McKesson Corporation (“McKesson”) publishes this Modern Slavery and Human Trafficking Statement (“this Statement”), pursuant to section 54 of the Modern Slavery Act 2015, on behalf of McKesson Global Procurement & Sourcing Limited (“MGPSL”) for the fiscal year ended 31 March 2022 (“FY22”). We are generally, and through our policies and practices in relation to procurement, people and culture and corporate responsibility, committed to taking steps to ensure that slavery and human trafficking play no part in our own business or in our supply chains.
BUSINESS AND ORGANISATION
MGPSL is a private limited company incorporated in England and Wales and wholly owned by McKesson, a company incorporated in the State of Delaware, United States of America. The shares of McKesson are traded on the New York Stock Exchange. The McKesson group is a global leader in healthcare supply chain management solutions, retail pharmacy, community oncology and specialty care, and healthcare information technology.
MGPSL is the global sourcing and procurement organization for McKesson, delivering value by establishing global partnerships and developing new service solutions with manufacturers and suppliers focused on both generic and brand pharmaceutical products. In addition, MGPSL manages McKesson’s global private label strategy with a focus on generic, over-the-counter and medical-surgical products. MGPSL itself does not physically manufacture
products or purchase products from suppliers as part of its core operations.
VALUES, POLICIES AND TRAINING
MGPSL is committed to acting ethically and with integrity in all its business relationships, aiming to ensure that modern slavery and human trafficking is not taking place anywhere in its business. MGPSL expects all organisations within its supply chain to adopt an equivalent approach in their operations and to share its ethical values which reflect the McKesson I2CARE principles, namely: Integrity, Inclusion, Customer-first, Accountability, Respect and Excellence.
We have a zero-tolerance approach to modern slavery and all forms of discriminatory or exploitative behaviour and treatment, whether within our own business or that of those who supply us; this stance is made clear in all
our policies and behaviours. Our key policies and procedures, which outline the steps that we have taken to mitigate against the risks of modern slavery, are set out below. These are reviewed on a regular basis.
- McKesson’s Code of Conduct, to which the I2CARE principles are central, sets out the conduct that we expect of our partners, employees, contractors and suppliers and expressly states.
- McKesson’s Responsible Sourcing Policy establishes a framework for assessing the social, environmental and ethical impacts of goods and services procured by McKesson.
- McKesson’s Global Antitrust and Fair Competition Policy sets out our approach to compliance with applicable antitrust and competition laws where we do business.
- McKesson’s Global Anti-Corruption Policy provides employees with information about requirements of applicable domestic and international anti-corruption and anti-bribery laws and the tools and guidance to comply with them.
- McKesson’s Open Door Policy ensures provides the framework for all employees to have the opportunity to raise concerns safely and without fear of reprisal, enabling active and open communication.
MGPSL adopted a new Modern Slavery Prevention Policy, during the fiscal year ending 31 March 2022, which further enhances MGPSL’s commitment to tackling modern slavery and human trafficking within its supply chain.
In addition to the Open Door Policy, MGPSL employees are encouraged to raise concerns, including potential violations of McKesson’s Code of Conduct, company policies and applicable laws via the McKesson Integrity Line, operated by an independent third party and available either by phone or online to all employees 24 hours a day, 7 days a week, in multiple languages, through which concerns can be raised anonymously.
As part of our people and culture policies and procedures we only use reputable recruitment firms and comply with all relevant local laws and regulations. We regularly review our recruitment procedures and providers, as well as our arrangements for employee and contractors welfare by championing mental and physical wellbeing.
All employees are paid at least the minimum wage in the local jurisdiction and in London employees and contractors are paid the London Living Wage or above.
The firm has a dedicated employee assistance program which is a life management and personal support telephone service and is available to our employees 24 hours a day. This is a confidential service which is designed to support mental, physical, social and financial wellbeing.
SUPPLY CHAIN and DUE DILIGENCE
Where appropriate, MGPSL's principal agreements include language that requires MGPSL's business partners to comply with all applicable laws that relate to their interactions with MGPSL, including, but not limited to, human trafficking, forced labour and other forms of modern slavery.
COVID-19 PANDEMIC
MGPSL recognises the unprecedented challenges that were brought about by the Covid-19 pandemic in FY21 and that have persisted into the current fiscal year as they continue to lead to an increased chance of modern slavery in industry supply chains as businesses continue to adapt to the situation. MGPSL has continued to take steps to manage risks as they have emerged in order to guard against the occurrence of modern slavery within its organisation and its supply chains.
To help prevent the spread of the virus and ensure continuation of its operations, MGPSL has continued to monitor the governmental guidance on the Covid-19 pandemic and continues to facilitate homeworking for its non-essential personnel. MGPSL has continued to pay sick pay in accordance with its internal policy.
All usual MGPSL recruitment checks have been carried out remotely and all employees have had continued access to their usual support or grievance procedures as they remained available online and escalation routes remained fully available.
MGPSL has supported business partners during the pandemic by continuing to pay for orders or services promptly.
MGPSL’s Board of Directors has been kept up to date throughout the pandemic of risks posed by the virus and has been actively involved in determining any necessary adjustments to existing measures to help to protect MGPSL employees.
EFFECTIVENESS
MGPSL believes its efforts to date as outlined in this statement have been appropriate in helping prevent modern slavery and human trafficking from entering its supply chains.
GOING FORWARD
Following a review of the effectiveness of the steps we have taken in FY22 to help ensure its supply chain is free of modern slavery or human trafficking, MGPSL intends to take the following further steps to combat the occurrence slavery and human trafficking:
- Provide training to its employees on modern slavery to help ensure a high level of awareness and understanding of the risks of modern slavery and human trafficking within its supply chains.
- Continue to monitor the legal and risk landscape within the context of MGPSL’s core operations and adapt mitigation actions accordingly.
- Conduct a modern slavery risk assessment considering the organisational structure of MGPSL, operational model and recruitment and employment practices.
This Statement has been approved by the Board of Directors of MGPSL, and the Board has authorized G.B. Thomas, Director, to sign the Statement on behalf of MGPSL.