Statement of Compliance with Section 54 of the U.K. Modern Slavery Act

Introduction

Section 54 of the U.K. Modern Slavery Act 2015 provides information regarding organisations’ efforts to address the issue of slavery and human trafficking.

This statement has been prepared on behalf of Bausch & Lomb U.K. Limited (the Company).

This statement constitutes the Company’s 2019 slavery and human trafficking statement which covers the period 1 January 2019 to 31 December 2019 and sets out the steps that we have taken to help ensure that modern slavery is not occurring in our business or in our supply chain.  

We fully support the intent of U.K. Modern Slavery Act 2015 and oppose human trafficking and slavery in all forms. We work to the highest professional standards to ensure that we comply with all laws and regulations applicable to the Company. The Company is committed to improving our practices to combat slavery and human trafficking within our own organisation and within our external supply chain. We expect our suppliers to conduct business abiding to all applicable laws, rules and regulations.

Organisation's Structure

We are part of the Bausch Health Group (Bausch Health), and our ultimate parent company is Bausch Health Companies, Inc. Bausch Health has its corporate headquarters in Laval, Quebec, Canada, and its U.S. headquarters are in Bridgewater, New Jersey. Bausch Health manufactures and markets a broad range of branded and generic pharmaceuticals, over-the-counter (OTC) products and medical devices (contact lenses, intraocular lenses, ophthalmic surgical equipment and aesthetic devices) directly or indirectly in more than 100 countries and has approximately 21,000 employees worldwide.

Bausch Health are focused on improving people’s lives with our health care products. We take this commitment seriously and, our Global Corporate Social Responsibility (CSR) strategy is endorsed and ingrained at the highest level in Bausch Health. It is central to how we want to run our business. We focus our CSR work in five key areas:

  • Operate with Integrity
  • Respect the Environment
  • Advance Global Health and Patient Care
  • Improve Our Communities
  • Support Employee Growth and Well-Being

In 2018 Bausch Health published its inaugural annual CSR report. Each year, our CSR Reports sets out Bausch Health’s accomplishments in the five key areas.

In addition, Bausch Health has issued a statement in relation to compliance with California Transparency in Supply Chains Act of 2010 (SB 657).

Corporate Governance Policies

Bausch Health’s strong system of internal controls enables the management team to comply with corporate policies and applicable laws and regulations. For many years, we have conducted annual corporate governance training to ensure our employees stay informed, up-to-date and in compliance with our Corporate Governance policies including our:

  • Standards of Business Conduct, which includes our commitment to the following standards among others:
    • Competitive Practices: We will engage only in fair and open competition in compliance with applicable laws, rules and regulations.
    • Integrity of Business Records and Reporting: We will record and report all data and information accurately, honestly, and in sufficient detail.
    • Dealing with Government Official: We are committed to complying with the letter and spirit of the United States Foreign Corrupt Practices Act and its other local equivalents, such as the UK Bribery Act 2010.
    • International Transactions: We will abide by all applicable laws, rules and regulations when conducting international transactions.
    • Quality Standards and Assurance: We will perform services and manufacture products with a commitment to a high level of quality. 
    • Conflicts of Interest: We will avoid conflicts of interest.
    • Equal Opportunity Workplace Environment: We will act with respect and consideration. 
    • Health, Safety and Environmental Protection: We will be sensitive to the effects of our operations on the environment and will strive to prevent injury and illness in the workplace.
    • Reporting Questionable Practices: We will encourage employees to ask questions and report potential compliance concerns.
  • Business Ethics Reporting Policy
  • Global Anti-bribery Policy

These policies apply to all Bausch Health employees, officers and directors. Certification on an annual basis that they have received, read, and been trained on these policies (biennially) is required. Bausch Health is  committed to adhere to the highest standards of ethics and integrity in all of our interactions with patients, health care providers, customers, fellow colleagues and other key stakeholders. Bausch Health vigorously enforces these policies and will take prompt and appropriate action, up to and including termination of employment or other relationship, of those found to be in violation.

