Grifols UK Ltd
Cambridge Business Park
Tel. 0845 241 3090
Grifols UK Limited
Transparency in Supply Chain Statement 2019 / 2020
1.1 Grifols UK Limited ("Grifols UK") is committed to preventing modern slavery and human trafficking in its business and supply chain. Consistent with our obligations under s.54 of the Modern Slavery Act 2015, we have set out below a statement of the steps Grifols UK has taken in the last financial year to ensure slavery and human trafficking is not taking place in any of its supply chains or in any parts of its own business.
2. Our business
2.1 Grifols UK is the UK subsidiary of Grifols, S.A., the holding company of the Grifols Group (the "Grifols Group"). The Grifols Group is a global healthcare business whose mission is to improve the health and wellbeing of people around the world by producing life-saving protein therapies for patients and by providing hospitals, pharmacies and healthcare professionals with the tools they need to deliver expert medical care. The Grifols Group has three primary divisions -- Bioscience, Diagnostic and Hospital – which develop, produce and market innovative products and services to medical professionals in more than 100 countries around the world.
2.2 Grifols UK supplies products produced by the Bioscience and Diagnostic Divisions of the Grifols Group to the UK market. Grifols UK is proud to have been a supplier of life-saving therapies to the NHS for over 30 years. We provide plasma-derived therapies - usually for chronic diseases – diagnostic reagents and analysers as well as automated blood-typing systems.
3. Our supply chains
3.1 Grifols UK's suppliers of bioscience products continue to be exclusively affiliates of the Grifols Group. All freight forwarders shipping products to Grifols UK are contracted directly by the affiliates.
3.2 Grifols UK's suppliers for diagnostic products are mainly affiliates of the Grifols Group. In addition, Grifols UK obtains supplies of diagnostic products from certain third party suppliers outside the UK. Grifols UK also acquires reagents from local suppliers in the UK. Shipping is arranged by the supplier in each instance.
3.3 On 23 December 2019, Grifols UK acquired the European rights to distribute a product known as 'Tavlesse'. As part of the acquisition, Grifols undertook a commercial and legal due diligence process which included an assessment of the supply chain for this product. No concerns as to modern slavery, human trafficking or other potentially related issues such as bribery or money laundering were identified.
4. Our policies and contractual controls
4.1 The Grifols Code of Conduct (the "Code") remained in force across the Grifols Group during the last financial year and continues to set out the corporate principles of the Grifols Group and establish the standards of behaviour required of everyone who forms part of the Grifols Group in order to maintain the "Grifols spirit". As explained in the Code, the Grifols Group seeks to conduct and develop its business on the basis of honesty, integrity and ethical values and the
Grifols Group is fully committed to compliance with all applicable laws, rules and regulations. This includes laws, rules and regulations prohibiting modern slavery or human trafficking.
4.2 The Code includes the principle of "Respect for Others".
Grifols is committed to maintaining relations based on respect, fairness and courtesy with all its employees, customers, suppliers, authorities and other individuals it comes into contact with in its activities, and to maintaining a working environment free of discrimination and harassment. Within the Code, there is also guidance on raising concerns and reporting misconduct, including using the Grifols Ethics Helpline. There have been no reports concerning allegations of modern slavery or human trafficking in connection with Grifols UK, or its supply chain, in the last financial year.
4.3 Grifols UK requires compliance with the Code from all its directors, officers and employees. In addition, our predominant suppliers and a number of the manufacturing companies that supply them are within the Grifols Group and therefore subject to the Code as well.
4.4 This statement takes into account, and supports, the policies, procedures and requirements documented in Grifols UK's Management System which is accredited to ISO 9001:2015. The implementation and operation of this Management System supports Grifols UK's anti-modern slavery position as set out in this statement.
4.5 During the last financial year, Grifols UK implemented the Grifols Group's 'Global Compliance Third Party Due Diligence Policy'. The Policy now applies to Grifols UK employees who establish business relationships with Third Parties that may be located anywhere around the world. The Due Diligence process, which includes the requirement for the completion of a questionnaire by all new Third Party suppliers, is aimed at ensuring Third Party corruption risks are responsibly evaluated and managed. The due diligence process increases transparency in Grifols UK's supply chains in general and is a new tool in the prevention of modern slavery, human trafficking and other potentially related issues such as bribery or money laundering.
5. Risk assessment and due diligence
5.1 Grifols UK is not aware of any slavery or human trafficking issues within its business or supply chains. In the last financial year, no potential issues of this type have been identified through internal audit, the Grifols Ethics Helpline or otherwise. Grifols UK has not received any information from the Grifols Group indicating that there may be any such issues with any of its intra-group suppliers or their supply chains. On this basis, we consider the risk of slavery or human trafficking in Grifols UK's business or supply chain to continue to be low. However, should any potential issue be identified, Grifols UK will act swiftly to investigate and, where necessary, act to ensure there is no modern slavery or human trafficking in its business or supply chain.
5.2 In addition, Grifols Biologicals LLC in Los Angeles (CA), one of the manufacturers of plasma-derived products commercialised by Grifols UK, is subject to the California Transparency in Supply Chains Act 2010, and has published a statement explaining the steps taken to prevent slavery and human trafficking in its supply chain. That statement can be found at http://www.grifolsusa.com/documents/17553/40543902/011218-supply-chain-transparency-grifols-inc/387e6f09-5288-4b78-996e-0a8459be7d4c.
6. Next steps
6.1 Grifols UK is committed to ensuring there is no slavery or human trafficking in its business or supply chain. It will continue to consider over the next financial year what further proportionate steps it may wish to take in support of this commitment.
7. Approval of this statement
7.1 This statement is made in compliance with Grifols UK Limited's obligations under s.54 of the Modern Slavery Act 2015 for the financial year to 31 December 2019. This statement was approved by the Board on 1st June 2020.
Grifols UK Ltd.
Date: 1st June 2020