Modern Slavery Statement | ClarusONE Sourcing

In accordance with section 54 of the Modern Slavery Act 2015 ClarusONE Sourcing Services LLP
("ClarusONE") publishes this UK Modern Slavery Act Statement (this "Statement") on its corporate
website and the UK Government’s ‘Modern Slavery Statement Registry’ for the fiscal year ended 31
March 2021. This Statement is approved by its Members

UK Modern Slavery Act Statement

ClarusONE is committed to good corporate citizenship and the highest ethical standards. To fulfil these
requirements, ClarusONE has established and maintains appropriate measures to ensure that slavery
and related human trafficking do not form part of its supply chain.

Business and Organisation

ClarusONE, a London-based limited liability partnership organized under the laws of England and
Wales, was established in 2016 and is jointly owned by McKesson Strategic Services Limited and
WMGS Europe Limited (each a "Member" and collectively the "Members"), which are wholly-owned
subsidiaries of McKesson Corporation ("McKesson") and Walmart, Inc. ("Walmart") respectively (each
a "Service Recipient" and collectively the "Service Recipients").

ClarusONE provides strategic pharmaceutical sourcing services for its Service Recipients to ensure that
both Service Recipients and their respective affiliates have access to generic pharmaceutical products
to meet customer demand at a competitive market cost.

McKesson (and its affiliates, which together are the “McKesson Group”) is a global leader in healthcare
supply chain management solutions, retail pharmacy, community oncology and specialty care, and
healthcare information technology.

Walmart (and its affiliates, which together are the “Walmart Group”) is engaged in retail and wholesale
operations in various formats around the world, and many of its operations include pharmacies.

ClarusONE's core operations are the services it provides to its Service Recipients and generic
pharmaceutical product suppliers, which include:

Soliciting, evaluating and negotiating product offers and contract terms;
issuing contract awards that establish the terms pursuant to which its Members may place purchase orders with suppliers; and
coordinating with the Service Recipients to forecast product demand and ensure customer needs are met

ClarusONE does not

have the authority to make purchasing commitments on behalf of its Service Recipients,
purchase products from product suppliers on its own account nor
does it take legal title to or possession of the products.

Accordingly, the product suppliers with which ClarusONE interacts on behalf of its Service Recipients in
the course of its core operations, namely the provision of strategic pharmaceutical sourcing services,
do not form part of ClarusONE's own supply chain.

The majority of ClarusONE’s personnel are employees seconded from either a Member or a Member
affiliate, with a low number of contracted workers as temporary resources, each engaged by ClarusONE
through a third party. Therefore, ClarusONE does not have any direct employees of its own.

Other than the aforementioned contracted workers, ClarusONE does not currently outsource any parts
of its core operations.

Values and Training

As a provider of strategic sourcing services in the pharmaceutical market, ClarusONE takes its social
responsibility seriously and is strongly committed to respecting applicable international human rights
and fair labour practices and explicitly condemns all kinds of slavery or human trafficking.

Both the McKesson Group and Walmart Group have implemented codes of conduct (each, a "Code of
Conduct" and collectively, the "Codes of Conduct") within their respective organisations, which
provide the guidelines for ClarusONE's interactions among its personnel and contractors as well as with
affiliates, customers, suppliers and other business partners. The ethical principles that are the basis of
the Codes of Conduct are at the heart of every decision ClarusONE makes.

The McKesson Group's Code of Conduct can be viewed at the following link:
https://www.mckesson.com/documents/investors/mckesson-code-of-conduct/

The Walmart Group's Code of Conduct can be viewed at the following link:
https://www.walmartethics.com/content/walmartethics/en_us/statement-of-ethics.html

ClarusONE commenced preparing a new ‘Modern Slavery Prevention Policy’. This new policy shall be
formally implemented during ClarusONE’s fiscal year ending 31 March 2022, which underlines
ClarusONE’s commitment to tackling modern slavery.

