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 2019.
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, it has not adopted its own code of conduct or related policies and procedures. 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.
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 employees and contractors as well with affiliates, customers, suppliers and other business partners.
McKesson's Code of Conduct can be viewed at the following link: http://www.mckesson.com/uploadedFiles/McKessoncom/ContenV Documents/lnvestors/CQ de%20of%20Conduct.pdf
Walmart's Code of Conduct can be viewed at the following link: https://www.walmartethics.com/uploadedFiles/Content/U.S.%20-%20Enqlish.pdf
The ethical principles that are the basis of the Codes of Conduct are at the heart of every decision ClarusONE makes. ClarusONE's employees are encouraged to raise concerns, including potential violations of: (i) the Codes of Conduct; (ii) ClarusONE policies; 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 conducts web-based and/or in person trainings for employees 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, upon request, 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.
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, 2019.
Statement of approval
This Statement has been approved by the Members of the Partnership: