Modern Slavery Act Statement

Modern Slavery Statement 2024

This statement is made in accordance with the United Kingdom’s Modern Slavery Act 2015 and Canada’s Fighting Against Forced Labour and Child Labour in Supply Chains Act 2023, and covers the reporting period from January 1st, 2024 to December 31st, 2024.

This statement is made on behalf of Hikma Pharmaceuticals PLC, including all its subsidiaries and the companies owned or controlled by it. The reporting entities covered by this single joint statement are listed in Annex I.

Unless expressly stated otherwise, references to ‘Hikma’, ‘we’, ‘us’ and ‘our’ refer to the companies comprising the Hikma group, and include the reporting entities listed in Annex I and all the subsidiaries and companies owned or controlled by Hikma Pharmaceuticals PLC.

Our commitment

We are firmly committed to conducting our business operations with the highest ethical standards and in compliance with applicable national and international laws, regulations, and codes. As a long-standing signatory and member of the United Nations Global Compact since 2007, we report annually on our progress. We have also been constituents of the FTSE4Good Index since 2014, reflecting our continued alignment with recognised environmental, social, and governance standards. In addition, we support the United Nations Guiding Principles on Business and Human Rights and are dedicated to upholding these standards across all our operations, regardless of jurisdiction.

In line with these commitments, we have implemented policies and processes to ensure our operations adhere to human rights standards and effectively prevent and address any potential abuses. A number of these policies and processes are outlined under the Codes and Policies section below, in our Modern Slavery Statement 2023, and additional information can be found in our Annual Report. Information on our work in relation to the integration of human rights aspects into our sustainability goals can be found in our annually published Sustainability Reports, available here.

We also have established controls to prevent and address modern slavery risks within our business operations and supply chains and continue to strengthen our measures to ensure that modern slavery—in all its forms, including slavery, servitude, forced or compulsory labour, exploitation (such as coercion, threats, deception, and child labour), and human trafficking—does not occur within our business. We require our partners, suppliers and third parties to do the same as set out in the Codes and Policies section below. This statement outlines the steps we have taken in 2024 to mitigate the risks of modern slavery within our business and supply chains.

Details of our past efforts and measures to address modern slavery risks can be found in our previous Modern Slavery Statements at the bottom of this page.

Our business structure

We help put better health, within reach, every day for millions of people around the world. For more than 45 years, we have been creating high-quality medicines and making them accessible to the people who need them.

Hikma operates globally through a network of 60 subsidiaries (59 as of the end of 2024), all of which are ultimately owned or controlled by Hikma Pharmaceuticals PLC, a publicly traded company headquartered in London, United Kingdom. We have a local presence in North America, the Middle East and North Africa (MENA), and Europe and have manufacturing and research and development (R&D) operations spread across 11 countries.

Our operational structure comprises distinct business segments that develop, manufacture, and market a broad range of pharmaceutical products. In the Generics segment, we supply oral, respiratory and other generic and specialty products to the North America retail market. Our Injectables segment supplies generic and speciality injectable products to hospitals across our markets, supported by our manufacturing facilities in the US, Europe, and MENA. Our Branded segment provides branded generic and in-licensed patented products from our local manufacturing facilities to retail and hospital customers across the MENA region.

We operate a global network of 9 R&D centres and 29 manufacturing plants that supply our global markets with a broad range of products. We are also developing a more diverse pipeline to meet the evolving needs of patients and healthcare professionals through investments in R&D and partnerships. In 2024, we further strengthened our manufacturing and R&D capabilities with the acquisition of Xellia Pharmaceuticals’ US finished dosage form (FDF) business and related assets, including a commercial portfolio, a differentiated product pipeline, a manufacturing facility in Cleveland, Ohio, and an R&D centre in Zagreb, Croatia.

Our venture capital arm is investing in opportunities in the growing digital health and life sciences space and is helping bring innovative health technologies to people around the world. Together, our approximately 9,500 colleagues are helping put better health within reach for patients and communities.

