxes should be checked every day.
    Rights to use multimedia components (photos, videos, podcasts, etc.) on the Internet should be
      acquired before they are used on the web site.
    If there are hyperlinks to external web sites on the site, they should not have any negative impact
      on the image of the Group.



             Any questions should be sent to the following e-mail address:
                              geraldine.gorgol@sanofi-aventis.com




3.5 IS security

The design of applications on the Internet, a truly public network, opens the way to many risks that must
be guarded against. To reduce risk and ensure that sanofi-aventis Internet applications are only
used for the purposes they were designed for, the following security measures should be
implemented.


        3.5.1 Hosting facilities

    Include security clauses in hosting agreements (see checklist contract in the appendix).
    Ensure that servers are exclusively dedicated to sanofi-aventis. Sharing servers with other
      companies is not allowed.
    Make sure that computer facilities are adequately secure and most particularly in terms of backup
      power supply, air conditioning and fire protection.
    A procedure should be in place to authorise access to computer facilities and authorisations issued
      should be reassessed from time to time.


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Internet Rules 2.1 – July 2010
 If the hoster is a third party, the document entitled Computer Facility Check List Standard (DSSI-
      STDT-014-EN) should be used to confirm the standard of security provided.
    Check that security rules are in place in the administration of servers (password system policy,
      updating process, patch management, firewall, etc.)


            The checklist for contracts is available in the appendix and a paragraph
            deals specifically with computer security clauses.




         3.5.2 Applications

    If there is authentication, ensure that passwords are kept numerically and that they comply with the
      Password Policy in terms of complexity (see Password Policy - DSSI-PLMO-006-FR).
    Ensure that developments comply with the secure development rules (see Secure Application
      Development Policy (DSSI-PLMO-010-FR).


For sensitive web applications, such as e-business sites or ones with patient data (for example for
clinical research), the following additional measures should be implemented:
    An intrusion test should be run and any vulnerabilities found should be corrected before the
      application is used.
    Personal data about patients should be kept in numerical form (especially in backups).


Do not hesitate to ask your IS security manager or the DSSI to help on sensitive projects.




        3.5.3 Sending information

Users should be authenticated and personal information should be sent on the Internet by means of a
digital protocol (SSL protocol) so that data are kept confidential.



              Any questions should be sent to the following e-mail address:
                                 jerome.lahalle@sanofi-aventis.com

           For further information and technical support, refer to the intranet

                               http://issecurity.sanofi-aventis.com




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Internet Rules 2.1 – July 2010
Useful documents referred to in this paragraph (active links):

        Policy on the use of passwords (DSSI-PLMO-006-FR)

        Digital authentication (DSSI-PLMO-002-FR)

        Secured Application Development (DSSI-PLMO-010-FR)

        Computer Facility Check List Standards (DSSI-STDT-014-EN)




         3.6 Accessibility

It is our duty as a health business to provide an access as wide as possible to information, and especially
for the disabled. The Group has thus decided to implement concrete actions to promote accessible
information media. This initiative by the Group applies to all types of information: conferences,
symposiums, text and multimedia publications and in particular web sites.
Consequently, sanofi-aventis has made the following arrangements:
    Every sanofi-aventis web site should be accessible to the disabled.
    The W3C-WAI wcag 2.0 international accessibility standards (http://www.w3.org/TR/WCAG20/) are
        the accessibility standards
                 Double A standard: for Group corporate information sites
                 Single A standard: for all other Group web sites.


In general, it should be noted that the accessibility criteria should be taken into account as early as
possible in the project process.
Likewise, it is perfectly possible to design web sites that are fully accessible, without adversely affecting
visual quality or attractive or innovative graphic aspects.



 For detailed information on implementing these recommendations, take a look at
        our intranet site on accessibility: http://accessibilite.sanofi-aventis.com.


                  You can also contact Tanguy Lohéac, accessibility expert:
                                   tanguy.loheac@sanofi-aventis.com




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Internet Rules 2.1 – July 2010
4. Appendices
Glossary

Term                   Definition
Domain name            Name of a web site in the present case of the sanofi-aventis Internet policy. For
                       example: sanofi-aventis.com, sanofiaventis.com and sanofi-avantis.com are three
                       different domain names that all lead to the same web site: www.sanofi-aventis.com
CCtld                  Country Coded Top Level Domain: country extension of a domain name. For
                       example: sanofi-aventis.fr, sanofi-aventis.us.
Gtld                   Generic Top Level Domain: generic extension of a domain name.
                       For example: sanofi-aventis.com, .net, .org
e-PSF                  E-Project Study Form: form used for assessing a project before it is built. It is used
                       for checking that the project is in line with the Internet policy before the site is
                       developed in any way.
e-PAF                  E-Project Assessment Form: form describing the features of the site as regards the
                       Internet policy requirements. It is used for assessing the web site when it is
                       submitted to the Internet Validation Committee.
HT Access              Protection system that temporarily restricts access to a site by access codes. In
                       general, its use is recommended to protect the site before it goes on-line.
SSL V3 128 bit         Encryption standard used for sending secure data on the web, for on-line
                       transactions, collecting information from users and data exchange. Results in the
                       address htpps://
                       For example: to be used for contact forms, registrations on an extranet by login
                       and password.
HTTPS                  Communication protocol used to access a secure web server. If HTTPS is given in
                       the URL instead of the usual HTTP, the message will be sent to a secure input port
                       on the server. Dialogue between web browser and server will then be managed
                       with security restrictions. In particular, data exchanges will be encrypted and the
                       web user will generally be identified.
Staging                Site validation environment. The site is on the Internet or on a non-Internet server
                       and can only be viewed by people in charge of validating the site.




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Internet Rules 2.1 – July 2010
The e-PSF


                                 e-Project Study Form (e-PSF)
    If you want, you can provide a mock-up of the web site (PDF for the design) and an English translation of the
                                            Home Page and site map.



► Project Overview
Project Name                                                         Country/Dept

Project Leader(s)                                                    Launch date

Project Objective(s) (What will the project achieve?)


Project Description (How objectives will be achieved, how the project relates to other activities, etc.)



Target Audience (Detail characteristics, audience size, expected number, frequency of contacts, etc.)



     Local         Global             Both          Public:          at large          Patients       Family
Healthcare professionals:                                     Practice (or mix):
    General practitioners             Specialists                     Private consulting-room            Hospital
    Pharmacists                       Paramedical                     Non-medical environment
    Opinion formers                   All
Other

► Project Description
Domain name
 Did you contact the central team at DN-Domain-names-management@sanofi-aventis.com to register your domain
name?
 What will the final domain name of the web site be?
If there are several domain names, please list them:
Is the web site a partnership?
Key aspects of daily management of the site
 Site Accessibility                    Open access                Controlled access          Open with restricted areas
 Site management shared with           Corporate/affiliates       Another laboratory         Others:
 Mailbox management                    Internal                   External
The Project’s main functionalities / Services (Detail only the most important services offered to visitors)
                                                                  Access to information           Forum / Blog
                                                                  Community of interest           Online education
                                                                  E-business                      Online Contact Form

Main Content / Information (Primary content sources and messages to be conveyed)
                                                                  Company Information              Pathology
                                                                  Product                          Clinical trials
                                                                  Other:
Technical Requirements




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     Internet Rules 2.1 – July 2010
HT Access on development environment
                                                                        SSL V3 128 bit (https)
                                                                        Other:
Web 2.0 (please specify the use of Facebook, YouTube, Twitter, etc.)



Constraints (internal and external deadlines, commitments, events, regulatory issues, etc.)




► Key Project Indicators
Internal Resources (people, materials required during project management and online management of the site)



                                                                    Costs       For        External        Providers
 BUDGET and Services provided:
                                                                    K€ / year   (company name, town, country)
    Initial Development               External       Internal
    Content provision                 External       Internal
    Updating online content.          External       Internal
    Site technical maintenance       External       Internal
    Site hosting                      External       Internal
    Use of mobile tools (PDA)         External       Internal
    Statistics (specify software)     External       Internal
    Site promotion                    External       Internal
    Search engine ranking             External       Internal
    Other partners (e.g. webcast):
Project Development timetable (Key milestones and timetable)


Site life (years)                       Site developments if planned (e.g. new targets or content)


Project Performance Indicators                   (Return on Investment or other measurements, key success factors)




 Expected number of visitors (monthly)                           Expected Frequency (monthly):
 Frequency of content updates (yearly)




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     Internet Rules 2.1 – July 2010
The e-PAF



                          e-Project Assessment Form (ePAF)
                  Please remember prior local validation is mandatory before IVC review


► Project Description
Project Name                                                               Country
Objective(s)
Audience Targeted
Project Description
Main Editorial
components
Expected Benefits
Budget                         (€uros)

Targeted Launch date          Day / Month / Year


► Access
Website test version URL
Login:                                                  Password:
Website final URL
Login:                                                  Password:

         If not in English, please provide attached the English version of the Home Page, site map
         and legal notice.

► Project Team
Project Team
                                Name                       Position                    e-mail
Project sponsor

Project Team Leader

Project Team Members

Service Providers Contacts
                          Contact Name             Company Name       e-mail              Telephone
Site creation
Site maintenance

Site Hosting
Content providing

Website Management
                          Contact (first, last name)              e-mail                  Telephone
Webmaster

Publishing manager




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    Internet Rules 2.1 – July 2010
► Domain name                                                                                 Yes   No   N/A


             Did you contact the central team to register your domain name? (at DN-
          Domain-names-management@sanofi-aventis.com)
               Is your website a partnership (with a laboratory, patient association,
          scientific board…)?

► Legal Affairs                                                                               Yes   No   N/A


What is the name and function of the legal contact who validated the project is compliant with local
                                            legislation?
Name                                 Function                             email
       Contracts
             Have the necessary contracts been done with your suppliers (site creation,
             maintenance, hosting, and promotion)?
             Are there any other services provided by third parties in connection with the
             site?
                      Please precise the service:               Is there a contract?
       Applicable Laws, Legal and Privacy notices
               Have you checked that your site comply with the applicable legislation in
               your country including any official requirements?
               Do you comply with the relevant regulations in connection with personal data
               protection?
               Have you posted a legal notice on the site (including a privacy statement)
               mentioning the mandatory points detailed in the Internet Rules (applicable
               law, site editor …) (cf. paragraph 3.2.2 of the Internet Rules)?
       External links
             Do you respect the relevant rules concerning external links:
                      Third-parties consent
                      Warning pop-up
                      First click responsibility
       Intellectual Property Rights and Copyright
               Do you have the necessary intellectual property rights and/or copyright to
               use the content of the site (text, images, photos, videos…)?
               Did you mention credits for photographs and videos?
               Have you put a copyright on your website?

► Regulatory Affairs                                                                          Yes   No   N/A


What are the names and functions of the medical and regulatory contacts who validated the project
                                is in line with local regulations?
Names                                 Functions                           emails

       Transparency
               Can a visitor identify the sponsor of the site?
                      How and where?
               Can a visitor identify the target audience (country and type of audience)?
                      How and where?
               Did you validate the content of the site according to the medico-regulatory
               requirements of the country of the targeted audience?
               Do you have links to other websites?
                      Did you add pop up window leading to outside links?
                      How often have you planned to check the links?
               Is the page content dated?

