Modern Slavery Act Statement
This statement is made pursuant to section 54(1) of the modern slavery act 2015.
Novus Clinical Limited (referred to in this statement as “Novus Clinical” or “the Company”) recognises our responsibility to identify, address and mitigate the risk of modern slavery and human trafficking in our operations and supply chains, and we are committed to doing so by operating to the highest ethical standards.
Novus Clinical has a zero-tolerance approach to slavery and human trafficking and is committed to acting ethically and with integrity in all its business dealings and relationships. Novus Clinical is committed to effecting, enforcing, and continuously improving its measures to detect and eradicate such abhorrent practices, should they touch upon the company in any way, particularly in its supply chains.
The Company is therefore committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all our contractors, suppliers, and other business partners and as part of our contracting processes we oblige such third parties to maintain the same standards.
To ensure that this commitment is fully realised, the Company has considered in depth the risks associated with its activities and identified and effected measures to mitigate such risks. Further details on this process and the measures identified and effected are set out in our Anti-Slavery and Human Trafficking Policy.
While the risk of modern slavery and human trafficking is relatively lower in the highly regulated pharmaceutical and pharmaceutical services industry, we recognise that this responsibility also extends to our business relationships. We have established and maintain systems and controls to safeguard against slavery and related human trafficking in our supply chain.
Our Business and Services
Novus Clinical is a privately owned business, headquartered in Leeds, UK. The Company is engaged in the provision of clinical trial drug supply services to the global pharmaceutical and biotech sector. Through a network of approved manufacturers and authorised distributors, the company provides access to the medicines pharmaceutical and biotech companies need to run their clinical trials. More information can be found on the ‘Our Services’ section of our website.
Due Diligence for Slavery and Human Trafficking
In order to identify and mitigate the risks of slavery and human trafficking occurring anywhere within the Company or its supply chains, Novus Clinical adopts the following due diligence processes:
- Regular reviewing of this Slavery and Human Trafficking Policy, taking into consideration whether any improvements to the Policy should be made.
- Identifying and assessing potential risk areas, including in its supply chains.
- Putting in place measures to mitigate the risk of slavery and human trafficking occurring in the Company or its supply chains.
- Monitoring the effectiveness of its measures, and potential risk areas (particularly in supply chains).
- Encouraging Personnel to report any issues and protecting whistleblowers.
Risk Assessments and Management
The Company has taken a systematic approach to this risk assessment, considering two primary types of risk factor as follows: general risk factors; and specific risk factors associated with its own business.
General risk factors
General risk factors for slavery/human trafficking include the following (as described in the Walk Free Slavery Index*), some of which risk factors clearly overlap:
- Living within a highly oppressive regime.
- Living within a conflict zone (where laws/protections tend to break down).
- Living in extreme poverty.
- Living within a country which has no protections/laws in place to prohibit slavery (although many countries do have such laws in place, many do not. Indeed, a number of G20 countries still have no such laws in place. It should also be noted that even in countries which do have such laws, including G20 countries such as the UK, the US, Australia, France, Germany and the Netherlands, it has become apparent in recent years that slavery is more prevalent than previously thought).
- The risk for women and girls is much higher than for men and boys.
- There is a much higher risk for boys and adolescents than for men.
- The risk for children generally is especially high.
- There is a much higher risk for migrants/displaced persons.
- Certain countries have a higher risk than others. For example, the 2018 Slavery Index states that the following 10 countries have the highest risk of slavery: North Korea, Eritrea, Burundi, Central African Republic, Afghanistan, Mauritania, South Sudan, Pakistan, Cambodia, and Iran.
- Low-skilled work is of a higher risk than highly skilled, technical work.
- Seasonal/temporary work is of a higher risk than long-term/permanent work.
- Hazardous/undesirable work is of a higher risk than other work.
- Lengthy, non-transparent supply chains can be a risk factor.
*Minderoo Foundation’s Walk Free initiative is an independent, privately funded international philanthropic human rights organisation based in Perth, Western Australia. Walk Free works towards ending modern slavery in all its forms by taking a strong, multifaceted, and global approach. It produces the Slavery Index on a periodic basis (https://www.walkfree.org/global-slavery-index/).
