The Modern Slavery Act (MSA) 2015 covers four activities:

This policy covers all four activities.

How is it relevant to us?

Modern slavery is a complex and multi-faceted crime and tackling it requires all of us to play a part. At first glance, you may think this whole subject is irrelevant to us, but it’s not.

At a very basic level, of course preventing exploitation and human trafficking, and protecting our workforce and reputation makes good business sense.

The MSA 2015 recognises the important part businesses can and should play in tackling slavery and encourages them to do more.

With this in mind, we need to pay particularly close attention to:

a. our supply chain
b. any outsourced activities, particularly in respect of situations over which we do not have primary or full control or in respect of activities which take place in jurisdictions that may not have adequate safeguards in place

Our Environment

CST and its associated companies operate within a particularly tightly regulated industry. We acquire pharmaceutical products abroad and import them into the UK, where we repackage them and sell them on to customers. At every stage in the supply chain, the transactions are subject to regulation and overwatch, either within the jurisdictions from where we acquire product or within the UK. Because of the nature of the regulations under which we operate, we are only able to acquire product from suppliers who are themselves regulated by supervising authorities within their own jurisdiction and who are, as is CST and its subsidiaries, subject to spot searches on their premises by the relevant regulatory authority.

In addition to the above, the nature of our operations requires that we have a skilled, motivated and stable workforce of high intelligence, commitment and integrity. We do not use transient labour and we recruit only through reputable organisations, such as the National Employment Agency (Job Centre Plus) or reputable private employment agencies, who are able to demonstrate compliance with and commitment to the obligations imposed by MSA.

Responsibilities

The firm, our managers and colleagues have responsibilities to ensure our fellow workers are safeguarded, treated fairly and with dignity.

Everyone must observe this policy and be aware that turning a blind eye is unacceptable and simply not an option.

The firm

We will:

i. develop and maintain clear policies and procedures preventing exploitation and human trafficking, and protecting our workforce and reputation
ii. be clear about our recruitment policy and adhere to it at all times (see General Recruitment)
iii. check our supply chains (see Supply chains)
iv. lead by example by making appropriate checks on all employees, recruitment agencies, suppliers, etc. to ensure we know who is working for us
v. ensure we have in place an open and transparent grievance process for all staff
vi. seek to raise awareness so that our colleagues know what we are doing to promote their welfare
vii. make a clear statement that we take our responsibilities to our employees and our clients seriously (see Anti-slavery statement)

Managers

Managers will:

i. listen and be approachable to colleagues
ii. respond appropriately if they are told something that might indicate a colleague is in an exploitative situation
iii. remain alert to indicators of slavery (see Identifying slavery)
iv. raise the awareness of our colleagues, by discussing issues and providing training, so that everyone can spot the signs of trafficking and exploitation and know what to do
v. use their experience and professional judgement to gauge situations

Colleagues

We all have responsibilities under this policy. Whatever your role or level of seniority, you must:

i. keep your eyes and ears open - if you suspect someone (a colleague or someone in our supply chain) is being controlled or forced by someone else to work or provide services, follow our reporting procedure (see Reporting slavery)
ii. follow our reporting procedure if a colleague tells you something you think might indicate they are or someone else is being exploited or ill-treated
iii. tell us if you think there is more we can do to prevent people from being exploited

The Risks

The principal areas of risk we face, related to slavery and human trafficking, include:

a. supply chains
b. recruitment through agencies
c. general recruitment

We manage these risk areas through our procedures set out in this policy and elsewhere.

Anti-slavery statement

We make a clear statement that we take our responsibilities to our employees, people working within our supply chain and our clients seriously.

We make this statement as part of our company reporting obligations

Supply chains

We thoroughly check supply chains to ensure the potential for slavery and human trafficking is significantly reduced.

We tell the companies we do business with that we are not prepared to accept any form of exploitation.

All of our supplier contracts contain an anti-slavery clause. This clause, which flows down through all layers of our supply chain, prohibits suppliers and their employees from engaging in slavery or human trafficking.

We ensure we can account for each step of our supply processes—we know who is providing goods and services to us and we have mechanisms and processes in place to check, including:

• Pharmaceutical products will only be requested from holders of a current Manufacturing and Importation Authorisation or Wholesale Distributor Authorisation, who have operations authorised by the MHRA to handle specific legal categories of medicines. Absolutely no other source of pharmaceutical supply is acceptable or allowed.

