The UK Modern Slavery Act is legislation that seeks to regulate and address the issues of modern-day slavery in business operations and their global supply chains. It states that companies with sales of more than £36 million or that conduct some or all of their business in the UK must publish an annual statement on their website related to their anti-slavery efforts.
Companies must confirm the steps taken to ensure that slavery and human trafficking are absent from the business and supply chain, or they must declare that no steps have been taken. These rules apply to public and private companies and partnerships, wherever they are incorporated or formed and in whatever sector they operate.
Act Requirements:
- Identify and analyze the risks of human trafficking and slavery in the supply chain.
- Create and maintain internal accountability standards and procedures for employees and contractors and taking action on those who fail to meet company standards regarding slavery and trafficking.
- Conduct audits of suppliers to evaluate supplier compliance with company standards for human trafficking and slavery in supply chains.
- Require direct suppliers to certify that materials incorporated into the product comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business.
- Provide company employees and managers, with direct responsibility for supply chain management, training on human trafficking and slavery, particularly with respect to mitigating risks within the supply chains of products.
The Home Office’s statutory guidance recommends that we cover the following 6 areas in our statement:
- Organization structure and supply chains
- Policies in relation to slavery and human trafficking
- Due diligence processes
- Risk assessment and management
- Key performance indicators to measure effectiveness of steps being taken
- Training on modern slavery and trafficking
Novavax Modern Slavery Statement 2023
In compliance with the UK Modern Slavery Act of 2015, the following describes the ongoing steps Novavax is taking to address and prevent modern slavery within our business and supply chains.
About Novavax
Novavax, a global company with headquarters in Gaithersburg, Md., U.S., is committed to protecting health of people worldwide by discovering, developing and commercializing innovative vaccines for serious infectious diseases.
Novavax has defined core values that guide our approach to doing business with the highest standards, as well as our culture of diversity, equity, and inclusion that taken together, enable us to create, develop, and fully leverage the strengths of our workforce to meet our growth objectives. To learn more, visit our website.
Our Supply Chain
Novavax built a global manufacturing and supply network during the 2020 pandemic to support production and supply of Nuvaxovid™, our protein-based COVID vaccine with Matrix-M™ adjuvant.
This manufacturing network includes our wholly owned sites in Uppsala, Sweden and Bohumil, Czech Republic, as well as manufacturing partners and suppliers in multiple countries, including India, Japan and South Korea. The resulting capacity will also support production for our pipeline, including candidates for our COVID-Influenza Combination and influenza stand-alone vaccines.
The NovaCode: Our Code of Business Conduct
Our NovaCode (the Code) sets the highest standards for our ethical business conduct at Novavax and provides guidance to help our employees make the right decisions. It outlines expectations for our employees when dealing with strategic partners, healthcare professionals, and the communities we serve. Except as otherwise required by applicable laws, this Code applies to Novavax, Inc. and all of its subsidiaries and other business entities worldwide.
While the Code applies to all employees, officers and directors, certain business partners such as joint ventures, agents, consultants, distributors, suppliers, vendors, independent contractors and temporary employees are also expected to live up to the principles of the Code. Managers who supervise our external business partners are responsible for ensuring that they understand and adhere to our standards.
The Code is available on our corporate website, Novavax.com, and our internal intranet.
Our Human Rights Policies
Novavax supports and will champion fundamental human rights. We will not work with business partners who employ children or forced labor. We will not tolerate violence or abuse. In every country where we operate, Novavax follows all laws, regulations, and international conventions related to human rights. Our medical and research activities follow the principles outlined in the Declaration of Helsinki.
Ethical Business Partners and expected Supplier Conduct
Novavax only works with partners, including our suppliers, contract manufacturers, suppliers and distributors who conduct their business with integrity. Every vendor we hire must uphold our principles and may not engage in unethical or illegal business practices. Before entering into a business relationship, we work to ensure that the appropriate due diligence screening has occurred, and that the vendor meets our standards of excellence. We have created mechanisms for employees to communicate any issues that are identified to appropriate Novavax personnel, including Legal, Corporate Compliance and Finance.
Novavax conducts periodic and regular reviews of Suppliers to evaluate their compliance with our policies and applicable legal and regulatory requirements. We are currently further evolving our review guidelines to expressly address human trafficking, slavery and illegal child labor issues in this process.
Accountability Activities
All employees are required to sign an acknowledgement annually that they have read and will adhere to the Code. In addition, Novavax invests in training for its employees and management, including those who have direct responsibility for supply chain management, particularly with respect to mitigation risks of human trafficking, slavery and illegal child labor within the supply chain.
To date, Novavax has not received any reports from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified, either at Novavax or in its supply chain.
Our Commitment to the Future
Novavax understands that tackling modern slavery requires a year-over-year commitment and will continue rigorous due diligence of our supply chain as well as review and improve procedures to help identify and prevent the risks of modern slavery or human trafficking. During the next year, Novavax is committed to:
Novavax is also in the process of establishing additional internal standards, procedures and systems, including diligence around identification and elimination of human trafficking, slavery and illegal child labor in its supply chain as well as accountability measures for its employees and contractors who fail to meet these standards. The new systems are being put in place in Q3 2023.
Finally, Novavax is committed to creating a workplace conducive to the open discussion of its business practices. We encourage our employees to share their concerns with their manager or another member of our Leadership, Corporate Compliance, Human Resources, Legal or Finance teams.
We encourage all of our stakeholders, including suppliers, distributors, consultants, service providers and other partners to contact us at [email protected] for general compliance questions, for questions relating to raising a concern or our Human Resources team for any concerns related to policies, procedures or regulations or matters regarding personal conduct.
In addition, the Company has established a “Whistleblower” procedure by which confidential complaints may be raised anonymously to Novavax.ethicspoint.com. This confidential and anonymous process may be utilized to raise new concerns or complaints or to revisit a previously raised concern or complaint that an individual believes has not been appropriately handled.
Helpline
Our helpline is available to anyone 24 hours a day and language translation is available. All calls and reports submitted are handled promptly and discreetly, and Novavax will review and investigate each matter promptly and accordingly. Confidentiality will be maintained to the fullest extent possible and Novavax strictly prohibits any form of retaliation.
- US: 844-612-0252
- SWEDEN: 020-12 72-95
- CZECH REPUBLIC: 800-144-499
- CANADA: 844-612-0252
- BELGIUM: 0800-71-203
- SINGAPORE: 800-492-2617
- SWITZERLAND: 0800–103-453
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