Year Ending 31 December 2016
Mundipharma IT Services Ltd is an IT company that is underpinned by an entrepreneurial spirit coupled with a desire and passion for recognising and acting upon opportunities for its customers who develop the potential of medical innovations that benefit patients’ lives.
Our business is run upon the principal foundation: to operate in an ethical and transparent manner; always doing what is right for our employees and stakeholders. This has led Mundipharma IT Services Ltd to incorporate the requirements of the Modern Day Slavery Act 2015 (the “Act”) into its Code of Business Ethics as well as encompassing those requirements into our compliance framework.
Our Code of Business Ethics together with the requirements of our Compliance programme are an integral part of our business DNA and it is this framework that enables and ensures that we protect all that we care about; our business, our people, our stakeholders and our customers. We take these responsibilities seriously and in upholding these high standards, we do not tolerate slavery or human trafficking within our organisation or our supply chain.
We recognise that our supply chain can be complicated due to the nature of our products and the sector in which we operate, however we currently consider ourselves to be low risk of exposure to slavery and human trafficking and we shall never knowingly deal with any organisation connected to slavery or human trafficking.
We are not aware of any areas in our operations and supply chain likely to lead to a breach of human rights and modern slavery laws that the reporting requirements of the Modern Slavery Act 2015 Act seek to capture.
Training, Communication and Raising Concern
Equipping those employees and senior members of the business, who are involved in the supply chain and procuring functions, with both the knowledge and understanding of the importance of the Act and the role it plays in helping to eradicate modern slavery and trafficking will help maintain and nurture a commercial environment that is fit for purpose for today’s global pressures. Specific training has and is being rolled out to relevant employees, and will also be included as part of our induction process for new employees through our Code of Business Ethics.
Mundipharma IT Services Ltd has an environment which encourages open and frank two-way communication and its employees are required to raise concern of any known or suspected violation of its Code of Business Ethics or other illegal or unethical business conduct. Any such concern can be raised in confidence without fear of retaliation, by approaching Management, HR, Legal or Compliance. Alternatively, individuals may report their concern, and if desired remain anonymous, through our independent third party Compliance and Ethics Hotline, which is available 24 hours a day.
Any concern raised will be fully investigated to determine what action is required.
Our employment practices are compliant with applicable employment and health and safety legislation, and as a result, we are confident that there is no slavery or human trafficking taking place within our organisation. Furthermore, we shall ensure that the employment agencies that we deal with, have enshrined within their policies and processes, mechanisms for identifying the risks associated with such practices that has led to the introduction of various laws in the employment field; in short, these agencies too must be fully compliant with applicable legislation.
It is our aim to not work with any supplier that we suspect is connected in any way with slavery or human trafficking. As part of our Compliance programme, taking steps to assure ourselves that we only partner with third parties that are fit and proper has been part of our on-boarding process for many years. This process has now been broadened to include screening for any potential or confirmed issues relating to slavery and or human trafficking.
In addition to pre-contract due diligence, any new contracts will require suppliers to ensure all goods and services provided to Mundipharma IT Services Ltd are undertaken in accordance with all applicable laws, including, where relevant the Act. No supplier contracts will be awarded to any supplier not able to comply with the legislation that the Act seeks to address.
For existing suppliers within the supply chain, we are reviewing and updating as required, contracts to include relevant clauses relating to slavery and human trafficking.
Any suspected breach of our Compliance programme or of our Code of Business Ethics, including the Act will result in appropriate steps being taken to investigate the potential wrong doing. Such investigations could lead to the termination of supplier contracts.
Mundipharma IT Services Ltd is not aware of any slavery or human trafficking taking place in our business or supply chain. Mundipharma IT Services Ltd will continue to apply appropriate risk-based due diligence processes as it further embeds the Act into its compliance programme.
This statement is made pursuant to section 54 of the Act and constitutes the Modern Slavery and Human Trafficking Statement for the Financial Year ended 31st December 2016 for Mundipharma IT Services Ltd.
This statement was approved by the Leadership Team of Mundipharma IT Services Ltd on 27th June 2017.
Chief Information Officer
Date: 27 June 2017