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 2021.
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 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 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.
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 compliance checks on its 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 its 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 its healthcare products, Alliance has an on-boarding process through which potential suppliers are vetted by its financial, commercial and quality teams; Alliance’s quality team carry out site audits. Alliance requires all of its 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 its cosmetics, Alliance requires full compliance with ISO 22716.
In the USA, Alliance adheres to USA21CFR800 and for foods in the USA it requires compliance with USA21CFR100.
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, suppliers or otherwise) 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 2021, we continued with the review of our enforcement processes and our “know-your supplier” project, to continue to strive towards ensuring that all those in our supply chain and contractors comply with our values. This review involves a process which sees representatives from the following departments working together to ensure compliance with our values and policies, including the auditing of our suppliers:
- Human resources;
- Sourcing/ Supply; and
- Commercial/ Sales.
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 service provided which specialises in market intelligence gathering in order to provide enhanced onboarding, and ongoing due diligence of new suppliers. We have also since started a project which another specialist company to enhance our ongoing monitoring of our partners which forms part of our wider ESG commitments. The initial activities have seen us written confirmations from a subset of our main suppliers (45) around their modern slavery compliance and programs and we continue to evolve that process to create a bespoke remote and in person auditing process over the next 12 months.
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 which also helps them to effectively fulfill the auditing of our supply chain.
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. 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.
- 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. 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 were required in the last 12-months.
Following a review of the effectiveness of the steps we have taken this year 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:
- Remote and, where necessary, in person auditing of supplier site by our chosen third-party service provider;
- Annual written confirmation from our suppliers of their internal procedures and training;
- Annual written confirmation from our compliance with our policy;
- Annual 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 2021. It was approved by the board on 18 March 2022.
Chief Executive Officer