Specific risk factors
Although the Company’s risk in relation to most of the general risk factors set out above has been assessed by it as low, the Company has identified two risk factors pertaining to its specific activities which may increase the risk level of some of the general risk factors:
- The Company operates globally, including in countries where the risk of slavery may be higher.
- The Company transports medicines internationally, via sometimes (but by no means always), lengthy supply chains. These supply chains include third parties offering the following types of services/supplies of goods:
- Pharmaceutical product manufacturers (globally), for supply of medicinal product.
- Pharmaceutical product wholesalers/distributers (globally), for supply of medicinal product.
- Logistics providers (globally), transporting medicines.
- Warehouse facilities (globally), storing and distributing medicines when required.
- Suppliers of specialised packaging (globally) for transport of pharmaceutical products.
The Company has assessed and implemented measures to combat these two specific risk factors, viewed in the light of the general risk factors, as set out in the following sections of this Statement.
Global Operation Risks
Novus Clinical operates globally. The Company may also employ staff or engage consultants in various countries. The following safeguards are in place in respect of employment of staff or engagement of consultants, wherever they may be across the globe:
Employment/Engagement
- The Company’s central HR Department (based in the UK) always adheres to its rigorous recruitment and engagement processes, wherever hires may be located, to ensure fairness and transparency in the recruitment process.
- The HR Department ensures that the applicable laws and relevant Company Policies are always adhered to, no matter where a candidate lives or works.
- Where recruitment agencies are used, their processes are checked before use.
- The HR Department takes legal/employment advice and services from country-specific sources where appropriate.
- Personnel’s passports or other appropriate forms of personal identity are checked.
- Those not eligible to work in the applicable country are not employed/engaged.
- Personnel’s right to work eligibility is checked in all countries, including the UK.
- Children are not employed. We may occasionally employ young adults (i.e., over the age of 16) but only in appropriate roles, with appropriate supervision and pay. We may also occasionally accept young people on short, supervised work experience placements.
- Employment contracts and benefits, to the extent reasonably possible, are kept uniform, regardless of country of employment/engagement.
- It is very rarely necessary (if at all) to employ or engage Personnel living in conflict zones, repressive regimes, or any of the listed high-risk countries.
With these measures in place, and the fact that the roles offered by Novus Clinical tend to be highly skilled/technical, the chances of Personnel being subjected to slavery or trafficking is considered low.
Customers / Third Parties
Customers and other third parties with whom the Company interacts can be situated all over the world (albeit they are unlikely to be in repressive regimes, conflict zones, or one of the listed high-risk countries). The Company’s customers tend to be large or medium-sized, well-funded and sophisticated, pharmaceutical companies working in high-tech, highly regulated environments, employing highly- skilled staff. Accordingly, the risk of encountering slavery within such third parties’ organisations has been assessed by the Company as low.
Our Supply Chains
Novus Clinical’s operations touch on many countries. The type of business the Company operates and the global nature of its business make it inevitable that the Company will engage with suppliers and supply chains right across the world. The UK’s Modern Slavery Act 2015 is particularly focused on supply chains, and UK businesses putting in place effective measures to ensure that they do not unwittingly tolerate slavery in their supply chains.
The Company has carefully assessed the risks relating to its supply chains. Wherever the Company
operates, it operates in a highly regulated, highly scrutinised environment. The manufacture and distribution of pharmaceutical products is extremely carefully controlled, for obvious reasons, in all countries in which the Company operates. Accordingly, the sector is tightly supervised by its many regulatory authorities. Just as in the UK, EU and US, other countries’ regulatory authorities generally require businesses operating in the pharmaceutical sphere to be licenced, demonstrating their compliance with very high ethical and quality standards. This includes not only manufacturers of pharmaceuticals, but also distributors, wholesalers and others operating in the market. By its nature, there must be transparency in the supply chain, to ensure that the quality and pedigree of the medicines sourced remains optimum.
The Company hold all necessary licences to perform their services and are subject to regular regulatory authority and customer audits/inspections. The Company has in place a robust Quality Management System and experienced, competent Quality Assurance team, ensuring the Company meets all required standards, no matter how exacting. For this reason, compliance with regulatory and legal requirements comes naturally to Novus Clinical and is of paramount importance to its people and its business.
