Modern Slavery Act Statement
Norton Healthcare Limited’s Modern Slavery Statement, published 18 February 2019.
This is the Modern Slavery Statement to be published for financial year ending 31 December 2017.
Norton Healthcare Limited is part of Teva Pharmaceutical Industries (“Teva”).
The following statement outlines Teva’s adherence to the Modern Slavery Act 2015 (the “Act”) and the ongoing steps taken to ensure compliance with the Act.
As highlighted in our Code of Conduct, it remains a fundamental policy to conduct our business with honesty, integrity and in accordance with the highest ethical standards.
We also remain committed to the ongoing review of our policies and practices to ensure we continue to meet the requirements of the Act and to uphold our highest ethical standards.
WHO ARE WE?
Teva is committed to increasing access to high-quality healthcare for people across the globe (including the UK), at every stage of life. We do this by developing, producing and marketing affordable generic drugs as well as innovative and specialty pharmaceuticals and active pharmaceutical ingredients. We produced 120 billion tablets and capsules in 2017. We are active in 60 countries, employing in the region of 50,000 people around the world.
Teva is committed to preventing acts of slavery and human trafficking from occurring within both our business and our supply chain, and expects the same high standards from our suppliers. Our responsibility in this area includes creating awareness and understanding of human rights and employment practices. We incorporated these principles into our Code of Conduct, strategies, policies and procedures, and by continuing to live out our values, we will uphold our basic responsibilities to our people and our environment.
We continue in our commitment to support and respect the protection of internationally proclaimed human rights. We uphold the elimination of all forms of forced and compulsory labour, and the effective abolition of child labour. Ensuring that we maintain the highest moral and ethical standards regarding labour practices also remains a top priority at Teva.
Teva manufactures finished products itself but also purchases goods and services, including raw material, from third party suppliers. As part of our processes to ensure ethical practices within our supply chain, we became a member of the Pharmaceutical Supply Chain Initiative (“PSCI”) in 2016, which includes 21 of the largest and leading pharmaceutical and healthcare companies. We continue to be a member of PSCI. The PSCI principles that govern supply chains in this sector continue to apply and inform our ethical labour practices which are included in our Code of Conduct. We incorporated these principles into our Supplier Code of Conduct in 2017. All new suppliers are obliged to accept these obligations when entering into legal agreements with Teva which includes Purchase Orders and our trading Terms and Conditions.
TEVA POLICIES AND CODES
Since 2010, Teva has participated in the United Nations Global Compact (UNGC). The UNGC is a strategic policy initiative of the United Nations which encourages companies around the world to adhere to 10 principles of responsible business relating to human rights, labour standards, environmental protection and anti-corruption. As part of our commitment to combating modern slavery, we implemented the formal communication of our Responsible Supply Chain policy which sets out our expectations for all our suppliers to comply with the UN Global Compact Principles. Suppliers are obliged to consider these responsibilities as part of selection and continued engagement with Teva.
Our Supplier Code of Conduct is made publicly available to suppliers on our global website, formal acceptance of this policy by suppliers is a pre-requisite to contracting and tendering with Teva. The PSCI Principles, which are aligned with our Supplier Code of Conduct (“SCOC”), are aligned with the UN Global Compact Principles.
SUPPLIER RISK ASSESSMENT/AUDIT
Under Teva policy, Teva utilised a risk-based assessment of suppliers considering, amongst other things, their potential risk of non-compliance to the SCOC. We acknowledge we must be particularly vigilant when sourcing in specific industry sectors with geographically distant supply chains. Suppliers prioritised as high or medium risk are further assessed for compliance with the SCOC and may thereafter be subject to an audit.
We worked with an external sustainability specialist and utilised its ‘Supplier Sustainability Ratings’ solution to further undertake initial assessments of our suppliers’ compliance with our SCOC.
As part of our commitment to our ongoing compliance with the Act, we have utilised our risk assessments to establish a risk mitigation general ways of working in respect of third party compliance with our SCOC.
EMPLOYEES, TRAINING AND WHISTLEBLOWING
Employee relations are managed across Teva by the Human Resources Department. Employee working hours are set out in a contract and any requirement to work additional hours outside of the standard contractual hours must be approved in advance by the relevant managers with the employee’s consent. All relevant UK employees are paid at least the UK National Living Wage.
Our own employees have been trained on and must comply with our Code of Conduct. We invest in educating our staff to recognise risks of breaches of our Code of Conduct or applicable laws in our business and supply chains. Through our training programmes, employees are encouraged to identify and report any potential breaches.
Suppliers, workers and service providers continue to be encouraged to report concerns or illegal activities in the workplace without threat of reprisal, intimidation or harassment – this includes concerns relating to ethical behaviour. Teva personnel should also promptly report any violations of Teva’s Code of Conduct, the SCOC or any policies or laws, to Teva’s Office of Business Integrity (OBI) through a dedicated telephone hotline.
This statement is made in accordance with Section 54(1) of the Modern Slavery Act 2015 and constitutes Teva’s slavery and human trafficking statement.