Modern Slavery Act Statement
For Norgine Limited and Norgine Pharmaceuticals Limited
Norgine is committed to acting in an ethical manner, with integrity and transparency in all its business dealings. In this statement we describe our business and supply chain, and how we responsibly operate them. We do not tolerate modern forms of slavery or human trafficking in our business. Detailed below are our current policies and procedures and the plans that we have to ensure compliance with the Modern Slavery Act 2015.
Norgine is a leading European specialist pharmaceutical company operating as a single integrated business with a direct commercial presence in all major European markets and Australia and New Zealand. Norgine employs over 1,000 people across our commercial, development and manufacturing operations and manages all aspects of product development, production, marketing, sale and supply.
Norgine owns a R&D site in Hengoed, Wales and two manufacturing sites in Hengoed, Wales and Dreux, France.
Our Policy on Modern Slavery and Human Trafficking
Our Norgine Business Code sets out our expectations and standards for how we treat our own employees, personnel, and contractors (“Norgine Personnel”) and how we expect Norgine Personnel to conduct themselves. We have a zero tolerance approach to any form of modern slavery or human trafficking in our supply chains and in any other part of our business.
Due Diligence Processes for Modern Slavery and Human Trafficking
Norgine is aware, in this era of rapid global migration, that the potential for human trafficking is more prevalent than ever before, with no sector or industry immune. Norgine has identified areas within its organisation where there could be a potential risk of modern slavery. Suppliers and business partners are informed of our expectations and must comply with the Norgine Business Code in all of their dealings with us. New business activities such as mergers and acquisitions or market expansion carry additional risk and therefore, are subject to comprehensive due diligence.
Where a potential risk has been identified, suppliers and business partners are required to demonstrate compliance and provide Norgine with any ethical code/policy or rules they have by which they are bound.
Norgine's Business Code affirms our commitment to ethical conduct and transparency, to ensure the quality and efficacy of our products and to responsibly promote and manage all Norgine Personnel and third parties who act for or on behalf of Norgine. Norgine sources materials from approved suppliers, manufactures in accordance with Good Manufacturing Practice (“GMP”) and distributes products in compliance with Good Distribution Practice (“GDP”).
All Norgine Personnel are required to undergo training and acknowledge their understanding of the Norgine Business Code. It is the responsibility of Norgine Personnel to speak up when they have a good faith concern that someone working for Norgine or on behalf of Norgine, is not acting in a manner consistent with the values and requirements of the Norgine Business Code. Norgine will investigate all concerns, in the manner appropriate to the circumstances.
The Norgine Business Code establishes the framework for achieving Norgine’s vision to become the ‘go to’ European specialist pharma company delivering innovative products for the benefit of patients, employees and other stakeholders. As we endeavour to achieve our vision, we must do so through the continued application of consistently high standards of ethical conduct.
Within Norgine there is a Governance Committee whose responsibilities include:
- Raising awareness that “Good Governance is Good Business” to the wider Norgine community; and
- Overseeing and monitoring the Norgine Business Code, reinforcing Norgine’s anti-corruption/ethical conduct commitment.
As part of its commitment to the Modern Slavery Act, Norgine has:
- Established a working group to monitor and address the requirements of the Modern Slavery Act; and
- Conducted a number of reviews and audits of suppliers to minimise the risk of modern slavery.
As part of its commitment to the Modern Slavery Act, Norgine will:
- Roll out training to all relevant Norgine Personnel to ensure that they understand Norgine’s approach to modern slavery and human trafficking;
- Continue to conduct periodic reviews and audits of suppliers to minimise the risk of modern slavery;
- Continue to require significant suppliers and business partners and those operating in high risk areas, to make a declaration stating that they have put steps in place to ensure that there is no modern slavery and human trafficking;
- Conduct a review of our contractual agreements, to ensure they reflect Norgine’s expectations of its suppliers and business partners to ensure compliance with the Act; and
- Amend the Norgine Business Code to include specific references to modern slavery and human trafficking under the Act.
This statement is made pursuant to section 54 (1) of the Modern Slavery Act 2015 and constitutes Norgine's modern slavery and human trafficking statement for the financial year ending 31st December 2017.
This statement was approved by the Board of Directors of Norgine Limited and Norgine Pharmaceuticals Limited on 31 October 2018.
Date of Prep: November 2018