Modern Slavery Statement - Reporting Year 2019
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, Europe and other sites in the Latin America and Asia Pacific regions. For more information, visit Perrigo online at http://www.perrigo.com.
Perrigo maintains a robust supply chain with production plants 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, Ranir, which was recently acquired during 2019, and the following subsidiaries operating in the United Kingdom during reporting year 2019:
- Galpharm International Ltd
- Rosemont Pharmaceuticals Ltd
- Wrafton Laboratories Ltd
- Omega Pharma UK Ltd
Policies and Commitments
Like previous years, Perrigo maintains a zero-tolerance stance on human trafficking, modern slavery and any other form of human rights abuse, discrimination or exploitation. Perrigo is proudly committed to Human Rights, both in our own operations, as well as with our business partners and suppliers. Perrigo’s annual Corporate Social Responsibility Report will provide additional yearly updates.
Perrigo’s policies and commitments to Human Rights and Modern Slavery remain consistent with last year. 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, 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, 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. Perrigo policies and codes are monitored and updated with regular frequency.
For more information on commitments and reporting, visit: https://www.perrigo.com/promoting-human-rights-everywhere-we-operate
Due Diligence and Risk Assessment
Our due diligence and risk assessments for 2019 also remain consistent with 2018. 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. Grievances are formally reviewed and investigated per a defined procedure, while maintaining a formal policy that prohibits any form of retaliation. Overall anonymized data from Ethics Point is additionally 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 Ethical and Social Compliance (E&SC) program is specific to suppliers and business partners around the globe and continued just as strong in 2019. Like previous years, it starts with the Supplier Code of Conduct, which is distributed to global suppliers to ensure Perrigo’s expectations are communicated. As new suppliers or 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. This process continued during 2019.
Measuring Effectiveness for 2019
Due to Perrigo’s zero tolerance approach, our goal is to never have an occurrence of modern slavery or related critical issue in any form. Further to this, our goal is to actively monitor and/or prequalify factories in scope of our risk assessment through a qualified 3rd party audit firm.
During 2019, more than 85 third party E&SC audits were conducted of factories within Perrigo’s supply chain, an increase of 15 audits from 2018. This does not include social audits conducted by Perrigo employees, nor the 110 self-assessments by the factories themselves. While these audits can, and have, produced findings, none were relating to modern slavery, child labor, or any such critical in nature. In cases of an audit finding, corrective and preventative actions were implemented to remediate any gaps or observations.
Additionally, Perrigo North America added another 18 sites and suppliers into the Sedex platform, while Perrigo U.K. continues to use Sedex as their primary scheme with relevant stakeholders. Sedex is the world’s largest collaborative platform for companies to share responsible sourcing data and progress.
Looking forward, our human rights and modern slavery commitments, policies and programs will continue into 2020. We will continue to look for additional improvement opportunities, such as integrating Ranir into Perrigo policies and standards, updating the Supplier Code, and inclusion of more factories into the E&SC program that meet the risk profile.
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 2019.
Murray S. Kessler
President and Chief Executive Officer
Perrigo Company plc
Previous Year Statements