Modern Slavery Statement

The Statement is made in accordance with Section 54 of the Modern Slavery Act 2015.

Overview - Organisational Structure and supply Chains

Grünenthal Limited (“Grünenthal UK”) is a distributor of pharmaceutical products within the United Kingdom, registered at Regus Lakeside House, 1 Furzeground Way, Stockley Park East Uxbridge, Middlesex, UB11 1BD. We are a part of the Grünenthal group of companies (“Group”), and our parent company is based in Aachen, Germany.

As a science-based, privately-owned pharmaceutical company, Grunenthal Group has a long track record of bringing innovative treatments and state-of-the-art technologies to people living with pain worldwide. Grunenthal Group is a fully integrated pharmaceutical company that offers support along the entire value chain – from drug development through to commercialisation.

To bring it to life, we execute our strategy and work on our company’s culture. We do that by giving our teams around the world a shared set of values that provide clarity about how we want to work together to achieve successful outcomes for our company and our patients. Our values, supported by specific behaviours, guide our decision making and give a clear indication of how we behave – as individuals and as an organisation. We want to bring our values and behaviours to life in everything we do – everyday, everywhere, every one of us.

Policies in relation to slavery and human trafficking

Code of Conduct for Business Partners

In order to protect Grünenthal against liability risks and reputational damage, we assess the integrity of our Business Partners worldwide. We can considerably reduce our risk of exposure by having a documented and clearly structured process in place that provides for a risk classification, a risk-based handling and a monitoring process We have defined processes in assessing low, medium and high risks and mitigate those accordingly.

Additionally, our UK Value and Behaviours Statement sets out a number of principles including our commitment to integrity.

Due Diligence & Risk Assessment and Management

As part of our compliance programme, we assess our business partners on a regular basis to assess whether they act ethically, compliantly and within the laws of the jurisdiction in which they operate. This process includes screening for high risk and/or potentially sanctioned business partners.

We have a number policies including Trade Secrets, Anti-money laundering and Third Party Due Diligence.

Third Party Due Diligence is conducted for third parties including, but not limited to, suppliers, vendors, contractors, agencies, distributors, wholesalers, investors, customers from the contract manufacturing business, licensed partners, healthcare professionals, healthcare organizations, patient organizations, etc. We trigger the risk assessments of our existing and potential partners using a number of factors (e.g. abstract risk level, Expected Spend, time since last Due Diligence).

We analyse the risks within our own business and our supply network based upon the industry in which we operate and the geographical locations in which we conduct business. Due to the nature of our business, we currently consider ourselves to be at low risk of exposure to slavery, human trafficking or child exploitation. We are not aware of any areas in our operations likely to lead to a breach of human rights and modern slavery laws.

Reporting Concerns

Any concern can be raised in confidence without fear of retaliation, by approaching Management, HR or Compliance. Alternatively, colleagues may report their concern via an Ethic Hotline. Any concern raised will be fully investigated and acted upon as appropriate.

Conclusion

Grunenthal UK Limited is not aware of any slavery, human trafficking or child exploitation taking place in its business.

Due diligence activities during the financial year ending 31st December 2020 did not give reason to suspect any instances of slavery, human trafficking or child exploitation within the businesses of its suppliers, customers or service providers.

This Statement was approved by the Leadership Team of Grunenthal UK Limited April 2021.