Pursuant to the California Transparency in Supply Chains Act of 2010 and Section 54 of the UK Modern Slavery Act of 2015, the Vetter group of companies (“Vetter”) provides the following statement to set out the steps taken by Vetter during the fiscal year ending 31st December 2020 to prevent modern slavery and human trafficking in its business and supply chains:
As a premier contract development and manufacturing organization (CDMO), Vetter is a global leader in the pharmaceutical fill & finish business and, as a family-owned, independent company with facilities in Germany, Austria and the US, as well as offices in Singapore, Japan, China and South Korea, we are fully committed to establishing, maintaining and improving systems and processes to prevent modern slavery both in our own operations and our supply chain.
Vetter realizes that today modern slavery can occur in many different forms such as coerced, forced or compulsory labor, child labor, domestic servitude, human trafficking, sex trafficking and workplace abuse. Therefore, throughout this statement we use the term "modern slavery”1 to encompass these various forms of coerced labor.
Vetter believes in the protection of human rights globally both in our own facilities as well as within our supply chain. To this end, we have established an integrated approach to compliance across our business also comprising risks related to modern slavery. Our commitment to these issues and to compliance in general is outlined in our Vetter Code of Conduct2 and in our Vetter Supplier Code of Conduct3. We have invested significant time and resources in creating an effective and efficient compliance management system and strive to collaborate with our customers and suppliers to support industry-wide improvements.
1. Corporate Policies
a) Vetter Code of Conduct
Our general commitment to compliance is outlined in our Vetter Code of Conduct that sets forth our code of ethics and covers the values and principles by which we conduct business worldwide. Our Code of Conduct confirms our commitment to honesty, integrity, social and environmental responsibility and to mutual trust and respect in every relationship of which we are part of. It provides information about the integrity standards that Vetter requires all employees and business partners, such as suppliers and customers, to follow, including standards relating to diversity, non-discrimination and anti-harassment. The Vetter Code of Conduct is applicable to, and complied by, every Vetter employee worldwide. We aim to extend the reach of our Code’s main principles to our trusted business partners as well.
b) Vetter’s Compliance Management Policy
Vetter’s Code of Conduct is accompanied by our Compliance Management Policy, that - translating our strong commitment to compliance - provides groupwide applicable rules for the general setup of Vetter’s compliance management system. It outlines the objective of our compliance management system - to mitigate Vetter’s potential corporate compliance exposure, especially, without limitation, in the areas anti-bribery and anti-corruption, fair competition, anti-modern slavery and harassment. It contains guidance for the identification and assessment of compliance related risks for the company as well as general measures to minimize them (e.g. principles for conducting business partner compliance due diligence). Furthermore, it describes structure and tasks of Vetter’s compliance organization, reporting channels for compliance related issues as well as procedures and guidelines for the handling of reported compliance incidents with a special focus on the protection of persons reporting incidents in good faith against any potential retaliation.
c) Vetter’s Supplier Code of Conduct
Our expectation towards our suppliers is to fully comply with all applicable laws, rules and regulations of the countries in which they do business as set out in our Supplier Code of Conduct. This includes, but is not limited to, the requirement that our suppliers commit to ethical business conduct and fair labor and employment practices such as prohibiting and refraining from any kind of child labor, forced labor, slavery or bondage in their organization and compliance with the applicable national laws regarding labor rights, work hours and wages. Vetter encourages its suppliers to select its subcontractors on the principles of Vetter’s Supplier Code of Conduct and to encourage subcontractors to comply with the minimum standards set forth therein. Furthermore, suppliers are encouraged to report compliance concerns. Since its implementation in 2015, the Vetter Supplier Code of Conduct is negotiated as part of Vetter’s agreements with suppliers.
2. Risk Awareness
Regular performance of compliance risk analysis is an essential part of Vetter’s compliance management system. In 2019 Vetter conducted its second companywide compliance risk analysis. A comprehensive analysis of the available company data and planned further development of Vetter’s business activities, the current market environment and the results of the interviews conducted through several levels of management within Vetter form the basis for the current company’s compliance risk profile. The aim to further sharpen this profile by conducting dedicated on site risk analyses with a special focus on certain geographical regions and functions in 2020, needed to be postponed due to the worldwide Corona pandemic and its accompanying restrictions. To bridge the time, Vetter focused in 2020 on conducting webinars – partly with participation of external business partners - with specific regional focuses and promoting the advisory function of Vetter’s Compliance Office within the company. The planned dedicated specific risk analyses will be conducted as soon as the circumstances will allow us to do so.
Based on published country risk profiles e.g. for corruption4 and modern slavery5, we conduct business partner due diligence. For this purpose, we developed a risk-based process for the systematic conduct of a compliance business partner due diligence and started in 2020 to implement it step by step at Vetter.
3. Accountability Standards
Vetter’s goal is to work with suppliers who embrace and comply with the principles of Vetter’s Supplier Code of Conduct, and in turn, to have these suppliers encourage compliance from any sub-supplier with whom they work in the delivery of any materials or services for Vetter. Vetter’s Supplier Code of Conduct foresees Vetter’s right to review and audit suppliers’ compliance with Vetter’s Supplier Code of Conduct. To the extent permitted by law and contractual provisions governing termination rights, we reserve the right to terminate relationships with third parties, including suppliers, who conduct business in a manner that conflicts with Vetter’s Code of Conduct or Vetter’s Supplier Code of Conduct.
Vetter employees who do not comply with the provisions of Vetter’s Code of Conduct may be subject to disciplinary action. Unless otherwise prohibited by law, disciplinary action may include termination of employment.
a) General Compliance Training
All in 2020 newly recruited employees of Vetter participating the obligatory onboarding process of the company received an introduction to Vetter’s Code of Conduct and compliance training via e-learning. All existing Vetter employees receive refresher trainings on a 2-years recurring basis, due to the corona pandemic either via instructor led online workshops in case of disciplinary supervisors or via e-learning. Vetter’s Code of Conduct and Supplier Code of Conduct as well as our Compliance training documents, are available in English and German. All trainings incorporated real case scenarios derived from the experiences from the advisory activities of the Compliance Office and from the compliance risk analysis exercises. Amongst the focus areas covered were prevention of modern slavery and increasing awareness for the requirement of conducting risk based business partner due diligence to identify, amongst others, risks of modern slavery in the supply chain. Employees are encouraged to raise questions and concerns.
b) Focused Compliance Training
Taking the outcomes of the Compliance Risk Analysis and the Compliance Health Check in 2019 into account we aim to continuously improve Vetter’s Compliance training system. In addition to the general Compliance trainings we conduct awareness trainings as needed.
Vetter monitors modern slavery risks based on the geographic locations in which we source materials from suppliers necessary - as well as based on the business segment in which we operate by reviewing published country risk profiles for corruption and modern slavery and sharing these within our organization. Vetter implemented a Whistleblowing Hotline which allows employees and external partners to raise, and thus the Vetter Compliance Office to pursue possible compliance complaints
Udo J. Vetter
1 A definition of modern slavery according to Transparency in Supply Chains Act can be found online under www.gov.uk: Transparency in Supply Chains etc. A practical guide, Annex A: Modern Slavery Definition, page 17.
2 Vetter’s Code of Conduct can be found online under https://www.vetter-pharma.com/en/about-us/corporate-social-responsibility/corporate-compliance
3 Vetter’s Supplier Code of Conduct can be found online under https://www.vetter-pharma.com/en/supplier/
4 See Transparency International’s Corruption Perceptions Index which measures the perceived levels of public sector corruption worldwide