Modern Slavery Statement
To download a PDF copy of the Modern Slavery Statement please click here.
Indivior’s Modern Slavery Statement is made in accordance with Section 54(1) of the UK Modern Slavery Act 2015 (“the Act”). 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. It has been submitted to the UK government’s Modern Slavery Registry. This statement covers Indivior PLC and its relevant subsidiaries1. It is designed to assist stakeholders in searching for statements, and to compare the actions that businesses subject to the requirements of the Act are taking to identify and address the risks of modern slavery in their operations and supply chains.
1 Indivior EU Limited, Indivior Global Holdings Limited, Indivior UK Limited and RBP Global Holdings Limited.
Indivior is a global pharmaceutical company, with a premium listing on the London Stock Exchange where it is a member of the FTSE250 index.
Indivior works to help change patients’ lives by developing medicines to treat addiction and serious mental illnesses. Indivior’s vision is that all patients around the world will have access to evidence-based treatment for the chronic conditions and co-occurring disorders of addiction. Indivior is dedicated to transforming addiction from a global human crisis to a recognized and treated chronic disease. Building on its global portfolio of opioid dependence treatments, Indivior has a pipeline of product candidates designed to both expand on its heritage in this category and potentially address other chronic conditions and co-occurring disorders of addiction, including alcohol use disorder.
In 2019, Indivior expanded its product portfolio by launching a medicine for the treatment of schizophrenia in adults in the US and has a licensing agreement to bring this treatment to patients suffering from schizophrenia in Canada.
Indivior operates a fine chemical plant in Hull (UK). It has research and development facilities in Hull and Fort Collins, Colorado (USA). Its US headquarters are located in Richmond, Virginia (USA) and it maintains a corporate, sales and marketing office in Slough (UK). Its portfolio of products is available in over forty countries worldwide.
Indivior has an able workforce and management team with a deep understanding of patient needs and a strong commitment to improving patient lives. Indivior employs more than 700 individuals globally.
Policy and Codes
Indivior believes that human rights are an absolute and universal standard. It 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 Conduct, Doing The Right Things Right, 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, the OECD Guidelines for Multinational Enterprises and the UK Modern Slavery Act 2015. All employees and contractors receive induction training about these requirements before commencing work.
Indivior’s will publish its first Supplier Code of Conduct in 2021 and this will be available at www.indivior.com. It aligns the prohibition of forced and child labour and slavery with the responsible business standards that it expects from its suppliers. It also specifically refers to the UK Modern Slavery Act 2015 and stipulates that adherence to the Act is a mandatory supplier requirement.
Indivior’s supply chain consists of businesses involved in the manufacture, assembly, and distribution of its products. It also includes organisations and individuals that supply Indivior with a variety of business, transport and administrative services. Indivior’s manufacturing operations are performed at the Fine Chemical Plant in Hull and at contract manufacturers that are based in the UK and the USA. Both countries have strictly regulated business environments, with strong enforcement of anti-slavery laws. Consequently Indivior believes that the risk of unidentified non-compliant behaviour by its Supply Chain manufacturing partners is low. Indivior will be publishing and implementing a Supplier Code of Conduct in the first half of 2021. This, along with Indivior’s contractual arrangements, will govern its relationships and provide guidance to business partners regarding Indivior’s expectations and requirements.
Indivior has in place various resources that enable suppliers to raise ethics questions and compliance concerns about Indivior’s business activities or the conduct of its employees and contractors. Suppliers can raise questions or concerns directly with the Chief Integrity & Compliance Officer at Compliance@Indivior.com.
Another resource is the Indivior EthicsLine, an external telephone and web-based reporting resource available 24 hours a day, seven (7) days a week. Any matter reported to Integrity & Compliance or through the EthicsLine is treated as confidentially as possible and is shared only with workforce members who need to know about these matters for the purposes of an investigation and, if appropriate, corrective action.
Indivior Integrity and Compliance Program Developments
The Indivior Integrity & Compliance Program (ICP) has a multi-year strategy to drive continuous learning and evolution. Recent activities have helped to maintain and strengthen Indivior’s commitment to compliance as a core performance indicator. Highlights include;
- Optimization of written policies, procedures, and standards of conduct
The project updated and simplified key policies and procedures, including the Indivior Global Code of Conduct and included the production of Indivior’s first Supplier Code of Conduct
- Development of the compliance officer roles and the Integrity & Compliance Committee
This project refined the role of the global Indivior Integrity & Compliance Committee and regional Compliance Committees to ensure effective oversight of the administration of the ICP. The activities included embedding a robust network of Compliance Champions across Indivior’s operations. It ensured the allocation of appropriate budget and headcount resources for the ICP to achieve continued program maturity, government agreement preparedness, full staffing of fully qualified compliance professionals, and the performance of required staff development activities.
- Training and education
This project delivered an interactive compliance training program with a comprehensive curriculum for all employees and contingent workers globally. The program included communicating the outcomes of workforce non-compliance as permitted within local laws. It was conducted in partnership with Indivior’s business units and provided real-time, targeted education and training based on findings from compliance audits, monitoring and investigations.
Risk and response
Indivior 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 otherwise. Indivior will act immediately to redress any matter that indicates that this sort of activity is taking place.
The Directors and Executive Committee of Indivior are ultimately responsible for;
- Implementing this statement;
- Providing adequate resources and investment to minimize the risk of slavery and human trafficking taking place within the business or its supply chain;
- Ensuring Indivior’s approach is regularly reviewed; and
- Ensuing 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 and its approach to the issues that It addresses. This can be submitted to us through the contact details provided on the Indivior global 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 6, 2021.
Chief Executive Officer
Code of 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 in place a Code of Conduct with which all of our employees and contractors are required to comply. The Code of 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 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.