Modern Slavery Statement
To download a PDF copy of the Modern Slavery Statement please click here.
This statement is made in accordance with Section 54(1) of the UK Modern Slavery Act 2015. It sets out the steps Indivior has taken and will be taking to prevent modern slavery and human trafficking in its business and supply chain.
Indivior is a global specialty pharmaceutical company with a longstanding legacy of leadership in patient advocacy and health policy while providing education on evidence-based treatment models that have revolutionized modern addiction treatment. Indivior is dedicated to transforming addiction from a global human crisis to a recognized and treated chronic disease.
The Group manufactures and markets buprenorphine medication-assisted treatments, which are increasingly recognized as an effective and evidence-based treatment for opioid use disorder. In 2019, the Group expanded its product portfolio by launching a medicine for the treatment of schizophrenia in adults in the US and has a licensing agreement to bring this treatment to patients suffering from schizophrenia in Canada.
The Group operates a fine chemical plant in Hull (UK). It has research and development facilities in Hull and Fort Collins, Colorado (USA). Its US headquarters are located in Richmond, Virginia and it maintains a corporate, sales and marketing office in Slough (UK). The Group has an able workforce and management team with a deep understanding of patient needs and a strong commitment to patient lives. Indivior has a global presence in over 40 countries. Indivior PLC is listed on the London Stock Exchange. On 31 December 2019, the Group had 796 employees, 532 of which were based in the United States of America.
Indivior believes that human rights are an absolute and universal standard. The Group is opposed to all forms of human slavery and trafficking and will not do business with any organisation that it knows to be involved in these activities.
The Group’s Code of Conduct, Doing The Right Things Right, includes a specific commitment to adhere to the provisions of the United Nations Universal Declaration of Human Rights and the Convention on the Rights of the Child, the OECD Guidelines for Multinational Enterprises and the UK Modern Slavery Act 2015. Article four of the United Nations Universal Declaration of Human Rights specifically prohibits slavery and the slave trade in all their forms and this is specifically highlighted within the Code. The Code of Conduct applies to the Group’s workforce globally. It is the Group’s policy that all employees and contractors receive induction training about these requirements when commencing work.
Indivior also has a confidential reporting and guidance tool, the Indivior EthicsLine, through which employees and contractors may report concerns or seek guidance on applicable Indivior policies. The EthicsLine may be used to report wrongdoing, including possible human rights violations. All reports are fully investigated and appropriate remedial action is taken.
Indivior’s supply chain consists of businesses involved in the manufacture, assembly and distribution of the Group’s products. It also includes companies that supply Indivior with a variety of business, transport and administrative services. The Code of Conduct states that the Group is committed to proactively encouraging its suppliers and contractors to demonstrate responsible behavior and high standards of business conduct. It does this by the conduct of regular dialogue and interaction with its suppliers and contractors.
Indivior recognizes its responsibility to ensure that its policies and systems robustly exclude slavery and forced labor from the business on an ongoing basis. The Group reviews its approach periodically to ensure that these issues are addressed in line with the requirements of the Modern Slavery Act 2015 and good business practice.
Indivior Integrity & Compliance Program Developments
Indivior demonstrates a commitment to continuous learning and evolution in its Program which is administered by its dedicated Integrity & Compliance department. Highlights in 2019 included;
- the Executive Committee (EC) assumed the role of the Indivior Compliance Committee to support the Chief Integrity & Compliance Officer in the administration of the Indivior Integrity & Compliance Program;
- the department was structured based on Centers of Excellence (COE) with targeted areas of expertise, including Risk Management, Monitoring and Analytics;
- the department inspired a learning organization and risk awareness by sharing insights from its assessments, monitoring and internal reviews, as well as relevant external news, to educate and drive continuous program evolution;
- the department leveraged independent compliance expertise to test, benchmark and inform Indivior’s continued commitment to build and evolve an effective compliance program; and
- within an already strong culture of reporting, management at all levels embraced continued reinforcement of a speak-up culture.
Risk and response
The Group considers that the risk that slavery and human trafficking is taking place within its business or supply chain is low and has uncovered no evidence to indicate otherwise. The Group will act immediately to redress any matter that indicates that this sort of activity is taking place.
The Directors and senior management of Indivior are ultimately responsible for;
- implementing this statement;
- providing adequate resources and investment to minimize the risk of human slavery and trafficking taking place within the business or its supply chain;
- ensuring that the Group’s approach is regularly reviewed; and
- ensuring that the commitments outlined in this statement are adhered to.
Review, publication and feedback
This statement will be reviewed and published annually. Indivior welcomes feedback from any of its stakeholders concerning this statement. This can be submitted to us through the contact details provided on the ‘Contact Us’ page of the Group’s website (www.indivior.com).
This statement was approved by the Nomination & Governance Committee, a committee of the Board of Directors of Indivior PLC, on May 6, 2020.
Chief Executive Officer
Code of Business Conduct
We are committed to responsible corporate behavior which includes high standards of business conduct in our relationships with employees, contractors, customers, shareholders, suppliers, governments, competitors and the local communities in which we operate.
We have put in place a Code of Business Conduct with which all of our employees and contractors are required to comply. The Code of Business Conduct requires our employees and contractors to conduct business ethically and fairly, to comply with laws and regulations and to avoid situations where their personal interests might conflict with the Group’s interests.
Compliance with the Code and associated polices is critical to the success of the Company. As such, adherence to the Code of Business Conduct along with any associated polices and training requirements will be considered in each employee’s annual performance appraisal. Where appropriate, the Company may assign global compliance objectives to employees as part of the annual performance appraisal.
The Code of Business Contact also requires our employees and contractors to comply with the various company policies, which include the key policies referred to below.
The complete Code can be found here: Indivior Code of Business Conduct.
We are committed to observing the laws and regulations which govern our operations in every country in which we do business. Our employees and contractors are required to comply with our Anti-Bribery Policy, which sets out the responsibilities of individuals, rules relating to gifts and hospitality and facilitation payments, political and charitable contributions, as well as potential “red flag” issues.
The complete policy can be found here: Indivior Anti-Bribery Policy.
Diversity and Inclusion Policy
We believe that a diverse workforce enables more relevant innovation, improved quality, and increased speed and efficiency in meeting the various needs of our global patients, customers and stakeholders. We are committed to equality of opportunity in all areas of employment and business regardless of personal characteristics including but not limited to gender, race, nationality, age, disability, sexual orientation or religion. Our policy on diversity is set out in its Diversity and Inclusion Policy, which sets out the key outcomes and practices in relation to diversity and inclusion.
The complete policy can be found here: Indivior Diversity and Inclusion Policy.
Our Whistleblower Policy is designed to enable all employees to raise concerns internally and at a senior level and to disclose information which the individual believes shows malpractice or impropriety within the group. These concerns include:
- Financial malpractice, impropriety or fraud
- Failure to comply with legal obligations
- Dangers to health and safety or the environment
- Criminal activity
- Improper conduct or unethical behavior
- Significant breaches of the Code of Business Conduct
- Attempts to conceal any of these once they have occurred.
The complete policy can be found here: Indivior Whistleblower Policy.