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Modern Slavery Statement

Modern Slavery Statement 2022

Accord Healthcare Ltd, Accord-UK Ltd and all subsidiaries (“Accord Healthcare EMENA”, “we”) Prohibition Against Human Trafficking and Modern Slavery - Modern Slavery Act 2015

Accord Healthcare EMENA is committed to meeting the highest legal, regulatory and ethical standards in all areas of our business, as well as within our supply chain. Accord Healthcare has grown rapidly to become one of the fastest growing generics and biosimilar pharmaceutical companies in the world with ambitions to ‘make it better’ through its mission to ensure patients gain access to high quality and affordable medicines throughout the world.

Accord Healthcare has a network that reaches over 80 countries around the world and an extensive presence in North America, Europe, South America, Australia, New Zealand and South Africa, US regions.

We recognise our responsibility in ensuring our business respects all areas of human rights..

Accord Healthcare EMENA takes a robust approach to slavery and human trafficking, and is dedicated to ensuring that modern slavery does not take place at any point during our business or supply chains.

Pursuant to applicable regulations, including Section 54 of the UK Modern Slavery Act of 2015, the Accord Healthcare EMENA provides the following statement:

This statement sets out actions taken by Accord Healthcare EMENA to understand and mitigate potential modern slavery risks related to our business and to put in place steps that are aimed at ensuring there is no slavery or human trafficking in our own business or our supply chain.

Accord Healthcare EMENA’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.


Our Business

Accord Healthcare EMENA business is the development, manufacture and sale of pharmaceutical products to hospitals, community pharmacies, clinical groups, dispensing doctors and wholesalers across Europe, Middle East and North Africa. We endeavour to deliver high quality affordable medicines to address unmet needs for patients all over the world. In addition to our broad In- house capabilities, Accord Healthcare EMENA has a successful history of strong and long-term partnering. 

Accord Healthcare EMENA has direct control over all steps of the development, registration, production, testing, quality control, supply chain and PV processes to support supply to over 80 countries worldwide: North America, Europe, Asia and South America.

Accord Healthcare EMENA believes in the protection of human rights globally both in the workplace at our own facilities and within our supply chain. We forbid slavery or human trafficking of any kind and are committed to promoting responsible business practices with our suppliers.

Through the work we do we seek to build and maintain excellent relations with our employees as well as with our suppliers, and in doing so, robust processes are put into place to identify and mitigate areas of risk including modern slavery and human trafficking. With dedicated internal resource we are able to manage and develop our principles that govern all areas of risk while ensuring we have a training and awareness framework to mitigate modern slavery and human trafficking.


Our Policies

Accord Healthcare EMENA’s Code of Conduct sets out our legal and ethical principles demonstrating our approach and responsibility in respecting all human rights. The Code of Conduct sets forth our code of ethics and expectations regarding responsible business conduct. It provides information about the standards of integrity that Accord Healthcare EMENA requires all employees to follow, including standards relating to fair treatment and diversity, anti-harassment and bullying, human trafficking and slavery.

Our position on respecting human rights is also reflected in our corporate policies, which define our approach around responsibility for protecting values, both within our company as well as within all business relationships with our third parties.


Training and Risk Awareness

Accord Healthcare EMENA conducts regular awareness training for all employees, with additional support given to those in roles considered to have a sensitive element or exposes them to areas of enhanced risk.

The training provides details on laws and ethics as well as arming each individual with knowledge helping them to spot possible warning signs of worrying behaviour while detailing avenues of support for escalating any concerns.

Additionally, all employees have access and must adhere to Accord Healthcare EMENA’s Code of Conduct and policies.

We have a process in place that allows employees to raise concerns safely, while remaining protected from identification and without risk of retaliation. Accord Healthcare EMENA takes any report seriously and will investigate all concerns raised.


Accountability Standards and Values

Our Code of Conduct governs the actions of Accord Healthcare EMENA and its employees and holds each individual to the highest level of ethical and social responsibilities.

Employees who do not comply with the provisions of the Code of Conduct may be disciplined, which may include dismissal.

To the extent permitted by law and contractual provisions governing termination rights, we reserve the right to terminate relationships with third parties, including suppliers, who conduct business in a manner that conflicts with the companies Code of Conduct.

Acknowledging responsibility reaches beyond the remit of certain functions and steps are taken to ensure all employees are aware and accountable for their behaviours. Our expectations are built on the fundamentals outlining Accord Healthcare EMENA’s culture of Challenge, Connect, Commit. Encouraging all employees to act with integrity, while working together to drive our business forward ensuring risk is mitigated and ensuring we operate in a compliant and ethical manner.


Assessment of modern slavery risk

Our firm belief is that the risk of modern slavery in our directly employed workforce is low due to the highly regulated nature of our industry and in the countries in which we operate, our employees being educated, skilled and undertaking work in controlled environments where there is an established Compliance Framework. We recognise that our exposure to the risk of modern slavery increases when we engage with third parties in certain sectors and countries.


