Introduction

This statement sets out the actions taken by Britannia Pharmaceutical Ltd (“Britannia”) to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year 1st January 2020 to 31st December 2020.

As part of the pharmaceutical industry, Britannia recognises that it has a responsibility to take a robust approach to slavery and human trafficking and is absolutely committed to preventing slavery and human trafficking in its business activities and ensuring that its supply chain is free from such activities.

Organisational Structure

This statement covers the activities of Britannia.

Britannia is a UK based niche pharmaceutical company, part of the STADA group of companies. Its primary expertise is in the development and marketing of products in the area of Parkinson’s disease.

Additionally it has developed non-opiate based therapeutics to assist in opiate detoxification and withdrawal and a therapy for the treatment of severe schizophrenia.

As a purchaser of materials, manufactured products and services from around the world (including in EMEA, USA and Asia Pacific) it strives to conduct its business with partners and suppliers that share the same high ethical standards.

• Walk Free Foundation listing of worst countries for child labour;
• The Global Slavery Index;
• The Child Labour Index; and
• Chartered Institute of Purchasing and Supply reference guidance.

Where a country is deemed a high risk Britannia will take all reasonable steps to ensure all workers have appropriate employment contracts, are of legal working age, and are paid a wage commensurate with the work that they do and the relevant practices in the country where that work is carried out. In the UK, Britannia strives to ensure it is legally compliant with all relevant employment legislation.

Our Supply chain

Britannia purchases medicines and medical products as well as pharmaceutical ingredients, componentry and services from third party suppliers.

Currently all its suppliers are being strongly encouraged to comply with Britannia’s Code of Ethics for procurement and supply practices.

Effective 1st January 2017, all suppliers must complete an Ethics questionnaire prior to Britannia doing business with them (and entering into a formal supply contract). The supplier will be required to provide information with regard to its policies on human rights and workplace conditions to ensure these are consistent with the requirements of the Universal Declaration of Human Rights and the International Labour Conventions.

Britannia will also require its suppliers to provide information and, where appropriate, evidence to demonstrate that they are also fully compliant with the requirements of the Modern Slavery Act 2015. All future commercial contracts will, where relevant, also include appropriate clauses and undertakings regarding the supplier’s compliance with the Modern Slavery Act 2015.

Britannia operates a zero tolerance policy to slavery and human trafficking.

No supply contract will be awarded to any supplier who is not able to comply with the undertakings detailed in the Modern Slavery Act 2015 and any breach of the Act by a supplier will result in dialogue with that supplier and potentially the termination of that supply contract.

Relevant Policies

Britannia operates the following policies that describe its approach to identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:

• Whistleblowing policy: Britannia encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, Britannia. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Britannia’s whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation.

• Employee code of conduct: Britannia’s code of conduct makes clear to its employees the actions and behaviour that is expected of them when representing Britannia. Britannia strives to maintain the highest standards of employee conduct and ethical behaviour when operating both within the UK and abroad and when managing its supply chain.

• Supplier Code of Ethics: Britannia is committed to ensuring that its suppliers adhere to the highest standards of ethics. All suppliers are required to demonstrate that they provide safe working conditions, treat workers with dignity and respect, and act ethically and within the law in their use of labour. Britannia works with suppliers to ensure that they meet the standards of the code and to improve their worker’s working conditions.

Approval

This statement has been approved by the Managing Director of Britannia on behalf of Britannia’s board of directors, who will review and update it annually.

Mr Robert Wood
31 December 2020