This statement sets out actions taken by Macarthys Laboratories Limited trading as Martindale Pharma (“Martindale Pharma” or the “Company” or the “Employer”) to understand and mitigate 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 or its supply chain.
The Company’s understanding of slavery and human trafficking is based on the definitions set out in the Modern Slavery Act 2015 and is guided by the UN Universal Declaration of Human Rights and the conventions of the International Labour Organisation particularly relating to forced or compulsory labour.
As part of the pharmaceutical industry, the Company 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.
The Company’s business is the manufacture and sale of pharmaceutical products to hospitals, retail pharmacies and wholesalers in the UK and overseas.
The Company currently operates in the following countries:
Effective 1 April 2016, the following is the process by which the Company will assess whether particular activities or countries where it operates are at risk in relation to slavery or human trafficking:
All countries in which Martindale Pharma operates or looking to operate in will be assessed using the following sources of information:-
Where a country is deemed high risk the Company will 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, the Company is legally compliant with all relevant employment legislation.
The Company purchases both medicines and medical products as well as pharmaceutical ingredients and componentry from third party suppliers.
Currently, suppliers must complete a questionnaire prior to the Company doing business with them (and where relevant entering into a formal supply contract). The supplier is 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.
Effective 1 July 2016, this supplier questionnaire will also require the supplier to provide information and evidence to demonstrate that it is 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 supplier compliance with the Modern Slavery Act.
Martindale Pharma operates a zero tolerance policy to slavery and human trafficking. No supplier contracts will be awarded to any supplier 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.
Responsibility for the Company’s anti-slavery initiatives is as follows:
In keeping with the Company’s commitment to act with integrity in all its business dealings, many of our existing policies are relevant to ensure that there is no slavery or trafficking in any part of the business.
Our relevant policies include:
The organisation has reviewed its key performance indicators) in light of the introduction of the Modern Slavery Act 2015. As a result, the organisation will review its existing supply chain during the next trading year and will ensure all new supplier contracts are evaluated for compliance with the Modern Slavery Act 2015.
The Human Resources department will take responsibility for ensuring that all employees are aware of the Company’s statement of compliance with the Modern Slavery Act 2015 and its on-going commitments and that this statement is displayed on the company intranet and included in the Employee Handbook.
Training will be given to employees and management who have direct responsibility for supply chain management, particularly with respect to mitigation of risks within the supply chain.
This statement has been approved by the Chief Executive Officer (CEO) of Martindale Pharma on behalf of the Board of Directors. The policy will be reviewed and updated as appropriate on an annual basis.
CEO, Martindale Pharma
Date: 18th April 2016