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   Internet Rules 2.1 – July 2010
Site Access (depending on the type of information and target)
                Do you provide product information to the general public?
                Is information on prescription-only medicines password-restricted?
                Is up-to-date Patient Information Leaflet readily available to the visitors?

                Do you provide product Information to health professionals?
                Is the site restricted only to health professionals?
                Is up-to-date Prescribing Information readily available to the visitors?

                Do you provide product information to the patients?
                Is the site password restricted to patients only?
                Is up-to-date Patient Information Leaflet readily available to the visitors?
                How does the patient get access to the site? (DTC, password provided by
                HCP, etc)
        Information on products
                Do you mention specific products?
                Do you provide advice on alternatives to treatment?
                Do you advise visitors to consult a healthcare professional for further
                information
        Information on clinical trials
                Does this site provide information on international clinical trials?
                Does information       comply     with     information   provided      by   Global
                Communication?
        Price list
                Do you provide a price list on the site?
                Was the price list approved by the appropriate person?
                Is it limited to price information only (do not include indication, efficacy or
                safety/tolerance concerns) ?
        Bibliography
                Is it complete and objective (including either favourable or possibly
                unfavourable articles)?
                Where are the selection criteria described?
        Interactive tool (please report to the web 2.0 guide)
                Is it clearly stated that interactive sessions are sponsored by sanofi-aventis?
                Is the access password restricted?

        MailBox / Contact Form
                Is the information about the Email sender requested by compulsory fields?
                Did you add an appropriate disclaimer to encourage visitors to reports
                adverse events according to local process in force?
                Have you identified internally the network in charge of answering questions?
                Is there an appropriate organisation to check the mailbox (at least once a
                day) and transfer mail to the appropriate department?


► Corporate Communication                                                                            Yes   No   N/A


       What is the name and function of the communication contact who validated the project?
Name                                  Function                           email




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  Internet Rules 2.1 – July 2010
Compliance with the corporate identity
               Did you use the graphics template for Internet communication (Corporate
               Guidelines and Identity – Electronic communication) (cf. paragraph 3.4.1 of
               the Internet Rules)?
               Does the logo link to sanofi-aventis web site (link to the local affiliate module
               or to the Corporate web site when no local module)?
       Content Management
               Are the contents of the web site in line with the Group’s values?
               Have you ensured that proposed links to external web sites, posted in the
               site, do not harm the Group’s image?
               Have you set up an organisation for the monitoring of the web site content?
               If photos/videos have been posted in the website, have you checked that
               they do not harm the Group’s image?


► IS Security                                                                                      Yes   No   N/A


             What is the name and function of the IS contact who validated the project?
Name                                 Function                             email

               Has the provider agreed to the three security clauses in the contract
               (paragraph 3.5.1 of the Internet Rules)?
               If there is an authentication or transmission of Personal Identifiable
               Information on the Web site, is SSL used to protect users’ credentials or
               data?
               Is the web server dedicated to sanofi-aventis?
               Have the providers been audited by IS Security?
               Has intrusion testing been done on the application?


► Accessibility                                                                                    Yes   No   N/A


  What is the name and function of the technical contact who validated the project is accessible?
Name                                 Function                            email

               Did you take into account accessibility requirements when building your
               website (paragraph 3.6 of the Internet Rules)?
               Did you test if your website is accessible?




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   Internet Rules 2.1 – July 2010
DN registration request form


                               Domain Name Registration Form
                                to be sent to nathalie.marcy@sanofi-aventis.com
                           and DN-domain-names-management@sanofi-aventis.com


► Information about the requestor
Name                                                                   Request Date

email                                                                  Telephone

Country                                                                Department


► Domain name registration
                            Domain Name(s)                                     Is the DN a            Any website for
    (please, use lowercase characters and no blank before and after the DN)    Trade Mark ™?             this DN?
                                                                                 Yes       No           Yes         No
                                                                                 Yes       No           Yes         No
                                                                                 Yes       No           Yes         No
                                                                                 Yes       No           Yes         No
                                                                                 Yes       No           Yes         No
                                                                                 Yes       No           Yes         No



► Website Description: if a website project is planned with the domain name(s)
Website Description and objectives



Website main functionalities and services                                                       Estimated Launch date


                                                                                                Day / Month / Year
Is SSL V3 128 bit (https) needed on the website?              Yes        No
Type of information
    General information            Product Information                 Online education      clinical trials
    Interactive session: forum, blog, webinar, live Q/A…            e-commerce


Targeted Audience (Define characteristics, audience size, expected number, frequency of contacts, etc.)



 Geographic:        Local             Global          Both
 Public :           at large          Families        Patients with a prescription of the product
 Healthcare professionals:            General practitioners or specialists       Pharmacists        Paramedical
                                      Opinion leaders           Others
Web 2.0 (please mention the use of Facebook, Youtube, Twitter,… for your project.)




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     Internet Rules 2.1 – July 2010
DN pointing request form




Pointing / domain name redirection request form
(Use the Tab key to move from box to box)

Applicant’s name:                                                Telephone:

                                                                 E-mail:

                                                                 Fax:

Applicant department:                                                                 Country:        Date of request:


Pointing/redirection date:




Domain name                                 IP address if pointing      Domain        name       if   MX address:
                                                                        redirection                   Name servers AND
(Use lower case without spaces before                                                                 IP address
and after the domain name)
E.g.:
www.mydomain.org                            125.25.33.12                                              Ns1.dn.ec
mydomain.org                                125.25.33.12                                              256.255.33.10

www.mydomain .com                                                       www.mydomain.org
___________________________                 __________________          _____________________         _________________




Comments:




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   Internet Rules 2.1 – July 2010
Check-list for contracts

This summary is only indicative to recap on the major clauses in agreements. It is not in any way complete
and should clearly be adapted in each country in accordance with the legislation applicable.

       Site design contract:

The contract should cover all stages of the site design, from the audit of needs through to overall quality
control on going live.
It is essential that a site can be run entirely independently, and that the service provider involved in
creating it does not claim ownership of it.
A web site includes creations that are or can be protected as intellectual property. These rights, detailed in
the contract, will be transferred to sanofi-aventis by the service provider on completion of the project. The
list of rights to be transferred is given below in the intellectual property clause.
In addition, guarantees should be provided in the contract to cover us in the event of content in breach of
the law or unfair competition.

         Accessibility clause: every site design contract should include a clause covering accessibility.
          This is because all new web sites should be accessible to the disabled. So that the site
          complies, it is necessary to specify at least compliance with the “silver” level quality standard.
          This standard consists of a set of criteria on the content and structure of web pages.

         Intellectual property clause: the purpose of this clause is to ensure that all intellectual property
          rights are transferred, either by acquisition or by concession (the period and territory should be
          specified). This clause should detail all rights that are expressly transferred, because everything
          not expressly transferred remains with the owner, such as:
                   o     Right to reproduce or have reproduced,
                   o     Right to disclose, dispose and transfer,
                   o     Right to represent or have represented,
                   o     Right to adapt, alter and translate.
                   o     Right to copy, represent and incorporate, in full or in part, with or without a change
                         of interface,
                   o     Right to publish, either directly or indirectly, by any electronic means or by
                         telecommunication, on any existing or future medium, on-line or off-line
                   o     Rights specific to the producer of databases.
                   o     Right to correct and develop. Likewise for design documents.

        The media concerned should also be listed, for example such as the Internet or any other present
        or future medium.
        The cost of transferring all rights should be included in the overall price of service.

          Dispossession guarantee clause: this clause covers the service provider’s intellectual property
           rights. It guarantees that all intellectual property rights that it owns have been duly acquired
           and that they are not in breach and/or are not obtained by unfair competition or pirating. In the
           event of an action for breach, the service provider undertakes to guarantee us untroubled
           enjoyment of the result of its service by paying all charges or costs due to any legal action and
           undertakes to find a replacement solution for sanofi-aventis.

       Maintenance contract:

The maintenance contract covers the various components of the site for which you must own intellectual
property rights enabling you to make corrections and changes to the site.

             Clause on definitions: Technical definitions in the contract should be clear and universally
              understandable. In particular, the term “fault” should be clearly defined, with different
              graduations (major fault / minor fault), which will subsequently enable the service provider’s
              work to be governed.

             Clause on maintenance content: this clause should be carefully scrutinised, to detail what
              services the service provider is committed to providing, namely developmental, corrective,

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Internet Rules 2.1 – July 2010
curative and preventive maintenance. Attention should be paid to what the service provider
              excludes.

             Response time clause: check that the response time is clearly stated in accordance with the
              level of criticality of the fault. Also check its starting point, which most often is when the fault
              is reported to the service provider.

             Clause on penalty for delay: the purpose of this clause is to encourage the service provider
              to meet the standards of service or deadlines that the service provider is committed to. It will
              have the effect of obliging the service provider to pay a certain sum of money in the case of
              late performance or non performance of its undertakings. The starting point for penalties for
              delay, the calculation basis and the length of time late should be precisely defined and
              calculated to ensure that the amount is not derisory. It is preferable that penalties relate to a
              precise undertaking rather than to all the host’s obligations.

             Correction and work-around solution clause: this is the possibility for the service provider to
              offer its customer a temporary work-around solution so that the customer can continue to
              run the program. This solution should be temporary and the service provider must then
              repair the program so that it runs as intended.

       Hosting contract:

Relations with the site host should be covered by contract. It is essential first to draw up a pre-contract
specification for an audit of the service provider.

             Host’s liability clause: particular attention should be paid to the limits of liability so as to be
              covered in the event of damage in particular if the service provider hosts important sanofi-
              aventis sites.

             Clause on penalty for delay or penalty for non-compliance with service level undertakings:
              see what was said for the maintenance contract.

             Site availability clause: include a clause of this type so that users have access to the site,
              taking into account hardware and software maintenance periods necessary for the service
              provider. The access can be specified in the contract in the form of an availability rate.

             Clause on personal data: a clause should be included where the host acknowledges that
              personal data collected are confidential by nature. It should not under any circumstances
              keep it, use it, disseminate or communicate it for its own purposes. This clause should be
              revised in accordance with current local legislation.

             Reversibility clause: this gives Sanofi-aventis the option of hosting the site in-house or of
              having it hosted by a third party. This clause should specify a reversibility plan detailing in
              advance essential points such as timing, costs, tasks and payment.

             Security clauses (see §3.5): ask the host to commit on systems updates and enabling the
              sanofi-aventis IS Security department to run regular vulnerability scans with a view to
              checking that there are no known weaknesses. Lastly, there should be clauses allowing
              sanofi-aventis to conduct security audits at the host:

                    Security upgrade clause
The service provider agrees to regularly upgrade and maintain the security of its networks, servers,
systems and applications, in compliance with the recommendations by software publishers and hardware
manufacturers supporting the service.

