Modern Slavery and Human Trafficking Statement


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.

Our Business

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:

  • United Kingdom (head office, manufacturing, distribution and sales)
  • United Arab Emirates (sales)
  • Saudi Arabia (scientific office)
  • Singapore (sales).

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:-

  • Walk Free Foundation listing of worst countries for child labour
  • The Global Slavery Index
  • The Child Labour Index

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.

Our Supply Chain

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:

  • Policies: The Head of Human Resources and the Human Resources department in general are responsible for ensuring all Company policies are fully compliant with UK employment legislation and that all policies are reviewed at least every two years. All policies are available to the Company’s employees via the Company intranet and in hard copy.
  • Risk assessments: These will be conducted by the Head of Supply Chain with support as required from Human Resources and Quality departments.
  • Investigations: It will be the responsibility of the Head of Supply Chain to investigate any concerns raised, whether these concerns are communicated directly to the role holder or via the Whistle Blowing Policy which the Company operates. The Head of the Supply Chain will be supported by the Human Resources department as required.

Relevant Policies

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:

  • Whistleblowing policy: The Company encourages all its workers to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organisation’s whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation.
  • Code of conduct: The Company’s code of conduct makes clear to employees the actions and behaviour expected of them when representing the Company. The Company strives to maintain the highest standards of employee conduct and ethical behaviour throughout its business and in managing its supply chain. The guidelines detailed in the code of conduct apply to all Company personnel, whether permanent or on fixed term contracts and including agency staff, contractors and workers employed via distributors to deliver services to the Company, its directors and all Company-related transactions.
  • Recruitment/Agency workers: The Company uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency.
  • Dignity at Work: The Company encourages and maintains a professional and friendly working environment where everyone is free to work without harassment, victimisation or bullying for any reason and where everyone in the workplace is treated with dignity and respect. The policy applies to all workers, job applicants, agency employees, contractors, consultants, suppliers and customers.
  • Anti-Bribery and Corruption: Martindale Pharma is committed to the highest standards of ethical conduct and integrity in its business activities in the UK and overseas. This policy outlines the Company’s position on preventing and prohibiting bribery, in accordance with the Bribery Act 2010. Martindale Pharma will not tolerate any form of bribery by, or of, its employees, agents or consultants or any person or body acting on its behalf. 
  • Corporate Social Responsibility: The Company manages its Corporate Social Responsibility programme based on four key areas: Our Community, Our Environment, Our Marketplace and Our People. Within each of these areas, the Company has identified key priorities that reflect our values and support our objectives of building a sustainable Company and maintaining our high ethical standards.
  • Equality and Diversity: Martindale Pharma is committed to being an equal opportunity employer and to ensuring that all employees, job applicants, customers/clients and other people with whom we deal are treated fairly and are not subjected to unfair or unlawful discrimination.

Performance Indicators

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.

Education and Training

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.

Board Approval

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.

Michael Harris
CEO, Martindale Pharma
Date:  18th April 2016