UK MODERN SLAVERY ACT STATEMENT 2023
Amicus Therapeutics UK Limited (“Amicus UK”) makes this statement (pursuant to section 54
Part 6 of the U.K. Modern Slavery Act of 2015) describing the steps Amicus UK has taken to
prevent slavery and human trafficking in its supply chain and businesses. This statement covers
Amicus UK’s financial year from January 1, 2023, to December 31, 2023.
Our Business
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 generally comprises (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.
Policies
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.
Compliance Programme
- 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.
Reporting
- 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 prohibits every form of Bribery and corrupt conduct, and
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.
Written Agreements
- Amicus UK contractually require the individuals and companies we engage to to fully
comply with all applicable local laws and regulations in all activities they may undertake
to provide services to us, depending on the nature of the services we include the right
to audit and visit any site to review compliance 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
In March 2023, a Modern Slavery Policy was published internally, and training was provided to
employees who are responsible for assessing suppliers and other third-party partners, assessed
as being at a higher risk of Modern Slavery.
Express language concerning requirements for an anti-slavery programme has been included in
our most significant supplier contract, and we will continue to include express provisions in other
services agreements depending on risk, over the course of 2024-2025. The language clause
requires suppliers and their employees to commit not to engage in slavery or human trafficking,
to carry out due diligence on their own supply chain and there is a right for Amicus to terminate
the contract in the event of non-compliance. The language assists us in assessing third parties we
work with; we continue to evolve our controls to detect and prevent modern slavery and other
labour rights violations.
During 2023, as part of our work concerning direct “product suppliers”, we have continued to
apply mechanisms and processes, implemented in 2022, to confirm their adherence to anti-slavery measures in their businesses.
An internal Modern Slavery Committee, led by a senior leader appointed as the Modern Slavery
Representative, was established in November 2022. This Committee has a delegated
responsibility from the Amicus UK board of directors to oversee and progress the programme.
The Modern Slavery Committee meets quarterly and has met twice in the first half of 2024.
Due diligence questions related to modern slavery will be used as part of supplier onboarding.
There have been no reports received in relation to modern slavery or human trafficking through
the Amicus’ Global Hotline (“Speak Up!”), as at the date of the Statement.
Amicus UK continues to assess these risks and over the course of 2024-2025 we will continue to
raise awareness in the organisation about these risks.
This Statement has been approved by the Amicus UK board of directors as of 27th June 2024.
Steve Arnold
Director
Amicus Therapeutics UK Limited