The Modern Slavery Act 2015 (the "Act") came into effect on 29 October 2015 and requires those entities carrying on a business or part of a business in the United Kingdom, supplying goods or services, and having annual turnover of £36 million or more, to disclose information regarding the steps they have taken to eradicate slavery and human trafficking from their supply chain as well as within their own organisation during the previous financial year.
ClarusONE Sourcing Services LLP ("ClarusONE") publishes this UK Modern Slavery Act Statement (this "Statement") on its corporate website for the fiscal year ended 31 March 2020.
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 systems and controls 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 wholly-owned subsidiaries of McKesson Corporation ("McKesson") and Walmart Stores, Inc. ("Walmart") ("each a "Member" and collectively the "Members"). ClarusONE provides strategic pharmaceutical sourcing services for its Members to ensure that both Members and their respective affiliates have access to generic pharmaceutical products to meet customer demand at a competitive market cost.
ClarusONE's services include:
soliciting and evaluating product offers;
issuing contract awards that establish the terms pursuant to which its Members may place purchase orders with suppliers;
coordinating with the Members to forecast product demand; and
negotiating and managing incentive arrangements for the benefit of the Members.
McKesson is a global leader in healthcare supply chain management solutions, retail pharmacy, community oncology and specialty care, and healthcare information technology.
Walmart is engaged in retail and wholesale operations in various formats around the world, and many of its operations include pharmacies.
ClarusONE does not have the authority to make purchasing commitments on behalf of its Members, and ClarusONE does not purchase products from product suppliers on its own account. Accordingly, the product suppliers with which ClarusONE interacts on behalf of its Members do not form part of ClarusONE's own supply chain.
Values and Training
ClarusONE does not have any direct employees of its own and it has not adopted its own code of conduct. Instead, personnel seconded to ClarusONE by McKesson must adhere to the policies and procedures of McKesson, and personnel seconded to ClarusOne by Walmart must adhere to the policies and procedures of Walmart. Additional ClarusONE polices have been introduced which cover the personnel of both Members.
Both of ClarusONE's Members 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 with affiliates, customers, suppliers and other business partners.
McKesson's Code of Conduct can be viewed at the following link: https://www.mckesson.com/documents/investors/mckesson-code-of-conduct/
Walmart's Code of Conduct can be viewed at the following link: https://www.walmartethics.com/content/walmartethics/en_us/statement-of-ethics.html
The ethical principles that are the basis of the Codes of Conduct are at the heart of every decision ClarusONE makes. ClarusONE's personnel are encouraged to raise concerns, including potential violations of: (i) the Codes of Conduct; (ii) its Member’s and/or ClarusONE’s policies and procedures; and (iii) the laws of the countries in which ClarusONE operates. There are sophisticated reporting mechanisms in place to collect and relay information regarding potential violations to appropriate resources within ClarusONE and within its Members for review and follow-up.
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.
Supply Chain and Due Diligence
As a provider of strategic sourcing services in the pharmaceutical market, ClarusONE takes its social responsibility seriously and is strongly committed to respecting international human rights and fair labour practices and explicitly condemns all kinds of slavery or human trafficking.
ClarusONE's principal supplier agreements include language that requires ClarusONE's suppliers to comply with all laws that relate to their interactions with ClarusONE, including any applicable national laws regarding human trafficking, forced labour and other forms of modern slavery.
In addition to its own efforts, ClarusONE can, whenever required, rely on the strong support of its Members, who have designed and implemented processes to: (i) assess suppliers of services and products introduced into the supply chain; and (ii) confirm that the policies and procedures of such suppliers are compliant with the Codes of Conduct.
ClarusONE continuously evaluates its monitoring program to ensure its actions are consistent with industry norms and coordinates with the policies and procedures of its Members to leverage their experience and knowledge.
ClarusONE believes its efforts to date have been effective in preventing slavery and human trafficking from entering the supply chain.
ClarusONE is aware that the unique and unprecedented set of challenges brought about by the Covid-19 pandemic could lead to an increase in modern slavery as businesses try to adapt to the situation. ClarusONE began taking steps to manage the risks as they emerged to guard against this happening within its organisation and that of its Members.
Covid-19 risk assessments were undertaken by ClarusONE to help formulate mitigation plans to protect the health and safety of its personnel.
In line with Government guidance, ClarusONE has facilitated homeworking for its personnel, and all non-essential travel and face to face meetings were suspended.
ClarusONE together with its Members are currently reviewing homeworking arrangements to ensure all personnel can continue to work safely from home and is looking to implement further social distancing measures as ClarusONE plans towards re-introducing personnel back into its business premises, initially on a voluntary basis, and only once it is safe enough to do so, in line with Government guidance.
ClarusONE personnel have had regular communications throughout the period, with additional communication being enacted including written communication from their own Member entities and regular group calls within ClarusONE. All usual recruitment checks have been carried out virtually and all personnel have continued to have access to usual support or grievance procedures as they remain available online and escalation routes have been unchanged.
ClarusONE continues to adhere to its Members’ processes during the pandemic, adapting them as necessary in line with Government guidance. For example, right to work checks for new colleagues were undertaken via digital means in accordance with the Government’s temporary process.
ClarusONE has worked closely with its suppliers throughout the period to source essential medicinal products for and on behalf of its Members to minimise interruptions in the Members’ supply chains and ensure the supply of essential medicines to the Member’s customers.
ClarusONE and its Members are continuously monitoring the situation and reviewing all existing measures in line with Government guidance. ClarusONE’s Board (consisting of representatives from its Members) and day to day 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.
In the upcoming financial years, ClarusONE intends to carry out the following steps to further combat slavery and human trafficking:
continuing to support and collaborate with its Members to enhance supplier due diligence processes;
developing a Modern Slavery Policy for ClarusONE which underlines its commitment to tackling modern slavery. It is planned to implement it during the forthcoming financial year.
training ClarusONE personnel to ensure a high level of understanding of the risks of modern slavery and human trafficking;
continuing to develop 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, 2020.
Please click here to view our previous version of the UK Modern Slavery Act Statement