Our Responsibilities

AUGUST 2022

A) Organisation

This statement applies to Flynn Pharma Limited (referred to in this statement as ‘the Organisation’).

B) Organisational Structure

Flynn Pharma Limited operates within the UK and Republic of Ireland from a single office-base in Stevenage, England, and from where the senior management and executive directors are based.

The Stevenage office provides the base for all of Flynn’s administrative operations including supply chain
management, sales and marketing, distribution, finance and general management. The majority of staff on the Stevenage site are directly employed on full UK employment contracts in accordance and in compliance with all relevant UK laws. The company’s sales staff are primarily employed through UK-based contract sales organisations (CSO) under contracts with the CSO.

C) Definitions

The Group considers that modern slavery encompasses:

• Human trafficking;
• Forced work, through mental or physical threat;
• Being owned or controlled by an employer through mental or physical abuse or the threat of abuse;
• Being dehumanised, treated as a commodity or being bought or sold as property;
• Being physically constrained or to have restriction placed on freedom of movement.

D) Committment

Flynn Pharma acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. Flynn Pharma understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.

Flynn Pharma does not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.

No labour provided to Flynn Pharma in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The Group strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in the UK and in Germany where the Group owns a wholly owned subsidiary.

E) Supply chains

In order to fulfil its activities, Flynn Pharma’s main supply chains include those related to the manufacture and supply of a range of prescription pharmaceuticals supplied to the Group’s domestic markets and occasionally to other countries in which the Group is not present, through export partners. We understand that Flynn Pharma’s first-tier suppliers are intermediary traders and therefore have further contractual relationships with lower-tier suppliers.

F) Potential exposure

Flynn Pharma considers its main exposure to the risk of slavery and human trafficking to be exceptionally low and where it does exist, to be limited in potential and theory only to the upstream sourcing of ingredients and other components that might contribute to or be required in the manufacture and packaging of products manufactured on our behalf.

In general, Flynn Pharma considers its exposure to slavery/human trafficking to be very limited. Nonetheless, it has taken steps to ensure that such practices do not take place in its business nor the business of any organisation that supplies goods and/or services to it.

G) Steps

Flynn Pharma carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its organisation or supply chains, including conducting a review of the controls of its suppliers.

Flynn Pharma has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.

In accordance with section 54(4) of the Modern Slavery Act 2015, Flynn Pharma is mindful to both the need and its responsibilities and going forward, in the conduct of its business, will have particular regard to:

• reviewing our supplier contracts to include termination powers in the event that the supplier is, or is suspected, to be involved in modern slavery;
• ensure measures are in place to identify and assess the potential risks in supply chains;
• undertake impact assessments of our services upon potential instances of slavery;
• create action plans to address risk to modern slavery;
• take actions to embed a zero tolerance policy towards modern slavery