Modern Slavery Statement - Reporting Year 2022
Perrigo Company plc (NYSE: PRGO) is a leading provider of Consumer Self-Care Products and over-the-counter (OTC) health and wellness solutions that enhance individual well-being by empowering consumers to proactively prevent or treat conditions that can be self-managed.
Group Statement and Structure
Perrigo is a publicly traded Irish corporation headquartered in Dublin Ireland. We currently operate in over 31 countries including the United States, United Kingdom, most countries across Europe, and parts of the Asia Pacific region. For more information, visit Perrigo online at http://www.perrigo.com.
Perrigo maintained production sites in 8 countries in 2022, predominantly in the United States. In addition, Perrigo maintains a prominent supply chain where 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 Company plc and its multiple global subsidiaries.
Human Rights Policy and Commitments
Human Rights is a basic principle and value for Perrigo. Our business is based upon the concept of making lives better, and this starts with how our products are made. Perrigo is proudly committed to Human Rights and strives to operate with the highest standards of integrity and excellence. The scope of this commitment applies to all employees of Perrigo globally, as well as any contractors, suppliers, and other third-parties doing business on our behalf.
As in previous years, Perrigo maintains a zero-tolerance stance on any form of human rights abuse, unlawful discrimination, or exploitation. This includes but is not limited to human trafficking and modern slavery, child and prison labor, dangerous working conditions, and other salient issues.
Perrigo’s policies and commitments to Human Rights and programs to prevent Modern Slavery remain consistent with previous years. Perrigo’s Supplier Ethical Standards applies to all subsidiaries and suppliers. It outlines and details our requirements for suppliers and business partners, and 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 adhere to our core values of Integrity, Respect, Responsibility, and Curiosity while complying with all laws and regulations in the jurisdictions in which we operate. Additional policies and procedures 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. Perrigo policies and codes are monitored and updated with regular frequency.
Perrigo’s annual Sustainability and ESG Report provides additional updates and context on our Human Rights commitment and can be found on Perrigo.com. Additionally, for more on our corporate human rights commitment, visit: https://www.perrigo.com/promoting-human-rights-everywhere-we-operate
Due Diligence and Risk Assessment
Perrigo’s Ethical and Social Compliance (E&SC) program applies rigorous due diligence to identify and/or prevent human rights issues from entering our supply chain, as well as remediates any issue that may have been identified.
For Perrigo owned plants and operations, all employees are trained on, and expected to adhere to, our Code of Conduct, Diversity, Equity and Inclusion Policy, Global Non-Discrimination and Anti-Harassment Policy, and other related policies. Perrigo also employs the use of a third-party grievance and whistleblowing line (EthicsPoint) where employees may anonymously report a concern, consistent with local law. Concerns are formally reviewed and investigated per a defined procedure, while anonymized summary data from EthicsPoint is reviewed for continual improvement. These are in addition to dedicated ethics and human resource representatives, at both the local and corporate level, as well as periodic third-party audits.
Perrigo’s E&SC program is specific to suppliers and business partners around the globe. It starts with the Supplier Ethical Standards, which is distributed to all suppliers globally to ensure Perrigo’s expectations are communicated. As new supplier partners enter 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, which constitutes approximately 50% of Perrigo net sales, Perrigo is also subject to various ethical trade requirements from retailer customers. Customer standards also prohibit illegal and unethical activities, such as modern slavery, with many requiring additional audits.
All employees receive mandatory training on Perrigo’s Code of Conduct, including how to use the third-party hotline EthicsPoint, the Diversity, Equity, and Inclusion Policy, the Global Non-Discrimination and Anti-Harassment Policy, and any other pertinent ethical or human resource policy at the start of employment, and on a regular pre-determined frequency throughout their employment. Training is generally documented in an electronic Learning Management System, which helps ensure no employee is overlooked. To reinforce our expectations against modern slavery and other human rights violations, relevant directors, employees, and suppliers are provided additional training, materials, and support as appropriate.
2022 Program Update
Perrigo continued to exercise due diligence and annual monitoring per our E&SC program, despite the ongoing disruptions from COVID-19. Perrigo conducted more than 170 third-party ethical/social audits, more than 50 supplier visits, and over 120 self-assessments of its supply chain in 2022. Sedex/SMETA continued to be our most frequent and preferred audit protocol.
Relatively minor non-conformances continued to be identified during some of these audits, however no evidence was found indicating modern slavery, child labor, or a related critical finding. When non-conformances were identified, corrective actions were put in place to remediate them, even if minor.
Perrigo’s corporate E&SC team upgraded their Sedex membership in 2022, enabling the use of additional tools for assessing supply chain risks. Along with the requirements set forth by Perrigo U.K., additional suppliers and Perrigo’s own manufacturing sites are expected to complete a self-assessment questionnaire (SAQ) on Sedex, the results of which allow Perrigo to properly assess our supply chain risks. Through training and on-site audits, Perrigo is able to mitigate risks identified through the SAQ. Sedex is the world’s largest collaborative platform for companies to share responsible sourcing data and progress.
Perrigo also joined the Pharmaceutical Supply Chain Initiative (PSCI) in 2022 as an Associate Member. PSCI’s purpose is to bring together members to define, establish, and promote responsible supply chain practices, human rights, environmental sustainability, and responsible business. We communicate and adhere to the PSCI Principles for Responsible Supply Chain Management through our Code of Conduct and Supplier Ethical Standards. Membership in PSCI gives Perrigo additional insight into the global pharmaceutical supply chain and provides industry specific risk mitigation tools and strategies.
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 2022.
Murray S. Kessler
President and Chief Executive Officer
Perrigo Company plc
Previous Year Statements