For the financial year ended 31 December 2022

1.  Chief Executive Officer’s Statement

Morningside Pharmaceuticals Limited (MPL) is committed to preventing acts of modern slavery and human trafficking from occurring within its business and supply chains, including subcontractors and partners. As part of the pharmaceutical industry, MPL recognises that it has a responsibility to take a robust approach to slavery and human trafficking in order to tackle hidden labour exploitation proactively. 

2.  Morningside Pharmaceuticals Limited

MPL is a manufacturer, wholesaler and supplier of branded and generic medicines and healthcare products worldwide. It is our vision to make quality healthcare an affordable and accessible reality throughout the world. MPL acknowledges its responsibility to the Modern Slavery Act 2015 and will ensure transparency within the organisation and with the supply and sale of goods and services to the organisation. MPL’s holding company is RandalSun Capital Limited and all trading activities are carried out through MPL.

3. Our Supply Chains and our Due Diligence                                                     

MPL purchases and manufactures licensed medicines and Healthcare products from the European Union (EU) and other non-EU countries. We believe that the area with a greater risk of these practices is within our Contract Manufacturing Organisations (CMOs) outside the EU.

Following a risk assessment on Anti-Slavery and Human Trafficking, we requested that our CMOs with the ‘Greatest Risk’ complete our Anti-Modern Slavery and Bribery Ethical Self-Assessment Questionnaire, as part of the due diligence process. They are requested to provide information about their policies on human rights, anti-bribery and workplace conditions. As part of this process the Questionnaire was revised and a Supplier Code of Conduct introduced in 2019 to produce a more focussed set of documents with the aim of encouraging prompt completion by our CMOs/suppliers. This was also issued in 2022.

We carried out a further risk assessment of our supply chain in December 2018 using the Global Slavery Index Data Map to identify low, medium and high-risk categories. As a result of our risk assessment, all CMOs and non-EU healthcare product suppliers are sent a Supplier Code of Conduct form to complete and to confirm their compliance with laws and regulations in relation to the provision of their services and the rights and welfare of their workers and the standards MPL expect of them.  For greater risk CMOs/suppliers, or those identified as a result of any concerns, we issue a self-assessment questionnaire and track completion. This activity is scheduled to take place biennially and was carried out in Q4 2022.

4.  Morningside Pharmaceuticals Limited’s Responsibilities and Policies

The CEO, Directors and Management take responsibility for implementing the measures set out in this statement and its objectives, and shall provide adequate resources (training, etc.) and investment to ensure that Modern Slavery and Human Trafficking is not taking place within the organisation and its supply chains. We have in place an Anti-Slavery and Human Trafficking Procedure that sets out the process to be followed in relation to suppliers.

In addition, our Anti-Slavery and Human Trafficking Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and monitoring to ensure slavery and human trafficking is not taking place anywhere in our supply chains. We also have systems in place to enable our workforce to raise concerns through our Grievance Policy, Whistleblowing Policy and our Anti-Corruption and Bribery Procedure.  We ensure compliance with UK legislation in relation to employment of staff and we have zero tolerance to slavery and human trafficking.

5.  Education and Training

The Human Resources Department will take responsibility for ensuring that all MPL employees are aware of MPL’s statement of compliance with the Modern Slavery Act 2015 and its on-going commitments; and must also ensure that this statement is displayed on MPL’s website and an overview of our Anti-Slavery and Human Trafficking Policy is included in the Employee Handbook. MPL will provide comprehensive training via the business’ electronic Learning Management System for all staff and during the employee induction process employees are informed as to where all relevant policies can be located.

Training will be provided to employees and Management at MPL who have direct responsibility for supply chain management, particularly with respect to the mitigation of risks within the supply chain. 

6.   Our Effectiveness in Combating Slavery
and Human Trafficking

A review of existing policies and procedures took place in 2022 and improved measures introduced where necessary. This has enabled us to continue to increase our effectiveness in combatting slavery and human trafficking. MPL is pleased to confirm the above measures have been embedded into the organisation’s processes and a robust system for identifying Modern Slavery and Human Trafficking is in place. We will continue to monitor and review all processes to ensure their effectiveness.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Anti-Slavery and Human Trafficking Statement for the financial year ending 31 December 2022.

Last edited on March 2, 2023

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