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Our modern slavery and human trafficking statement

Introduction

This statement is made by Pharmanovia in support of the UK Modern Slavery Act 2015. We are committed to improving our practices to combat slavery and human trafficking and recognise that we have a responsibility to take a robust approach to slavery and human trafficking. We are absolutely committed to preventing slavery and human trafficking in our corporate activities, and to ensuring that our supply chains are free from slavery and human trafficking. At all times we seek to be vigilant, and we report and act upon any concerns raised by any of our stakeholders.

At its core, our business is based on delivering high-quality medicines in a way that demonstrates our responsibility as a business to ensure we adhere to the highest standards of medical practice. We firmly believe that this includes fair and honest management of our supply chains.

We have a zero tolerance to modern slavery, and this is reflected in our Anti-slavery and human trafficking policy which is applicable to employees and our supply chain. Amongst other things, the policy educates the reader on what modern slavery is and encourages the prompt reporting of any activity that would constitute modern slavery. The board requests updates on what the business units have done to tackle the issue of modern slavery. Our business practices also aim to prevent violations such as making on time and sufficient payments and acting fairly in its requests and demands for goods and services. We also set the ordering standards of our customers to ensure that we too are not faced with high pressure and unmanageable deadlines.

Each financial year, Pharmanovia publishes a statement setting out the steps we have taken to contribute towards tackling this issue. This statement relates to our actions and activities during the financial year ended 31 March 2021 and thereafter.

Organisational structure and business

Pharmanovia comprises Atnahs Pharma UK Limited (UK), Atnahs International Holdings Limited (Jersey), Antigua BidCo Limited (UK), Antigua MidCo Limited (UK), Antigua HoldCo Limited (UK), Atnahs Pharma UK Limited Dubai Branch (UAE), Atnahs Pharma US Limited (UK), Atnahs Pharma BB Limited (UK), Atnahs Pharma Australia Pty Limited (Australia), Marlborough Pharmaceuticals Limited (UK), Huntley Pharmaceuticals Limited (UK), Atnahs Pharma Ilac Ticaret Limited (Turkey), Pharmanovia India Private Limited (India), Atnahs Pharma Netherlands BV (Netherlands), Lamepro BV, Pharmanovia Belgium BV (Belgium), Atnahs Pharma Italy S.R.L (Italy), Atnahs Pharma Switzerland AG (Switzerland), Pharmanovia APAC Pte Limited, Atnahs Pharma Nordics A/S (Denmark) and Atnahs Pharma Denmark Aps (Denmark). Pharmanovia is a pharmaceutical business that holds licences for and develops pharmaceutical products in the UK and throughout the world. We acquire mature and established prescription medicines from large cap and speciality pharma and distribute these worldwide. More information on Pharmanovia’s products can be found on the website www.pharmanovia.com.

Our business

We have a zero tolerance to modern slavery and this is reflected in our Anti-slavery and human trafficking policy which is applicable to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners. Amongst other things, the policy educates the reader on what modern slavery is and encourages the prompt reporting of any activity that would constitute modern slavery.

The board of directors has overall responsibility for ensuring our Anti-Slavery and human trafficking policy complies with our legal and ethical obligations, and that all those under our control comply with it. The General Counsel has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.

Training on this policy, and on the risk our business faces from modern slavery in its supply chains, will be provided as necessary.

Our supply chains

Our supply chain includes the procurement of pharmaceutical products and their components. We work ethically and work only with those who can demonstrate that they work in the same way. Our industry is subject to regulation, approval and licensing which facilitates transparency in the supply chains and assists with the due diligence processes. We source our products globally but primarily from Europe and North America and risk is assessed on a case by case basis.

Whilst recognising our statutory obligation to set out the steps we have taken to ensure that modern slavery and human trafficking is not taking place in our supply chains, we acknowledge that we do not control the conduct of individuals and organisations in our supply chains. To underpin our compliance with practical steps, we adopt and will continue to adopt the following measures: a) conduct risk assessments to determine which parts of our business and which of our suppliers are most at risk of modern slavery so that efforts can be focused on those areas; b) engage with our suppliers both to convey to them our Anti-Slavery and Human Trafficking Policy and to gain an understanding of the measures taken by them to ensure modern slavery is not occurring in their businesses and their supply chain; c) supplier pre-screening in accordance with our Partner Onboarding Policy and self-reporting for our suppliers on safeguarding controls; d) inclusion of contractual provisions for our suppliers to confirm their adherence to this policy and accept our right to audit their activities and (where practicable) relationships, both routinely and at times of reasonable suspicion.

Looking ahead

Pharmanovia is committed to continuously improving the way it manages its business operations. We strive to improve our policies, processes and controls to ensure that modern slavery and human trafficking do not take place in any of our supply chains or within our business.

Board approval

This statement has been approved by the board of Atnahs Pharma UK Limited on behalf of the Pharmanovia Group on 8 April 2021.