Modern Slavery Statement - Reporting Year 2020
Perrigo Company plc is a leading provider of Quality, Affordable 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 5 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 and traded on the NYSE and TASE (PRGO). 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.
In 2020, Perrigo maintained production sites in 10 countries, 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 2020:
- Galpharm International Ltd
- Wrafton Laboratories Ltd
- Omega Pharma UK Ltd
- Ranir Ltd
- Solent Oral Care Ltd
Human Rights Policy and Commitments
A respect for 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 strive 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 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 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-rightseverywhere-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 and other related policies. Perrigo also employs the use of EthicsPoint, a 3rd party grievance and whistleblowing line where any global employee globe 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 glove. 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.
2020 Program Update
Despite the disruptions caused by COVID-19, Perrigo continued to exercise due diligence and annual monitoring, leveraging virtual audits, desktop reviews and self-assessments where allowed and where appropriate. Perrigo conducted more than 115 third party ethical/social audits of its supply chain in 2020, primarily using Sedex/SMETA and BSCI audit protocols. This does not include first party audits conducted by Perrigo employees, nor self-assessments conducted by the factory themselves.
While non-conformances were identified in several of these audits, 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, with additional audits performed as appropriate to verify the completion and effectiveness.
The Ranir Ltd business started integration into the E&SC program by adopting the Perrigo Supplier Code of Conduct and continuing to perform it’s BSCI and Sedex audits. Perrigo North America continued to enhance their usage of the Sedex platform, often through the new virtual SMETA audit while Perrigo U.K. continued to use Sedex as their primary web-based platform to monitor and manage E&SC compliance performance. 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 officially updated late in 2020 with expanded sections and an additional Modern Slavery awareness training program was developed in 2020. Both with an expected 2021 rollout.
Looking forward, our human rights and modern slavery commitments, policies and programs will continue into 2021 with the goal of zero instances of Modern Slavery or human rights abuse. We will continue to monitor the COVID impact, while looking for improvement opportunities, distribution of the updated Supplier Code of Conduct, the roll-out of newly developed training 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 2020.
Murray S. Kessler
President and Chief Executive Officer
Perrigo Company plc
Previous Year Statements