THE MODERN SLAVERY ACT 2016 (the “Act”)
SLAVERY AND HUMAN TRAFFICKING STATEMENT FOR THE PERIOD 1 MAY 2015 TO 30 APRIL 2016 INTRODUCTION FROM THE CHIEF EXECUTIVE OFFICER
Consort Medical and its subsidiaries are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls with a view to ensuring that modern slavery is not taking place in our own business or, to the extent reasonably possible, in any of our supply chains.
ORGANISATION’S STRUCTURE AND BUSINESS
Consort Medical is a leading global contract development and manufacturing organisation (CDMO), providing advanced delivery technologies, formulation and manufacturing solutions for drugs.
Our customers include some of the world’s largest pharmaceutical companies.
The group has its head office in the UK and trading companies across Europe, as well as sales representatives in the United States, China, Canada and India. The group has an annual turnover of £276.9m for the period 1 May 2015 to 30 April 2016 and therefore in excess of the Act’s threshold of £36m.
Our business is organised into two integrated operating divisions:
Bespak (Devices) — a global market leader in the development and manufacture of drug delivery devices, serving pharmaceutical companies with inhaler and auto-injector technologies and development and manufacturing services.
Aesica (Drugs) — a leading pharmaceutical CDMO serving pharmaceutical companies with active pharmaceutical ingredient (API) and finished dose formulation development and manufacturing services.
OUR SUPPLY CHAINS
Our supply chains include the sourcing of raw materials, polymers, packaging and semi-finished goods for manufacture of drug delivery devices, components and pharmaceutical products, as well as goods and services required to operate our manufacturing sites such as energy, maintenance, facilities management, operating supplies, and capital equipment.
OUR EMPLOYMENT PRACTICES
Our employment practices are compliant with applicable employment and health and safety legislation and wherever possible we endeavour to exceed our legal obligations. Where we do not engage staff directly and rely on the provision of agency staff, we require our supplier(s) to adhere to our supplier Code of Conduct which requires suppliers to ensure that there is no modern slavery or human trafficking in their business.
OUR POLICIES ON SLAVERY AND HUMAN TRAFFICKING
Our group policies reflect our commitment to act ethically and with integrity in all our business relationships and in the wake of the Act we have adopted a new policy to draw our staff’s attention to the Act and inform them how to report any relevant concerns.
DUE DILIGENCE PROCESSES FOR SLAVERY AND HUMAN TRAFFICKING
As part of our initiative to identify and mitigate risk we have a rigorous supplier selection process which includes supplier questionnaires, and a risk based approach to supplier auditing. Where appropriate, we build long term relationships and take a partnering approach with our suppliers.
SUPPLIER ADHERENCE TO OUR APPROACH
We request new suppliers to comply with our Code of Conduct which requires suppliers to ensure that there is no modern slavery or human trafficking in their business.
All Directors and Executive Committee members have been briefed on the subject. Additionally, to ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we have provided a briefing note to relevant members of staff.
OUR EFFECTIVENESS IN COMBATING SLAVERY AND HUMAN TRAFFICKING
We take the following steps to prevent slavery and human trafficking taking place in any part of our business or, to the extent reasonably possible, supply chains:
- Use of labour monitoring and payroll systems to ensure we pay staff at least in accordance local legislation and that our staff have the necessary rights to work in the country in which they are employed;
- In support of the Group’s employees’ rights, Aesica recognises Trade Unions in each of its operating countries (being the UK, Germany and Italy) and works pro-actively to foster and maintain a collaborative relationship with the Workers’ Council in Germany. Bespak works closely with its Employee Council, which represents employees across the business and encourages them to discuss a range of employment matters indiscriminately.
- Conduct audits of certain suppliers which may include investigations regarding their employment practices and transparency of their supply chains;
- Where appropriate, taking into account the size of our spend, nature of the product and results of supplier audits, there is communication and personal contact with the next link in the supply chain to understand their compliance with our expectations.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our group’s slavery and human trafficking statement for the current financial year
Jonathan Glenn, CEO, Consort Medical plc