Modern Slavery Statement – Sigma Pharmaceuticals plc and Group Companies

Introduction

At Sigma, we have a vision to provide a class leading service, delivering satisfied customers, suppliers and employees. We can only achieve that by protecting, respecting and championing the human rights of everyone connected to our operations and supply chain. Conducting our business in an ethical and responsible manner is therefore a key part of our history – and future – as a family run business and we expect the same standards from our suppliers.

Both the Board, Executive Committee and I are responsible for ensuring Sigma meets its human rights’ responsibilities. We are absolutely committed to preventing acts of modern slavery and human trafficking from occurring both within the business in the UK and its supply chain which extends outside of the UK.

This statement is made in compliance with section 54 of the Modern Slavery Act 2015 and sets out the reviews and steps taken by Sigma during the financial year ending 31st August 2023 to understand all potential modern slavery risks related to our business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in our own business and supply chains.

Hatul Shah
Chief Executive Officer

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Our Organisation

Sigma has been serving Independent Pharmacies, Dispensing Doctors and Hospitals for over 40 years. Being one of the largest independent pharmacy wholesalers in the UK, meeting the independent needs of customers is at our heart.

Our business is the manufacture and supply of pharmaceutical products to both retail pharmacies across the UK and also into the wholesale pharmaceutical market for use by the larger pharmaceutical suppliers. You can find out more about what we do at our website https://www.sigmaplc.com/. Sigma has around 350 employees, all of whom are based in the UK.

As a manufacturer and supplier of pharmaceutical products we are regulated by the MHRA and given the higher standard of regulation we are required to comply with, we aim to implement that higher standard across the business.

Sigma is still a family-owned group of companies, registered and represented in the UK. Its executive board members are a majority of family members, and all are committed to follow the ethical and diligent principles set out by the founders of the Group.

High-risk activities

The following is the process by which the company assesses whether or not particular activities are high risk in relation to slavery or human trafficking:

To identify something, you first of all need to know what you’re looking out for, and then you need to go and actually look out for it. To understand what we’re looking for, we reviewed the risks within our business.

Our staff are largely directly employed and overseen by us, and so are not considered to be in a category which is vulnerable to modern slavery in this country. So our focus was therefore on our supply chain, where we work with under 50 key suppliers alongside a wide range of other suppliers who supply goods for sale, provide services at events and support our operations. Our suppliers range from small to very large suppliers and are based in Mainland Europe, China, India and the Middle-East.

Our review identified the following activities for our specific business and supply chain which are considered to be at high risk of slavery or human trafficking:
● Workers in the factories manufacturing the products that we source and sell
● Agency workers in the sub-contractors we use for logistics and transport

Responsibility

Responsibility for our anti-slavery and human trafficking initiatives lie with the following departments within Sigma:

  • Policies: The HR Team are responsible for the updated Company handbook of which the countering slavery and human trafficking policy sits.
  • Due diligence:
    – Our procurement teams have responsibility for looking into how the workers in the factories manufacturing the products that we source and sell are treated.
    – Our Operations team has responsibility for looking into the labour practices of our logistics and transport service provider partners.
  • Training: Our HR Team are responsible for creating, and ensuring all departments complete relevant modern slavery training, this includes any new joiners to the business.

Relevant policies

Sigma has a number of policies which aim to minimise the risk of modern slavery in the supply:

New Supplier Verification Policy – we have a New Supplier Verification Policy which sets out internal requirements for buying goods and services. It includes a Responsible Procurement Process which covers issues of human rights, child and forced labour and modern slavery, which we expect our supplier to comply with.

Supplier Questionnaire and Audit – We also require suppliers to complete a Due Diligence Questionnaire which covers their governance, policies, training and supply chain management processes. And where a supplier may pose a higher risk, we require suppliers to provide an independent ethical audit, especially if they are based in a higher risk country.

The Sigma Procurement team is responsible for assessing the information submitted by suppliers and continuously monitoring all suppliers. Should a supplier fail to provide the information requested or to not meet Sigma’s expectations, Sigma will take appropriate action, which may include not entering into a relationship or terminating the relationship with the supplier concerned.

International Supplier Visits – It is our usual practice when considering a new supplier who may be overseas for us to physically go and visit them and to determine whether there are concerns from an employment or staff treatment perspective.

Terms and Conditions – Our terms and conditions on which we do business require all our suppliers to ensure they do not allow slavery and trafficking within their supply chains and would allow us to terminate if they did not comply.

Whistleblowing Policy – we have a whistleblowing policy which encourages staff to report any concerns including any related to suppliers and their practices. This allows people to report anonymously and ensures that there are no reprisals for raising a concern. Colleagues, or others who have concerns can raise this with the direct line manager or if they are not comfortable with this then they can raise it with our People Director or a senior member of the People Team.

Employee Handbook – Our Handbook makes clear to colleagues the actions and behaviour expected of them when representing Sigma. We strive to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.

Training – During the year, we have continued to provide advice and guidance to those teams who have direct responsibility for relevant supply chains and our Procurement team has participated in further modern slavery training. We also maintain a Modern Slavery Act Guidance document which is available to staff through Sigma’s staff handbook.

Looking Ahead

Sigma is committed to acting ethically and with integrity and transparency in all business dealings.

Sigma is committed to acting ethically and with integrity in all its business relationships. We are acutely aware of our responsibilities and combating modern slavery and protecting human rights is a vital responsibility for us as a business.

As a result, our modern slavery work cannot stand still. We must remain aware of emerging risks and be alert to the dynamic nature of both modern slavery and the impacts of our own operations. And we are committed to meeting that challenge.

Over the course of the next financial year, we will therefore aim to enhance our procedures to help us identify, prevent and mitigate any risks of modern slavery or human trafficking in relation to new and existing suppliers through the following actions:

  • Employee Code of Conduct/Anti-Bribery and Corruption policy, including an updated Conflict of Interest policy – a new code of conduct for our employees to help them apply and uphold our standards, so that every part of Sigma operates ethically and with integrity.
  • Supplier Code of Conduct – a new Code of Conduct for our suppliers that help them adhere to the same standards as ours, provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour.
  • Enhanced Training – an online suite of training packages rolled out to all employees and a training giving awareness of slavery and human trafficking would be included.

Approval

This statement is made in accordance with Section 54(1) of the Modern Slavery Act 2015 and constitutes Sigma’s slavery and human trafficking statement for the financial year commencing 1 September 2022 and ending 31 August 2023. This statement was approved by the Board of Directors for the Sigma Group on 12th March 2024.

Mr Hatul Shah
Executive Director & Responsible Person MRPharmS MBA

This statement has been formally approved by the board of Sigma and signed on their behalf.