In 2024, we launched 132 new products, received 136 approvals, and submitted 206 regulatory filings to support the ongoing development of our product pipeline. Our product portfolio can be found here. During the same period, our core revenue reached $3,156 million, with North America contributing 62%, MENA 31%, and Europe and the rest of the world 7%.

A full list of our subsidiaries, and more information on our business structure, operations, and workforce are available in our Annual Report.

Our supply chain

Due to the global nature of our operations, our supply chains are complex and have considerable scale. We source a wide range of goods and services from thousands of suppliers from around the world, and we partner with wholesalers and distributors to supply our products to those who need them.

Different goods and services are sourced to support our manufacturing and R&D operations, such as raw materials and pharmaceutical ingredients for manufacturing drug substances and/or finished drug products, clinical trial support, machinery, equipment, laboratory supplies, and various material used for primary and secondary packaging.

We also source goods and services to support the various aspects of our business. These include equipment, office supplies, technologies, digital solutions and tools, IT systems and services, consulting services, professional services, marketing and distribution support, transportation, and other services necessary to support our operations. Additionally, we engage with various suppliers and third parties for the provision of different services such as catering, facility management, warehousing, transportation, clinical studies, engineering, and construction services to ensure the seamless functioning of our operations.

We partner with a network of external distributors whose support makes our products available to those who need them, as well as contract manufacturing organisations that supply finished and semi-finished products for sale and distribution by us.

In 2024, we spent close to $2 billion with over 7,000 suppliers. The highest category of our supplier spend during this period was for direct materials to support our drug production operations, including raw materials and packaging. In terms of indirect spend, the highest spend categories were machinery and equipment, professional services, and warehousing and logistics.

We continue to map the extent of our operations and supply chains and the various risks associated with the categories of supply and the geographical location of our suppliers. The current geographical reach of our Tier 1 suppliers extends to 70 countries worldwide. Approximately 36% of our total supplier expenditure is allocated to suppliers based in North America, 50% in Europe, and 14% between suppliers in the MENA, Asia, and other regions.

Identifying modern slavery risks in our operations and supply chain

Our risk assessment and due diligence processes are based on applicable laws and regulations and incorporate labour and human rights criteria. As described in our Modern Slavery Statement for 2023, we screen suppliers through our Third Party Onboarding and Management tool which, in addition to evaluating ethical, legal and financial risks, focuses on identifying indicators of modern slavery by considering various internal and external factors. In 2024, we expanded the list of factors, which now includes the category of products or services sourced, the geographical location of the supplier, country risk indices, compliance history, adverse information, the presence of migrant workers, and the nature of the business relationship.

Based on our risk assessment and the nature of our operations, we continue to believe that the risk of modern slavery in our directly employed workforce is low, mainly due to our adherence to the laws and regulation that apply to us, the enforcement of our policies and procedures, the highly skilled nature of our workforce, and the heavily regulated nature of the pharmaceutical industry.

However, based on our due diligence process, we recognise that the risk of modern slavery in our supply chain increases when we deal with suppliers, particularly suppliers that provide services and materials with greater exposure to modern slavery risks, such as certain commodities and raw materials, or those operating in high-risk jurisdictions where weak enforcement of international human rights standards may be prevalent. In addition, the risk of modern slavery in our supply chain may increase following acquisitions, as we inherit existing contracts and business relationships that may have different risk profiles and supplier oversight practices.

While the identification of modern slavery risks forms part of our broader risk detection framework, in 2024, we continued to specifically tailor and enhance our risk assessment criteria and due diligence process to improve the identification of modern slavery risks in our supply chains. We incorporated and/or used multiple indices that assess country-specific risks based on the prevalence of modern slavery, ethical standards, and human rights enforcement. These include, but are not limited to, the Walk Free Global Slavery Index and the Transparency International Corruption Perceptions Index.

Beyond country risk profiles, we have refined our criteria to assess the modern slavery risks associated with different categories of goods and services. This assessment is based on various governmental guidelines and indices, including the U.S. Department of Labor’s List of Goods Produced by Child Labor or Forced Labor. We have also consulted various publicly available material regarding the pharmaceutical industry such as the Rights DD, Pharmaceutical Supply Chain Initiative and other standards.

