Introduction from Alliance’s CEO
We pride ourselves in delivering clinically valuable healthcare products to consumers and patients around the world – products which enable people to lead healthier lives, either through the treatment of existing conditions, or through promoting wellbeing through prevention.
We see this as both a privilege and a responsibility – a privilege because we’re actively making a difference to people’s lives and a responsibility to ensure that we can continue to do so in the future. In recognition of this, we strive to maintain the highest standards of professional and ethical conduct throughout the business and in managing our relations with all our stakeholders.
Maintaining the sustainability of our business for the longer term requires us to work together to ensure that we continue to uphold the ethical business practices which underpin our business and on which our stakeholders trust in Alliance is based. We need to work hard to maintain our reputation for being a Responsible Business – one that acts with integrity, which respects and values the relationships that we have worked together to build over the past 20+ years - our relationships with our suppliers and distributors, with our colleagues, with our shareholders and other stakeholders - and most importantly, with the consumers and patients who rely on our products to improve their health and wellbeing.
In this section, we look to bring together our key business principles - the underlying policies and practices which set out how we do business. It is these policies and practices, together with our values-based culture, which form the basis of our approach to Responsible Business, and which help to ensure that we can maintain our reputation as we continue to build the sustainability and resilience of the business in the years ahead.
Peter Butterfield, CEO
We have long recognised that our relevance and value is in how we work together, both with our colleagues and with our customers, suppliers, and other external stakeholders. As such, the success of our business is underpinned by our strong collaborative culture.
Our culture is founded on our core values – in particular, the values of Accountability (taking responsibility and delivering what we promise) and Integrity (building trust in all our relationships through openness and fairness) remain at the heart of how we engage with each other and underpin how we conduct all our external business relationships.
Whilst our policies and procedures provide the framework for how we conduct ourselves and our business activities, it is this strong, values-based culture and the ethical approach embodied within it, which encourage us all to ‘do the right thing’ from an ethical perspective as we go about our day-to-day business activities.
Product Quality and Safety
We work hard to ensure the quality, safety and efficacy of our products and maintain reliable supplies. Maintaining the trust of our customers depends on it.
We are committed to ensuring that all our products meet the highest standards of safety and efficacy and that we remain fully compliant with all applicable regulations. Our quality assurance systems and processes aim to provide an appropriate level of confidence that suppliers, vendors and contractors are able to supply consistent quality of materials, components and services in compliance with regulatory requirements and to identify and mitigate any associated risks. All our contract manufacturers are expected to comply with appropriate external quality standards, such as EU GMP1, ISO 13485, ISO 22716 and GPvP2, and to hold appropriate third-party authorisations, e.g., MIA3 for medicines, issued by a competent authority.
The nature of our business means that we are frequently subject to inspections and audits from a number of government bodies to ensure that we remain compliant with the authorisations we hold to support those aspects of our supply chain which we are directly involved with. We wholeheartedly welcome these and always commit to providing prompt, accurate and complete responses to associated requests for information.
1 Good Manufacturing Practice
2 Good Pharmacovigilance Practice
3 Medical Industry Accredited
Responsible Marketing, Advertising and Sales Practices
Alliance is committed to ethical business practices regarding the marketing, advertising, and sales of our brands, and we have robust standard operating procedures in place to achieve this, with comprehensive training for all compliance staff, to ensure our activities comply with the appropriate standards and legislation.
Ultimately this provides reassurance for healthcare professionals, patients and consumers regarding the integrity of Alliance’s brands.
Through our membership of key trade associations such as the Association of the British Pharmaceutical Industry (ABPI), the Proprietary Association of Great Britain (PAGB) and the Association of the British HealthTech Industry (ABHI), we are able to stay at the forefront of continually evolving compliance legislation.
Our processes are regularly audited and refined to ensure continued compliance with relevant internal and external regulatory requirements.