• The WDA number for a UK supplier must be confirmed as still current on the MHRA website. GDP compliance for suppliers must be confirmed by checking EudraGMDP website

• For European Suppliers that are both EEA and Non-EEA members, a copy of the wholesaler’s national WDA is obtained and is retained on file together with a notarised translation of the licence. The European and translated licences are kept filed in the Regulatory Office. Where possible, the WDA number will be checked against the relevant national agency website to confirm as still current.

• For both UK and European wholesalers an updated copy of the WDA, notarised translation (when applicable) and GDP compliance is requested from the supplier perpetually on an annual basis. Alternatively, confirmation is required that no changes have taken place over the last 12 months and their documentation remains the same as held on our records.

Where we use agencies to supply staff, we will:

• Ensure that our HR Department follows this Anti Slavery Policy and only uses agreed, specified, reputable recruitment agencies.

• So far as we can, we will ensure that the potential for slavery and human trafficking within our employment supply chain is reduced by:

a) Thoroughly checking recruitment agencies before adding them to our list of approved suppliers;
b) Conducting background checks on all approved suppliers where this is possible;
c) Ensuring that the employees provided by agencies have the appropriate original documentation;
d) Requiring that agencies providing employees confirm that the appropriate checks have been made by them with regard to staff they are providing;
e) Making sure that documents produced, either by putative employees or agency supplies are rigorously checked for authenticity;
f) Ensuring that approved suppliers are regularly reviewed at appropriate periods.

General recruitment

We always ensure all staff have a written contract of employment and that they have not had to pay any direct or indirect fees to obtain work.

We always ensure staff are legally able to work in the UK.

We check the names and addresses of our staff (a number of people listing the same address may indicate high shared occupancy, often a factor for those being exploited).

We provide information to all new recruits on their statutory rights including sick pay, holiday pay and any other benefits they may be entitled to.

If, through our recruitment process, we suspect someone is being exploited, the HR department will follow our reporting procedures (See Reporting slavery).

Identifying Slavery

There is no typical victim and some victims do not understand they have been exploited and are entitled to help and support.

However, the following key signs could indicate that someone may be a slavery or trafficking victim.

a. The person is not in possession of their own passport, identification or travel documents.
b. The person is acting as though they are being instructed or coached by someone else.
c. They allow others to speak for them when spoken to directly.
d. They are dropped off and collected from work.
e. The person is withdrawn, or they appear frightened.
f. The person does not seem to be able to contact friends or family freely.
g. The person has limited social interaction or contact with people outside their immediate environment.

This list is not exhaustive.

Remember, a person may display a number of the trafficking indicators set out above but they may not necessarily be a victim of slavery or trafficking. Often you will build up a picture of the person’s circumstances which may indicate something is not quite right.

If you have a suspicion, report it.

Reporting Slavery

Talking to someone about your concerns may stop someone else from being exploited or abused.

If you think that someone is in immediate danger, dial 999.

Otherwise, you should discuss your concerns with the HR Manager who will decide a course of action and provide any further advice.

Not all victims may want to be helped and there may be instances where reporting a suspected trafficking case puts the potential victim at risk, so it is important that in the absence of an immediate danger, you discuss your concerns first with the HR Manager/Operations Director before taking any further action.

Training

We provide specialist training to those staff members who are involved in managing recruitment, our external supply chains and areas within the business involving groups of staff identified as particularly at risk in respect of MSA issues.

More general awareness training is provided to all staff within regular training sessions

Monitoring Our Procedures

We will review our Anti-slavery policy regularly.

As we have identified that one of the few areas within the business where MSA vulnerability exists is casual externally recruited staff, as a key performance MSA indicator, we will produce an annual calculation of the ratio of external agency workers to directly employed staff and a of directly employed employees to employed bank staff.

 
This Policy covers the period 1 April 2018 to 31 March 2019

Caroline Poynter
Operations Director CST Pharma Ltd

This Policy has been approved by the Board of Directors for the following companies. They have all delegated authority to Caroline Poynter to sign this Policy on their behalf:

CST Pharma Limited
DMG Wholesale Limited
Acre Pharma Limited