In addition to this assessment, we have developed targeted modern slavery questionnaires to evaluate specific risks within our suppliers' direct and indirect supply chains. The questionnaires are based on research and a review of available information, materials, and guidance, including resources provided by the Social Responsibility Alliance. We also ensured the questions covered potential areas of modern slavery risk within our supply chain to gain visibility into suppliers’ operations and effectively identify potential risks. These questionnaires assess a range of risk factors relevant to identify modern slavery, including suppliers' internal controls, labour practices, and the presence of migrant, contract, temporary, or seasonal workers. Prospective suppliers are required to complete a basic modern slavery risk questionnaire. If a supplier is identified as high-risk based on our scoring criteria and responses to the basic modern slavery questionnaire, they will be required to complete an enhanced modern slavery questionnaire with more detailed inquiries to further assess and evaluate modern slavery risks. Once completed, a risk re-assessment is conducted and, depending on the evaluation, a risk score is given to each supplier.

We are also considering ways to improve our visibility beyond our direct supply chain. As part of this effort, our enhanced modern slavery questionnaire includes targeted questions aimed at assessing the extent to which suppliers identified as high-risk for modern slavery have visibility over their own supply chains, specifically in relation to identifying and managing modern slavery risks. These questions focus on determining whether our direct suppliers are actively screening for modern slavery risks within their own operations and across their extended supply chains. They also assess whether any such risks have been identified, and whether suppliers have implemented measures, such as contractual obligations to ensure their own suppliers comply with applicable laws and regulations, including those related to modern slavery. This approach is intended to promote transparency and encourage responsible practices throughout the broader supply chain.

Based on this assessment and review, suppliers are assigned a risk rating, categorizing the level of risk inherent in the business relationship as low, medium, or high.

We have also successfully assessed suppliers who make up around 60% of our procurement spend for 2024 against labour and human rights (including sub-topics related to anti-exploitation and anti-slavery), ethics, environment and sustainability areas, either through our collaboration with EcoVadis or through leveraging our own sustainability questionnaire.

Our sustainability questionnaire was developed in 2024 to ensure accessibility for suppliers not registered on EcoVadis, and to enable a consistent assessment across all relevant areas. This questionnaire evaluates suppliers against key criteria, including human and labour rights (which includes modern slavery), health and safety standards, environmental practices, and ethical conduct. We also produce internal sustainability reports on a biannual basis, which include information on suppliers identified as having lower theme scores or specific concerns. These supplier profiles are regularly monitored to ensure that any risks are appropriately addressed. The reports are shared with senior leadership to support informed decision-making and oversight.

New Process Developed for Legacy Suppliers

In addition to the above enhancements, and to ensure a comprehensive assessment of our supply chain, we continue to prioritise due diligence efforts in areas where they are likely to have the greatest impact. As part of this approach, in 2024, we developed and implemented a methodology to assess our existing legacy suppliers for modern slavery risks. As part of this effort, we applied a risk assessment approach to evaluate risk exposure that combines the indices and criteria outlined above to identify materials and services that carry a high likelihood of modern slavery risk based on country risk profiles and the risk associated with the category of goods and services these suppliers provide. After identifying high-risk profiles, we used EcoVadis and/or our modern slavery questionnaires to assess risks associated with modern slavery. Based on the results, appropriate actions for medium and high-risk suppliers were determined on a case-by-case basis, with action plans implemented as needed as described under the Supplier and Third Party Management Process section below.

Assessment of Legacy Suppliers Providing Materials

We assessed existing legacy suppliers of materials and commodities that carried a heightened risk of modern slavery who meet a certain spend threshold, regardless of their geographical location. In 2024, we identified 67 suppliers who supplied categories identified as high-risk materials, representing around 3.7% of our total 2024 spend. Following the implementation of the risk assessment process described above, 4 suppliers were issued corrective action plans, and 28 suppliers remain under assessment for various reasons, including incomplete questionnaires, the rest did not require further action.

