Cohens Group Modern Slavery & Human Trafficking Statement

Introduction

Modern slavery is a crime resulting in an abhorrent abuse of human rights. The term ‘modern slavery’ is used to encapsulate the crimes of slavery, servitude, forced or compulsory labour and human trafficking.

This statement sets out The Cohens Group’s actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year 1st September 2017 to 31st August 2018.

As part of the pharmaceutical industry, The Cohens Group recognises that it has a responsibility to take a robust approach to slavery and human trafficking.

The Cohens Group is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to being transparent in its efforts to ensure that it and its supply chains are free from slavery and human trafficking.

This policy applies to all persons working for The Cohens Group or on its behalf in any capacity. This policy does not form part of any of The Cohens Group’s employees’ contract of employment.

The Cohens Group encourages openness about modern slavery issues and will support any person who raises genuine concerns under this policy in good faith – even if they eventually turn out to be mistaken.

Organisational Structure and Supply Chains

This statement covers the activities of The Cohens Group:

• The Cohens Group is a family owned company specialising in pharmacy services. The Cohens Group was founded in 1979 and has achieved over 40 years of experience within pharmacy services with its creative and innovative range of pharmacy services including free collection and delivery of prescriptions, medicine usage reviews and medication compliance aids. The Cohens Group develops relationships with its customers to understand their health and welfare needs; this enables The Cohens Group to provide an individual service to meet the customers’ needs and expectations.
• The Cohens Group also provides additional services within the provision of pharmacy services.
• The Cohens Group’s workforce is employed on a variety of permanent and temporary contracts. All right to work, residency, and qualification and employment history verification checks are conducted in accordance with legislation.

The Cohens Group currently operates in the following countries:

• United Kingdom

There are no activities that are considered to be at high risk of slavery or human trafficking.

The Cohens Group expects the same standards from its business partners, including suppliers, and will communicate and reinforce its commitment to preventing slavery and human trafficking to them throughout the relationship. Through the supplier/procurement code of conduct The Cohens Group will request that all suppliers also adhere to the Modern Slavery Act 2015 and will include prohibitions against the use of modern slavery as part of its contracting processes. The Cohens Group also expects its business partners will hold their suppliers to the same standards.

Responsibility

Responsibility for The Cohens Group’s anti-slavery initiatives is as follows:

• Policies: Managing Director and Head of HR are responsible for ensuring this policy, and those listed below, comply with The Cohens Group’s ethical and legal requirements and are complied with by all relevant policies. Day-to-day responsibility for implementing this policy and monitoring its effectiveness lies with Andrew John Managing Director – who will also deal with any queries and/or feedback relating to modern slavery compliance.
• Investigations/Due Diligence: The Managing Director and Head of HR are responsible for investigations and due diligence in relation to known or suspected instances of slavery and human trafficking.
• Training: The Managing Director and Head of HR are responsible for ensuring that the awareness of slavery and human trafficking risks are communicated throughout The Cohens Group and through the supply chain. They are also responsible for ensuring that all persons working for The Cohens Group or on its behalf in any capacity both within The Cohens Group and throughout the supply chain understand and comply with this policy and have received appropriate training on it. Training on this policy and the risk of modern slavery forms part of the induction training programme for all individuals who work for The Cohens Group – and regular follow up training will be provided as appropriate.

Relevant Policies

In addition to this policy, The Cohens Group operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:

• Employee Concerns (Whistleblowing) Policy: The Cohens Group encourages all its stakeholders to report any concerns related to the direct activities, or the supply chains of, The Cohens Group. This can include any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The Cohens Group’s policy is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers or others who have concerns can report any activities associated to slavery and human trafficking by contacting their immediate line manager, Human Resources or the Managing Director confidentially via the stakeholder communication link located on The Cohens Group website.
• Employee Code of Conduct: The code makes clear to employees the actions and behaviour expected of them when representing The Cohens Group. The Cohens Group strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.
• Recruitment Policy: The Cohens Group only employs people on a permanent or a temporary contractual basis. Prior to commencement of employment all employees are subject to right to work, residency, SIA and employment checks in accordance with the relevant legislation. The Recruitment Policy is compliant to all EU and UK legislation, including the minimum wage and therefore is not at risk of slavery and human trafficking.

Due Diligence

The Cohens Group undertakes due diligence when considering taking on new suppliers and regularly reviews its existing suppliers. Regular checks and audits are carried out on existing suppliers via the audit check questionnaire.

All Pharmaceutical supplier and manufacturer contracts are evaluated prior to any agreement in respect of the modern slavery and human trafficking risks of in accordance with the supply chain selection process.

If required, take steps to improve substandard suppliers’ practices, including providing advice to suppliers and require them to implement action plans where applicable. If required, invoke sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate The Cohens Group’s supplier code of conduct, including the termination of the business relationship. Audits carried out on The Cohens Group suppliers have confirmed that they meet The Cohens Group supplier code of conduct and therefore no sanctions including termination of contracts have been issued.

Performance Indicators

In light of the introduction of the Modern Slavery Act 2015 The Cohens Group will:
Review its existing supply chains by the end of the financial year, this being 31 August 2017 to ensure their compliance to the Modern Slavery Act 2015 utilising the Wholesale Dealer Licence (WDL) and Controlled Drugs Licence (CD) and maintaining the appropriate database.

Training

The Cohens Group will require all staff, including managers within The Cohens Group to receive awareness training on modern slavery as a module within The Cohens Group’s induction, management development and refresher programmes.

Awareness-Raising Programme

As well as training staff, The Cohens Group will raise awareness of modern slavery by providing the statement on The Cohens Group intranet site.

Board Member Approval

This statement has been approved by The Cohens Group’s board of directors, who will review and update it annually.

Managing Directors signature:

Date: 31 March 2019