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 2022 for Napp
Napp Pharmaceuticals Limited (including the holding company Napp Pharmaceutical Holdings Limited and the wholly owned subsidiary, Qdem Pharmaceuticals Ltd) is a privately-owned, UK pharmaceutical company, based in the heart of the Cambridge science community. Napp has grown up with the NHS, providing innovative medicines to patients in the UK since the 1920s. We know how to navigate its complexities and we’ve shaped our structure to its unique needs, so as the NHS changes, we change too. We foster a flexible culture at Napp where our people thrive on the ability to be agile and autonomous in response to the needs of our partners. From launching the UK’s first monoclonal antibody biosimilar to introducing cutting-edge primary care medicines in respiratory and diabetes, we are always striving to move medicine forward for doctors and patients in the UK.
Our business is committed to operating in an ethical and transparent manner. In line with this commitment, the business is cognisant to incorporate and follow and have incorporated the requirements of the Modern Slavery Act 2015 (subsequently amended by the Modern Slavery (Amendment) Bill 2021) (the “Act”) into our Code of Business Ethics and our compliance framework.
We take the upholding of these high standards seriously and do not tolerate slavery, human trafficking, or child exploitation within our organisation or from those from whom we buy products or services. We analyse the risks within our own business and our supply network annually following the introduction of the Act and we do not believe our risk in our supply chains has changed since our previous Statement in 2022 for the financial year ended 31 December 2021. Due to the nature of our business, we currently consider ourselves to be at low risk of exposure to slavery, human trafficking, or child exploitation. We are not aware of any areas in our operations likely to lead to a breach of human rights and modern slavery laws. However, we remain committed to never knowingly dealing with any organisation connected to slavery, human trafficking, or child exploitation.
Training, Communication and Raising Concern
Napp Pharmaceuticals Limited aims on an ongoing basis to continue to equip those employees involved in procurement activities, with both the knowledge and understanding of the importance of the Act and the roles that employees play in helping to eradicate modern slavery and trafficking. Human rights concerns (and in particular any form of forced labour, child labour, slavery, or human trafficking) are specifically mentioned in our Third-Party Code of Conduct as practices that we require our suppliers to prohibit.
Napp Pharmaceuticals Limited has an environment which encourages open and frank two-way communication, and its employees are encouraged and expected to raise any concerns of known or suspected violations of its Code of Business Ethics or of 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 Integrity Line at integrityline.mundipharma.com. which is available 24 hours a day. Any concern raised will be fully investigated and acted upon as appropriate.
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, human trafficking or child exploitation taking place within our organisation. Furthermore, we shall ensure that the employment agencies that we deal with are also fully compliant with the applicable legislation.
It is our aim to not work with any supplier that we suspect is connected in any way with slavery, human trafficking, or child exploitation. As part of our compliance programme, we take steps to assure ourselves that we only partner with third parties who act ethically, compliantly and within the laws of the jurisdiction in which they operate. We operate a risk-based due diligence procedure covering third party relationships or partners. The due diligence process involves assessing the third party, where appropriate, through completion of a questionnaire, business justification review and background checks (including screening against watchlists and adverse media) on third party organisations.
Any suspected breach of our compliance programme or of our Third-Party Code of Conduct, including the Act, will be investigated and such investigations could lead to the termination of supplier contracts and other actions as appropriate.
Napp Pharmaceuticals Limited is not aware of any slavery, human trafficking or child exploitation taking place in its business.
Due diligence activities during the financial year ending 31st December 2022 did not identify any instances of slavery, human trafficking, or child exploitation within the businesses of its suppliers, customers, or service providers.
Napp Pharmaceuticals Limited will continue to raise awareness, apply, and monitor appropriate risk-based due diligence processes to supplier relationships as part of its ongoing compliance programme in order to mitigate the risk of modern slavery.
This Statement was approved by the Board of Napp Pharmaceuticals Limited on 29 June 2023.