Assessment of Legacy Suppliers Providing Services

We adopted a phased approach, prioritising legacy suppliers in high-risk countries where we have a substantial presence or operations. This assessment focused on jurisdictions identified using the indices and criteria outlined above. In 2024, we identified 30 suppliers of high-risk services in these jurisdictions which included, amongst other services, construction, catering and security. Following the implementation of the risk assessment process described above, 5 suppliers were issued corrective action plans, 9 suppliers remain under assessment due to incomplete questionnaires and other outstanding factors, the rest did not require further action.

To ensure a consistent and comprehensive assessment of modern slavery risks, we plan to extend this methodology to our next priority group of service providers within the legacy supply chain who provide services in countries that present heightened risk of modern slavery and weak enforcement of human rights.

Preventing and addressing modern slavery risks

Governance

Our Corporate Compliance Programme, including modern slavery, is overseen at the highest levels of the organisation. It is governed by the Board-level Compliance, Responsibility and Ethics Committee (“CREC”), which assists the Board of Directors in fulfilling its compliance and risk management responsibilities. The CREC also has direct oversight of ethical issues related to our suppliers. The terms of reference for the CREC are available here, details of our Board of Directors can be found here.

Our Chief Compliance Officer (“CCO”) is a member of senior management and is responsible for the day-to-day management of Hikma’s Compliance Programme, including managing policies, conducting training, auditing, monitoring, and overseeing investigations. The CCO provides periodic reports on the Compliance Programme to Hikma’s Executive Committee and the CREC. The Board of Directors also oversees our risk programme and receives reports on relevant issues, which include risks for third-party management and ethics and compliance.

Hikma’s Modern Slavery Taskforce (“MS Taskforce”) comprises senior members from the Legal, Procurement, and Compliance teams, who meet on a monthly basis, or more often if required, to discuss developments and coordinate action in relation to modern slavery in our operations and supply chains. The MS Taskforce continuously identifies areas where we can strengthen our procedures for detecting and preventing risks of modern slavery risks in our supply chains. In 2024, the MS Taskforce has consulted with legal advisers and risk assessment specialists to evaluate various ways we can enhance our risk assessment and due diligence process to ensure the effective implementation of our measures for identifying, preventing, and mitigating risks of modern slavery in our supply chain, including meeting with service providers to discuss supplier audit protocols and solutions.

The MS Taskforce is also responsible for raising awareness and providing function-specific training on updated due diligence processes, modern slavery legislation requirements and risk mitigation strategies. The work of the MS Taskforce is reported regularly to senior management and is presented to the Board of Directors on an annual basis, ensuring continued alignment and engagement in our commitment to addressing modern slavery risks. Further information on the work and accomplishments of the MS Taskforce can be found in our Modern Slavery Statement 2023.

Codes and policies

We are dedicated to achieving best practices across our operations, including our supply chains. We work alongside our industry partners to uphold ethical labour practices and safeguard human rights.

Our Code of Conduct (“Code”) sets out the core standards and ethical behaviours that we expect our employees, contractors, and third parties with whom we contract or do business to apply and uphold, including compliance with human rights and labour rights principles and modern slavery laws. The core principles enshrined in our Code are underpinned by a number of group, regional and local policies, procedures and guidelines that help uphold our values and mitigate against human rights violations and risk of modern slavery.

Our Supplier Code of Conduct reinforces these commitments by setting clear expectations for suppliers, partners, and third parties. It requires them to operate in alignment with our values, explicitly prohibits the use of forced labour, child labour or modern slavery, and promotes responsible practices throughout their own supply chains. Our Supplier Code of Conduct also imposes a responsibility on our suppliers to ensure that their own suppliers and contractors are subject to the same standards, restrictions, and expectations as their own. Additionally, it requires our suppliers to demonstrate that they have undertaken reasonable enquiry into, and are not aware of, any instances of modern slavery directly or indirectly linked to their business operations, products, or services. The Supplier Code of Conduct, and our Code of Conduct, also include details of our Speak-Up channels, enabling suppliers and others to report concerns related to misconduct or potential modern slavery.