Our Clinical Trial Drug Supply services involve the shipping of highly valuable and highly regulated medicinal products around the world. Accordingly, the Company relies on its extensive, international network of approved suppliers. This reliance could generate a high risk of modern slavery or human trafficking somewhere along our supply chains. However, in our sector, this risk is significantly decreased due to the stringent requirements and high levels of scrutiny/transparency governing every aspect of, and link in, the supply chain. Even so, Novus Clinical is not complacent and remains vigilant in attempting to identify and eradicate any such problems from our supply chain. How we achieve this is set out in the section below.
Supplier Adherence to Novus Clinical’s Values and Ethics
To ensure that all those in our supply chain comply with our values and ethics we have in place a rigorous supply chain assessment and compliance program. This is led by staff from the following departments: Managing Director; Legal; Quality Assurance; and HR. This supplier assessment and compliance program includes:
- Robust assessment of applicable new suppliers, prior to doing business with them, including requirement to complete approval forms and quality/compliance questionnaire. New suppliers are required to agree to comply with Novus Clinical’s anti-slavery and human trafficking principles.
- Remote or (where applicable) in-person auditing of vendors/suppliers.
- Checking of suppliers’ credentials, such as licences held.
- Contractual obligation to comply with all applicable law, including law relating to anti-slavery and human trafficking (with right to terminate if such obligation is breached).
- Contractual right to audit applicable suppliers periodically for the duration of the relationship.
- Contractual obligation to ensure suppliers hold their own sub-contractors to the same standards as those of Novus Clinical.
- Where applicable, effecting quality/technical agreements setting out clear responsibilities and standards.
Training
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to all our personnel. We train our Personnel on our processes and policies, but also on the ‘red flags’ which may indicate slavery is present in particular circumstances. These ‘red flags’ include instances where workers or groups of workers:
- Appear to be under the control of someone else and reluctant to interact with others.
- Do not have personal identification or are unable to produce any.
- Have few personal belongings, wear the same clothes every day or wear unsuitable clothes for work.
- Are not able to move around freely.
- Are reluctant to talk to strangers or the authorities.
- Appear frightened, withdrawn, or show signs of physical or psychological abuse.
- Are dropped off and collected for work, always in the same way, especially at unusual times, i.e., very early or late at night.
Our policies on slavery and human trafficking
In keeping with our values, many of our policies assist with the ongoing prevention of modern slavery or trafficking in our business. The Company has in place a robust Anti-Slavery and Human Trafficking Policy (NOV-CORP-POL-005) which sits on the company’s Quality Management System. This policy:
- Reflects the Company’s commitment to anti-slavery and human trafficking, and to ensuring that there is no slavery or human trafficking in any part of the Company’s business or in its supply chains;
- Reflects the Company’s commitment to acting ethically and with integrity in all of its business relations;
- Sets out the risk identification steps and mitigating measures that are taken by the Company to mitigate those risks; and
- ensures Company personnel understand their role in combatting slavery and human trafficking, encouraging escalation of any activities that they suspect could be slavery or human trafficking, and if needed personnel understanding their ability to ‘whistle blow’ on such matters.
Several other Company policies are in place which support ethical trading, and support the Company in its commitment to anti-slavery and human trafficking, including:
- Privacy Notice (NOV-CORP-POL-003)
- Anti-Fraud, Bribery and Fraud Risk Management Policy (NOV-CORP-POL-004)
- Anti-Money Laundering Policy (NOV-CORP-POL-006)
- Anti-Trust and Competition Policy (NOV-CORP-POL-007)
- Environmental and Sustainability Policy (NOV-CORP-POL-008)
- Diversity, Equity, and Inclusion Policy (NOV-CORP-POL-009)
- Health and Safety Policy (NOV-CORP-POL-011)
- Whistleblowing Policy (NOV-CORP-POL-012)
Measuring our effectiveness in combating slavery and human trafficking
Novus Clinical will review the effectiveness of its modern slavery processes and controls through its established risk management program and will action any issues identified. This will include assessing those systems and controls in place to detect and mitigate modern slavery risk within the supply chain.
Novus Clinical recognise that as a complex issue, modern slavery requires more effort to uncover, particularly in lower tiers of supply. As such, the company will continue to develop its onboarding and due diligence activities of suppliers and will consider the need for additional ways to assess the effectiveness of its actions.