Ethics Point

The Business Ethics Reporting Policy is designed to make it easy for reporters to make disclosures, without fear of any detrimental treatment. Bausch Health maintains an independent Ethics Point Hotline that allows its worldwide employees to provide a confidential way to raise concerns of unethical conduct, including those related to supply chain. It consists of toll-free telephone lines that are available anytime — 24 hours a day, seven days a week in over 100 languages, and an online reporting service. It is operated by an external independent firm. Concerns may be raised anonymously.

Labour Standards Assurance System

The Labour Standards Assurance System (LSAS) has been developed by NHS Supply Chain, in conjunction with the Department of Health and industry bodies. LSAS provides an extra level of corporate, social and ethical governance with regard to labour standards, marking a major but progressive change in its procurement methodology. In July 2017, the Surgical Business Unit of the Company achieved Level 2 accreditation of LSAS. In 2019 the Company successfully maintained Level 2 accreditation of LSAS.

The Company’s Labour Standards Assurance System Policy (LSAS Policy) reflects our commitment to acting ethically and with integrity in our business relationships and to implementing and enforcing effective systems and controls to help ensure slavery and human trafficking is not taking place in our supply chains.

Training on LSAS and the LSAS policy forms part of the induction process for all individuals who work for the Company, and annually thereafter. In addition, the LSAS policy is publicly available on the Company’s website. This policy shall also be communicated to key suppliers, contractors and business partners of the Company, specifically those that are connected to the UK Surgical Business. Conducting annual training on LSAS and the LSAS policy with employees helps them take ownership and accountability for doing their part to create a culture of awareness, a high level of understanding of the risks of modern slavery and human trafficking and compliance to help ensure that there is no modern slavery or human trafficking in our supply chains or in any part of our business.

Supply Chain

Supplier Evaluation, Qualification, and Verification

Bausch Health uses a risk‐based assessment process for evaluating, verifying and selecting direct suppliers. This qualification process may include supplier questionnaires or audits of supplier facilities, which may be completed by Bausch Health or a third party, following which Bausch Health verifies each direct supplier through the completion of a supplier risk assessment. Bausch Health expects all of its suppliers to abide by all applicable laws and regulations and maintain the highest ethical standards.

Supplier Agreements and Certification

In its supply agreements, purchase orders and other arrangements with its direct suppliers, Bausch Health includes provisions requiring such direct suppliers to comply with applicable laws and regulations, including as relates to the products or materials being supplied.

Supplier Audits

Bausch Health regularly conducts audits of its suppliers for compliance with applicable law and regulations and good manufacturing standards, as well as the performance of obligations under and the compliance with the terms and conditions of purchase orders and supply agreements. Bausch Health may conduct these audits directly or may utilise a third party.

Supplier Due Diligence

As part of our LSAS initiative to identify and mitigate risk we contacted all key suppliers within the UK Surgical Business supply chain that were categorised as high and medium risk, requesting that they complete the Company’s Modern Slavery Questionnaire. The Questionnaire seeks information regarding the supplier’s business, including the locations of a supplier’s operations, the policies employed by the supplier, information about labour practices, remuneration, health and safety, how they manage the risk of modern slavery or human trafficking in their supply chains, etc.

In addition, Bausch Health’s Third-Party Due Diligence Standard Operating Procedures contains procedures on carrying out checks on suppliers before we deal with them.

Future

The Company is committed to continually demonstrate additional improvements and enhancements to our processes, which includes ongoing training and further development of initiatives to raise awareness amongst its employees. We will continue to work to maintain Level 2 accreditation of LSAS with completion of annual LSAS audit and aim to demonstrate additional improvements and enhancements to our processes. It is our belief that the process and KPI’s that form part of Level 2 accreditation of LSAS will enhance our visibility and ability to identify modern slavery and human trafficking risks.

The Company strives to continuously improve our management systems and our performance in the areas of labour standards, environmental health and safety, and encourages the same from our suppliers. The Company will undertake a comprehensive review of our LSAS Policy to help ensure an evolution of our approach to modern slavery and human trafficking risks.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 31 December 2019. It was approved by the Board on 26 June 2020.

Ben Hesketh
General Manager, UK&I
26 June 2020

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Statement of Compliance with Section 54 of the U.K. Modern Slavery Act
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