As part of our commitment to promoting human and labour rights and ensuring these principles are effectively implemented in our operations, we have established a range of supporting policies and procedures. These include health and safety protocols, risk assessment and due diligence processes to evaluate supplier and third-party compliance with ethical and legal obligations, and a robust whistleblowing infrastructure to enable the reporting of concerns or misconduct. We also maintain an investigation framework to address any instances where rights may be compromised, as well as policies designed to support fair employment practices. Our policies are approved by the senior leadership team and are communicated to employees at regular intervals through a range of channels. They are published on our internal intranet, ensuring accessibility to all staff, and are supported by targeted training initiatives as needed to promote understanding and strengthen compliance.

We regularly review our Code, Supplier Code of Conduct, and related policies to ensure they remain effective, relevant, and aligned with evolving risks and best practices. This review process involves input from key stakeholders, including the Board of Directors when appropriate or required, and supports our culture of continuous improvement and accountability.

In 2024, we reviewed several key policies to reinforce our commitment to ethical conduct and a safe working environment. These included, but are not limited to, our Anti-Bribery and Corruption Policy, Investigation Policy, and our Anti-Harassment Policy, which prohibits all forms of violence, harassment, and intimidation.

Supplier and third party management process

Our Third Party Onboarding and Management tool enables us to assess various risks, including potential labour rights or modern slavery risks, before entering into a commercial relationship with the supplier. After onboarding, suppliers are subject to ongoing monitoring to ensure that any changes to their risk profiles during the course of the relationship are promptly identified and appropriately addressed. We also conduct audits on suppliers involved in the manufacture of active pharmaceutical ingredients to ensure compliance with applicable regulatory requirements. Details of our Third Party Risk Management process, including the tool, due diligence checks and onboarding process is provided in our Modern Slavery Statement 2023.

We apply a set of risk evaluation criteria to categorise suppliers based on their risk profiles, including their potential exposure to modern slavery. From our preliminary risk assessment in 2024, 55% of our assessed supplier base has a low risk profile, 38% has a medium risk profile, and 7% has a high-risk profile, most of which were rated high risk based on the category of material or service they provide.

Profiles identified as presenting medium or high risk are subject to enhanced due diligence and further evaluations, and the appropriate response is determined on a case-by-case basis in collaboration with relevant departments, including the Compliance, Procurement, and Legal functions. The nature of the actions we take depends on several factors, such as the type, severity, likelihood of the identified risk, the underlying cause of non-compliance, and the degree of influence we can exercise.

For suppliers with modern slavery risks, we consider the same factors in determining appropriate actions which may include, among others:

  • Direct engagement with the supplier to further assess and understand the nature and extent of the risk,
  • Requesting relevant documentation, such as policies, procedures, and assurances demonstrating compliance with labour and human rights standards,
  • Developing a corrective action plan to address any identified gaps,
  • Conducting a formal investigation where necessary to assess the severity of the concern,
  • Commissioning audits,
  • Exploring alternative sourcing options to reduce dependency on high-risk suppliers; and
  • Terminating the business relationship where concerns are not adequately addressed or where the level of risk is deemed unacceptable.


Where corrective action plans are developed in collaboration with suppliers to address identified risks of modern slavery, members of our Procurement and Compliance teams work closely with suppliers to ensure proper implementation. Progress is subject to regular review and oversight by senior members of the Compliance and Procurement teams to ensure effective follow-up and resolution. This multi-disciplinary approach ensures that we apply consistent and effective measures to detect, address, and prevent modern slavery risks across our supply chains.

Throughout 2023 and 2024, we proactively engaged with suppliers flagged as high-risk under the Labour and Human Rights screening factor on EcoVadis in 2023. Our aim was to support these suppliers in addressing identified gaps, allow them to provide any necessary documentation and completing their corrective action plans. As a result of these efforts, no suppliers currently assessed through EcoVadis are flagged as high-risk under this factor. We remain committed to expanding supplier participation in the EcoVadis sustainability assessment, as part of our continuous effort to uphold and promote the highest standards of labour and human rights across our supply chain.