Modern slavery statement
The Board of Novus Clinical Limited continues to work with management to ensure the company is effective in combatting modern slavery. This commitment forms part of the Company’s wider sustainability strategy.
The Board can confirm that in the last 12 months:
- No slavery or human trafficking issues have been identified;
- No reports were made under the Modern Slavery Act Policy or under the Freedom to Speak Up Policy with respect to modern slavery and human trafficking; and,
- No remedial actions have been required.
This statement is made pursuant to section 54 of the Modern Slavery Act 2015 and constitutes the Company’s slavery and human trafficking statement for the financial year ending 31 August 2024. It is approved by the directors of the Novus Clinical Limited Board and signed by its Managing Director below.
Signed and Approved on behalf of Novus Clinical Limited:
Jonathan Waring-Hughes
Managing Director
This statement is made pursuant to section 54(1) of the modern slavery act 2015.
Novus Clinical Limited (referred to in this statement as “Novus Clinical” or “the Company”) recognises our responsibility to identify, address and mitigate the risk of modern slavery and human trafficking in our operations and supply chains, and we are committed to doing so by operating to the highest ethical standards.
Novus Clinical has a zero-tolerance approach to slavery and human trafficking and is committed to acting ethically and with integrity in all its business dealings and relationships. Novus Clinical is committed to effecting, enforcing, and continuously improving its measures to detect and eradicate such abhorrent practices, should they touch upon the company in any way, particularly in its supply chains.
The Company is therefore committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all our contractors, suppliers, and other business partners and as part of our contracting processes we oblige such third parties to maintain the same standards.
To ensure that this commitment is fully realised, the Company has considered in depth the risks associated with its activities and identified and effected measures to mitigate such risks. Further details on this process and the measures identified and effected are set out in our Anti-Slavery and Human Trafficking Policy.
While the risk of modern slavery and human trafficking is relatively lower in the highly regulated pharmaceutical and pharmaceutical services industry, we recognise that this responsibility also extends to our business relationships. We have established and maintain systems and controls to safeguard against slavery and related human trafficking in our supply chain.
Our Business and Services
Novus Clinical is a privately owned business, headquartered in Leeds, UK. The Company is engaged in the provision of clinical trial drug supply services to the global pharmaceutical and biotech sector. Through a network of approved manufacturers and authorised distributors, the company provides access to the medicines pharmaceutical and biotech companies need to run their clinical trials. More information can be found on the ‘Our Services’ section of our website.
Due Diligence for Slavery and Human Trafficking
In order to identify and mitigate the risks of slavery and human trafficking occurring anywhere within the Company or its supply chains, Novus Clinical adopts the following due diligence processes:
- Regular reviewing of this Slavery and Human Trafficking Policy, taking into consideration whether any improvements to the Policy should be made.
- Identifying and assessing potential risk areas, including in its supply chains.
- Putting in place measures to mitigate the risk of slavery and human trafficking occurring in the Company or its supply chains.
- Monitoring the effectiveness of its measures, and potential risk areas (particularly in supply chains).
- Encouraging Personnel to report any issues and protecting whistleblowers.
Risk Assessments and Management
The Company has taken a systematic approach to this risk assessment, considering two primary types of risk factor as follows: general risk factors; and specific risk factors associated with its own business.
General risk factors
General risk factors for slavery/human trafficking include the following (as described in the Walk Free Slavery Index*), some of which risk factors clearly overlap:
- Living within a highly oppressive regime.
- Living within a conflict zone (where laws/protections tend to break down).
- Living in extreme poverty.
- Living within a country which has no protections/laws in place to prohibit slavery (although many countries do have such laws in place, many do not. Indeed, a number of G20 countries still have no such laws in place. It should also be noted that even in countries which do have such laws, including G20 countries such as the UK, the US, Australia, France, Germany and the Netherlands, it has become apparent in recent years that slavery is more prevalent than previously thought).
- The risk for women and girls is much higher than for men and boys.
- There is a much higher risk for boys and adolescents than for men.
- The risk for children generally is especially high.
- There is a much higher risk for migrants/displaced persons.
- Certain countries have a higher risk than others. For example, the 2018 Slavery Index states that the following 10 countries have the highest risk of slavery: North Korea, Eritrea, Burundi, Central African Republic, Afghanistan, Mauritania, South Sudan, Pakistan, Cambodia, and Iran.