Privacy and Data Protection
We are committed to safeguarding the privacy of your data that we may collect on our websites, from third parties, or when you otherwise interact with our business. As part of the day-to-day operation of our business we use personal data in relation to individuals who are not employed in our group for the following: (i) Marketing of our products; (ii) Fulfilling orders placed with us for our products; (iii) Assisting with customer queries or reports of problems relating to our products (including adverse events) and keeping records required by law; and (iv) Dealing with applications for employment. We work hard to ensure compliance with all applicable laws and regulations relating to the collation, processing and retention of personal data. Annual training is provided to all employees on data protection (including the requirements of GDPR) and as a business we periodically audit our operations to ensure that we have the relevant systems and checks around the collation, processing and retention of data.
Diversity and Inclusion
Alliance operates in 9 countries around the world, embracing the differing perspectives and diversity of thought that people from different backgrounds and geographies can bring in addressing the challenges we face as a global business.
We are committed to equality of treatment for all employees, and those seeking employment with the Group, regardless of gender, marital status, race, ethnic origin, colour, nationality, national origin, disability, sexual orientation, religion or age, geographical origin, social status, or area of abode. The Group is committed to complying with all current legislation concerning unfair discrimination and to encouraging good practice in equality of treatment. In furtherance of this commitment, Our Equal Opportunities Policy Statement, sets out our commitments, and the expectation we have of all our employees to ensure we treat others with fairness, respect, and integrity.
Engagement with Healthcare Professionals
Alliance is committed to providing transparency and clarity around our collaboration with healthcare professionals, healthcare organisations and patient organisations. In the UK and Republic of Ireland, Alliance publishes transfers of value in accordance with the ABPI and IPHA Codes of Practice.
Anti-Bribery, Corruption, Fraud and Anti-Tax Evasion Facilitation
It is our policy to conduct all business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships, wherever we operate, and to implementing and enforcing effective systems to counter bribery and corruption.
Alliance has an anti-bribery and corruption policy, designed to assist in the prevention of bribery and corruption by or involving the Group’s employees. The policy provides guidance both to the Group and its employees and contractors, with respect to their respective obligations and potential liabilities under applicable laws and regulations including the Bribery Act 2010. All employees and contractors are expected to comply with this policy.
We do however recognise that, as part of our wider business operations, there may of course be occasions where we need to offer actual or potential customers things of value, such as free samples of our products. In these circumstances, we will carefully assess any such gestures to ensure that they are sensible and proportionate.
Alliance does not make and/or accept/request any form of improper payments, and we have procedures in place to help employees identify potential facilitation payments. Employees undergo annual refresher training on Anti-Bribery, Corruption, Fraud and Anti-Tax Evasion Facilitation and as part of our internal policies, all employees are required to report any requests or offers of improper payments which are either made to them or which they become aware of.
Alliance has in place policies to allow it to adhere to applicable legal requirements including the UK Bribery Act, the US Foreign Corrupt Practices Act, and the UK Criminal Finances Act.
Protection of the Group’s Assets
All employees are required to protect and/or use the Group’s assets sensibly, including all equipment which is made available to them to allow them to carry out their duties, such as computers, telephones & electronic devices. We are all collectively responsible for ensuring that our facilities, data, systems, money, and intellectual property are protected, and to this end the Group has appropriate internal policies in place to govern the use, operation, and protection of the same.
Acceptable use policies are in place in respect of our IT systems – our employees, contractors or agents who have access to our IT systems are bound by our acceptable use policies which demand that our Group IT is not used for inappropriate, sexually explicit, derogatory, or otherwise offensive jokes or statements, or to conduct any business for any other organisation. Subject to the local laws and regulations, our acceptable use policies may permit sensible incidental use of our IT systems by our employees for personal matters, with the proviso that it does not interfere with the performance of their role or the business.
All Alliance employees share in the collective success of our business through our share options scheme. As a public company, we have in place an appropriate Share Dealing Policy which applies to all employees and covers the dealing in the Company’s shares (including the exercise of share options and sale thereafter of the shares derived from them which may be granted to our employees). The Share Dealing Policy includes guidance on the Market Abuse Regulation and “price sensitive information”, as well as the procedures for seeking consent to deal in the Company’s shares. All employees are given and induction by the Legal Department on the Market Abuse Regulation, “price sensitive information” and share dealing, as well as undergoing annual desktop refresher courses.
