Modern Slavery

1. Our Policy
Gaelic Laboratories Limited and Athlone Laboratories Limited are opposed to slavery and human trafficking in any part of our business or our supply chain. We are therefore committed to ensuring that we have adequate policies and procedures in place to identify and prevent these practices.

2. Our Business
We distribute a broad range of own- and third party-branded pharmaceuticals to hospitals, pharmacy wholesale channels and other healthcare providers and related industries around the world. Seasonal work is not a feature of the industry in which we operate. More information on our business is available at www.gaelicathlone.com

3. Our Structure
Our business is organised into the following trading companies, both based in the Republic of Ireland:

• Gaelic Laboratories Limited
• Athlone Laboratories Limited

4. Our Supply Chains
Our primary supply chain partners are authorised pharmaceutical manufacturers and distributors. The large majority of these are located in countries where the risk of modern slavery and human trafficking is low. Where we deal with suppliers in countries where this risk is higher, we have put more robust controls and due diligence in place.

The following list contains a summary of the activities that we consider present the highest risk of slavery and human trafficking in the industries in which we operate, with a summary of the steps we have in place to avoid these affecting our activities or our supply chains. Industry Risk Steps Taken include:

• Representing manufacturers or engaging contract manufacturing in high risk countries
• Quality and ethical due diligence checks/reports
• Risk based approach to desktop and site auditing including third party auditors or compliance schemes
• Robust agreements including quality and supply chain integrity clauses
• Open regular two-way communications on compliance expectations and performance
• Provision of training to our partners where required
• Agreeing mitigating controls and corrective actions where required
• Terminating the relationship if mitigation not possible

5. Our Policies on Slavery and Human Trafficking
Our Code of Conduct sets out our Group’s commitment to acting ethically and with integrity towards our employees and in all our business relationships. The code sets out our commitment to fair employment practices and sets out our commitment to preventing, as far as practicable, slavery and human trafficking in our supply chains.

We have established our Supply Chain Integrity Procedure and Code of Practice to reflect the requirements of these Group policies. These documents outline the detailed requirements we follow and which have been integrated into local company procedures.

6. Procedures on Slavery and Human Trafficking
As part of our compliance with the policies and procedures referred to above, we take the following steps:

• Assess potential risk areas in our supply chains;
• Mitigate the risk of slavery and human trafficking occurring in our supply chains, including by reviewing, where necessary, the controls that our suppliers have in place and carrying out other suitable checks including audits;
• monitor potential risk areas in our supply chains on a periodic basis.

7. Procedures on Slavery
Responsibility for ensuring that our procedures are adequate and are adhered to in all areas of our activities rest with the senior management team.

8. Training & Awareness
To ensure a suitable understanding of the risks of modern slavery and human trafficking in our business and our supply chains, directors and relevant employees in our business have received training in the procedures relevant to their responsibilities. Employees working with supply chain partners in high risk countries have completed additional bespoke training. Supply Chain integrity training forms a part of our ongoing training procedure.