As part of our approach to managing risk throughout the contractual relationship, suppliers acknowledge their compliance with the prohibition of modern slavery and our Supplier Code of Conduct, which sets out expectations on ethical conduct. These expectations are reinforced through contractual clauses that explicitly require compliance with our Code and applicable laws, and reserve our right to terminate the relationship in cases of non-compliance with applicable legal requirements, including modern slavery legislation. Information on the standard clauses we have in our supplier contract templates is provided in our Modern Slavery Statement for 2022.

Recognising that modern slavery and human rights violations can be particularly difficult to detect in the lower tiers of our supply chain, we have engaged with multiple external audit professionals to assess and identify suitable audit solutions. These efforts have focused on evaluating audit methodologies that place a strong emphasis on labour and human rights risks, particularly in high-risk sectors and geographies. We are exploring both targeted and risk-based audit models, including remote and on-site approaches, to improve visibility into working conditions and identify potential issues that may not be easily detected through due diligence methods.

Training

Our Code provides guidance to our employees and partners on the ethics of Hikma’s business activities through the identification and discussion of various risks associated with our business. All our employees, officers and directors have undertaken training on the Code, which raises awareness of the risks of slavery and human trafficking and other legal and ethical considerations, such as privacy, health and safety and bribery and corruption.  The training also covers how to respond to any misconduct and violations and clarifies internal escalation channels for reporting misconduct and/or to voice grievances. As of 2024, the training had a completion rate of 98%.

Additionally, a refresher training on our Code of Conduct was rolled out to all employees in 2024, which included dedicated content on modern slavery. The refresher training was made available in 7 different languages and has been completed by 98% of employees to date.

Also, in 2024, members of the MS Taskforce delivered tailored training on modern slavery to key functions that are on the front line of risk detection, including the Operations, Procurement, and Compliance teams. Additional training was also provided to the site leadership teams in the USA. The training covered the risks and indicators of modern slavery, supplier risk management process, due diligence requirements, relevant legislation, the procedures for escalating concerns and a case study.

Employment processes

We respect the principles set out in the UN Declaration of Human Rights and the International Labour Organisation (“ILO”). Our employment practices are aligned with international standards and applicable local laws, ensuring, as a minimum, compliance with ILO standards on minimum working age and child labour, as well as national legal requirements. We take our responsibility seriously to ensure that all workers are treated fairly, are not subject to exploitation, work in safe conditions and recognise employees’ freedom of association and rights to collective bargaining. Our Group Environmental, Health and Safety Policy Statement outlines the principles for ensuring health and safety, which is further supplemented by local policies and procedures to ensure that health and safety considerations are consistently applied in line with international standards.

Our talent acquisition policy outlines our global recruitment procedure and ensures that we continue to offer a fair and equal employment opportunity for all candidates. We adhere to the ‘employer pays' principle; with the exception of a few specialized, high-level targeted roles, vacancies are openly posted on the Careers’ Page on our website. Candidates can apply using the application process, and no individual is required to pay fees to obtain a job.

In 2024, we continued our collaboration with a specialist third-party organisation to obtain updated living wage data for six of the largest countries where we operate. Based on that, we have implemented compensation adjustments in one country and continue to work on the data for the remaining countries. In 2025, we plan to conduct a review of our salary scales across the organisation.

We actively engage with our employees through regular surveys and other channels to ensure their concerns and feedback are heard and addressed. In 2024, we conducted an employee engagement survey to assess levels of engagement and enablement, with a focus on key areas that include wellbeing and compensation. Based on the findings, targeted actions were developed at both the Group and site levels and the survey results were shared with employees and announced through employee broadcasts, and town halls were held in various sites to discuss outcomes and improve employee engagement. Further information on our commitment to employee engagement can be found on page 27, and on our efforts to empower our people on page 54, of our 2024 Annual Report.