- Low-skilled work is of a higher risk than highly skilled, technical work.
- Seasonal/temporary work is of a higher risk than long-term/permanent work.
- Hazardous/undesirable work is of a higher risk than other work.
- Lengthy, non-transparent supply chains can be a risk factor.
*Minderoo Foundation’s Walk Free initiative is an independent, privately funded international philanthropic human rights organisation based in Perth, Western Australia. Walk Free works towards ending modern slavery in all its forms by taking a strong, multifaceted, and global approach. It produces the Slavery Index on a periodic basis (https://www.walkfree.org/global-slavery-index/).
Specific risk factors
Although the Company’s risk in relation to most of the general risk factors set out above has been assessed by it as low, the Company has identified two risk factors pertaining to its specific activities which may increase the risk level of some of the general risk factors:
- The Company operates globally, including in countries where the risk of slavery may be higher.
- The Company transports medicines internationally, via sometimes (but by no means always), lengthy supply chains. These supply chains include third parties offering the following types of services/supplies of goods:
- Pharmaceutical product manufacturers (globally), for supply of medicinal product.
- Pharmaceutical product wholesalers/distributers (globally), for supply of medicinal product.
- Logistics providers (globally), transporting medicines.
- Warehouse facilities (globally), storing and distributing medicines when required.
- Suppliers of specialised packaging (globally) for transport of pharmaceutical products.
The Company has assessed and implemented measures to combat these two specific risk factors, viewed in the light of the general risk factors, as set out in the following sections of this Statement.
Global Operation Risks
Novus Clinical operates globally. The Company may also employ staff or engage consultants in various countries. The following safeguards are in place in respect of employment of staff or engagement of consultants, wherever they may be across the globe:
Employment/Engagement
- The Company’s central HR Department (based in the UK) always adheres to its rigorous recruitment and engagement processes, wherever hires may be located, to ensure fairness and transparency in the recruitment process.
- The HR Department ensures that the applicable laws and relevant Company Policies are always adhered to, no matter where a candidate lives or works.
- Where recruitment agencies are used, their processes are checked before use.
- The HR Department takes legal/employment advice and services from country-specific sources where appropriate.
- Personnel’s passports or other appropriate forms of personal identity are checked.
- Those not eligible to work in the applicable country are not employed/engaged.
- Personnel’s right to work eligibility is checked in all countries, including the UK.
- Children are not employed. We may occasionally employ young adults (i.e., over the age of 16) but only in appropriate roles, with appropriate supervision and pay. We may also occasionally accept young people on short, supervised work experience placements.
- Employment contracts and benefits, to the extent reasonably possible, are kept uniform, regardless of country of employment/engagement.
- It is very rarely necessary (if at all) to employ or engage Personnel living in conflict zones, repressive regimes, or any of the listed high-risk countries.
With these measures in place, and the fact that the roles offered by Novus Clinical tend to be highly skilled/technical, the chances of Personnel being subjected to slavery or trafficking is considered low.
Customers / Third Parties
Customers and other third parties with whom the Company interacts can be situated all over the world (albeit they are unlikely to be in repressive regimes, conflict zones, or one of the listed high-risk countries). The Company’s customers tend to be large or medium-sized, well-funded and sophisticated, pharmaceutical companies working in high-tech, highly regulated environments, employing highly- skilled staff. Accordingly, the risk of encountering slavery within such third parties’ organisations has been assessed by the Company as low.
Our Supply Chains
Novus Clinical’s operations touch on many countries. The type of business the Company operates and the global nature of its business make it inevitable that the Company will engage with suppliers and supply chains right across the world. The UK’s Modern Slavery Act 2015 is particularly focused on supply chains, and UK businesses putting in place effective measures to ensure that they do not unwittingly tolerate slavery in their supply chains.
The Company has carefully assessed the risks relating to its supply chains. Wherever the Company
operates, it operates in a highly regulated, highly scrutinised environment. The manufacture and distribution of pharmaceutical products is extremely carefully controlled, for obvious reasons, in all countries in which the Company operates. Accordingly, the sector is tightly supervised by its many regulatory authorities. Just as in the UK, EU and US, other countries’ regulatory authorities generally require businesses operating in the pharmaceutical sphere to be licenced, demonstrating their compliance with very high ethical and quality standards. This includes not only manufacturers of pharmaceuticals, but also distributors, wholesalers and others operating in the market. By its nature, there must be transparency in the supply chain, to ensure that the quality and pedigree of the medicines sourced remains optimum.
