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Modern Slavery Act

Modern Slavery Act 2015

Accord Healthcare Ltd, Accord-UK Ltd and any subsidiaries (“the Company”) Prohibition Against Human Trafficking and Modern Slavery

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

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

The Company’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.

As part of the pharmaceutical industry, the Company recognises that it has a responsibility to take a robust approach to slavery and human trafficking and is absolutely committed to preventing slavery and human trafficking in its business activities and ensuring to the best of its ability that its supply chain is free from such activities.

Our Business

The Company’s 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.

The company 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. We have several corporate policies, including our Code of Conduct, our Respect at Work Policy, and our Know Your Business Partner checks, which address our position on these issues.

Code of Conduct

The Company’s Code of Conduct sets forth our code of ethics and expectations regarding responsible business conduct. It provides information about the standards of integrity that The Company requires all employees to follow, including standards relating to fair treatment and diversity, anti-harassment and bullying, human trafficking and slavery.

Our Supply Chain

Our company purchases medicines, pharmaceutical ingredients and componentry from third party suppliers.
Whilst the company neither requires annual certifications nor conducts formal on-site audits of all its’ supplier relationships, the company:

a) conducts new vendor due diligence via a Know Your Business Partner process which includes a review of publicly available news related to legal and ethical practices/ violations, a search of UK and US sanctions lists and a questionnaire requesting more detailed information about the suppliers’ operations and key employees.
b) ensures its’ supply contracts contain provisions by which suppliers agree to comply with all laws related to their performance under those agreements.
c) conducts on-site visits of its’ primary suppliers from time to time to review and discuss contract and quality performance.

The company’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. Any exceptions to the above diligence are risk assessed and reviewed by the Compliance Manager before proceeding with the business relationship.

Accountability Standards

The Company has a Code of Conduct in place that governs the actions of our company and employees and holds them to the highest level of ethical and social responsibilities. The Company’s goal is to work with suppliers who embrace and comply with our principles, and, in turn, to have these suppliers encourage compliance from any suppliers with whom they work in delivery of goods or services for The Company.

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.

Relevant Policies

In keeping with the Company’s commitment to act with integrity in all its business dealings, many of our existing policies are relevant to ensure that there is no slavery or trafficking in any part of the business. All relevant staff are trained in these policies as part of the company’s ongoing training program.

Our relevant policies include:

  • Public Interest Disclosure (“Whistle-blowing”) Policy: The Company encourages all its workers to report any concerns related to the direct activities, or the supply chains of, The Company. The Company’s whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation.
  • Code of conduct: The Company’s code of conduct makes clear to employees the actions and behaviour expected of them when representing the Company. The Company strives to maintain the highest standards of employee conduct and ethical behaviour throughout its business and in managing its supply chain. The guidelines detailed in the code of conduct apply to all Company personnel, whether permanent or on fixed term contracts and including agency staff, contractors and workers employed via distributors to deliver services to the Company, its directors and all Company-related transactions.
  • Recruitment/Agency workers: The Company uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency.
  • Anti-Harassment & Bullying: The Company encourages and maintains a professional and friendly working environment where everyone is free to work without harassment, victimisation or bullying for any reason and where everyone in the workplace is treated with dignity and respect. The policy applies to all workers, job applicants, agency employees, contractors, consultants, suppliers and customers.
  • Anti- Corruption: The company is committed to the highest standards of ethical conduct and integrity in its business activities in the UK and overseas. This policy outlines the Company’s position on preventing and prohibiting bribery, in accordance with the Bribery Act 2010. The company will not tolerate any form of bribery by, or of, its employees, agents or consultants or any person or body acting on its behalf.
  • Corporate Social Responsibility: The company takes its social responsibilities very seriously, supporting a wide range of good causes and initiatives around the world. Our strategy is to support programs and projects that offer shared value for both parties. These initiatives also need to be consistent with our business, improving health and the quality of life, contributing to a qualified and productive workforce and enriching life. To help make a difference in the community, we work with chosen community partners through a company matching donations program. We encourage employees to get actively involved with our community partners through either volunteering or raising sponsorship.
  • Equality and Diversity: The company is committed to being an equal opportunity employer and to ensuring that all employees, job applicants, customers/clients and other people with whom we deal are treated fairly and are not subjected to unfair or unlawful discrimination.

Regular Reviews

As a business we measure and review, on an annual basis, any suppliers that score negatively on our Know Your Business Partner process. These suppliers may as a consequence be discontinued from use or risk-assessed for continued use if deemed essential. A further supplier audit may also be conducted.