                    Security audit clause
The service provider agrees that security audits will be conducted on its networks, servers, systems,
applications and procedures, supporting the service, on request by sanofi-aventis, and undertakes to
implement recommendations that may be made as soon as possible.




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Internet Rules 2.1 – July 2010
 Clause on periodic vulnerability analysis
In the case of a service accessible on the Internet, the service provider agrees that vulnerability analyses
will automatically be conducted regularly on its systems and applications, supporting the service, and
undertakes to implement recommendations that may be made as quickly as possible.


        Site promotion related contracts

              The listing contract: it is necessary to ensure that no third party names are used for listing,
               or there may be liability for breach.
              The advertising space purchase contract: this type of transaction should also be covered by
               an agreement with the advertiser or agency.
              Similarly, any promotional activity with a third party should be governed by contract (e-
               mailing, viral marketing campaign, launch via social networks, etc.)

        Partnership contracts

              Hyperlinks enabling one web page to be connected to another, either within the site, or
               outside. Before creating a link with a site, it is first necessary to get the agreement of the
               publisher of the other site.
              Content is often exchanged or combined in “co-sponsoring” or “co-branding” form with a
               section of the partner’s site. Content is identifiable as coming from the partner’s site. A link
               enabling Internet users to go directly to that content
              The affiliation contract which enables routing from partner or affiliated sites is also possible.

In general, it is necessary to pay attention in all agreements to the liability clause. In it, if a limit on liability
is set, it should cover damage attributable to the service provider in performing the contract.


As this list of clauses and contracts is only indicative, contracts should always be validated by the usual
legal experts, who may add to them if necessary in accordance with current local legislation.




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Internet Rules 2.1 – July 2010
The consent request email for links

When a site belonging to sanofi-aventis offers Internet users a link to a third party site, a prior consent
letter should be sent to the administrator of the third party site.


The letter can be in the following form:




“Sanofi-aventis publishes and operates the (name of your web site) web site, which deals with
(description of your web site, general content, positioning, target).
We would like to provide a link to your web site (name of the third party web site). To do so, we need
your consent for the following:


    -   Conditions applicable to the link: (state the section hosting the link, simple link or link with
        description of the pointed web site, use of the third party logo, update of the link)
    -   Period of validity of the link: (state the period)
    -   When Internet users click the link, a pop-up window appears to warn them that they are leaving
        our web site and are being routed to yours (and also states that we are no longer responsible for
        the information provided).


If you do not reply within two weeks, we shall assume that you agree with this pointing arrangement.


Please feel free to contact us if you have any questions or need further information about our web site or
this procedure.




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Internet Rules 2.1 – July 2010
Site exit pop-up


       The linked web site to belongs to sanofi-aventis and complies with the various rules and
        regulations


Example for the United States:




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Internet Rules 2.1 – July 2010
   The linked web site does not belong to sanofi-aventis




    Example of the Lantus web site in the United States:




                                                                34

Internet Rules 2.1 – July 2010
Example of terms and conditions

                 Terms mentioned in red should be replaced and adapted to your site.
 Terms mentioned in grey are advisory, given for drafting your terms and conditions, and should be
                                     deleted in the final version.
               Terms and conditions should be validated by your local legal department.



This page describes the terms and conditions that apply to all Internet users visiting this
site. By consulting them you unconditionally undertake to comply with them. As terms and
conditions may be amended at any time, without prior notice, we advise you to consult them
regularly.


    1. Intellectual property


This site belongs to and is operated by name of the sanofi-aventis subsidiary, (hereinafter
“sanofi-aventis”) belonging to the sanofi-aventis Group. The layout and each of the
components, including trademarks, logos and domain names, appearing on the site name
and url of the site (hereinafter the "Site"), are protected by current laws on intellectual
property, and belong to sanofi-aventis or its subsidiaries, or their use is the subject of an
authorisation.
No component of the Site may be copied, reproduced, altered, edited, downloaded,
denatured, transmitted or distributed in any way whatsoever, on any medium whatsoever, in
whole or in part, without the prior written consent of sanofi-aventis, except solely for use for
press requirements conditional on compliance with intellectual property rights and any other
property rights that are mentioned. Only copying for private use is authorised for your own
personal, private, non-commercial use, on your personal computer.
The following statement should appear on any authorised copy of all or part of the content of
the Site: "COPYRIGHT year the site was created – current year - name of the sanofi-
aventis subsidiary - ALL RIGHTS RESERVED".

Any authorised use of items composing or shown on the site must not be denatured,
changed or altered in any way whatsoever.
Sanofi-aventis or its subsidiaries reserve the right to take legal action against any breach of
its intellectual property rights.


    2. Nature of information


Information, especially financial, published on the Site shall not be considered as an
encouragement to invest. It should not under any circumstances be interpreted as
prospecting or as a public offering, nor is it an offer to subscribe, buy or swap shares or
other securities in sanofi-aventis and/or its subsidiaries concerned. Sanofi-aventis draws
                                                                                        35

Internet Rules 2.1 – July 2010
your attention to the fact that financial information posted on the Site is regularly updated
(if financial information is provided on-line).
The Site may offer opinions by experts consulted in a particular field in relation to the
content of the Site or excerpts from press articles. Any such information solely represents
the opinion of the expert consulted or the publication, and is not necessarily the opinion of
the sanofi-aventis Group. Any such experts are not employees of the sanofi-aventis Group
and do not receive any emoluments in exchange for sanofi-aventis using their opinion.
Sanofi-aventis is not responsible for the accuracy or completeness of any such information
and opinions. Experts’ opinions reflect their own personal views and should never be
interpreted as being the opinion or responsibility of sanofi-aventis.
The Site also includes information on health, physical condition, the medical field and
medical treatments solely for human use. Said information is published on the Site for
information purposes only and is no substitute for the advice of your physician or
pharmacist. The information should not be used under any circumstances to make a medical
diagnosis of an illness or physical problem, or for prescribing or using drugs presented on
the Site. In all instances you should refer to your physician or pharmacist.


    3. Links to other sites


The liability of sanofi-aventis or of the sanofi-aventis parent company shall not be incurred
by a third party site that can be accessed via the Site. We do not have any way of
controlling the content of such third party sites which remain entirely independent of sanofi-
aventis. Moreover, the existence of a link between the Site and a third party site does not
under any circumstances mean that sanofi-aventis approves the content of that site in any
way whatsoever and in particular the use that may be made of it.
In addition, you are responsible for taking the precautions necessary to prevent any
infection from the Site, in particular by one or more computer viruses, Trojan horses or any
other "parasite".
External sites may include hypertext links to the Site. Any such links should not be created
without the express prior consent of sanofi-aventis. In any case, sanofi-aventis is not in any
way liable for the non-availability of such sites and sanofi-aventis does not scrutinise, check
or approve them and is not responsible for contents, advertising, products or other
components available on or via those sites.


    4. Personal information and other information


4.1 Sanofi-aventis will not disclose to third parties personal data about you that you may
convey to it by e-mail. It will only be used with a view to providing you with an answer as
effectively as possible.


                                                                                            36

Internet Rules 2.1 – July 2010
If there is a law on personal data protection in your country, you should complete
and mention the following paragraph:


In accordance with local legislation “give the name, number and references of the law
in force”, you have the right to access, alter, rectify and delete personal data that concerns
you. To do so, request as follows:
On-line: the webmaster’s address
Ensure that the mail box mentioned is active and that its holder checks it daily.
If possible, do not give the e-mail address of a sanofi-aventis employee, prefer
generic addresses of “webmaster@mysite.com” type
By post: physical address of the subsidiary or department


4.2 The Site is not intended to receive confidential information from you. Consequently, and
except for personal data mentioned above, any information, whatever its form - document,
data, graphic, question, suggestion, concept, comment or other - that you send us via the
Site will not under any circumstances be deemed confidential. Consequently, the act of
sending it to us alone gives us the right to use it, reproduce it, publish it, alter it or send it
with a view to dealing with your request.


    5. Limitations on liability


Sanofi-aventis strives to the best of its ability to ensure that information published on the
Site is accurate and up-to-date. It reserves the right to correct content at any time, without
prior notice. However, sanofi-aventis cannot guarantee that the information available on the
Site is accurate, correct, up-to-date or complete.
Consequently, and except for property damage resulting from gross or intentional negligence
by sanofi-aventis, the group declines any liability:


             for any inaccuracy, error or omission as regards information available on the
               Site;
             for any damage resulting from fraudulent intrusion by a third party resulting in
               an alteration of information or items made available on the Site
             and more broadly, for any property damage or consequential loss, for any
               reason, of any origin, nature or with any consequences whatsoever, even if
               sanofi-aventis had been warned of the possibility of such damage or loss,
               caused (i) because of any access to the Site or because it was impossible to
               access it, (ii) because of the use of the Site, including any harm or virus that
               may infect your computer or any other property, and/or (iii) because of the
               credence given to any information coming directly or indirectly from the Site.

                                                                                                37

Internet Rules 2.1 – July 2010
The components of the Site or of any other site are provided "as is" without any guarantee
of any kind, whether implicit or explicit. Sanofi-aventis does not offer any implicit or explicit
guarantee, relative, without limitation, to their market value or suitability for any given
purpose.


    6. Availability of the web site


You acknowledge (i) that it is technically impossible to provide the Site free from any defect
and that sanofi-aventis cannot undertake to do so; (ii) that defects may lead to the Site
being temporarily unavailable; and that (iii) operation of the Site can be affected by events
and/or matters that sanofi-aventis does not control, such, for example, as means of
transmission and communication between you and sanofi-aventis and between sanofi-
aventis and other networks.
Sanofi-aventis and/or its suppliers may, at any time, alter or interrupt, temporarily or
permanently, all or part of the Site to undertake maintenance and/or make improvements
and/or changes to the Site. Sanofi-aventis is not responsible for any alteration, suspension
or interruption of the Site.


    7. Information on products


Information included and published on the Site may include direct or indirect references to
products, programmes and services of the sanofi-aventis Group that are not announced or
available in some countries or some regions or that may be supplied under a different name
and may be subject to regulations and terms of use that differ depending on the country.
Such references do not mean that the sanofi-aventis Group intends to sell those products,
programmes or services in your country. Refer to the local sanofi-aventis Group subsidiary
or your sanofi-aventis Group sales partner for any information about the products,
programmes and services available to you.


    8. Legal provisions


The Site and its content are governed by the Laws of name of country, and any disputes
relating thereto are subject to the jurisdiction of the courts of name of country.


    9. Terms and conditions


9.1 Publisher of the Site:
This is the subsidiary

                                                                                              38

Internet Rules 2.1 – July 2010
Physical address of the subsidiary or department
Name of the sanofi-aventis subsidiary is a joint stock company with capital of amount of

capital, listed in the name of the register for your country and company number.


