Modern Slavery Statement
Alliance Pharma PLC and its subsidiaries (“Alliance” / “We” / ”Our”/ “Group”) is committed to ensuring that there is no modern slavery or human trafficking in any part of our business including our supply chains .
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 2022.
OUR BUSINESS AND STRUCTURE
We are a growing consumer healthcare company. Our purpose is to empower people to make a positive difference to their health and wellbeing by making our trusted and proven brands available around the world.
We deliver organic growth through investing in our priority brands and channels, in related innovation, and through selective geographic expansion to increase the reach of our brands. Periodically, we may look to enhance our organic growth through selective, complementary acquisitions.
Headquartered in the UK, the Group employs around 285 people based in locations across Europe, North America, and the Asia Pacific region. Our model is to outsource our manufacturing and logistics.
Alliance Pharma PLC is the ultimate parent company of the group, with our shares admitted to trading on the AIM Market of the London Stock Exchange. Alliance has operating affiliates incorporated in the UK, mainland Europe, Hong Kong, China, Singapore, Thailand, Philippines, India 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 detection and prevention of modern slavery or trafficking in our business.
We are committed to ensuring that there is no modern slavery or human trafficking in any part of our business including our supply chains. Our Anti-Slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to continuing to work to implement and enforce effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.
Our Employee Code of Conduct sets out the behavioural standards expected from all individuals when representing the Group. The code includes a section on the detection and prevention of modern slavery. 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.
Our Partner Code of Conduct, applicable to all external contracting parties providing goods and services to Alliance (including our distributors), makes explicit reference to Alliance’s expectations around the detection and prevention of modern slavery in our partners’ workplaces and supply chains.
Under Alliance’s Anti-Bribery and Corruption Policy we see the business commit to the highest standards of ethical conduct and integrity in our 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 our employees, agents or consultants or any other person or body acting on our behalf.
Our Speak-Up Policy encourages an environment of accountability and integrity. Alliance and its Speak-UP Policy offers all employees and contractors a confidential process through which concerns can be raised within the organisation in the knowledge that they will be taken seriously and dealt with in an appropriate and professional manner. In 2022, Alliance partnered with Safecall, an independent third-party helpline, to enable employees, partners, and the general public to report (including on an anonymous basis) any concerns about Alliance’s practices, including any modern slavery concerns.
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 and software platforms, 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.
In 2022, we engaged a compliance expert to conduct a review of both our know your client/know your supplier due diligence providers and adverse media event reporting and escalation.
All Alliance’s pharmaceutical products (and their components) comply with Good Manufacturing Practice (GMP) rules. To be GMP compliant, manufacturers must follow strict rules regarding the quality of (a) products they produce, (b) their facilities and (c) their employees. Alliance itself carries out regular site visits and compliance (including modern slavery) checks on our manufacturers and their facilities, which are in addition to periodic inspections (on a risk assessment basis) by government regulators to check they are GMP compliant, including regular site visits to sites of our direct supplier for both auditing and relationship purposes.
The components for Alliance’s products are sourced in Europe, the USA and in some instances, certain components and materials are provided by non-European suppliers and manufacturers based in China and South East Asia.
For our healthcare products, Alliance has an on-boarding process through which potential suppliers are vetted by our financial, commercial and quality teams; Alliance’s quality team carry out site audits. Alliance requires all of our suppliers to comply with ISO 13485; 2016, and Medical Device Distribution Standards, and is currently working towards being ready for full compliance with the Medical Device Regulations. For our cosmetics, Alliance requires full compliance with ISO 22716.
In the USA, Alliance adheres to USA21CFR800 and for foods in the USA we requires compliance with USA21CFR100.
SUPPLIER ADHERENCE TO OUR VALUES AND ETHICS
In addition to our Partner Code of Conduct, 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 our partners (whether this be distributors, suppliers or otherwise) we would, in the first instance, seek to understand and resolve these concerns (with the welfare of the victim(s) as the primary basis of any corrective action) and if we were unable to do so, we would cease to work with such partner.
SLAVE FREE ALLIANCE
Alliance is now a member of Slave-Free Alliance, a UK charity that supports organisations that are committed to slave-free business operations and supply chains. Slave-Free Alliance provides training, technical services and dedicated support for strategic change to help organisations and their people demonstrate their commitment to addressing modern slavery risk. In 2022, Alliance carried out a desktop-based self-assessment of our current anti-modern slavery approach with assistance from Slave-Free Alliance.
ALLIANCE EMPLOYEE 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 modern slavery awareness training to our employee. Annual desktop training is provided to assist with the understanding and identification of modern slavery and human trafficking. In 2022, Slave-Free Alliance delivered bespoke, workshop-based modern slavery training to our sourcing and quality teams to help these teams better identify modern slavery “red flags” during quality audits and supplier site visits.
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
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. These include:
- Vetting and screening of third-party suppliers/partners at the time of onboarding.
- Ongoing monitoring on a risk-based approach as part of the further development of our processes.
- Subcontractor inspections both on an ad-hoc and scheduled basis.
- Speak-Up procedures being widely communicated and effectively implemented.
- General awareness training to all employees and targeted training to 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. In the last 12 months:
- No slavery or human trafficking issues have been identified.
- No reports were made under the Anti-Slavery Act Policy or under the Speak-Up Policy with respect to modern slavery and human trafficking.
- No remedial actions were required in the last 12-months.
In 2023, Slave-Free Alliance will undertake a modern slavery gap analysis assessment so that we know where the Group is in relation to understanding how modern slavery could manifest in our business and what (if any) next actions are recommended.
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 2022. It was approved by the board on 17 March 2023.
Chief Executive Officer