Our modern slavery and human trafficking statement

Introduction

Pharmanovia is committed to protecting and respecting human rights and has a zero-tolerance approach towards modern slavery. We are committed to ensuring that there is no modern slavery and human trafficking in our supply chains or in any part of our business. We do not enter into business with any organisation, which knowingly supports, or is found to be involved in slavery, servitude or forced or compulsory labour.

As an equal opportunities’ employer, we’re also committed to creating and ensuring a non-discriminatory and respectful working environment for our people. Our recruitment and people management processes are designed to ensure that all prospective employees are legally entitled to work in the UK or their country of work.

Our business

Pharmanovia comprises Atnahs Pharma UK Limited (UK), Pharmanovia BidCo Limited (UK), Pharmanovia MidCo Limited (UK), Pharmanovia HoldCo Limited (UK), Atnahs Pharma UK Limited Dubai Branch (UAE), Atnahs Pharma US Limited (UK), Pharmanovia UK Limited (UK), Atnahs Pharma Australia Pty Limited (Australia), Marlborough Pharmaceuticals Limited (UK), , Atnahs Pharma Ilac Ticaret Limited (Turkey), Pharmanovia India Private Limited (India), Atnahs Pharma Netherlands BV (Netherlands), Pharmanovia Benelux BV (Netherlands), Pharmanovia Belgium BV (Belgium), Atnahs Pharma Italy S.R.L (Italy), Atnahs Pharma Switzerland AG (Switzerland), Pharmanovia APAC Pte Limited, Pharmanovia Korea Limited (Korea), Pharmanovia A/S (Denmark) and Atnahs Pharma Denmark Aps (Denmark).
Pharmanovia is a privately owned pharmaceutical business, that holds licences for, develops and pharmaceutical products globally, in a model that incorporates partnering with other likeminded organisations. More information on Pharmanovia’s products can be found on the website www.pharmanovia.com.

Our supply chain

Our supply chain includes the procurement of pharmaceutical products and their components. Our industry is highly regulated and requires approval and licensing which facilitates transparency in the supply chains. The consistent application of robust supply chain due diligence principles, internally referred to as “Know your Business Partner (KYBP)” enables us to make a judgement on business transactions and the ethical integrity of our supply chain partners.

We further aim to build strong partnerships with each of our strategic suppliers to ensure they comply with our values and that they are aware of our commitment to protect human rights and the environment and as part of our procurement selection processes, we require all of our suppliers to comply with the requirements of the Modern Slavery Act and include appropriate contractual obligations within all of our commercial agreements.

We source our products globally and risk is assessed on a case-by-case basis. We have reviewed our existing business partners and assessing these against key modern slavery risk indicators. Where we have identified business partners displaying characteristics of a higher level of modern slavery risk, we have requested them provide further information, to determine whether appropriate policy and processes to identify and manage these risks are in place, and whether the level of due diligence they undertake and protection they afford their supply chain and employees is sufficient to meet our requirements.

If a supplier fails to adequately address our concerns or remediate any risks identified, the relationship would be re-evaluated and if necessary, terminated.

Where potential modern slavery impacts are identified within a contract requirement, we will work with our suppliers to develop appropriate KPIs to monitor and manage performance in regard to these risks.

Our policies

We are committed to doing the right thing by ensuring we respect human rights and the environment. We manage a governance framework for all material focus areas within our sustainable framework and follow best practice guidelines provided by the Government Commercial Function, on which our policy and processes are based.

The following policies are available to all staff through Navex, our compliance portal and the intranet:

• Code of conduct
• Speak Up policy
• Dignity at work policy
• Diversity, Equity and inclusion policy
• Equal Opportunities

In addition to the above policies, all procurement team members are required to undertake mandatory modern slavery awareness training and follow modern slavery procurement guidance and awareness, as published on GOV.UK.

Reporting non-compliance

Our SpeakUp channel is operated by an independent 3rd party, and we encourage both employees and business partners to raise any concerns they have, if the know or suspect, that our internal policies or applicable laws and regulations have been violated. All calls are made in confidence and anonymously if required, and without any fear of recrimination.

Approval

This statement has been drafted with input from the key relevant functions and has been approved by the board of Atnahs Pharma UK Limited on behalf of the Pharmanovia Group.

Approved by: Dr James Burt (For and on behalf of the Company)
Position: Chief Executive Officer
Date: 01 December 2022