UK MODERN SLAVERY ACT STATEMENT
This Modern Slavery Statement is published by ClarusONE Sourcing Services LLP ("ClarusONE") in
accordance with our obligations under The Modern Slavery Act 2015.
ClarusONE is opposed to all forms of modern slavery and this serious issue must be tackled head on.
This Statement sets out the new and ongoing steps ClarusONE is taking to address and prevent modern
slavery taking place both within our business and our supply chains.
This is our fourth statement and is in respect of the financial year ended 31 March 2022.
BUSINESS AND ORGANISATION
ClarusONE is a London-based limited liability partnership 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, collectively 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, collectively 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 Service Recipients may
place purchase orders with pharmaceutical product suppliers; and
• coordinating with the Service Recipients to forecast pharmaceutical product demand and ensure
their customer needs are met.
ClarusONE does not have the authority to make purchasing commitments on behalf of its Service
Recipients, and ClarusONE does not purchase products from pharmaceutical product suppliers on its
own account neither does ClarusONE takes legal title to or possession of pharmaceutical products.
Accordingly, the pharmaceutical product suppliers with which ClarusONE interacts with 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 the Walmart Group or the
McKesson Group , 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.
OUR VALUES
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 operate under published codes of conduct (each, a "Code
of Conduct" and collectively, the "Codes of Conduct") within their respective organisations. These
Codes of Conduct establish the high standards to which ClarusONE conducts its’ business operations
and 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/Code-of-Conduct-2022/
The Walmart Group's Code of Conduct can be viewed at the following link:
https://www.walmartethics.com/content/walmartethics/en_us/code-of-conduct.html
HOW WE APPROACH MODERN SLAVERY RISKS IN OUR BUSINESS
Policies
In addition to the Codes of Conduct which ClarusONE operates under, a new ‘Modern Slavery
Prevention Policy’ has been formally adopted in September 2021, underlining ClarusONE’s commitment
to tackling modern slavery.
This policy is complemented by a number of other policies which are relevant to Modern Slavery, all
of which are updated and made available to all ClarusONE personnel:
• Absence policy;
• Dignity at work policy;
• Grievance procedure;
• Rules of conduct/disciplinary procedure;
• Work delivery policy;
• Protected leave policy;
• Refer a friend scheme;
• Temporary holiday policy; and
• HR Overseas Working Policy
Risk Assessment
In order to assess the risk of modern slavery in its supply chains, ClarusONE utilises
internationally recognised standards and guidance to conduct a risk assessment, which ensures that
processes and practices are fit for purpose. This risk assessment considers:
• the organisational structure of ClarusONE;
• its operational model; and
• recruitment and employment practices in place during FY22.
The outcome of the comprehensive risk assessment will be presented to the Board of ClarusONE during
the second quarter of the fiscal year ending 31 March 2023. ClarusONE will continue to take
appropriate steps to tackle slavery and human trafficking and to mitigate and manage potential
risks.
Against the criteria assessed, the current indication is a low risk of slavery and human
trafficking from entering ClarusONE’s supply chains.
Training & Awareness
All ClarusONE associates undertake annual training regarding Modern Slavery. The training presents
an opportunity to build awareness and ensure that associates are aware of all of the tools at their
disposal, should they experience any issues relating to Modern Slavery.
GOING FORWARDS
In the upcoming financial year, 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 policy, risk assessment and mitigation actions accordingly;
• continue to monitor the legal landscape within the UK and implement any additional measures, as
appropriate;
• continue periodic training for ClarusONE personnel to help ensure a high level of understanding
of the risks of modern slavery and human trafficking and awareness of ClarusONE’s Modern Slavery
Prevention Policy;
• build awareness through associate communications events through the course of the fiscal year;
and
• continue to monitor and adapt ClarusONE’s workplace safety measures as required to help keep its
personnel safe in line with applicable health and safety laws.
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 31 March 2022.
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
Please click here to view our 2021 version of the UK Modern Slavery Act Statement