9.2 Head of Publication:
This is the person in charge of validating the contents, the editorial line, etc.
Depending on the site, it may either be the Head of Communication, or the
Marketing Manager, or the Medical Manager, or sometimes the Product Manager.
Name and surname of the Head of publication


9.3 Site hosting:
Name and address of host


    10. Photo / video credits:
This is the name of the photographer or agency
List credits and copyright for photographs, images and videos used on the site




                                                                                     39

Internet Rules 2.1 – July 2010
The Contact Us page


Contact pages should be a form with predefined fields. Direct “mail to” links are not allowed.




                                                                                                 40

Internet Rules 2.1 – July 2010
Contact Us pages should include a form for Internet users to fill in before posting their comment and/or
question.
They should be secure by https.
They should also state that they are not intended for receiving adverse event notifications (and propose an
alternative way).


The form can include the following items


       Choice General public/physicians (required field)
       Title
       Surname (required field)
       Name (required field)
       Company
       E-mail (required field)
       Address
       Post code
       Town
       Country
       Telephone (required field)
       Subject
       Message (required field)




                                                                                                        41

Internet Rules 2.1 – July 2010
The graphic charter applicable to all sanofi-aventis product and/or
theme sites




The logo block at the top of the page of a product and/or theme site is positioned as follows:


- At the top right of the page only use the logo (sanofi-aventis name with graphics and smile).
- Positioning in the specified horizontal “silhouette” form




                                                                                                  42

Internet Rules 2.1 – July 2010

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Internet rules 2.1 new version