The Group operates a formal Whistleblowing Policy and procedures, which offers all employees access to a confidential forum in which it is possible to raise concerns about potential and perceived improprieties. The process is managed by the Company Secretary, who is the Whistleblowing Officer for the Group. In certain circumstances, provided it is appropriate to do so, Human Resources may also be involved in concerns which are raised. The outcomes of any investigations carried out in accordance with the Policy are reported to and reviewed by the Audit and Risk Committee, as well as to the employee who has raised the issue.
Conflicts of Interest
Conflicts of interest may arise when two or more competing interests could impair one’s ability to make objective or unbiased business decisions. Conflicts of interest may take the form of financial interests in a competitor, supplier or customer business, recruiting a close family member, close or longstanding friendships or relationships with competitors, suppliers or customers or engaging in employment outside Alliance.
Our policies require our employees, business partners, suppliers, agents and anyone else working on behalf of Alliance to disclose or seek direction on any issues that could potentially conflict with their responsibilities to Alliance. Pursuant to our policies, we require all cases of potential conflicts of interest to be disclosed to Alliance, discussed openly and recorded, and appropriate actions are taken to manage any potential impact on Alliance of the same. Annual updates on the status of any such conflict is required.
We are committed to ensuring that we and those whom we deal with respect human rights and all applicable laws and regulations relating to the same. Alliance has an anti-slavery and human trafficking policy, designed to promote compliance with the UK Modern Slavery Act 2015, which provides guidance to employees, contractors and other business partners on slavery and human trafficking.
We are committed to ensuring there is transparency not only in our own business but also in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. The measures taken by Alliance to tackle any slavery and human trafficking in its business and its supply chains are described in our annual Modern Slavery Statement.
We expect the same high standards from all of our contractors, suppliers, and other business partners, and as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.
We are constantly striving to evolve our supply chain to ensure that our partners not only commit to comply but actually comply with our Anti-Modern Slavery Policy. We use a number of external research tools to allow us to monitor the publicly available information relating to our partners and continue to evolve or methods of auditing our partners.
We recognise that everything we do has an impact on the natural environment and on the people and communities within it and we are committed to looking for ways to reduce our impact in these areas to ensure a better future for all.
From ongoing environmental improvements to our HQ building, to increasing the level of assurance around our supply chain, and the ethical business considerations which underpin these relationships, we’re committed to operating our business in a sustainable and responsible way.
We are constantly striving to evolve our supply chain to ensure that we can effectively source materials from more responsible suppliers. We expect our suppliers to adhere to the same high standards that we aspire to and ensure their activities are conducted as far as possible in a manner that protects the environment and the resources being utilised.
Health and Safety, Working Environment
We believe that good health and safety practices are an integral part of achieving our aims as a business. We are committed to continuing to provide a healthy and safe working environment for all our employees around the world, as well as all contractors, visitors, customers, and the public with whom we work with. We comply and monitor for changes in all applicable laws and regulations and, where necessary, take appropriate actions to minimise any risks identified.
Alliance promotes a culture which promotes a collective responsibility, and this is embodied in our value of Accountability – all our employees are expected to remain accountable for behaving safely when discharging their obligations, including complying with all applicable working procedures and safe working practices. It is the responsibility of all employees, and those working with us, to take steps to prevent accidents, to be attentive to safety and to report hazards, injuries or behaviours and practices that may cause harm.
Corporate Social Responsibility
Alliance has always been a strong and consistent supporter of the wider community and we are committed to making a difference in the communities in which we operate. We encourage participation in and support for charitable and humanitarian organisations, through activities such as our values-based PRAISE awards to employees, which give recipients the opportunity to nominate a charity to receive a cash donation, to our volunteering days, fundraising activities, and product donations, which support both local and international charities.