UK Modern Slavery Act Statement

Caligor Coghlan Pharma Services (the “Company”) is pleased to issue this modern slavery and human trafficking statement in compliance with Section 54 of the United Kingdom’s Modern Slavery Act 2015 and to reflect the Company’s support of human rights worldwide. The statement is issued for the Company fiscal year that ended December 31, 2018. Although subject to review annually, the statement will also apply to subsequent fiscal years unless and until withdrawn, superseded, or modified by the company.

Company

Caligor Coghlan Pharma Services is a company organized under the laws of Texas, USA and laws of the United Kingdom. The Company is engaged in the practice of providing packaging and labelling of pharmaceuticals, consulting, and comparator product sourcing for clinical trials. Its partners and employees include less than 100 staff globally. The Company offers premier pharmaceutical support services, compliance, regulatory, and labelling and packaging services globally. Our clients include clinical trial sponsors, CROs, pharmaceutical and medical device companies and any individual or company engaged in biotechnology throughout the world.

Supply Chain

The Company’s supply chain consists primarily of suppliers of clinical trial products, comparator drugs (manufacturers), providers of packaging and labelling materials, and office services and office goods. The Company’s professional services suppliers include, for example, accountants, information technology professionals, marketing professionals, travel agents, lawyers, and consultants in various fields. The Company’s office services suppliers include, for example, office and document managers, delivery services, and catering, maintenance, repair, and cleaning services. The Company’s suppliers of labelling and packaging materials include those which provide the base materials such as labelling stock.

Comparator product suppliers are normally drug manufactures or licensed wholesalers.

Modern Slavery and Human Trafficking Risks

The company believes that the risks of modern slavery and human trafficking practices within its business are very low. The Company’s business is a sophisticated pharmaceutical support service that does not involve and is not built upon the type of low skilled labour often associated with such practices. Rather, the Company’s product is skilled advice, packaged product, advocacy, consulting, and services generated by highly trained professionals.

The Company also believes that the risks of modern slavery and human trafficking violations within its supply chain are very low. The Company’s professional service suppliers provide sophisticated and often bespoke professional advice and services.  These services also do not use or depend on low skilled labour. The Company’s services suppliers are engaged in a range of activities, from higher skilled to lower skilled, but almost all are engaged in services conducted in close cooperation with Company personnel. Consequently, these services are conducted in a professional environment where exploitive practices would be difficult if not impossible to hide. The Company’s suppliers of goods are reputable retailers and wholesalers. The Company does not contract with source suppliers in industries or regions of the world where the risks of modern slavery and human trafficking are relatively high.

Policy, Detection, and Deterrence

Despite the very low risks of modern slavery and human trafficking practices within its business and supply chain, the Company has adopted a supplier policy that, among other things, is designed to raise awareness about the evils of such practices and to help detect and deter them. In this regard, the policy provides that the Company will not knowingly do business with a prospective or current supplier that engages in modern slavery or human trafficking practices. The policy also reminds personnel to remain vigilant about such practices and to report promptly to Company management any prospective or current supplier known to engage in or suspected of such practices. The policy is included in the Company Handbook accessible to all Company personnel. In addition, the policy has been incorporated into the policy and compliance training conducted for all new personnel.

The Company has also instructed its primary buyers of goods and services to promote compliance with the Company’s supplier policy, including its prohibition on modern slavery and human trafficking practices, in their dealings with prospective and current suppliers. The buyers have been instructed to take various actions as appropriate toward this end. These may include, for example, due diligence on prospective and current suppliers with regard to modern slavery and human trafficking issues and the termination of negotiations or contracts if concerns are identified. They may also include, as a further example, the insertion of legal compliance clauses in supplier contracts and the ongoing monitoring of performance under such clauses.

Approval

On behalf of the Company, the undersigned executive has approved and issued the foregoing statement as of the 10th day of April 2019 and has instructed that it be posted on the Company’s website.

Geoff M. Fatzinger
Global Vice President, Regulatory Affairs

Caligor Coghlan Pharma Services
US: 1500-B Business Park Drive l Austin, TX, 78602
UK: Unit 8 Masthead, Capstan Court l Crossways Business Park, Dartford, DA2 6QG