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Modern Slavery Act Statement

SLAVERY AND HUMAN TRAFFICKING STATEMENT

INTRODUCTION

The following statement outlines Teva’s adherence to the Modern Slavery Act 2015 (the “Act”) and the steps taken to ensure compliance with the Act.

As highlighted in our Code of Conduct, it is a fundamental policy to conduct our business with honesty, integrity and in accordance with the highest ethical standards.

We are committed to the ongoing review of our policies and practices to ensure we continue to meet the requirements of the Act and to uphold our highest ethical standards.


WHO ARE WE?

Teva is committed to increasing access to high-quality healthcare for people across the globe (including the UK), at every stage of life. We do this by developing, producing and marketing affordable generic drugs as well as innovative and specialty pharmaceuticals and active pharmaceutical ingredients. Today we have a portfolio of more than 1800 molecules, and produce approximately 120 billion tablets and capsules a year. We are active in 80 countries, employing in the region of 57,000 people around the world.


ETHICAL VALUES

Teva is committed to preventing acts of slavery and human trafficking from occurring within both our business and our supply chain, and expects the same high standards from our suppliers. Our responsibility in this area includes creating awareness and understanding of human rights and employment practices. By incorporating these principles into our Code of Conduct, strategies, policies and procedures, and living out our values, we will uphold our basic responsibilities to our people and our environment.

We support and respect the protection of internationally proclaimed human rights. We uphold the elimination of all forms of forced and compulsory labour, and the effective abolition of child labour. Ensuring that we maintain the highest moral and ethical standards regarding labour practices is a top priority at Teva.


SUPPLY CHAIN

Teva manufactures finished products itself but also purchases goods and services, including raw material, from third party suppliers. As part of our processes to ensure ethical practices within our supply chain, we became a member of the Pharmaceutical Supply Chain Initiative (“PSCI”) in 2016, which includes 21 of the largest and leading pharmaceutical and healthcare companies. We engaged with PSCI members and reviewed the PSCI principles that govern supply chain management in our sector. These principles set the guidelines for, amongst other things, our ethical labour practices which are included in our Code of Conduct. We support and have incorporated these principles into our Supplier Code of Conduct (see below) and are formally embedding compliance with these into our legal agreements with suppliers.


TEVA POLICIES AND CODES

Since 2010, Teva has participated in the United Nations Global Compact (UNGC). The UNGC is a strategic policy initiative of the United Nations which encourages companies around the world to adhere to 10 principles of responsible business relating to human rights, labour standards, environmental protection and anti-corruption. As part of our commitment to combating modern slavery, we will implement the formal communication of our Responsible Supply Chain policy which sets out our expectations for all our suppliers to comply with the UN Global Compact Principles. Suppliers are obliged to consider these responsibilities as part of selection and continued engagement with Teva.

Our Supplier Code of Conduct is made publicly available to suppliers on our website, formal acceptance of this policy by suppliers as a pre-requisite to contracting and tendering with Teva will be further rolled out. The PSCI Principles, which are included in our Supplier Code of Conduct (“SCOC”), are fully aligned with the UN Global Compact Principles.


SUPPLIER RISK ASSESSMENT/AUDIT

Under Teva policy, Teva will commence a risk-based approach assessment of suppliers considering, amongst other things, their potential risk of non-compliance to the SCOC. We acknowledge we must be particularly vigilant when sourcing in specific industry sectors with geographically distant supply chains. Suppliers prioritised as high or medium risk will be further assessed for compliance with the SCOC and may thereafter be subject to an audit. Such audits shall be conducted in line with the PSCI audit guidance publication, and using a PSCI approved auditor.

We are also working with an external sustainability specialist utilising its ‘Supplier Sustainability Ratings’ solution to further assist us with initial assessments of our suppliers’ compliance with our SCOC.

As part of our commitment to an ongoing review of our policies and practices, additional policies and processes will be formally implemented to embed procedural requirements in respect of suppliers’ compliance with our SCOC. These policies and procedures will also require supplier acceptance of our audit requirements.


EMPLOYEES, TRAINING AND WHISTLEBLOWING

Employee relations are managed across Teva by the Human Resources Department. Employee working hours are set out in contract and any requirement to work additional hours outside of the standard contractual hours must be approved in advance by the relevant managers with the employee’s consent. All relevant UK employees are paid at least the UK National Living Wage.

Our own employees are trained on and must comply with our Code of Conduct. We invest in educating our staff to recognise risks of breaches of our Code of Conduct or applicable laws in our business and supply chains. Through our training programmes, employees are encouraged to identify and report any potential breaches.

Suppliers, workers and service providers are encouraged to report concerns or illegal activities in the workplace without threat of reprisal, intimidation or harassment – this includes concerns relating to ethical behaviour. Teva personnel should also promptly report any violations of Teva’s Code of Conduct, the SCOC or any policies or laws, to Teva’s Office of Business Integrity (OBI) through a dedicated telephone hotline. Where data privacy laws restrict reporting certain issues to the hotline, reports can be made to alternative management resources at Teva.

This statement is made in accordance with Section 54(1) of the Modern Slavery Act 2015 and constitutes Teva’s slavery and human trafficking statement