Modern Slavery Statement
Alliance Pharma PLC and its subsidiaries (the “Company” / “Alliance” / “We” / “Group”) is committed to improving its practices to combat slavery and human trafficking.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Alliance’s statement on slavery and human trafficking for the financial year ending 31 December 2019.
OUR BUSINESS AND STRUCTURE
We are an international healthcare group. The Group owns or licenses the rights to more than 90 pharmaceutical and consumer healthcare products.
Headquartered in the UK with affiliate offices in Europe, the Far East and the US and wide international reach through an extensive network of distributors, Alliance sells its products in more than 100 countries.
Alliance Pharma PLC is the ultimate parent company of the group, with its shares listed on the Alternative Investment Market of the London Stock Exchange. Alliance has operating affiliates incorporated in the UK, mainland Europe, Hong Kong, China, Singapore and the USA.
OUR SUPPLY CHAINS
Our supply chains include:
- Raw material/API suppliers
- Componentry suppliers
- Contract manufacturers
- Freight forwarders
- Warehouse storage
OUR POLICIES ON SLAVERY AND HUMAN TRAFFICKING
In keeping with our PRAISE values, many of our policies assist with the ongoing prevention of modern slavery or trafficking in our business.
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Anti- Slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.
Our Ethics and Business Integrity Policy sets out the behavioural standards expected from all individuals when representing the organisation, which demonstrates our commitment to maintaining the highest standards of professional and ethical conduct throughout the business and in managing our supply chain. The guidelines detailed in the code apply to all Alliance personnel, whether permanent or on fixed term contracts and includes agency workers, contractors and directors.
Under Alliance’s Anti-Bribery and Corruption Policy we see the business commit to the highest standards of ethical conduct and integrity in its business activities in the UK and overseas and this commitment is set out in the organisation’s Anti-Bribery and Corruption Policy. Alliance has a zero-tolerance approach to any form of bribery by its employees, agents or consultants or any other person or body acting on its behalf.
The Whistleblowing Policy encourages an environment of accountability and integrity. Alliance and its Whistleblowing Policy offers all employees a confidential process through which complaints can be raised within the organisation in the knowledge that they will be taken seriously and dealt with in an appropriate and professional manner.
DUE DILIGENCE PROCESSES FOR SLAVERY AND HUMAN TRAFFICKING
As part of our initiative to identify and mitigate risk we have in place systems, including the use of external due diligence advisers, to:
• Identify and assess potential risk areas in our supply chains.
• Mitigate the risk of slavery and human trafficking occurring in our supply chains.
• Monitor potential risk areas in our supply chains.
• Protect whistleblowers.
Alliance believes that the quality of our partners in the supply chain, is a good measure of how those partners view the importance of the fight against modern slavery. An ethical supplier, in terms of quality, safety and efficacy of products, is a good indicator of the ethical stance of such third party on matters such as compliance with Anti-Modern Slavery legislation and practices.
As such, Alliance ensures the Quality, Safety and Efficacy of its products through compliance with applicable legislation, regulation and standards in every territory in which it does business. These regulations cover all activities carried out by the Group from pre-approval (product and facility design), through gaining authorizations to market products (clinical safety and efficacy) to post-market surveillance (complaints and vigilance).
All Alliance facilities, processes and personnel are subject to a continuous self-assessment audit programme to ensure that compliance is maintained, in addition to being subject to frequent audits and inspections by, or on behalf of, supra-national, national and regional governmental regulatory authorities.
All suppliers, distributors, consultants and other companies whose activities may impact the quality, safety or efficacy of our products undergo a formal assessment for compliance prior to being approved to operate with or on behalf of Alliance and once approved, they continue to be subject to and / or documentary assessment to ensure continued compliance with the legislation, regulation and standards applicable to their own processes, facilities and personnel.
SUPPLIER ADHERENCE TO OUR VALUES AND ETHICS
All of Alliance’s new supplier contracts include applicable Modern Slavery Act warranties and undertakings. We demand that all new suppliers acknowledge their responsibilities to operate in a manner that is free from modern slavery and human trafficking practices. In the event that Alliance was to have any concerns related to its partners (whether this be distributors or suppliers) it would, in the first instance, seek to understand and resolve these concerns and if it were unable to do so, it would cease to work with such partner.
We have zero tolerance to slavery and human trafficking. As part of our ongoing commitments, in 2020, we continued with the review of our enforcement processes and “know-your partner” projects, to ensure all those in our supply chain and contractors comply with our values. This review involves a process where representatives from the following departments have worked together to ensure compliance with our values and policies, including the auditing of our suppliers:
- Quality; and
Out of the review process which took place over the last 12 months, the decision was taken by Alliance to engage an independent third-party agency to provide enhanced onboarding due diligence of new suppliers, as well as ongoing monitoring of suppliers.
ALLIANCE STAFF AND TRAINING
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to our employee. Annual desktop training is provided to assist with the understanding and identification of modern slavery and human trafficking.
In respect of agency workers, Alliance only engages with reputable employment agencies in relation the engagement of temporary or contract personnel.
OUR EFFECTIVENESS IN COMBATING SLAVERY AND HUMAN TRAFFICKING
As part of our current review process around the robustness of our processes, we continue to monitor and assess the appropriateness of the use various key performance indicators (KPIs) to measure how effective we are and have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains. Due to the unprecedented impact of the Covid-19 pandemic during 2020 and beyond, legal restrictions have hampered our ability to conduct physical inspections of our suppliers. Whilst we have not been able to make any site visits, we have continued to ensure that our vetting and screening processes have been robustly utilized and enforced, with no reported issues having caused the Group to reject any suppliers. Formal annual training of relevant employees remains a requirement, as well as “on the job” training through the year from peers.
Once permitted by applicable laws, the Group will carry out site-visits on a risk based approach and we anticipate being able to continue to utilise all of the following measures in its efforts to combat Modern Slavery within its supply chain:
- Vetting and screening of third-party suppliers/partners at the time of onboarding.
- Subcontractor site inspections both on an ad-hoc and scheduled basis.
- Whistleblowing procedures being widely communicated and effectively implemented.
- Training for relevant employees in key functions.
- Remedial action if any issues are identified.
The Board of Alliance continues to work with management to ensure the business is effective in combatting slavery. As such, the Board, having established a formal ESG Committee at the start of 2021, has including Anti-Modern Slavery as one of the areas which the committee has responsibility for. In the last 12 months:
- No slavery or human trafficking issues have been identified;
- No reports were made under the Modern Slavery Act Policy or under the Whistleblowing Policy with respect to modern slavery and human trafficking;
- No remedial actions have been required.
Due to the unprecedented impact of the Covid-19 pandemic during 2020 and beyond, legal restrictions have hampered our ability to conduct physical inspections of our suppliers. As such and following a review of the effectiveness of the steps we were able to take over the last 12 months to ensure that here is no slavery or human trafficking in our supply chains, we have begun the roll out of the following enhanced steps to combat slavery and human trafficking, with the aim of ensuring these are fully adopted by the end of 2021:
- External assistance with the monitoring of annual written confirmation from our suppliers of their internal procedures and training, and compliance with our policy;
- Site visits to suppliers, on a risk based annual approach; and
- Enhanced training for key individuals over and above the current annual training.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Group’s slavery and human trafficking statement for the financial year ending 31 December 2020. It was approved by the board on 19 March 2021.
Chief Executive Officer