The Modern Slavery Act 2015 (the “Act”) came into effect on 29 October 2015 and requires those entities carrying on a business or part of a business in the United Kingdom, supplying goods or services, and having annual turnover of £36 million or more, to disclose information regarding the steps they have taken to eradicate slavery and human trafficking from their supply chain as well as within their own organization during the previous financial year.

McKesson Corporation (“McKesson”) publishes this UK Modern Slavery Act Statement (this “Statement”) on its corporate website in the name and on behalf of ClarusONE Sourcing Services LLP (“ClarusONE”) for the fiscal year ended 31 March 2017.

UK Modern Slavery Act Statement

ClarusONE is committed to good corporate citizenship and the highest ethical standards. To fulfil these requirements, ClarusONE has established and maintains systems and controls to ensure that slavery and related human trafficking do not form part of its supply chain.

BUSINESS AND ORGANIZATION

ClarusONE was established in 2016, and is a London-based limited liability partnership organized under the laws of England and Wales, which is jointly owned by wholly-owned subsidiaries of McKesson and Walmart Stores, Inc. (“Walmart” ad, together with McKesson, the “Members” and each, a “Member”), respectively. ClarusONE provides strategic sourcing services to the Members. ClarusONE’s approach is to deliver value by developing an innovative and differentiated sourcing model that fosters global partnerships in the generic pharmaceutical market.  

McKesson is a global leader in healthcare supply chain management solutions, retail pharmacy, community oncology and specialty care, and healthcare information technology.  

Walmart is engaged in retail and wholesale operations in various formats around the world, and many of its operations include pharmacies.

VALUES AND TRAINING

ClarusONE is committed to sourcing quality generic pharmaceutical products, on behalf of its Members, from suppliers who share ClarusONE’s ethical values.

Both of ClarusONE’s Members have implemented codes of conduct (each, a “Code of Conduct” and collectively, the “Codes of Conduct”) within their respective organisations, which provide the guidelines for ClarusONE’s interactions among its employees and contractors as well with affiliates, customers, suppliers and other business partners.

McKesson’s Code of Conduct can be viewed at the following link: 

http://www.mckesson.com/uploadedFiles/McKessoncom/Content/_Documents/Investors/Code%20of%20Conduct.pdf

Walmart’s Code of Conduct can be viewed at the following link:

https://www.walmartethics.com/uploadedFiles/Content/U.S.%20-%20English.pdf

The ethical principles that are the basis of the Codes of Conduct are at the heart of every decision ClarusONE makes. ClarusONE’s employees are encouraged to raise concerns, including potential violations of: (i) the Codes of Conduct; (ii) ClarusONE policies; and (iii) the laws of the countries in which ClarusONE operates. There are sophisticated reporting mechanisms in place to collect and relay information regarding potential violations to appropriate resources within ClarusONE and within its Members for review and follow-up.

ClarusONE conducts web-based and/or in person trainings for employees to emphasize the importance of acting with integrity and consistently with the Codes of Conduct.

SUPPLY CHAIN AND DUE DILIGENCE

As a provider of strategic sourcing services in the pharmaceutical market, ClarusONE takes its social responsibility seriously and is strongly committed to respecting international human rights and fair labour practices and explicitly condemns all kinds of slavery or human trafficking.

ClarusONE’s principal supplier agreements include language that requires ClarusONE’s suppliers to comply with all laws that relate to their interactions with ClarusONE, including any applicable national laws regarding human trafficking, forced labour and other forms of modern slavery.

In addition to its own efforts, ClarusONE can, whenever required, upon request, rely on the strong support of its Members, who have designed and implemented processes to: (i) assess suppliers of services and products introduced into the supply chain; and (ii) confirm that the policies and procedures of such suppliers are compliant with the Codes of Conduct.

EFFECTIVENESS

ClarusONE continuously evaluates its monitoring program to ensure its actions are consistent with industry norms and coordinates with the policies and procedures of its Members to leverage their experience and knowledge.

ClarusONE believes its efforts to date have been effective in preventing slavery and human trafficking from entering the supply chain.

This Statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and constitutes ClarusONE’s slavery and human trafficking statement for its financial year ended March 31, 2017.

London, United Kingdom.

Ted Boyle

President

ClarusONE Sourcing Services LLP

September __, 2017