Modern Slavery Statement - Reporting Year 2021
Perrigo Company plc (NYSE: PRGO) is a leading provider of 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. Led by its consumer self-care strategy, Perrigo is the largest store brand OTC player in the U.S. in the categories in which it competes through more than 9,000 SKUs under customer 'own brand' labels. Additionally, Perrigo is a Top 10 OTC company by revenue in Europe, where it markets more than 200 branded OTC products throughout 28 countries.
Group Statement and Structure
Perrigo is a publicly traded Irish corporation headquartered in Dublin Ireland. We currently operate in over 28 countries including the United Kingdom, the United States, Europe and Asia Pacific regions. For more information, visit Perrigo online at http://www.perrigo.com.
Perrigo maintained production sites in 10 countries before divesting its RX division in 2021, and in 9 countries after the divestiture, the largest of which 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 plc and its multiple global subsidiaries. This includes, but not limited to, Perrigo’s Consumer Self-Care America (CSCA) subsidiary in North America and the following subsidiaries operating in the United Kingdom during reporting year 2021:
• Galpharm International Ltd
• Wrafton Laboratories Ltd
• Omega Pharma Ltd
• Ranir Ltd
• Solent Oral Care Ltd
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 being 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 3rd parties doing business on our behalf.
Like previous years, Perrigo maintains a zero-tolerance stance on any form of human rights abuse, discrimination or exploitation. This includes but is not limited to human trafficking & modern slavery, child & 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 (formerly Supplier Code of Conduct) applies to all subsidiaries and suppliers. 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, in 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 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 Corporate Social Responsibility 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 uses due diligence to identify and/or prevent human rights issues from entering our supply chain, as well as remediate any issues 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, Positive Work Environment, Harassment, Anti-discrimination and other related policies. Perrigo also employs the use of a 3rd party grievance and whistleblowing line where any global employee can anonymously report a concern. Grievances are formally reviewed and investigated per a defined procedure, while anonymized summary data from Ethics Point is reviewed for continual improvement. 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 E&SC program is specific to suppliers and business partners around the globe. It starts with the Supplier Ethical Standards, which is distributed to global suppliers 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, 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 are required to train 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 in most areas, 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.
2021 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 180 third party ethical/social audits and over 70 self-assessments of its supply chain in 2021. While more than 5 different types of audits were conducted, Sedex/SMETA continued to be our dominate and preferred audit protocol. This audit count does not include first party assessments by our dedicated audit teams.
Relatively minor non-conformances continued to be identified during some of these audits, however no concerning findings were found relating to modern slavery, child labor, or any related such critical finding. When non-conformances are identified, corrective actions were put in place to remediate them, even if minor.
Our Consumer Self-Care America division (CSCA) continued to increase their usage of the Sedex platform throughout the supply chain, in addition to supporting other customer audit programs. Perrigo U.K. continued to use Sedex as their primary platform, having Tier 1 sites to complete a self-assessment questionnaire (SAQ) on Sedex, with those in higher risk countries having an independent audit in place prior to approval. Sedex is the world’s largest collaborative platform for companies to share responsible sourcing data and progress.
In terms of policy and training updates, the Supplier Code of Conduct was renamed as the Supplier Ethical Standards during its most recent update in 2021 and included expanded sections of Modern Slavery and other related ethical concerns.
Looking forward, 2022 and 2023 are expected to see several enhancements to our E&SC program. We have established dedicated new resources to E&SC in early 2022 with the intent of enhancing the current program by way of supplier training and standardizing global processes. Additionally, several of our customers have introduced or revised their responsible sourcing programs, which has been increasing the number of audits and overall supply chain engagement. We continue to be committed to prequalify, monitor, remediate and enforce E&SC throughout our supply chain.
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 2021.
Murray S. Kessler
President and Chief Executive Officer
Perrigo Company plc
Previous Year Statements