  • 1. Sanofi-aventis Internet rules Version 2.1 - Simplified process Last updated: July, 2010 1 Internet Rules 2.1 – July 2010
  • 2. Foreword: Why a simplified version of the Internet rules?  5 fields are now reviewed instead of 8  In a justified emergency, the web site can be validated before it goes on-line in 72 hours (Fast-Track process)  An ad hoc process can be set up enabling the site to be validated after it goes on-line (on request by the subsidiary and after approval by the Internet Validation Committee)  The e-PSF becomes optional. On the other hand, centralised management of the domain names remains mandatory. Web use in the Group is growing and it has become an essential medium. More than 580 web sites were listed in the Group at end 2009, which is a 40% increase in 4 years. The Internet Validation Committee has validated about a hundred projects a year since 2005 (own sites, in partnership, web 2.0), which demonstrates the growing importance of the web for our business. More than ever, the Internet is supplementing other media traditionally used in our marketing mix. It is a channel with very great potential for promoting our products and activities, as well as informing our patients about our main therapeutic fields. But being on the Internet also has risks. Being on the Internet is not risk-free for a group like ours. So precautions must be taken to limit potential risks so that serious damage is not suffered (such as legal risks, non-compliance with regulations, hacking of our sites, unauthorised access to or retrieval of confidential data, alteration or inconsistency of our image or messages). Note that 74% of sites reviewed in 2008 and 46% in 2009 did not comply with the Group’s Internet standards (out of a total of 294 projects reviewed in 2 years). This is why there have to be Internet rules – which keep pace with evolving needs. It is inconceivable for sanofi-aventis to be on the Internet unless some principles are abided by. As regards changes in our internal organisation and the limitations of our environment, we believe it is necessary to free up the process of validating web sites, so we have simplified it by altering the points mentioned in the introduction above. 2 Internet Rules 2.1 – July 2010
  • 3. The Internet rules and forms mentioned in this document can be downloaded at Is@ Group: http://internet.sanofi-aventis.com 3 Internet Rules 2.1 – July 2010
  • 4. CONTENTS 1. Scope ............................................................................. 5 2. The validation procedure ............................................... 6 2.1 Phase 1 : The site project...................................................................................................6 2.2 Phase 2 : Building the site .................................................................................................8 2.3 Phase 3 : Launching the site .............................................................................................9 3. Validation components ................................................ 11 3.1 Domain names ..................................................................................................................11 3.2 Legal affairs.......................................................................................................................11 3.2.1 Formalise contractual relations and comply with the legislation in every country....................... 11 3.2.2 Terms and conditions .................................................................................................................. 12 3.2.3 Site exit pop-up ........................................................................................................................... 12 3.2.4 Copyright and intellectual property rights.................................................................................... 13 3.3 Regulatory Affairs.............................................................................................................13 3.3.1 General principles ....................................................................................................................... 13 3.3.2 Transparency .............................................................................................................................. 14 3.3.3 Access to the site ........................................................................................................................ 14 3.3.4 Specific questions related to the type of information .................................................................. 14 3.4 Communication.................................................................................................................16 3.4.1 Graphic charter............................................................................................................................ 16 3.4.2 Content management.................................................................................................................. 17 3.5 IS security..........................................................................................................................17 3.5.1 Hosting facilities .......................................................................................................................... 17 3.5.2 Applications ................................................................................................................................. 18 3.5.3 Sending information .................................................................................................................... 18 3.6 Accessibility......................................................................................................................19 4. Appendices .................................................................. 20 Glossary ................................................................................................................................................... 20 The e-PSF................................................................................................................................................ 21 The e-PAF................................................................................................................................................ 23 DN registration request form.................................................................................................................... 27 DN pointing request form ......................................................................................................................... 28 Check-list for contracts ............................................................................................................................ 29 The consent request email for links ......................................................................................................... 32 Site exit pop-up ........................................................................................................................................ 33 Example of terms and conditions............................................................................................................. 35 The Contact Us page ............................................................................................................................... 40 The graphic charter applicable to all sanofi-aventis product and/or theme sites..................................... 42 4 Internet Rules 2.1 – July 2010
  • 5. 1. Scope Version 2.1 of the Internet rules covers Internet projects intended for external targets (outside sanofi-aventis). An Internet project can be a web site, of course, but can also be an e-crf system, an e-purchasing system involving suppliers, an e-recruitment system, etc. External targets can be customers, patients, doctors, health authorities, payers, shareholders, suppliers, partners (patients’ associations, universities, hospitals, etc.), job applicants, etc. The Group’s Internet rules 2.1 apply to:  Internet projects that sanofi-aventis owns and is solely responsible for  Internet projects that sanofi-aventis sponsors (partnership with a site owned by a third party) So any site, although it uses Internet technologies and is accessible on the Internet, that only concerns sanofi-aventis employees is not covered by these rules. For example, web sites for sales forces are not within the scope of the Internet rules 2.1. Web 2.0 initiatives (using social networking for example) are covered in a document supplementing the Internet rules: the Web 2.0 Guide. Please refer to it (downloadable on the intranet). Projects that sanofi-aventis sponsors are covered in an ancillary document to the Internet rules: Internet partnerships. Please refer to it if your project comes under this heading. 5 Internet Rules 2.1 – July 2010
  • 6. 2. The validation procedure IDEA PROJECT DEVELOPMENT LAUNCHING / RUNNING STAGE 1 STAGE 2 Registering the Domain name Validating the project Domain Name Registration Form e-Project Assessment Form or Web 2.0 Checklist (depending on the project) OPTIONAL: project monitoring Activating the domain name e- Project Study Form Domain Name Pointing Form All forms mentioned in this section are given in the appendix and are available on the intranet at http://internet.sanofi-aventis.com 2.1 PHASE 1: THE SITE PROJECT Registering the domain name and presenting the Internet project a) How do I register my domain name? When you begin an Internet project, and once you have chosen your project’s domain name(s), send your request to the e-mail address DN-Domain-names-management@sanofi-aventis.com, using the “DN Registration Form” (see appendix). The management of all sanofi-aventis domain names is based on the following principles:  Centralised administrative registration of domain names  Centralised technical management of domain names (on sanofi-aventis DNS servers) 6 Internet Rules 2.1 – July 2010
  • 7. b) Who do I present my project to, when and how? AT LOCAL LEVEL Firstly, your project must have been validated at local level (Internet website or web 2.0 project). The following steps are absolutely necessary in the strategic validation of your project and must be respected before the presentation of your project at global level: 1- Know the global digital strategy 2- Define your website and project objectives a. Why and how a website is the right tool to achieve your objectives? b. What are the objectives of the website itself? 3- Define how your website is innovative in comparison with existing tools 4- Define your audience targeted a. Profile (from general public to Healthcare Specialists) b. Characteristics c. Geographical localization 5- Define your messages and publishing frequency a. Contents, services and functionalities b. Customer loyalty and added-value services enhancement  Think as if you were in visitor’s shoes! 6- Include medical, regulatory, legal and IT local correspondents the soonest, in order to get their validation at the very beginning of the project 7- Define how the website will be promoted (set up a promotion plan) 8- Define the success and profitability indicators (ROI) a. Website frequentation b. Visitor’s behaviour on the website c. Impact of the website in terms of product notoriety, image or sales 9- Manage the lifecycle of your website a. Updates frequency (mandatory to maintain your website attractive) b. Contents creation c. Allocated resources (for updates, promotion…) AT GLOBAL LEVEL In parallel, you must inform the Internet coordination team that you are initiating an Internet project, before starting the building of the website. To do so, please be sure to complete correctly the section “project description” in the domain name registration form. If you want, you can get the support of the Internet coordination team when undertaking your project. To get their help, send an e-PSF (e-Project Study Form in the appendix or available on the 7 Internet Rules 2.1 – July 2010
  • 8. intranet) to Internet-Committee@sanofi-aventis.com. You will have the benefit of regular support, and can ask the team for advice while running your Internet project. The E-PSF stage is optional. 2.2 PHASE 2: BUILDING THE SITE Validation of the Internet project with the Internet Validation Committee a) When does this phase take place? This second phase takes place when the Internet project has been developed, and is ready to go on line. The site should be completed, installed on its permanent hosting platform, and not accessible to web users (protected by HT Access). b) What is the Internet Validation Committee and what does it do? The Internet Validation Committee validates all Internet projects before or after they go on line, according to the procedure set in the Internet rules. It is a multi-disciplinary body, tasked with setting and ensuring application of the Group Internet rules in sanofi-aventis. Local validations of the project remain primordial, and the IVC does not substitute for the local validation process (in terms of medical and regulatory contents validation for example). It consists of global representatives from the following sectors: Corporate Communication Thierry Le Magny, Géraldine Gorgol Legal Affairs Isabelle Cadiau, Anne-Sophie Nibert Medical and Regulatory Affairs Cécile Gousset, Françoise Rey, Sylvie Pujol, Peggy (Promotional Material Excellence team) Dolin-Brunel Information System Security Jérôme Lahalle, Olivier Fourmaux Accessibility Tanguy Lohéac Marketing Céline Degand Information System Technologies Dominique Lacan Coordination Caroline Debuire, Frédéric Dimur It meets fortnightly on a Friday morning. A schedule of meetings is available on the intranet at http://internet.sanofi-aventis.com c) The traditional validation procedure To have your Internet project validated by the Internet Committee, you should send an e-PAF (e-Project Assessment Form in the appendix or available on the intranet) to Internet-Committee@sanofi- aventis.com at the latest by the Tuesday before the Internet Validation Committee meeting. 8 Internet Rules 2.1 – July 2010
  • 9. At the end of the assessment, which takes up to two working days, the Internet Validation Committee gives an answer to the person in charge of the web site, who may be asked to make changes before the site goes on line, if it does not comply with the Internet rules 2.1. Exception: the emergency validation procedure (Fast-Track process) Sometimes the dates of the Internet Validation Committee meeting may not fit in with the date scheduled for your web site to go on line. If and only if the site launch date is linked to a major event (such as a product launch, marketing authorisation announcement, crisis on a product, international congress, etc.) an exceptional review between two meetings of the Internet Committee can be arranged. d) The Ad Hoc procedure assigned per subsidiary Depending on the number of sites already validated by the Internet Committee, and especially depending on the degree of compliance of sites previously presented, some teams/subsidiaries have acquired certain expertise in the Internet rules. It is possible to set up a simpler procedure, to speed up reviews by the Internet Committee. Each case will be looked at individually, and depending on the conclusions of the analysis by the Committee with the team/subsidiary concerned, a Ad Hoc procedure may be implemented, which may even include the possibility of accepting sites after they go on line if necessary. In which case, the domain name will be pointed before validation. Nonetheless, if there are repeated breaches of the Internet rules reported during the use of the Ad Hoc stage, the subsidiary will be required to go back to the traditional procedure. 2.3 PHASE 3: LAUNCHING THE SITE Putting your Internet project on line a) How is the web site activated? Once the site has been validated by the Internet Validation Committee and any changes requested have been made, the Internet project can then be put on line. To do so, the domain name should be pointed to your web site’s IP address. To request pointing, the pointing request form “DN Pointing Form” (see appendix) should be completely filled in and sent to the address DN-Domain-names-management@sanofi-aventis.com. The domain name pointing will be confirmed in the days following the request. b) What happens once the site is launched? The project manager is responsible for the site and in particular must ensure compliance with the Internet rules 2.1 throughout the life of the site. If necessary, he/she must ask the Committee if there is a question or problem. In addition, every web site may be checked to ensure it complies with the Internet rules. 9 Internet Rules 2.1 – July 2010
  • 10. Where applicable, a summary of any requests for changes will be sent to the person in charge of the site. Lastly, if major changes are made to the Internet project (such as a change of positioning of a site, new design, new service, new web 2.0 tool, etc.), they must be reported to the Internet Validation Committee. c) What should I do if a site is on-line but has not been validated? There are two possibilities:  The site has never been reviewed by the Internet Committee, and has been on-line for a long time This can be the case for example with sites on the Internet before the Internet rules were published, or web sites from mergers or acquisitions. Every site owner concerned must send an e-PAF to the Internet Validation Committee at the following address Internet-committee@sanofi-aventis.com. The site will then be assessed by the Committee and an assessment report will be sent to the person responsible for the site, detailing any changes to be made.  The site has been reviewed by the Internet Committee, or has been put on-line without making the requested changes The Internet Validation Committee may decide to close a site put on-line without the Committee’s authorisation, notified by e-mail to the person in charge of the site. It must be closed as soon as possible after notification is sent: 1 Either by the project manager, by any means available (e.g. HT Access, redirection) 2 Or by disabling the domain name pointing if necessary. 10 Internet Rules 2.1 – July 2010
