Perrigo – Modern Slavery Statement - Reporting Year 2018
The Perrigo Company plc (“Perrigo”) is dedicated to making lives better by bringing "Quality, Affordable Self-care Products™" that consumers trust everywhere they are sold. The Company is a leading provider of over-the-counter health and wellness solutions that enhance individual well-being by empowering consumers to proactively prevent or treat conditions that can be self-managed. Visit Perrigo online at http://www.perrigo.com.
Group Statement and Structure
Perrigo is a publicly traded Irish corporation headquartered in Dublin Ireland and traded on the NYSE and TASE. We currently operate in over 35 countries including the United Kingdom, the United States of America, throughout Europe and other sites in Latin American and the Asia Pacific region. For more information, visit Perrigo online at http://www.perrigo.com.
Perrigo maintains a robust supply chain with operational facilities and factories in approximately 10 countries. In addition, we source products, raw materials, packaging, and other goods/services from partners and suppliers around the globe.
The following commitment and statement on Modern Slavery is a group statement, pertaining to Perrigo plc and its multiple global subsidiaries. This includes, but not limited to, Perrigo’s Consumer Self-Care America (CSCA) subsidiary in North America, as well as the following subsidiaries operating in the United Kingdom during reporting year 2018:
- Galpharm International Limited
- Rosemont Pharmaceuticals Limited
- Wrafton Laboratories Limited
- Omega Pharma UK Ltd
Policies and Commitments
Perrigo continues to have a zero-tolerance stance on human trafficking, modern slavery and any other form of human rights abuse and exploitation. Perrigo maintains a public commitment to Human Rights, and provides annual progress and program updates via the Corporate Social Responsibility Report.
Perrigo’s Supplier Code of Conduct applies to all subsidiaries. It outlines and details our requirements for suppliers and business partners, which explicitly prohibits the use of child, forced or trafficked labor of any kind, among many other health, safety and ethical labor requirements.
Similarly, our Code of Conduct applies to all employees and highlights our commitment, at a minimum, to adhering to our core values of Integrity, Respect and Responsibility while complying with all laws and regulations in the jurisdictions in which we operate.
Additional policies, procedures and employee handbooks may also be available at the subsidiary level to further support and define any unique customer or business requirements beyond what is covered in our corporate Codes.
During 2018, both the Code of Conduct and Employee Handbooks received minor updates, which prompted training for employees. Furthermore, the annual Corporate Social Responsibility report was published, highlighting successes and opportunities as it relates to our employees and supply chain human rights.
For more information on commitments and reporting, visit: https://www.perrigo.com/promoting-human-rights-everywhere-we-operate
Due Diligence and Risk Assessment
For Perrigo owned plants and operations, all employees are trained on, and expected to adhere to, our Code of Conduct, employee handbook, and various policies that outline an employee’s behavioral expectations, such as the Positive Work Environment and Harassment Policies. To help ensure any such violations are reported, Perrigo maintains Ethics Point, a 3rd party grievance and whistleblowing line where any employee around the globe can anonymously report anything of a suspicious or non-compliant nature. Any grievances are formally reviewed and investigated per a defined procedure, while maintaining a formal policy that prohibits any form of retaliation. These are in addition to dedicated ethics and human resource representatives, located both locally and corporately, as well as periodic 3rd party surveillance audits.
Perrigo’s Ethical and Social Compliance (E&SC) program is specific to suppliers and business partners around the globe. It starts with the Supplier Code of Conduct, which is distributed to our suppliers around the globe to ensure Perrigo’s expectations are communicated. Then, as a new supplier or partner enters Perrigo’s supply chain, they undergo a risk assessment, which takes into consideration the brand, label, product, the production activity that occurs, and the country in which production occurs. Results of this assessment may initiate a prequalification audit as part of due diligence, as well as, or in addition to, a self-assessment.
Due to the nature of the store brand, OTC business, Perrigo is also subject to various ethical trade requirements from retailer customers. Retailer standards also prohibit illegal and unethical activities, such as modern slavery, with many requiring additional audits to be conducted.
All employees are required to be trained on Perrigo’s Code of Conduct, the Grievance Hotline, the Positive Work Environment Policy, Harassment Policy, and any other pertinent ethical or human resource policy at the start of employment, and on a regular pre-determined frequency thereafter. Training is documented in an electronic Learning Management System, which helps ensure no employee is overlooked. Additionally, to reinforce our expectations against modern slavery and other human rights violations, relevant directors, key employees and suppliers are provided training, materials, signage and support as appropriate.
This process continued during 2018, as all new and existing employees received any pertinent training during orientation, and/or at the pre-established interval.
Due to Perrigo’s zero tolerance approach, our goal is to never have an occurrence, of any form, of modern slavery or related critical issue. Further to this, our goal is to regularly monitor and/or prequalify factories in scope of the risk assessment through a 3rd party vendor.
During 2018, over 70 third party ethical and social compliance audits were conducted of Perrigo and supplier factories globally. While occasional observations were found, none were relating to modern slavery, child labor, or any such critical in nature. Corrective and preventative actions were additionally implemented to address any gaps or remediate any observations.
Additionally, more Perrigo sites and suppliers were added into the Sedex system, notably for North America. Perrigo U.K. continues to use the Sedex system as a primary method for managing and collaborating with relevant stakeholders.
This statement has been approved by the Board, and is made pursuant to relevant legal requirements within the United States and section 54(1) of the U.K. Modern Slavery Act 2015, which constitutes Perrigo’s slavery and human trafficking statement for the financial year ending 2018.
President and Chief Executive Officer
Perrigo Company PLC