ClarusONE's personnel are encouraged to raise concerns, including potential violations of: (i) the Codes
of Conduct; (ii) internal policies and procedures; and (iii) the laws of the countries in which ClarusONE
operates. ClarusONE provides different resources to which concerns can be raised. This includes an
independent third party to whom concerns can be raised anonymously. ClarusONE does not tolerate
any form of retaliation for raising concerns in good faith, asking questions or participating in an
investigation

ClarusONE and the Members conduct web-based and/or in person trainings for personnel to emphasize
the importance of acting with integrity and consistently with the Codes of Conduct and relevant
applicable laws and internal policies. In the fiscal year ended 31 March 2021, all ClarusONE personnel
received awareness training on the UK Modern Slavery Act and its implications to ensure a high level
of understanding of the risks of modern slavery and human trafficking.

Supply Chain and Due Diligence

In order to assess the risk of modern slavery in its supply chains, ClarusONE commenced a risk
assessment considering the organisational structure of ClarusONE, its operational model and
recruitment and employment practices. Based on the outcome of that risk assessment, ClarusONE will
continue to take appropriate steps to tackle slavery and human trafficking and to mitigate and manage
potential risks.

ClarusONE's principal supplier agreements include language that requires ClarusONE's suppliers to
comply with all applicable laws that relate to their interactions with ClarusONE

Effectiveness

ClarusONE believes its efforts to date have been appropriate in preventing slavery and human trafficking
from entering ClarusONE’s supply chains.

COVID-19 Pandemic

ClarusONE is aware that the unique and unprecedented set of challenges brought about by the Covid-
19 pandemic that has continued into the current financial year might still lead to an increase in modern
slavery as businesses continue to adapt to the situation. ClarusONE has continued taking steps to
manage the changing risks as they emerged to guard against modern slavery incidents happening within
its organisation.

In line with UK Government guidance, ClarusONE continued to facilitate homeworking for its personnel
during the fiscal year and all non-essential travel and face to face meetings remained suspended. To
the extent personnel voluntarily attended the office, personnel were required to follow ClarusONE’s
office safety guidelines which complied with UK Government guidance.

ClarusONE personnel received regular written, individual and group video-conference communications
from ClarusONE’s Leadership team about the business throughout the fiscal year. All usual recruitment
checks were carried out virtually and all personnel continued to have access to usual support or
grievance procedures and escalation routes were unchanged.

ClarusONE worked closely with its suppliers throughout the period to help to source essential medicinal
products for and on behalf of its Service Recipients to minimise disruptions in the Service Recipients’
own supply chains and ensure the supply of essential medicines was available to customers and end
users.

ClarusONE continuously monitors the situation and reviews all existing measures in line with UK
Government guidance. ClarusONE’s Board (consisting of representatives from its Members) and
Leadership team has been kept up to date throughout the pandemic regarding risk levels and is actively
involved in determining any adjustments that need to be made to existing measures to help protect
ClarusONE’s personnel.

Going Forwards

In the upcoming financial years, ClarusONE intends to carry out the following steps to further combat
slavery and human trafficking:

continue to monitor the risk landscape within the context of ClarusONE’s core operations and adapt ClarusONE’s risk assessment and mitigation actions accordingly;
continue to monitor the legal landscape within the UK and implement any additional measures as appropriate;
launch and raise awareness of the new ClarusONE Modern Slavery Prevention Policy;
continue periodic training for ClarusONE personnel to help ensure a high level of understanding of the risks of modern slavery and human trafficking;
maintain ClarusONE’s workplace safety measures as required to help keep its personnel safe in response to the evolving Covid-19 pandemic.

This Statement is made pursuant to Section 54 of the Modem Slavery Act 2015 and constitutes
ClarusONE's slavery and human trafficking statement for its financial year ended March 31, 2021.

Statement of approval

This Statement has been approved by the Members of ClarusONE Sourcing Services LLP:

Please click here to view our 2019 version of the UK Modern Slavery Act Statement

Please click here to view our 2020 version of the UK Modern Slavery Act Statement