Modern Slavery Statement

Overview
The Modern Slavery Act 2015 requires commercial organisations supplying goods or services with a turnover of above £36 million to prepare and publish an annual 'Slavery and Human Trafficking Statement'. The Statement must set out the steps an organisation has taken, if any, during its financial year to ensure that slavery or human trafficking is not taking place in its supply chain.
 
What is Modern Slavery?
Modern slavery is an international crime, affecting an estimated 29.8 million slaves around the world.  It is a growing global issue that transcends age, gender and ethnicities. It includes victims who have been brought from overseas and vulnerable people in the UK, who are forced to illegally work against their will across many different sectors such as agriculture, hospitality, construction, retail and manufacturing.
 
Our policy
The company is working towards establishing a zero-tolerance position on violations of anti-human trafficking and anti-modern slavery laws. If we find breaches of these laws within our supply chain, we will look to support companies in their efforts to comply with the legislation. We will also actively consider how we support or conduct business with organisations involved in slavery, human trafficking, forced or child labour.
 
Our CLEARR values: Collaboration, Leadership, Excellence, Agility, Respect, and Responsibility underpin our culture and how we do business. They are embedded throughout our business and set the parameters for how we expect people to behave with their colleagues, customers and the world at large. We seek to treat everyone fairly and consistently, creating a workplace and business environment that is open, transparent and trusted. Our policies and procedures relating to the Modern Slavery Act are in line with our culture and values.
 
Our structure and supply chains
 
Strathclyde Pharmaceuticals Limited is a healthcare company which distributes and sells pharmaceutical and consumer healthcare products. Turnover was £52m in 2016, all of which was from the UK and Europe.   
 
We invest in developing long term relationships and identifying third parties that best meet the company’s needs; this is particularly important because of the specialist nature of our products (all Pharmaceutical suppliers have to have a Wholesale dealers licenses).  The supply of pharmaceuticals are governed by regulation to ensure supply chain standards.
 
 
We believe that the risk of modern slavery in third parties with which we have a direct relationship is relatively low as they have to have a Wholesale Dealers Licence and are based within Europe. This is supported by the findings of a risk assessment conducted for the Pharmaceutical Supply Chain Initiative which concluded that favourable working conditions in the first tier of supply lower the risk of exposure to labour exploitation, but risks increase in lower tiers of supply. We place obligations on our third parties to take responsibility for controlling their own supply chain, and this is reiterated in our policy on working with third parties and is included in our supplier contracts.
 
Both the Responsible Purchasing Policy and Supplier Code of Conduct will be reviewed annually, and updated as and when deemed appropriate by the Ethics Team, to ensure they are continually developed and remain fit for purpose.
 
Our procedures
We have a number of procedures in place that contribute to ensuring modern slavery does not occur in our business or supply chains.
 
Employment:
• Robust recruitment processes in line with UK employment laws, including: 'right to work'
document checks; contracts of employment and checks to ensure everyone employed is 16 and above.
• Market-related pay and reward, which is reviewed annually and linked to professional services firms' benchmarks.
 
Employee training:
We want to help our people to understand more about this growing issue and how to report any suspicions they may have, whether in a business or personal context. We have highlighted the modernslavery.co.uk site to all our employees, which holds useful information on how to recognise different types of slavery, how to spot the signs and provides details of a telephone helpline. We have developed resources and made them available to our people, including summary documents with an overview of the Modern Slavery Act, and links to the modernslavery.co.uk site.
 
Reporting knowledge or suspicion of slavery:
We encourage any staff to report any concerns to senior staff or report directly using the modernslavery.co.uk web site.
 
Looking forward: key performance indicators
Going forward, we aim to work towards:
• developing an employee training module that will be undertaken by all employees.
This training will outline what modern slavery is, how to identify it and what individuals should do if they suspect there are any cases of slavery occurring. Completion of this training will form a compulsory part of our employees' annual review and new starter induction processes.
• developing a procedure to monitor how our suppliers comply with our supplier Code of Conduct.
 
 
Additional Links:
www.modernslavery.co.uk