  • 11. 3. Validation components These mandatory components determine whether or not a web site is validated. The components concern six separate fields: domain names, legal affairs, regulatory affairs, communication, computer security and accessibility. 3.1 Domain names All domain names should:  comply with the sanofi-aventis naming policy  be bought directly by sanofi-aventis and not by a any third party  be hosted on sanofi-aventis DNS servers Any pointing enabling a site to be put on-line is done by sanofi-aventis in-house staff, and can be done in only two cases:  either before the site is put on-line, provided that an HT Access is set up  or after approval by the Internet Committee Important information: For legal liability reasons, when sanofi-aventis partners or sponsors a site, the domain name must not be registered by sanofi-aventis. Registration and pointing forms for domain names are available in the appendix. All DN requests should be sent to the following e-mail address: DN-Domain-names-management@sanofi-aventis.com 3.2 Legal affairs 3.2.1 Formalise contractual relations and comply with the legislation in every country You should have the following points validated by your Legal Department:  Validation and verification of contractual relations (see checklist in the appendix): Web site design agreement Maintenance agreement 11 Internet Rules 2.1 – July 2010
  • 12. Internet access and hosting agreement Site promotion related agreements Partnership agreement  Checking the legislation applicable in each country: National and international legal provisions: the laws in each country, as well as international agreements (such as Community law for the EU), should be taken into account Recommendations, codes of conduct and practices on the Internet: personal data should be collected and processed in accordance with the specific laws in each country. Current regulations: check that information given on the site is aimed at the right audience (patients/doctors), is not unlawful and does not create offence; does not mention third parties’ products or services; information should not defame or denigrate; it should respect customs and practices in countries where it is disclosed. So it is essential, before going on-line and even before the e-PAF is sent to the Internet Validation Committee, for you to check with your legal department that the web site complies with all the requirements that apply to it. 3.2.2 Terms and conditions  Terms and conditions should be shown on all Group sites. The terms and conditions should be tailored to take account of legislation in the country concerned and should also cover legal information, limitation of liability, a statement relative to privacy and the protection of intellectual property rights (e.g. copyright), the publisher of the site, and the name of the Head of publication.  Legal information on privacy and the processing of personal data should also be provided.  This information should be easy to consult from all pages on the site.  An example of terms and conditions is available in the appendix. We strongly recommend that you use it and have it checked by your legal department. 3.2.3 Site exit pop-up  It is recommended that the limitation of liability clause be displayed on entering and leaving the site, especially for hyperlinks to third party web sites. Examples of site exit pop-ups are available in the appendix.  Any link to an external partner’s site should not be installed without the prior agreement of the third party and sanofi-aventis. The terms and conditions and site exit pop-up should be validated by your legal department. 12 Internet Rules 2.1 – July 2010
  • 13. 3.2.4 Copyright and intellectual property rights  Sanofi-aventis should hold the intellectual property rights on content used on sites (including text, photos, videos, animations and logos).  A copyright symbol should be inserted with the name of the company owning the site and the date at the bottom of every page of the site. Examples available in the appendix: checklist for agreements/ contracts, letter requesting consent for links to third party sites, site exit pop-ups, terms and conditions. All requests to legal affairs should be sent to: isabelle.cadiau@sanofi-aventis.com 3.3 Regulatory Affairs 3.3.1. General principles  The website must imperatively be validated by the structure in charge of the project (affiliate, region or global) before being sent to the Internet Validation Committee. The regulatory and medical representatives of the structure are responsible for the contents validation.  These principles are the minimal standards that everyone in the Group should meet worldwide.  They do not cancel or replace stricter local regulations.  Information specific to a given country should comply with local rules.  Promotional information (full page or banner advertising) and medical information given on web sites should be validated, in compliance with the process of promotional document validation, well before it is put on-line on web sites and then after it is put on-line whenever any promotional information is changed.  Remember that information on the Internet is subject to the same rules and regulations on medical information as it is in all other media. 13 Internet Rules 2.1 – July 2010
  • 14. 3.3.2 Transparency  The identity of the Group should be clearly stated on the first page as well as the nature of the partnership if there is one (cooperation or simple financial support, educational grant).  The target audience should be clearly identified (country of residence, general public, health professional, shareholder or journalist) and clearly specified on the site (in general at the top of the site page).  The content should be suited to the target audience and the purpose of the site should be clearly stated.  Links should be appropriate and clearly highlighted for the target audience with site exit pop-ups. Examples of pop-ups are available in the appendix. if the site belongs to sanofi-aventis and complies with the same rules and regulations (same country), there is no need to add the pop-up; if the external site belongs to sanofi-aventis and complies with different rules and regulations (different countries), a pop-up should be added stating that the web site cannot comply with regulatory criteria that apply to the audience in question; if the external site does not belong to sanofi-aventis, it is necessary to add a pop-up warning users that they are leaving the sanofi-aventis web site; if a page provides several links, a clearly visible message at the top of the page can replace the pop-up. This solution applies if it complies with local regulations.  The sources of any information given on the site and its date of publication should be stated on the site.  The date of the last update of the various information given should be stated on every page and be specific to each item of the content. 3.3.3 Access to the site  Site open to the general public: information on prescription products (excluding the US) should not be put on-line.  Information for health professionals: a password is required to access this page, or a clause limiting access in the form of a pop-up with confirmation click, in accordance with local regulations.  Information for patients given a prescription medicine: proof of prescription should be provided or access should be granted by the prescribing doctor. 3.3.4 Specific questions related to the type of information  Product information: depending on the target audience, the Patient Information sheet / the Summary of Product Characteristics or any other official Product Information required by the local authorities should be easily accessible by means of a clear, easy-access link. 14 Internet Rules 2.1 – July 2010
  • 15.  General information on health: free. Web sites that provide information on health should always advise web users to consult a health professional for any further information. Drugs can be alluded to provided that they are presented in an exhaustive and objective way. Generally, only therapeutic classes are mentioned; if the law allows, the international non-proprietary name (INN) should be preferred to the brand name. If brand names are used, they should be accompanied by the INN, for reasons of clarity.  Public information on clinical trials: the sanofi-aventis Group is committed to transparency on clinical trials: information on clinical trials in progress and the results of clinical research can be accessed by the public firstly through records of clinical trials, and secondly on databases of clinical trial results. Sanofi-aventis has chosen to save its clinical trials to the www.clinicaltrials.gov web site and publishes the results of its clinical trials on the www.clinicalstudyresults.org web site. Useful link: http://www.sanofi-aventis.com/recherche_innovation/dev_clinique/engagements/engagements.asp  Clinical trial results: this information should be validated by the Communication Department.  Clinical trials in progress: secure site that can only be accessed by health professionals who are directly taking part in the trials. The decision to deploy this type of network should be validated by the department managing the trial (International Clinical Development or Global Medical Affairs and/or the Global Marketing Clinical Operations).  Price list: possible at country level if validated. Information should be limited to the product name, its INN, presentation and price. Information should be dated.  Bibliography or database of publications: it should be as complete as possible, up-to-date and not restricted to articles favourable to our products. The search and selection criteria should be clearly specified.  Photographs: authorisation to use and pay for copyright should be obtained. Credits (name of the photographer/agency) should be stated.  Interactive sessions (forums, webinars): refer to the web 2.0 document. Sessions should only be on a precise date for a predefined audience, and access should be by password.  Contact page: Direct access to e-mail addresses or direct reference via “mail to” should be avoided. There should be a contact form that includes required fields (name, address, profession and electronic address) and a general statement advising members of the public against reporting undesirable effects or other drug monitoring events to this address. An example is available in the appendix.  The mail box should be checked every day and reports of undesirable events should be sent to the drug monitoring department of the subsidiary concerned Examples available in the appendix: contact form and site exit pop-up. 15 Internet Rules 2.1 – July 2010
  • 16. For further information, refer to: The FIIM’s Code of marketing practices for pharmaceuticals The sanofi-aventis Principles of good promotion practices Intranet The Promotional Material Excellence intranet Contact Promotional-Material-Excellence-Team@sanofi-aventis.com 3.4 Communication Three types of web site are identified: Group and Subsidiaries’ Corporate Communication  Corporate sites: sanofi-aventis.com, sanofi-aventis.tv and sanofipasteur.com.  Subsidiaries’ sites: sanofi-aventis.us, sanofi-aventis.de, etc. Internet initiatives  Product, pathology, environment and social media sites Partnerships with third parties Information provided by sanofi-aventis and spokespersons on the Internet should comply with the basic principles of respect for the Group’s identity, image and values. Every web site should comply with the graphic charter and content management principles. 3.4.1 Graphic charter Every web site should comply with the Corporate Identity Guideline, as specified by the Communication Department:  The Group’s symbols, colours and logos should be used in compliance with the Group graphic charter.  The Group logo block consists of the “sanofi-aventis” logo and the “Because health matters” signature. These two parts are indissociable.  The Group logo should appear on all pages (home page and inside pages) of all Group web sites.  The Corporate Identity Guidelines and especially rules concerning Internet electronic communication are available at IS@: Communication / Guidelines and Graphic Identity (the model is also available in the appendix to this document).  When a web site is built in partnership with another company, a special graphic charter may be needed, in which case the Group Communication Department should be consulted. At the very least, the Group logo should appear on all pages on the site. 16 Internet Rules 2.1 – July 2010
  • 17. The graphic charter to be used for web sites is given in the appendix (example of a site). 3.4.2 Content management The content of web sites calls for special attention because it represents the image of the Group and should always accord with Group values:  Information on the Group should only be provided on the sanofi-aventis.com, sanofi-aventis.tv and sanofipasteur.com Group web sites. Local information provided by subsidiaries should be based on the example of the Group web site.  People in charge of content management should be identified. They are responsible for the content and for updating it. A “contact” or “webmaster” link should also be provided on all Group web sites. Mail boxes should be checked every day.  Rights to use multimedia components (photos, videos, podcasts, etc.) on the Internet should be acquired before they are used on the web site.  If there are hyperlinks to external web sites on the site, they should not have any negative impact on the image of the Group. Any questions should be sent to the following e-mail address: geraldine.gorgol@sanofi-aventis.com 3.5 IS security The design of applications on the Internet, a truly public network, opens the way to many risks that must be guarded against. To reduce risk and ensure that sanofi-aventis Internet applications are only used for the purposes they were designed for, the following security measures should be implemented. 3.5.1 Hosting facilities  Include security clauses in hosting agreements (see checklist contract in the appendix).  Ensure that servers are exclusively dedicated to sanofi-aventis. Sharing servers with other companies is not allowed.  Make sure that computer facilities are adequately secure and most particularly in terms of backup power supply, air conditioning and fire protection.  A procedure should be in place to authorise access to computer facilities and authorisations issued should be reassessed from time to time. 17 Internet Rules 2.1 – July 2010
  • 18.  If the hoster is a third party, the document entitled Computer Facility Check List Standard (DSSI- STDT-014-EN) should be used to confirm the standard of security provided.  Check that security rules are in place in the administration of servers (password system policy, updating process, patch management, firewall, etc.) The checklist for contracts is available in the appendix and a paragraph deals specifically with computer security clauses. 3.5.2 Applications  If there is authentication, ensure that passwords are kept numerically and that they comply with the Password Policy in terms of complexity (see Password Policy - DSSI-PLMO-006-FR).  Ensure that developments comply with the secure development rules (see Secure Application Development Policy (DSSI-PLMO-010-FR). For sensitive web applications, such as e-business sites or ones with patient data (for example for clinical research), the following additional measures should be implemented:  An intrusion test should be run and any vulnerabilities found should be corrected before the application is used.  Personal data about patients should be kept in numerical form (especially in backups). Do not hesitate to ask your IS security manager or the DSSI to help on sensitive projects. 3.5.3 Sending information Users should be authenticated and personal information should be sent on the Internet by means of a digital protocol (SSL protocol) so that data are kept confidential. Any questions should be sent to the following e-mail address: jerome.lahalle@sanofi-aventis.com For further information and technical support, refer to the intranet http://issecurity.sanofi-aventis.com 18 Internet Rules 2.1 – July 2010
  • 19. Useful documents referred to in this paragraph (active links):  Policy on the use of passwords (DSSI-PLMO-006-FR)  Digital authentication (DSSI-PLMO-002-FR)  Secured Application Development (DSSI-PLMO-010-FR)  Computer Facility Check List Standards (DSSI-STDT-014-EN) 3.6 Accessibility It is our duty as a health business to provide an access as wide as possible to information, and especially for the disabled. The Group has thus decided to implement concrete actions to promote accessible information media. This initiative by the Group applies to all types of information: conferences, symposiums, text and multimedia publications and in particular web sites. Consequently, sanofi-aventis has made the following arrangements:  Every sanofi-aventis web site should be accessible to the disabled.  The W3C-WAI wcag 2.0 international accessibility standards (http://www.w3.org/TR/WCAG20/) are the accessibility standards Double A standard: for Group corporate information sites Single A standard: for all other Group web sites. In general, it should be noted that the accessibility criteria should be taken into account as early as possible in the project process. Likewise, it is perfectly possible to design web sites that are fully accessible, without adversely affecting visual quality or attractive or innovative graphic aspects. For detailed information on implementing these recommendations, take a look at our intranet site on accessibility: http://accessibilite.sanofi-aventis.com. You can also contact Tanguy Lohéac, accessibility expert: tanguy.loheac@sanofi-aventis.com 19 Internet Rules 2.1 – July 2010
