2023 Modern Slavery and Human Trafficking Policy Statement

Company Director’s Introduction 

Ensuring slavery and human trafficking is eradicated is a responsibility in which we all have an important role to play, especially within the pharmaceutical industry, whether that’s decision making to cease using suppliers not conforming with ethical standards, reporting slavery or human trafficking practices, or protecting whistleblowers. Our ethical mission at Luye Pharma Limited is to work responsibly to respect all human rights, and not tolerate slavery or human trafficking within our business or our supply chains. 

This statement is intended to show the steps Luye Pharma Limited takes and our plans for continued improvement to ensure that slavery and human trafficking is not taking place in any of our supply chains or any part of our business in compliance with part 6, section 54 of the Modern Slavery Act 2015. 

Our Organisation Structure, Business and Supply Chains 

Luye Pharma Limited is a private limited company, founded on September 2018, that offers a range of branded and generic medicinal products. Luye Pharma Limited is committed to providing quality products primarily to the British market with its registered office at Unit 11a, Surrey Technology Centre 40 Occam Road, Surrey Research Park, Guildford, Surrey, United Kingdom, GU2 7YG. Luye Pharma Limited employees include marketing, sales, supply chain, consultants and contracted companies providing services such as Pharmacovigilance and Medical Information. Luye Pharma Limited has approximately 2 direct suppliers with manufacturing sites based in the United Kingdom and Europe and who comply with ethical standards. Luye Pharma Limited primarily distributes products to responsible wholesalers, hospitals and pharmacies within the United Kingdom. 

The main risk of slavery and human trafficking lies within Luye Pharma Limited’s supply chains, with suppliers and vendors operating in UK and in third countries such as Germany, which is mitigated by our due diligence processes. 

Our Policies 

Luye Pharma Limited is committed to protecting its employees, and all those affected by its business activities and involved in its supply chains from slavery, servitude, forced or compulsory labour and human trafficking. Luye Pharma Limited recognises that these are abhorrent acts and that Luye Pharma Limited and every other company have an ethical responsibility to ensure these practices are not part of their business and supply chains and as such has a zero tolerance policy on slavery and human trafficking. 

Our Due Diligence Processes 

As part of our quality management system, we are committed to ensuring our business as well as our supply chain including our customers, suppliers and vendors comply with ethical standards as well as EU/UK Good Manufacturing Practice, EU/UK Good Distribution Practice and/or the appropriate ISO standard(s) to meet our business requirements. All customers, suppliers and vendors (e.g., freight agents) have the appropriate quality-related credentials for business practices and the majority of them are subject to inspections/audits by local regulatory agencies/notified bodies. We work hard to create long term relationships with all parties within our supply chains in order to enable transparency, and allow for open and honest communication regarding business practices. We also agree prices and lead times in commercial agreements with suppliers to ensure these are attainable while meeting ethical standards. We are committed to the ongoing assessment of our suppliers and vendors, including regular quality audits and in the last fiscal year have continued to work on conducting face to face and/or paper-based audits of them against the required quality standards. We have incorporated our requirements and due diligence process into new and updated commercial agreements with our suppliers and vendors to ensure they comply to ethical standards and commitments against slavery and human trafficking. Luye Pharma Limited works primarily with UK customers, and will only trade with customers that agree to Luye Pharma Limited’s terms and conditions of sale which includes our zero tolerance approach to modern slavery and human trafficking and ethical standards. 

We expect our business and all partners within our supply chains to operate in compliance with ethical values and policies against slavery and human trafficking. In the event that practices of slavery and/or human trafficking are identified within our business and/or supply chains, we will work with the offender to put in place effective corrective and preventive actions within a suitable timeframe, as we believe this is the best approach to educate and spread the message to eradicate slavery and human trafficking. However, for any partners within our supply chain who are not willing to be open and transparent, and stop practices of slavery and/or human trafficking within the required timeframe we will terminate the business relationship. 

Our Training and Awareness 

All staff within Luye Pharma Limited are trained on slavery and human trafficking as part of our annual training, including staff being encouraged to come forward with issues relating to slavery and human trafficking. All staff must read and understand this policy which have been communicated to them through various communications. 

This statement is also available online on Luye Pharma Limited website, https://luye.co.uk/ and can also be provided as a hard copy upon request to complianceUK@luye.com, in order to further educate and make our customers, suppliers and vendors aware of slavery and human trafficking. 

Our Effectiveness and Performance Indicators 

This statement may be reviewed and amended annually by Luye Pharma Limited’s Directors to take into account the steps Luye Pharma Limited has taken and will continue to take against slavery, servitude, forced or compulsory labour and human trafficking each year. To ensure Luye Pharma Limited’s Senior Management Team is aware of any issues and our ethical progress against slavery and human trafficking we have incorporated a review of our effectiveness and performance indicators in relation to this policy into our annual management reviews. 

This statement is made for the current financial year pursuant to part 6, section 54(1), of the Modern Slavery Act 2015.