Date of Statement April 2019

Period Covered April 2017 – March 2018

Approved by Dr James Burt, Executive Vice President

General (the “Site") is owned and operated by Accord Healthcare, Ltd. (“Accord”), a company registered in England and Wales, with company number 04596349 and with registered office at Sage House, 319 Pinner Road, North Harrow, Middlesex, HA1 4HF, United Kingdom. Accord’s VAT number is GB 894350693.

Terms of Use
By accessing the Site or by otherwise accessing any content found on this Site, you agree to be bound by the following terms and conditions (“T&C”).

Contents of this Site
All the information and contents of the Site (including, but not limited to, its graphics, logos, designs, images and source codes used for programming) are the property of Accord or its licensors, as the case may be.

You may not use or reproduce or allow anyone to use or reproduce any “Accord” names and logos, and any other graphics or trademarks (whether registered or unregistered) appearing on the Site for any reason without written permission from Accord.

The software that operates the Site is proprietary software and you may not use it except as expressly allowed under these T&C. You may not copy, reverse engineer, modify or otherwise deal with the software.

Where the Site contains links to other sites and resources provided by third parties, these links are provided for your information and convenience only. Accord does not have control over, and is not responsible for, the availability and content of those sites and resources. 

Changes to the Site, its contents and these T&C
Accord reserves the right to alter the Site, its contents and these T&C at any time, without prior notice. Any modification will take effect immediately. You agree to check these T&C regularly for modifications and additions.

Contents Use
You may download material displayed on the Site for non-commercial, personal use only, provided you also retain all copyright and other proprietary notices contained in the materials or as specified on the Site. Save as expressly permitted above, all use and reproduction of any material on this Site or any incorporation of the same into any other material, in whatever media or format, is strictly prohibited. You agree not to use the Site for any commercial or business purposes.

Slavery and Human Trafficking
Accord is absolutely committed to preventing slavery and human trafficking in its business activities and ensuring to the best of its ability that its supply chain is free from such activities. For further details, see Accord’s Modern Slavery Act Statement.

Personal Data
Accord may process the personal data supplied by you to Accord in accordance with Accord’s Cookies and Privacy Policy.

Liability and Indemnity
Although Accord endeavours to ensure the high quality and accuracy of the Site, Accord makes no warranty, express or implied, such as to the accuracy, completeness or adequacy, of the contents of the Site, which are provided "as is".

In no event will Accord, its affiliates, agents, suppliers or licensors be liable for any direct, special, incidental, exemplary, punitive, consequential or other loss or damage (including, without limitation, damages for loss of business profits, business interruption, loss of business information or other pecuniary loss) that may arise directly or indirectly from the use of (or failure to use) or reliance on the contents of this Site, even if Accord has been advised of the possibility that such damages may arise. For the avoidance of doubt:

  • Accord does not guarantee absence of virus or other elements that could damage or alter your computer system, electronic documents or files. Accord hereby notifies to all users that these may occur. Therefore, Accord does not accept liability for any damage that these elements could cause to you or to third parties.
  • Accord will not be liable if for any reason the Site is unavailable at any time or for any period. Accord accepts no responsibility for any errors, omissions, delays, or losses including loss of data during or as a result of the unavailability of the Site.

You agree to indemnify Accord, its affiliates, agents, suppliers or licensors immediately on demand, against all claims, liability, damages, costs and expenses, including reasonable legal fees, arising out of any breach of these T&C by you or your use of the Site.

Governing Law and Jurisdiction
These T&C will be governed by and construed in accordance with the laws of England. You (and Accord) submit irrevocably to the exclusive jurisdiction of the English Courts.

Other Terms
Notices to Accord must be given in writing, by letter, and sent to Sage House, 319 Pinner Road, North Harrow Middlesex, HA1 4HF, United Kingdom.

If any provision in these T&C is determined to be illegal, invalid or unenforceable, in whole or in part, then such provision or part of it shall, to the extent that it is illegal, invalid or unenforceable, be deemed not to form part of these T&C and the legality, validity and enforceability of the remainder of these T&C shall not be affected.

Save as expressly referred to therein, Accord makes no representations or warranties of any kind, express or implied, with respect to Site and its contents.

Headings in these T&C are for convenience only and have no legal meaning or effect, nor shall they be taken into account in interpreting these T&C.

Accord rights under the T&C may be waived only in writing and specifically.

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