  • 20. 4. Appendices Glossary Term Definition Domain name Name of a web site in the present case of the sanofi-aventis Internet policy. For example: sanofi-aventis.com, sanofiaventis.com and sanofi-avantis.com are three different domain names that all lead to the same web site: www.sanofi-aventis.com CCtld Country Coded Top Level Domain: country extension of a domain name. For example: sanofi-aventis.fr, sanofi-aventis.us. Gtld Generic Top Level Domain: generic extension of a domain name. For example: sanofi-aventis.com, .net, .org e-PSF E-Project Study Form: form used for assessing a project before it is built. It is used for checking that the project is in line with the Internet policy before the site is developed in any way. e-PAF E-Project Assessment Form: form describing the features of the site as regards the Internet policy requirements. It is used for assessing the web site when it is submitted to the Internet Validation Committee. HT Access Protection system that temporarily restricts access to a site by access codes. In general, its use is recommended to protect the site before it goes on-line. SSL V3 128 bit Encryption standard used for sending secure data on the web, for on-line transactions, collecting information from users and data exchange. Results in the address htpps:// For example: to be used for contact forms, registrations on an extranet by login and password. HTTPS Communication protocol used to access a secure web server. If HTTPS is given in the URL instead of the usual HTTP, the message will be sent to a secure input port on the server. Dialogue between web browser and server will then be managed with security restrictions. In particular, data exchanges will be encrypted and the web user will generally be identified. Staging Site validation environment. The site is on the Internet or on a non-Internet server and can only be viewed by people in charge of validating the site. 20 Internet Rules 2.1 – July 2010
  • 21. The e-PSF e-Project Study Form (e-PSF) If you want, you can provide a mock-up of the web site (PDF for the design) and an English translation of the Home Page and site map. ► Project Overview Project Name Country/Dept Project Leader(s) Launch date Project Objective(s) (What will the project achieve?) Project Description (How objectives will be achieved, how the project relates to other activities, etc.) Target Audience (Detail characteristics, audience size, expected number, frequency of contacts, etc.) Local Global Both Public: at large Patients Family Healthcare professionals: Practice (or mix): General practitioners Specialists Private consulting-room Hospital Pharmacists Paramedical Non-medical environment Opinion formers All Other ► Project Description Domain name Did you contact the central team at DN-Domain-names-management@sanofi-aventis.com to register your domain name? What will the final domain name of the web site be? If there are several domain names, please list them: Is the web site a partnership? Key aspects of daily management of the site Site Accessibility Open access Controlled access Open with restricted areas Site management shared with Corporate/affiliates Another laboratory Others: Mailbox management Internal External The Project’s main functionalities / Services (Detail only the most important services offered to visitors) Access to information Forum / Blog Community of interest Online education E-business Online Contact Form Main Content / Information (Primary content sources and messages to be conveyed) Company Information Pathology Product Clinical trials Other: Technical Requirements 21 Internet Rules 2.1 – July 2010
  • 22. HT Access on development environment SSL V3 128 bit (https) Other: Web 2.0 (please specify the use of Facebook, YouTube, Twitter, etc.) Constraints (internal and external deadlines, commitments, events, regulatory issues, etc.) ► Key Project Indicators Internal Resources (people, materials required during project management and online management of the site) Costs For External Providers BUDGET and Services provided: K€ / year (company name, town, country) Initial Development External Internal Content provision External Internal Updating online content. External Internal Site technical maintenance External Internal Site hosting External Internal Use of mobile tools (PDA) External Internal Statistics (specify software) External Internal Site promotion External Internal Search engine ranking External Internal Other partners (e.g. webcast): Project Development timetable (Key milestones and timetable) Site life (years) Site developments if planned (e.g. new targets or content) Project Performance Indicators (Return on Investment or other measurements, key success factors) Expected number of visitors (monthly) Expected Frequency (monthly): Frequency of content updates (yearly) 22 Internet Rules 2.1 – July 2010
  • 23. The e-PAF e-Project Assessment Form (ePAF) Please remember prior local validation is mandatory before IVC review ► Project Description Project Name Country Objective(s) Audience Targeted Project Description Main Editorial components Expected Benefits Budget (€uros) Targeted Launch date Day / Month / Year ► Access Website test version URL Login: Password: Website final URL Login: Password: If not in English, please provide attached the English version of the Home Page, site map and legal notice. ► Project Team Project Team Name Position e-mail Project sponsor Project Team Leader Project Team Members Service Providers Contacts Contact Name Company Name e-mail Telephone Site creation Site maintenance Site Hosting Content providing Website Management Contact (first, last name) e-mail Telephone Webmaster Publishing manager 23 Internet Rules 2.1 – July 2010
  • 24. ► Domain name Yes No N/A Did you contact the central team to register your domain name? (at DN- Domain-names-management@sanofi-aventis.com) Is your website a partnership (with a laboratory, patient association, scientific board…)? ► Legal Affairs Yes No N/A What is the name and function of the legal contact who validated the project is compliant with local legislation? Name Function email Contracts Have the necessary contracts been done with your suppliers (site creation, maintenance, hosting, and promotion)? Are there any other services provided by third parties in connection with the site?  Please precise the service: Is there a contract? Applicable Laws, Legal and Privacy notices Have you checked that your site comply with the applicable legislation in your country including any official requirements? Do you comply with the relevant regulations in connection with personal data protection? Have you posted a legal notice on the site (including a privacy statement) mentioning the mandatory points detailed in the Internet Rules (applicable law, site editor …) (cf. paragraph 3.2.2 of the Internet Rules)? External links Do you respect the relevant rules concerning external links:  Third-parties consent  Warning pop-up  First click responsibility Intellectual Property Rights and Copyright Do you have the necessary intellectual property rights and/or copyright to use the content of the site (text, images, photos, videos…)? Did you mention credits for photographs and videos? Have you put a copyright on your website? ► Regulatory Affairs Yes No N/A What are the names and functions of the medical and regulatory contacts who validated the project is in line with local regulations? Names Functions emails Transparency Can a visitor identify the sponsor of the site?  How and where? Can a visitor identify the target audience (country and type of audience)?  How and where? Did you validate the content of the site according to the medico-regulatory requirements of the country of the targeted audience? Do you have links to other websites?  Did you add pop up window leading to outside links?  How often have you planned to check the links? Is the page content dated? 24 Internet Rules 2.1 – July 2010
  • 25. Site Access (depending on the type of information and target) Do you provide product information to the general public? Is information on prescription-only medicines password-restricted? Is up-to-date Patient Information Leaflet readily available to the visitors? Do you provide product Information to health professionals? Is the site restricted only to health professionals? Is up-to-date Prescribing Information readily available to the visitors? Do you provide product information to the patients? Is the site password restricted to patients only? Is up-to-date Patient Information Leaflet readily available to the visitors? How does the patient get access to the site? (DTC, password provided by HCP, etc) Information on products Do you mention specific products? Do you provide advice on alternatives to treatment? Do you advise visitors to consult a healthcare professional for further information Information on clinical trials Does this site provide information on international clinical trials? Does information comply with information provided by Global Communication? Price list Do you provide a price list on the site? Was the price list approved by the appropriate person? Is it limited to price information only (do not include indication, efficacy or safety/tolerance concerns) ? Bibliography Is it complete and objective (including either favourable or possibly unfavourable articles)? Where are the selection criteria described? Interactive tool (please report to the web 2.0 guide) Is it clearly stated that interactive sessions are sponsored by sanofi-aventis? Is the access password restricted? MailBox / Contact Form Is the information about the Email sender requested by compulsory fields? Did you add an appropriate disclaimer to encourage visitors to reports adverse events according to local process in force? Have you identified internally the network in charge of answering questions? Is there an appropriate organisation to check the mailbox (at least once a day) and transfer mail to the appropriate department? ► Corporate Communication Yes No N/A What is the name and function of the communication contact who validated the project? Name Function email 25 Internet Rules 2.1 – July 2010
  • 26. Compliance with the corporate identity Did you use the graphics template for Internet communication (Corporate Guidelines and Identity – Electronic communication) (cf. paragraph 3.4.1 of the Internet Rules)? Does the logo link to sanofi-aventis web site (link to the local affiliate module or to the Corporate web site when no local module)? Content Management Are the contents of the web site in line with the Group’s values? Have you ensured that proposed links to external web sites, posted in the site, do not harm the Group’s image? Have you set up an organisation for the monitoring of the web site content? If photos/videos have been posted in the website, have you checked that they do not harm the Group’s image? ► IS Security Yes No N/A What is the name and function of the IS contact who validated the project? Name Function email Has the provider agreed to the three security clauses in the contract (paragraph 3.5.1 of the Internet Rules)? If there is an authentication or transmission of Personal Identifiable Information on the Web site, is SSL used to protect users’ credentials or data? Is the web server dedicated to sanofi-aventis? Have the providers been audited by IS Security? Has intrusion testing been done on the application? ► Accessibility Yes No N/A What is the name and function of the technical contact who validated the project is accessible? Name Function email Did you take into account accessibility requirements when building your website (paragraph 3.6 of the Internet Rules)? Did you test if your website is accessible? 26 Internet Rules 2.1 – July 2010
  • 27. DN registration request form Domain Name Registration Form to be sent to nathalie.marcy@sanofi-aventis.com and DN-domain-names-management@sanofi-aventis.com ► Information about the requestor Name Request Date email Telephone Country Department ► Domain name registration Domain Name(s) Is the DN a Any website for (please, use lowercase characters and no blank before and after the DN) Trade Mark ™? this DN? Yes No Yes No Yes No Yes No Yes No Yes No Yes No Yes No Yes No Yes No Yes No Yes No ► Website Description: if a website project is planned with the domain name(s) Website Description and objectives Website main functionalities and services Estimated Launch date Day / Month / Year Is SSL V3 128 bit (https) needed on the website? Yes No Type of information General information Product Information Online education clinical trials Interactive session: forum, blog, webinar, live Q/A… e-commerce Targeted Audience (Define characteristics, audience size, expected number, frequency of contacts, etc.) Geographic: Local Global Both Public : at large Families Patients with a prescription of the product Healthcare professionals: General practitioners or specialists Pharmacists Paramedical Opinion leaders Others Web 2.0 (please mention the use of Facebook, Youtube, Twitter,… for your project.) 27 Internet Rules 2.1 – July 2010
  • 28. DN pointing request form Pointing / domain name redirection request form (Use the Tab key to move from box to box) Applicant’s name: Telephone: E-mail: Fax: Applicant department: Country: Date of request: Pointing/redirection date: Domain name IP address if pointing Domain name if MX address: redirection Name servers AND (Use lower case without spaces before IP address and after the domain name) E.g.: www.mydomain.org 125.25.33.12 Ns1.dn.ec mydomain.org 125.25.33.12 256.255.33.10 www.mydomain .com www.mydomain.org ___________________________ __________________ _____________________ _________________ Comments: 28 Internet Rules 2.1 – July 2010
  • 29. Check-list for contracts This summary is only indicative to recap on the major clauses in agreements. It is not in any way complete and should clearly be adapted in each country in accordance with the legislation applicable.  Site design contract: The contract should cover all stages of the site design, from the audit of needs through to overall quality control on going live. It is essential that a site can be run entirely independently, and that the service provider involved in creating it does not claim ownership of it. A web site includes creations that are or can be protected as intellectual property. These rights, detailed in the contract, will be transferred to sanofi-aventis by the service provider on completion of the project. The list of rights to be transferred is given below in the intellectual property clause. In addition, guarantees should be provided in the contract to cover us in the event of content in breach of the law or unfair competition.  Accessibility clause: every site design contract should include a clause covering accessibility. This is because all new web sites should be accessible to the disabled. So that the site complies, it is necessary to specify at least compliance with the “silver” level quality standard. This standard consists of a set of criteria on the content and structure of web pages.  Intellectual property clause: the purpose of this clause is to ensure that all intellectual property rights are transferred, either by acquisition or by concession (the period and territory should be specified). This clause should detail all rights that are expressly transferred, because everything not expressly transferred remains with the owner, such as: o Right to reproduce or have reproduced, o Right to disclose, dispose and transfer, o Right to represent or have represented, o Right to adapt, alter and translate. o Right to copy, represent and incorporate, in full or in part, with or without a change of interface, o Right to publish, either directly or indirectly, by any electronic means or by telecommunication, on any existing or future medium, on-line or off-line o Rights specific to the producer of databases. o Right to correct and develop. Likewise for design documents. The media concerned should also be listed, for example such as the Internet or any other present or future medium. The cost of transferring all rights should be included in the overall price of service.  Dispossession guarantee clause: this clause covers the service provider’s intellectual property rights. It guarantees that all intellectual property rights that it owns have been duly acquired and that they are not in breach and/or are not obtained by unfair competition or pirating. In the event of an action for breach, the service provider undertakes to guarantee us untroubled enjoyment of the result of its service by paying all charges or costs due to any legal action and undertakes to find a replacement solution for sanofi-aventis.  Maintenance contract: The maintenance contract covers the various components of the site for which you must own intellectual property rights enabling you to make corrections and changes to the site.  Clause on definitions: Technical definitions in the contract should be clear and universally understandable. In particular, the term “fault” should be clearly defined, with different graduations (major fault / minor fault), which will subsequently enable the service provider’s work to be governed.  Clause on maintenance content: this clause should be carefully scrutinised, to detail what services the service provider is committed to providing, namely developmental, corrective, 29 Internet Rules 2.1 – July 2010
