FOCUS PHARMACEUTICALS LIMITED

Policies described

Freedom of workers to terminate employment Prohibits any threat of violence, harassment and intimidation Prohibits child labour Prohibits discrimination

Training described

Your whole organisation

Worker engagement and working conditions

Your suppliers Professional auditors Workers within your organisation Workers within your supply chain

Grievance mechanisms

Using anonymous whistleblowing services, such as a helpline or mobile phone app

Other monitoring

We have a contractual right to visit the facilities of our Suppliers and Manufacturers to control the way they operate (including the working conditions across their operations).

Demonstrated progress

We take a range of measures to monitor the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or Partners. We are committed to continuously improving the way we manages our business operations. As part of this commitment we will continue to review and improve our policies, processes and controls to ensure that modern slavery does not take place in any of our supply chains or our own business.

Reported risks and mitigations

• Risk: Global business activities in multiple locations and jurisdictions with various approaches regarding modern slavery.
• Area: Within your supply chains
• Tier: Tier 1 suppliers Tier 2 suppliers Tier 3 suppliers and below
• Group: Migrants Refugees Children
• Location: India
• Mitigation: ADVANZ PHARMA has implemented a “Standards for Product Manufacturers and Suppliers” Policy that sets forth ADVANZ PHARMA standards and requirements for all its Manufacturers and Suppliers in the areas of ethics, labor rights, health and safety, environmental and human rights practices. In addition we require from any new business partner to complete and sign an Anti-Corruption and Modern Slavery Declaration and to comply with all the mentioned requirements.
• Risk: Business interactions with a large scale of third party vendors, including distributors, suppliers, manufacturers which means that compliance with applicable Human rights laws is harder to control.
• Risk: Operational entities in several locations and jurisdictions with a decentralised management structure which increases the difficulty to monitor and control staff behaviour.
• Area: Within your own operations
• Group: Migrants Children
• Mitigation: We have implemented a robust Compliance programme within the Group including policies, control processes and trainings, In addition we are conducting internal and external audits on a yearly basis to control and monitor our worlwide activities.