Menarini Diagnostics UK’s Modern Slavery Statement 2019

This statement has been published in accordance with the Modern Slavery Act 2015. The Act requires businesses to state the actions they have taken during the financial year to ensure that modern slavery is not taking place in their operations and supply chains.
The aim of this statement is to provide an update on the progress that Menarini Diagnostics UK Limited has made during the financial year ending 31 December 2019, and will continue to make, to prevent modern slavery in the business and our supply chains.
Menarini Diagnostics UK fully endorses the Modern Slavery Act 2015 in order to eliminate all forms of human slavery, human trafficking and forced labour (“Modern Slavery”). Menarini Diagnostics UK acknowledges the importance of companies working together to tackle such issues in our society and around the world.
Menarini Diagnostics UK condemns all forms of Modern Slavery including child, forced or compulsory labour. It is acknowledged by Menarini Diagnostics UK and its staff that we all have a responsibility to be aware of Modern Slavery. Employees and business partners are requested to speak up and report incidents if they believe that someone has done, is doing, or may be about to do something that violates this principle.
The Menarini Business and Supply Chains
Menarini is one of Europe's leading pharmaceutical and healthcare companies, with headquarters in Florence and research facilities in Pomezia, near Rome. The organisation, which was incorporated over 100 years ago has over forty subsidiaries operating throughout Eastern and Western Europe, with a network of marketing partners covering other countries around the world. The Menarini group consists of pharmaceutical, over the counter medicine and diagnostic divisions, as well as several other divisions concerned with bio-medical measurement. The Menarini group turnover is over £3 billion, with further expansion across the world planned during 2020.
Menarini Diagnostics was established in the UK during 1987 and the company is now established as one of the fastest growing Diagnostics companies in the UK with annual growth in excess of 20%. To date Menarini has already placed more than 700 analysers of various types in the UK market. We are market leaders in the field of Diabetes Diagnostics, with leading edge systems for HbA1c, blood glucose and continuous glucose monitoring. We are also growing rapidly in the areas of Immunohistochemistry, Autoimmune disease, viral detection and near patient systems for veterinary diagnostics.
Menarini, both in the UK and internationally, acts according to its Ethical Code and Group Conduct Policies. These policies, which in total cover affiliates in more than 40 countries, specify ethical behaviour towards all employees. They also require all supplier organizations in the company’s supply chain to meet the same ethical standards. These standards preclude unfair or inhumane working conditions, human slavery, human trafficking and forced labour.
Adherence to the company’s Ethical Code and Group Conduct Policies, and both internal and external audit of compliance, preclude any possibility of the company or its supply chain conducting any practices such as modern day slavery, inhumane working conditions, human trafficking and forced labour.
Beyond this, Menarini Diagnostics UK supports and respects human rights and has implemented the UN Guiding Principles on Business and Human Rights and we periodically assess our human rights risks at a corporate level to ensure that we focus on where our business has the greatest potential to impact people.
Menarini Diagnostics UK requires its business partners to comply with all applicable laws, regulations, industry codes and contractual terms as well as with generally accepted sustainability standards. All transactions by Menarini Diagnostics UK with third parties are made on the basis of quality, efficacy, safety, sustainability and ethical integrity. Menarini Diagnostics UK remains committed to these principles and requires its suppliers to acknowledge and adhere to the principles embodied in its Code of Conduct and to ensure that their own suppliers will also comply.
Assessment of Modern Slavery Risk
i) Workforce
The risk of modern slavery in our directly employed workforce is low. This is due to the highly regulated nature of our industry, our employees being largely UK-based nationals or local, are educated or skilled, or undertaking work in controlled environments where there are established policies and processes.
ii) Third Parties
At Menarini Diagnostics UK we understand that there is a potential exposure to Modern Slavery when we are purchasing goods and services from third parties.
Our exposure to the risk of labour exploitation increases when we engage with third parties and, recognising this, in 2018 we implemented our Third Party Due Diligence procedure BM3-2-2 to strictly control our third party relationships. The process includes mandatory third party risk assessment for each third party company, or individual, incorporating background checks and red flag review to preclude against Modern Day Slavery and mitigate against any risk of exposure.
Modern Slavery Training
All employees at Menarini Diagnostics UK are trained on the Menarini Diagnostics UK Code of Conduct which covers Modern Slavery. The Modern Slavery training programme that we developed in 2015 has been delivered across our UK business and incorporated into our induction programme for new employees.
Further steps taken by Menarini Diagnostics UK globally to prevent Modern Slavery in our supply chains
Menarini Diagnostics UK uses a risk based approach to identify the highest risk suppliers and service providers and corrective action is taken based on the risk presented by the supplier/provider.
Corporate Supply chains are subject to supplier audit using a protocol that covers all aspects of human rights, including Modern Slavery.
Menarini Diagnostics UK consults industry and cross-industry best practices to continuously improve our approach to identifying and addressing modern day slavery risks.
In 2019 our Corporate Compliance Group undertook a global cross-functional project to identify and assess potential risks to our compliance status. The Project had the objectives to gather and visualise information on compliance risk exposure; allocate resources more efficiently and effectively and identify patterns and trends on risk exposure over time. The project is scheduled for completion during 2020.
Menarini Diagnostics UK will continue to update its policies and procedures, raise awareness on the important topic of Modern Day Slavery and look at how it can address the issue within its business and supply chain. We will continue to work at maintaining appropriate safeguards against any unethical treatment of persons involved in our supply chain or our own business.
This statement has been approved by the Managing Director of Menarini Diagnostics UK Diagnostics Limited.
Paul Tolan
Managing Director
A. Menarini Diagnostics UK

11 Nov 2020

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