UK MODERN SLAVERY ACT STATEMENT 2022
Amicus Therapeutics UK Limited (“Amicus UK”) makes this statement pursuant to section 54 Part 6 of the U.K. Modern Slavery Act of 2015 and it sets out the steps Amicus UK have taken with the intention to prevent slavery and human trafficking taking place in its supply chain and businesses. It covers Amicus UK’s financial year from January 1, 2022 to December 31, 2022.
Amicus UK is a subsidiary of Amicus Therapeutics Inc. (Nasdaq: FOLD) which is a global, patient- dedicated group of companies focused on discovering, developing, and delivering medicines for people living with rare genetic and metabolic disorders (“the Amicus Group”).
Amicus UK’s supply chain is generally comprised of (i) suppliers of direct materials (active ingredients, manufacturing, packaging materials and logistics providers) and (ii) suppliers of indirect services (professional services, facilities, sales, and marketing agencies and clinical research organisations). In our office spaces, we engage suppliers to provide office cleaning services.
From our internal risk assessment, we consider the risk of modern slavery, trafficking and / or human rights violations in our operations to be low. Nevertheless, we undertake a series of measures to raise awareness and enhance our programme. Should any concerns be identified, we will take targeted remedial and/or preventative action, as appropriate.
This statement is made by and relates to Amicus UK only.
Our Code of Conduct is the guide to our culture and values. The Code was updated in 2021 to include our mission focused behaviours which are: innovation, mission, performance, and integrity. The Code is a critical document that explains our broad values and our commitment to a culture of compliance.
The Code of Conduct and Compliance Programme, along with other policies and standard operating procedures, contain multiple provisions that help to combat modern slavery, forced labour, and human trafficking, specifically:
Code of Conduct Section 3.3
- Commits all Amicus Group companies, including Amicus UK, to never using child or forced labour and establishes that should we become aware of suppliers who violate these principles, we will terminate our relationship with them as their association with us is a reflection on our ethics.
- Affirms that upholding human rights is a direct reflection of our commitment to ethical business practices and that Amicus Group is committed to providing all associates with fair and competitive wages in exchange for high performance conducted with high integrity.
- Sets out that we comply with the wage and labour laws of every country in which we operate and will never use child or forced labour in our operations.
- Amicus Group’s compliance and ethics programme requires that Amicus UK employees receive training on and must adhere to the Code of Conduct. The Code of Conduct and the written policies and training programmes that support it, are designed to create a culture of ethics and integrity and to facilitate compliance with the laws of all jurisdictions in which Amicus UK operates.
- All Amicus Group and Amicus UK employees are advised to speak up if they have any concerns relating to a breach of our Code of Conduct or any applicable laws. - Amicus Group’s Compliance programme provides relevant training and multiple channels of communication through which Amicus UK employees, contractors, and business partners can report concerns regarding potential misconduct (including directly or through Amicus’ Hotline (“Speak Up!”) or website).
- Anonymous reports can be made through our Global Hotline. All our toll-free hotline numbers are easily accessible on the front page of our intranet. Employees and contractors may also make a report electronically through the Hotline’s web-portal. Amicus Group and Amicus UK take violations of our Code and the law very seriously. All allegations of wrongdoing will be promptly and thoroughly investigated without fear of retaliation.
Global Anti Bribery and Corruption Policy
- Amicus Group and Amicus UK does not solicit, accept, offer, promise, or pay bribes — whether directly or through a third party. This is vital to maintaining the trust of our employees, of the patients we serve, and of the customers and partners with whom we work.
- At Amicus UK, we contractually require the individuals and companies we hire to fully comply with all applicable local laws and regulations in all their activities on our behalf as well as the right to audit and visit any site to review the services provided by our vendors and suppliers.
Due Diligence Processes
Amicus UK Employees
- All employees who work for Amicus UK are background checked, having their identity, qualifications and previous work history verified as a condition of employment. We abide by the requirements of the UK Border Agency and verify employees’ right to live and work in the UK. Regular audits are made of employees who have only a temporary right to remain. Amicus UK ensures that all employees are paid at minimum in accordance with National Minimum Wage legislation. Employees are encouraged to provide feedback through regular staff surveys. The results of these surveys influence our business activities and decision making.
Ongoing and Future Efforts
During 2022, a “Sustainability Questionnaire” was sent out to Amicus’ direct “product suppliers”, which contained a “Human Rights & Safety” section covering topics such as “ethical and legal employment practices”, “policy on forced, bonded or compulsory labour”, and compliance with “minimum hiring age and minimum wages”.
In April 2023, a session at the international town hall meeting, broadcast to all employees in the international business, was held to increase awareness in the organisation about the risk of Modern Slavery. To follow on from this session, a Modern Slavery Policy has been drafted, with the organisation to be trained on the policy in the second half of 2023.
A senior leader has been appointed as the Modern Slavery representative for the organisation, will chair the Modern Slavery Steering Committee and act as an additional point of contact for employees to raise concerns should they suspect or have any concerns related to Modern Slavery. The Modern Slavery Steering Committee will continue to progress the program and provide updates to the Board of Directors of Amicus Therapeutics UK Limited.
Amicus continues to assess the risk of Modern Slavery and over the course of 2023-2024 we will update our due diligence questionnaire to include questions related to Modern Slavery and include Modern Slavery clauses as standard in our contracts with third parties, including a right to terminate in the event of non-compliance. This will ensure we continually assess the third parties we work with and ensure we continue to evolve our controls to detect and prevent modern slavery and other labour rights violations.
This Statement has been approved by the Board of Directors of Amicus Limited of Amicus UK as of 27th June 2023.
Amicus Therapeutics UK Limited