Modern Slavery Act
The UK Modern Slavery Act 2015 requires companies that conduct business in the UK to publicly report the activities they undertake to prevent human trafficking and slavery. Early Access Care LLC maintains a practice of complying with local minimum age laws and requirements and has a well-established Supplier Code of Business Conduct.
- We behave ethically in business relationships, dealings and activities.
- We practice the highest standards of business conduct.
- We comply with all laws, regulations, industry codes of practice, and policies, standards, and procedures that apply to our business activities.
- We conduct our business activities with respect for people and a commitment to human rights, diversity, equal opportunity and freedom from exposure to improper conduct.
- We create and maintain safe and healthful working conditions.
Early Access Care is committed to ensuring that its supply chains are free from slavery or human trafficking.
Uk Modern Slavery Act Statement
Section 54(1) of the Modern Slavery Act 2015 requires commercial organizations to prepare a slavery and human trafficking statement for each financial year. This statement is issued for the Company fiscal year that ended December 31, 2018. Although subject to review annually, the statement will also apply to subsequent fiscal years unless and until withdrawn, superseded, or modified by the company. Early Access Care LLC (the “Company”) maintains its practice of complying with local minimum age laws and requirements and does not employ child labor, or forced or compulsory labor, in any of its facilities globally.
The Company is committed to ensuring that its supply chains are free from slavery or human trafficking. The Company has enacted a Supplier Code of Conduct with which both its existing and new suppliers are contractually obliged to adhere to, it has introduced new measures to effectively vet potential new suppliers for compliance with modern slavery requirements, and it is committed to providing tailored training on anti-slavery and human trafficking requirements and awareness to its key staff.
Organization Of The Business
Early Access Care LLC is a company organized under the laws of Connecticut, USA. The parent company has its head office in the United States.
The Company, provides services that support pharmaceutical and biotechnology companies to implement and execute programs for expanded access, also known in local regions by many different names according to local laws and regulations.
The Company's Supply Chains
The Company's professional services suppliers include, for example, accountants, information technology professionals, marketing professionals, travel agents, lawyers, and consultants in various fields. The company's office services suppliers include, for example, office and document managers, labeling and packaging materials, administrative services, distribution arrangements delivery services, maintenance, repair, and cleaning services.
The Company contracts with vendors in a number of countries. The Company is committed to implementing a risk assessment procedure and accompanying due diligence process in respect of suppliers in higher risk countries (according to the Human Slavery Index) to ensure that suppliers comply with the Company's code of conduct and ethical standards.
The Company's Policies On Slavery And Human Trafficking
Company is committed to ensuring that there is no modern slavery or human trafficking in its supply chains or in any part of the Company's business.
The Company's Supplier Code of Conduct outlines its expectation that suppliers will respect and abide by the Company's human rights standards to ensure that slavery and human trafficking is not taking place anywhere in the Company's supply chains.
The Company does not contract with source suppliers in industries or regions of the world where the risks of modern slavery and human trafficking are relatively high. The Company's services suppliers are engaged in a range of activities, from higher skilled to lower skilled, but almost all are engaged in services conducted in close cooperation with Company personnel.
Potential new Suppliers identified in the higher risk geography and higher risk industry overlap will be subject to increased scrutiny. Such further due diligence may include site visits which may include environmental, health & safety, quality and sustainability audits.
These key indicators include:
- the country in which the supplier is based and its ranking on the Global Slavery Index
- the services or goods which the supplier provides
- the supplier's relationships with suppliers and others, including trade unions and other bodies representing workers.
The Company has also implemented an ongoing risk assessment system for its existing supply chains based on the key indicators outlined above. If an existing supplier presents a modern slavery risk based on those factors, the Company will review the arrangements with that supplier and conduct further due diligence to assess the extent to which that supplier complies with anti-slavery requirements.
Supplier Adherence To The Company's Values And Ethics
The Company has zero tolerance to slavery and human trafficking. To ensure all those in the Company's supply chain and contractors comply with the Company's values, all agreements with suppliers require that suppliers represent and warrant to the Company that they comply with all applicable laws and regulations.
For any supplier not meeting the Company's expectations under its contractual arrangements, the Company reserves the right to terminate the agreement. In addition, the Company requires that all suppliers comply with the Company's Supplier Code of Business Conduct.
Relevant functions in the Company that deal with external suppliers, must also comply with all Company policies and procedures, and all laws and regulations that apply to Company business operations and are trained annually on these considerations. This includes laws regarding slavery and human trafficking. Any violations of this policy are subject to disciplinary measures including dismissal as appropriate. Company employees are instructed to conduct due diligence on prospective and current suppliers with regard to modern slavery and human trafficking issues and the termination of negotiations or contracts if concerns are identified. They may also include, as a further example, the insertion of legal compliance clauses in supplier contracts and the ongoing monitoring of performance under such clauses.
Detection And Deterrence
The Company will use the following key performance indicators to measure how effective the Company's anti-slavery measures are in ensuring that slavery and human trafficking is not taking place in any part of the Company's business or supply chains:
- ensuring that all staff in relevant functions within the Company have been trained in anti-slavery and human trafficking requirements, in terms of awareness of risk, appropriate decision-making and swift action;
- carrying out an annual Third-Party Risk Assessment exercise
- ensuring all suppliers with which the Company contracts and who have been identified as presenting a modern slavery risk have been made aware of the Company's Supplier Code of Conduct, including in respect of anti-slavery and human trafficking.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the Company's slavery and human trafficking statement as of October 1, 2019.