Modern Slavery Statement
This statement is made in accordance with Section 54(1) of the UK Modern Slavery Act 2015. It sets out the steps Indivior has taken and will be taking to prevent modern slavery and human trafficking in its business and supply chain.
Indivior is a global specialty pharmaceutical company and the world leader in opioid addiction treatment. Our vision is for all patients around the world to have access to quality treatment for the chronic relapsing condition and co-morbidities of addiction. Indivior PLC is listed on the London Stock Exchange and is a constituent of the FTSE 250 index. On 31 December 2016, the Group had 965 employees, around 600 of which are based in North America.
The Group primarily researches, develops and manufactures buprenorphine-based products for the treatment of opioid dependence. The Group has a manufacturing, research and development facility in Hull in the United Kingdom. The Group’s headquarters are based in Richmond, Virginia in the United States of America and it maintains a corporate office in Slough in the United Kingdom. The Group also has employees based in several countries around the world. These employees mainly conduct sales and marketing activity.
Indivior believes that human rights are an absolute and universal standard. The Group is opposed to all forms of human slavery and trafficking and will not do business with any organisation that it knows to be involved in these activities.
The Group’s Code of Business Conduct includes a specific commitment to adhere to the provisions of the United Nations Universal Declaration of Human Rights and the Convention on the Rights of the Child. Article four of the United Nations Universal Declaration of Human Rights specifically prohibits slavery and the slave trade in all their forms. The Code of Business Conduct applies to the Group’s employees and contractors globally. It is our policy that all employees receive induction training about these requirements when commencing work for the Group.
Indivior also has a confidential reporting and guidance tool, the Indivior EthicsLine, through which employees and contractors may report concerns or seek guidance on applicable Indivior policies. The EthicsLine may be used to report wrongdoing, including possible human rights violations. All reports are fully investigated and appropriate remedial action is taken.
Indivior’s supply chain consists of businesses involved in the manufacture, assembly and distribution of the Group’s products. It also includes companies that supply Indivior with a variety of business, transport and administrative services. The Code of Business Conduct states that the Group is committed to proactively encouraging its suppliers and contractors to demonstrate responsible behavior and high standards of business conduct. It does this by the conduct of regular dialogue and interaction with its suppliers and contractors.
Indivior recognizes its responsibilty to ensure that its policies and systems robustly exclude slavery and forced labour from the business on an ongoing basis. The Group is planning to review its procedures to ensure that these issues will be continuously addressed in line with the requirements of the Modern Slavery Act 2015 and good business practice.
Risk and response
The Group considers that the risk that slavery and human trafficking is taking place within its business or supply chain is low and has uncovered no evidence to indicate that it is. The Group will act immediately to redress any matter that indicates that this sort of activity is taking place.
The Directors and senior management of Indivior are ultimately responsible for;
- Implementing this statement;
- Providing adequate resources and investment to minimize the risk of human slavery and trafficking taking place within the business or its supply chain;
- Ensuring that the Group’s approach is regularly reviewed;
- Ensuring that the commitments outlined in this statement are adhered to.
Review, publication and feedback
This statement will be reviewed and published annually. Indivior welcomes feedback from any of its stakeholders concerning this statement. This can be submitted to us by applying the contact details on the Group’s website (www.indivior.com).
This statement was approved by the Nomination & Governance Committee, a committee of the Board of Directors of Indivior PLC, on May 16, 2017.
Chief Executive Officer
Code of Business Conduct
We are committed to responsible corporate behavior which includes high standards of business conduct in our relationships with employees, contractors, customers, shareholders, suppliers, governments, competitors and the local communities in which we operate.
We have put in place a Code of Business Conduct with which all of our employees and contractors are required to comply. The Code of Business Conduct requires our employees and contractors to conduct business ethically and fairly, to comply with laws and regulations and to avoid situations where their personal interests might conflict with the Group’s interests.
Compliance with the Code and associated polices is critical to the success of the Company. As such, adherence to the Code of Business Conduct along with any associated polices and training requirements will be considered in each employee’s annual performance appraisal. Where appropriate, the Company may assign global compliance objectives to employees as part of the annual performance appraisal.
The Code of Business Contact also requires our employees and contractors to comply with the various company policies, which include the key policies referred to below.
The complete Code can be found here: Indivior Code of Business Conduct.
We are committed to observing the laws and regulations which govern our operations in every country in which we do business. Our employees and contractors are required to comply with our Anti-Bribery Policy, which sets out the responsibilities of individuals, rules relating to gifts and hospitality and facilitation payments, political and charitable contributions, as well as potential “red flag” issues.
The complete policy can be found here: Indivior Anti-Bribery Policy.
Diversity and Inclusion Policy
We believe that a diverse workforce enables more relevant innovation, improved quality, and increased speed and efficiency in meeting the various needs of our global patients, customers and stakeholders. We are committed to equality of opportunity in all areas of employment and business regardless of personal characteristics including but not limited to gender, race, nationality, age, disability, sexual orientation or religion. Our policy on diversity is set out in its Diversity and Inclusion Policy, which sets out the key outcomes and practices in relation to diversity and inclusion.
The complete policy can be found here: Indivior Diversity and Inclusion Policy.
Our Whistleblower Policy is designed to enable all employees to raise concerns internally and at a senior level and to disclose information which the individual believes shows malpractice or impropriety within the group. These concerns include:
- Financial malpractice, impropriety or fraud
- Failure to comply with legal obligations
- Dangers to health and safety or the environment
- Criminal activity
- Improper conduct or unethical behavior
- Significant breaches of the Code of Business Conduct
- Attempts to conceal any of these once they have occurred.
The complete policy can be found here: Indivior Whistleblower Policy.