Reporting and investigation procedure

We maintain an open and transparent culture where employees and external stakeholders can report concerns or suspected violations of our Code of Conduct, policies or applicable laws through our Speak Up line. Operated by an independent third party, our Speak Up line is accessible via our website and provides unanimous reporting, support in 7 languages (Arabic, English, French, German, Italian, Portuguese, and Chinese) and toll-free phone lines in the US and some of the countries in European Union.

In 2024, as part of our website update, we ensured that the Speak Up channel remains prominent on our main website and all sub-sites. We also reviewed our Speak Up infrastructure to identify areas for improvement. We have established modern slavery and forced or child labour as a standalone reporting category, rather than a sub-category under human rights, for our US and MENA channels. We are currently working with our independent third-party provider to implement the same change across our EU channels. This change aims to enhance the clarity, prioritisation, and response to these specific risks. Additionally, to comply with local legal requirements in certain countries, we offer local reporting channels alongside our Group-level reporting mechanisms. We remain committed to fostering a safe environment where individuals can report concerns without fear of reprisal or retaliation and continue to enforce our Non-Retaliation Policy to ensure that anyone reporting potential violations or misconduct is protected from adverse consequences.

All reported concerns are thoroughly investigated, and appropriate remedial actions are taken as necessary. No substantiated cases suggesting instances of modern slavery, health and safety or employment law violations were received in 2024.

Measuring the effectiveness of our controls

We rely on our Third Party Risk Management programme to detect, mitigate, and address potential risks of modern slavery. The programme also enables us to evaluate the effectiveness of our internal controls and assess the adequacy of any actions taken to identify areas of improvement and enhancement, including relevant policies, contractual protections, and training initiatives.

To assess the effectiveness of our internal controls in identifying and addressing modern slavery risks, we monitor a range of indicators. These include, among other things, the number of suppliers screened through our Third Party Risk Management tool, including both new and legacy suppliers; the number of modern slavery or labour rights’ risks or incidents raised through the process; and the number of remediation actions initiated, including corrective and preventive actions. We also track the number of Speak Up cases reported that relate to modern slavery or broader human rights concerns.

Developed corrective action plans are regularly reviewed and reported to senior members of the Compliance and Procurement teams to ensure appropriate monitoring of risk profile, follow-up and resolution as further provided under the Supplier and Third Party Management Process section above.

Additionally, our controls have enabled us to proactively identify and address potential risks at various stages of the commercial relationship with suppliers. In one instance, adverse information related to a member of a supplier’s corporate group was flagged during onboarding through our Third Party Risk Management tool. In response, we issued our enhanced modern slavery questionnaire, which included detailed questions to enable us to identify the risk and we engaged directly with the supplier to assess the nature of their relationship with the affiliated entity. We also requested additional data to determine which corrective actions could be pursued. Our team worked with the supplier’s representatives to evaluate their response and we continue to work with the supplier to ensure satisfactory responses and information are received prior to completing onboarding.

We acknowledge that modern slavery is a complex and often hidden issue, especially within the lower tiers of our supply chain. Therefore, we are committed to continuously enhancing our existing controls improving risk detection and response across our operations and supply chain, and ensuring our practices remain effective and aligned with evolving best practices. In 2025, we will build on these efforts by exploring additional ways to assess the effectiveness of our actions in combating modern slavery, including:

  • Continue to enhance our due diligence processes. We are discussing collaboration opportunities with audit service providers to improve risk identification and visibility into working conditions and identify risks
  • Increase awareness of modern slavery across our workforce and consolidate existing human rights-related policies into a single, comprehensive Human Rights Statement.
  • Increase collaboration with industry experts, other businesses, organisations and initiatives to help support with anti-slavery activity.
  • Strengthen the ongoing monitoring of existing legacy suppliers, including expanding the number of jurisdictions and suppliers covered by our risk assessment methodology.

 

This Modern Slavery Statement 2024 was reviewed by senior management teams of the reporting entities listed in Annex I and was approved by the Board of Directors of Hikma Pharmaceuticals PLC on 24 April 2025.