Due Diligence

Accord Healthcare EMENA conducts due diligence into the background and reputation of all the suppliers we work with. We evaluate and confirm our business relationships are based on an understanding of our desire to demonstrate our commitment of operating in a transparent and compliant manner while engaging with other likeminded organisations. We expect all suppliers to act in accordance with our strong values, continually operating ethically, fairly and with the highest integrity.

Accord Healthcare EMENA’s goal is to work with suppliers who embrace and comply with our principles, and, in turn, have these suppliers encourage compliance from any suppliers with whom they work with.

We regularly review the limitations and requirements of the due diligence processes in operation. All suppliers and business partners are reviewed in line with a documented programme based on a pre-defined risk profile. Any suppliers or business partners who no longer meet our high expectations, or for whom negative behaviours have been displayed, may as a consequence, be discontinued from use or risk-assessed for continued use if deemed essential.


Our Supply Chain

Accord Healthcare EMENA purchases medicines, pharmaceutical ingredients and componentry from third party suppliers.

Whilst Accord Healthcare EMENA neither requires annual certifications nor conducts formal on-site audits of all its’ supplier relationships, we do conduct new supplier due diligence via a Know Your Business Partner process which includes assessment of the supplier’s modern slavery position, where they are required to publish one by law, a review of publicly available news related to legal and ethical practices/ violations and a questionnaire requesting more detailed information about the suppliers’ operations and key employees. Accord Healthcare EMENA also offers training support for partners without established compliance frameworks in place.

Accord Healthcare EMENA ensures its’ supply contracts contain provisions by which suppliers agree to comply with all laws related to their performance under those agreements and conducts on-site visits of its’ primary suppliers from time to time to review and discuss contract and quality performance.

Accord Healthcare EMENA requires suppliers to abide by all applicable laws and regulations, including relevant labour laws.

Accord Healthcare EMENA’s aspiration is to select and work with suppliers who embrace and comply with the principles of our code and conduct within their business and that of their suppliers. We are targeting SMETA supplier audits for our key suppliers by 2023 to ensure continued development of our suppliers respect of workers.

Any exceptions to the above diligence are risk assessed and reviewed by the Senior Director Compliance EMENA before proceeding with the business relationship.


Our ongoing approach

Our supply chains are more than just our products, but also include a wealth of expert knowledge and skills from our third-party contractors that act on our behalf. We advocate ‘Subject Matter’ Experts in various roles throughout the business help us to develop our ethical learnings and approach.

Our Supply teams work closely with the Compliance and EHS functions to ensure that our suppliers and third-party contractors not only have a clear expectation of what is required, but also why it is required. Together they ensure that processes being followed by the relevant teams and both rigorous and robust and in line with acknowledged best practices.


Further steps

Accord HealthcareEMENA will continue to review and improve its practices to identify and eliminate potential modern slavery or human trafficking from our business, which includes further development of our Third-Party Risk Management Framework.


Reporting and investigating concerns

Accord Healthcare EMENA strives to adhere to the highest ethical standards of business conduct and seek to avoid even the appearance of impropriety in the actions of its Employees, and Business Partners.   

We strive to maintain a safe environment where people feel confident to raise concerns about possible breaches of our Code of Conduct, our internal policies or suspected violations of country laws and regulations. Employees within Accord Healthcare EMENA are actively encouraged to raise issues internally or report potential concerns to an independent third-party provider through our Speak Up Hotline, confidentially and anonymously if they prefer. Accord Healthcare EMENA is committed to promptly investigating all reports of possible misconduct and any unethical, illegal or inappropriate activity. For the financial year ended 31st March 2022 no reports have been received in relation to modern slavery or human trafficking.


Approval process

Accord Healthcare Ltd operates and manages its subsidiaries through policies, processes and systems which are designed to be consistently applied across Accord Healthcare EMENA. 

The statement has been prepared after consulting with the key relevant functions which collaborate to deliver our labour rights risk identification, assessment and management processes for our operations and supply chain.

Date of Statement 2022

Our next statement will follow the year ending 31st March 2023.
DIRECTOR NAME: Paul Tredwell – Executive Vice President
Date: 26th September 2022

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Slavery and Human Trafficking
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The board of directors and management teams of Accord Healthcare Ltd’s (AHL) and its subsidiaries are fully committed to complying with competition law. The fundamental objective of competition law is to prevent distortion of competition in the market because competition ensures an efficient allocation of resources and, ultimately, enhances consumer welfare.

AHL is committed to bringing affordable life-saving medicines to patients and has thus adopted a robust compliance programme that includes a fair competition policy, employee training to aid understanding of competition law and how it applies to our business, and a whistleblowing line allowing our employees and business partners to safely (and anonymously) report any policy breaches.


Accord Healthcare Ltd Board of Directors
October 2019