Modern Slavery

Cohens Group Modern Slavery and Human Trafficking Statement

Our Business

Gorgemead Limited t/a the Cohens Group is a private family owned limited company headquartered in Bolton, England. The Cohens Group has over 40 years of experience within pharmacy with its creative and innovative range of pharmacy services including free collection and delivery of prescriptions, medicine usage reviews and medication compliance aids. Cohens is a community pharmacy and healthcare provider with 213 pharmacies across the UK, mainly located in communities and health centre locations. 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.

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. 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 and we will not knowingly support or do business with any organisation involved in slavery or human trafficking. The Cohens Group encourages openness about modern slavery issues and will support any person who raises genuine concerns under this statement in good faith – even if they eventually turn out to be mistaken.

The detail of how we do this is set out in our Anti- Slavery and Human Trafficking policy which is supported by the policies below and through the standard operating procedures we have in place for the procurement of goods and services for the business.

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

Our Workforce

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. We have structures in place where employees can seek advice and support, additionally a confidential whistleblowing service to ensure that they can raise concerns to senior management without fear of retribution or victimisation.

Our Policies

Relevant Policies

In addition to this statement, 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, these policies are available on the company intranet and available to all line managers and employees to ensure we are compliant with our legal obligations

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 Directors 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.

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. In addition employees are advised on our position with regards to our obligations in respect of Anti- slavery and Human Trafficking as part of the on-boarding process.

Our Supply Chain

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 “Approval of Suppliers and Customer process 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.
The Cohens Group undertakes due diligence when considering taking on new suppliers. 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.

Next Steps

Ongoing reviewing and checks on our existing suppliers on a risk assessment basis for Modern Slavery Act compliance.

Review of our policies and procedures in support of our approach to our commitment to Modern Slavery.

Awareness of our obligations in respect of modern slavery and human trafficking to be included in the annual GDPR training and our inductions for new starters we need to agree this point as I do not think we do this annually and we do not have a robust process in place for new starters and GDPR.

Responsibility for this statement

This statement has been approved by The Cohens Group’s board of directors, who have overall responsibility for ensuring compliance with this statement and our related policies. Management at all levels are responsible for ensuring those reporting to them understand this statement and comply with our Anti-Slavery and Human Trafficking policy.

Director

Andrew Caunce
Date: 12th February 2022