  • 30. curative and preventive maintenance. Attention should be paid to what the service provider excludes.  Response time clause: check that the response time is clearly stated in accordance with the level of criticality of the fault. Also check its starting point, which most often is when the fault is reported to the service provider.  Clause on penalty for delay: the purpose of this clause is to encourage the service provider to meet the standards of service or deadlines that the service provider is committed to. It will have the effect of obliging the service provider to pay a certain sum of money in the case of late performance or non performance of its undertakings. The starting point for penalties for delay, the calculation basis and the length of time late should be precisely defined and calculated to ensure that the amount is not derisory. It is preferable that penalties relate to a precise undertaking rather than to all the host’s obligations.  Correction and work-around solution clause: this is the possibility for the service provider to offer its customer a temporary work-around solution so that the customer can continue to run the program. This solution should be temporary and the service provider must then repair the program so that it runs as intended.  Hosting contract: Relations with the site host should be covered by contract. It is essential first to draw up a pre-contract specification for an audit of the service provider.  Host’s liability clause: particular attention should be paid to the limits of liability so as to be covered in the event of damage in particular if the service provider hosts important sanofi- aventis sites.  Clause on penalty for delay or penalty for non-compliance with service level undertakings: see what was said for the maintenance contract.  Site availability clause: include a clause of this type so that users have access to the site, taking into account hardware and software maintenance periods necessary for the service provider. The access can be specified in the contract in the form of an availability rate.  Clause on personal data: a clause should be included where the host acknowledges that personal data collected are confidential by nature. It should not under any circumstances keep it, use it, disseminate or communicate it for its own purposes. This clause should be revised in accordance with current local legislation.  Reversibility clause: this gives Sanofi-aventis the option of hosting the site in-house or of having it hosted by a third party. This clause should specify a reversibility plan detailing in advance essential points such as timing, costs, tasks and payment.  Security clauses (see §3.5): ask the host to commit on systems updates and enabling the sanofi-aventis IS Security department to run regular vulnerability scans with a view to checking that there are no known weaknesses. Lastly, there should be clauses allowing sanofi-aventis to conduct security audits at the host:  Security upgrade clause The service provider agrees to regularly upgrade and maintain the security of its networks, servers, systems and applications, in compliance with the recommendations by software publishers and hardware manufacturers supporting the service.  Security audit clause The service provider agrees that security audits will be conducted on its networks, servers, systems, applications and procedures, supporting the service, on request by sanofi-aventis, and undertakes to implement recommendations that may be made as soon as possible. 30 Internet Rules 2.1 – July 2010
  • 31.  Clause on periodic vulnerability analysis In the case of a service accessible on the Internet, the service provider agrees that vulnerability analyses will automatically be conducted regularly on its systems and applications, supporting the service, and undertakes to implement recommendations that may be made as quickly as possible.  Site promotion related contracts  The listing contract: it is necessary to ensure that no third party names are used for listing, or there may be liability for breach.  The advertising space purchase contract: this type of transaction should also be covered by an agreement with the advertiser or agency.  Similarly, any promotional activity with a third party should be governed by contract (e- mailing, viral marketing campaign, launch via social networks, etc.)  Partnership contracts  Hyperlinks enabling one web page to be connected to another, either within the site, or outside. Before creating a link with a site, it is first necessary to get the agreement of the publisher of the other site.  Content is often exchanged or combined in “co-sponsoring” or “co-branding” form with a section of the partner’s site. Content is identifiable as coming from the partner’s site. A link enabling Internet users to go directly to that content  The affiliation contract which enables routing from partner or affiliated sites is also possible. In general, it is necessary to pay attention in all agreements to the liability clause. In it, if a limit on liability is set, it should cover damage attributable to the service provider in performing the contract. As this list of clauses and contracts is only indicative, contracts should always be validated by the usual legal experts, who may add to them if necessary in accordance with current local legislation. 31 Internet Rules 2.1 – July 2010
  • 32. The consent request email for links When a site belonging to sanofi-aventis offers Internet users a link to a third party site, a prior consent letter should be sent to the administrator of the third party site. The letter can be in the following form: “Sanofi-aventis publishes and operates the (name of your web site) web site, which deals with (description of your web site, general content, positioning, target). We would like to provide a link to your web site (name of the third party web site). To do so, we need your consent for the following: - Conditions applicable to the link: (state the section hosting the link, simple link or link with description of the pointed web site, use of the third party logo, update of the link) - Period of validity of the link: (state the period) - When Internet users click the link, a pop-up window appears to warn them that they are leaving our web site and are being routed to yours (and also states that we are no longer responsible for the information provided). If you do not reply within two weeks, we shall assume that you agree with this pointing arrangement. Please feel free to contact us if you have any questions or need further information about our web site or this procedure. 32 Internet Rules 2.1 – July 2010
  • 33. Site exit pop-up  The linked web site to belongs to sanofi-aventis and complies with the various rules and regulations Example for the United States: 33 Internet Rules 2.1 – July 2010
  • 34. The linked web site does not belong to sanofi-aventis Example of the Lantus web site in the United States: 34 Internet Rules 2.1 – July 2010
  • 35. Example of terms and conditions Terms mentioned in red should be replaced and adapted to your site. Terms mentioned in grey are advisory, given for drafting your terms and conditions, and should be deleted in the final version. Terms and conditions should be validated by your local legal department. This page describes the terms and conditions that apply to all Internet users visiting this site. By consulting them you unconditionally undertake to comply with them. As terms and conditions may be amended at any time, without prior notice, we advise you to consult them regularly. 1. Intellectual property This site belongs to and is operated by name of the sanofi-aventis subsidiary, (hereinafter “sanofi-aventis”) belonging to the sanofi-aventis Group. The layout and each of the components, including trademarks, logos and domain names, appearing on the site name and url of the site (hereinafter the "Site"), are protected by current laws on intellectual property, and belong to sanofi-aventis or its subsidiaries, or their use is the subject of an authorisation. No component of the Site may be copied, reproduced, altered, edited, downloaded, denatured, transmitted or distributed in any way whatsoever, on any medium whatsoever, in whole or in part, without the prior written consent of sanofi-aventis, except solely for use for press requirements conditional on compliance with intellectual property rights and any other property rights that are mentioned. Only copying for private use is authorised for your own personal, private, non-commercial use, on your personal computer. The following statement should appear on any authorised copy of all or part of the content of the Site: "COPYRIGHT year the site was created – current year - name of the sanofi- aventis subsidiary - ALL RIGHTS RESERVED". Any authorised use of items composing or shown on the site must not be denatured, changed or altered in any way whatsoever. Sanofi-aventis or its subsidiaries reserve the right to take legal action against any breach of its intellectual property rights. 2. Nature of information Information, especially financial, published on the Site shall not be considered as an encouragement to invest. It should not under any circumstances be interpreted as prospecting or as a public offering, nor is it an offer to subscribe, buy or swap shares or other securities in sanofi-aventis and/or its subsidiaries concerned. Sanofi-aventis draws 35 Internet Rules 2.1 – July 2010
  • 36. your attention to the fact that financial information posted on the Site is regularly updated (if financial information is provided on-line). The Site may offer opinions by experts consulted in a particular field in relation to the content of the Site or excerpts from press articles. Any such information solely represents the opinion of the expert consulted or the publication, and is not necessarily the opinion of the sanofi-aventis Group. Any such experts are not employees of the sanofi-aventis Group and do not receive any emoluments in exchange for sanofi-aventis using their opinion. Sanofi-aventis is not responsible for the accuracy or completeness of any such information and opinions. Experts’ opinions reflect their own personal views and should never be interpreted as being the opinion or responsibility of sanofi-aventis. The Site also includes information on health, physical condition, the medical field and medical treatments solely for human use. Said information is published on the Site for information purposes only and is no substitute for the advice of your physician or pharmacist. The information should not be used under any circumstances to make a medical diagnosis of an illness or physical problem, or for prescribing or using drugs presented on the Site. In all instances you should refer to your physician or pharmacist. 3. Links to other sites The liability of sanofi-aventis or of the sanofi-aventis parent company shall not be incurred by a third party site that can be accessed via the Site. We do not have any way of controlling the content of such third party sites which remain entirely independent of sanofi- aventis. Moreover, the existence of a link between the Site and a third party site does not under any circumstances mean that sanofi-aventis approves the content of that site in any way whatsoever and in particular the use that may be made of it. In addition, you are responsible for taking the precautions necessary to prevent any infection from the Site, in particular by one or more computer viruses, Trojan horses or any other "parasite". External sites may include hypertext links to the Site. Any such links should not be created without the express prior consent of sanofi-aventis. In any case, sanofi-aventis is not in any way liable for the non-availability of such sites and sanofi-aventis does not scrutinise, check or approve them and is not responsible for contents, advertising, products or other components available on or via those sites. 4. Personal information and other information 4.1 Sanofi-aventis will not disclose to third parties personal data about you that you may convey to it by e-mail. It will only be used with a view to providing you with an answer as effectively as possible. 36 Internet Rules 2.1 – July 2010
  • 37. If there is a law on personal data protection in your country, you should complete and mention the following paragraph: In accordance with local legislation “give the name, number and references of the law in force”, you have the right to access, alter, rectify and delete personal data that concerns you. To do so, request as follows: On-line: the webmaster’s address Ensure that the mail box mentioned is active and that its holder checks it daily. If possible, do not give the e-mail address of a sanofi-aventis employee, prefer generic addresses of “webmaster@mysite.com” type By post: physical address of the subsidiary or department 4.2 The Site is not intended to receive confidential information from you. Consequently, and except for personal data mentioned above, any information, whatever its form - document, data, graphic, question, suggestion, concept, comment or other - that you send us via the Site will not under any circumstances be deemed confidential. Consequently, the act of sending it to us alone gives us the right to use it, reproduce it, publish it, alter it or send it with a view to dealing with your request. 5. Limitations on liability Sanofi-aventis strives to the best of its ability to ensure that information published on the Site is accurate and up-to-date. It reserves the right to correct content at any time, without prior notice. However, sanofi-aventis cannot guarantee that the information available on the Site is accurate, correct, up-to-date or complete. Consequently, and except for property damage resulting from gross or intentional negligence by sanofi-aventis, the group declines any liability:  for any inaccuracy, error or omission as regards information available on the Site;  for any damage resulting from fraudulent intrusion by a third party resulting in an alteration of information or items made available on the Site  and more broadly, for any property damage or consequential loss, for any reason, of any origin, nature or with any consequences whatsoever, even if sanofi-aventis had been warned of the possibility of such damage or loss, caused (i) because of any access to the Site or because it was impossible to access it, (ii) because of the use of the Site, including any harm or virus that may infect your computer or any other property, and/or (iii) because of the credence given to any information coming directly or indirectly from the Site. 37 Internet Rules 2.1 – July 2010
  • 38. The components of the Site or of any other site are provided "as is" without any guarantee of any kind, whether implicit or explicit. Sanofi-aventis does not offer any implicit or explicit guarantee, relative, without limitation, to their market value or suitability for any given purpose. 6. Availability of the web site You acknowledge (i) that it is technically impossible to provide the Site free from any defect and that sanofi-aventis cannot undertake to do so; (ii) that defects may lead to the Site being temporarily unavailable; and that (iii) operation of the Site can be affected by events and/or matters that sanofi-aventis does not control, such, for example, as means of transmission and communication between you and sanofi-aventis and between sanofi- aventis and other networks. Sanofi-aventis and/or its suppliers may, at any time, alter or interrupt, temporarily or permanently, all or part of the Site to undertake maintenance and/or make improvements and/or changes to the Site. Sanofi-aventis is not responsible for any alteration, suspension or interruption of the Site. 7. Information on products Information included and published on the Site may include direct or indirect references to products, programmes and services of the sanofi-aventis Group that are not announced or available in some countries or some regions or that may be supplied under a different name and may be subject to regulations and terms of use that differ depending on the country. Such references do not mean that the sanofi-aventis Group intends to sell those products, programmes or services in your country. Refer to the local sanofi-aventis Group subsidiary or your sanofi-aventis Group sales partner for any information about the products, programmes and services available to you. 8. Legal provisions The Site and its content are governed by the Laws of name of country, and any disputes relating thereto are subject to the jurisdiction of the courts of name of country. 9. Terms and conditions 9.1 Publisher of the Site: This is the subsidiary 38 Internet Rules 2.1 – July 2010
  • 39. Physical address of the subsidiary or department Name of the sanofi-aventis subsidiary is a joint stock company with capital of amount of capital, listed in the name of the register for your country and company number. 9.2 Head of Publication: This is the person in charge of validating the contents, the editorial line, etc. Depending on the site, it may either be the Head of Communication, or the Marketing Manager, or the Medical Manager, or sometimes the Product Manager. Name and surname of the Head of publication 9.3 Site hosting: Name and address of host 10. Photo / video credits: This is the name of the photographer or agency List credits and copyright for photographs, images and videos used on the site 39 Internet Rules 2.1 – July 2010
  • 40. The Contact Us page Contact pages should be a form with predefined fields. Direct “mail to” links are not allowed. 40 Internet Rules 2.1 – July 2010
  • 41. Contact Us pages should include a form for Internet users to fill in before posting their comment and/or question. They should be secure by https. They should also state that they are not intended for receiving adverse event notifications (and propose an alternative way). The form can include the following items  Choice General public/physicians (required field)  Title  Surname (required field)  Name (required field)  Company  E-mail (required field)  Address  Post code  Town  Country  Telephone (required field)  Subject  Message (required field) 41 Internet Rules 2.1 – July 2010
  • 42. The graphic charter applicable to all sanofi-aventis product and/or theme sites The logo block at the top of the page of a product and/or theme site is positioned as follows: - At the top right of the page only use the logo (sanofi-aventis name with graphics and smile). - Positioning in the specified horizontal “silhouette” form 42 Internet Rules 2.1 – July 2010