The Company hold all necessary licences to perform their services and are subject to regular regulatory authority and customer audits/inspections. The Company has in place a robust Quality Management System and experienced, competent Quality Assurance team, ensuring the Company meets all required standards, no matter how exacting. For this reason, compliance with regulatory and legal requirements comes naturally to Novus Clinical and is of paramount importance to its people and its business.
Our Clinical Trial Drug Supply services involve the shipping of highly valuable and highly regulated medicinal products around the world. Accordingly, the Company relies on its extensive, international network of approved suppliers. This reliance could generate a high risk of modern slavery or human trafficking somewhere along our supply chains. However, in our sector, this risk is significantly decreased due to the stringent requirements and high levels of scrutiny/transparency governing every aspect of, and link in, the supply chain. Even so, Novus Clinical is not complacent and remains vigilant in attempting to identify and eradicate any such problems from our supply chain. How we achieve this is set out in the section below.
Supplier Adherence to Novus Clinical’s Values and Ethics
To ensure that all those in our supply chain comply with our values and ethics we have in place a rigorous supply chain assessment and compliance program. This is led by staff from the following departments: Managing Director; Legal; Quality Assurance; and HR. This supplier assessment and compliance program includes:
- Robust assessment of applicable new suppliers, prior to doing business with them, including requirement to complete approval forms and quality/compliance questionnaire. New suppliers are required to agree to comply with Novus Clinical’s anti-slavery and human trafficking principles.
- Remote or (where applicable) in-person auditing of vendors/suppliers.
- Checking of suppliers’ credentials, such as licences held.
- Contractual obligation to comply with all applicable law, including law relating to anti-slavery and human trafficking (with right to terminate if such obligation is breached).
- Contractual right to audit applicable suppliers periodically for the duration of the relationship.
- Contractual obligation to ensure suppliers hold their own sub-contractors to the same standards as those of Novus Clinical.
- Where applicable, effecting quality/technical agreements setting out clear responsibilities and standards.
Training
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to all our personnel. We train our Personnel on our processes and policies, but also on the ‘red flags’ which may indicate slavery is present in particular circumstances. These ‘red flags’ include instances where workers or groups of workers:
- Appear to be under the control of someone else and reluctant to interact with others.
- Do not have personal identification or are unable to produce any.
- Have few personal belongings, wear the same clothes every day or wear unsuitable clothes for work.
- Are not able to move around freely.
- Are reluctant to talk to strangers or the authorities.
- Appear frightened, withdrawn, or show signs of physical or psychological abuse.
- Are dropped off and collected for work, always in the same way, especially at unusual times, i.e., very early or late at night.
Our policies on slavery and human trafficking
In keeping with our values, many of our policies assist with the ongoing prevention of modern slavery or trafficking in our business. The Company has in place a robust Anti-Slavery and Human Trafficking Policy (NOV-CORP-POL-005) which sits on the company’s Quality Management System. This policy:
- Reflects the Company’s commitment to anti-slavery and human trafficking, and to ensuring that there is no slavery or human trafficking in any part of the Company’s business or in its supply chains;
- Reflects the Company’s commitment to acting ethically and with integrity in all of its business relations;
- Sets out the risk identification steps and mitigating measures that are taken by the Company to mitigate those risks; and
- ensures Company personnel understand their role in combatting slavery and human trafficking, encouraging escalation of any activities that they suspect could be slavery or human trafficking, and if needed personnel understanding their ability to ‘whistle blow’ on such matters.
Several other Company policies are in place which support ethical trading, and support the Company in its commitment to anti-slavery and human trafficking, including:
- Privacy Notice (NOV-CORP-POL-003)
- Anti-Fraud, Bribery and Fraud Risk Management Policy (NOV-CORP-POL-004)
- Anti-Money Laundering Policy (NOV-CORP-POL-006)
- Anti-Trust and Competition Policy (NOV-CORP-POL-007)
- Environmental and Sustainability Policy (NOV-CORP-POL-008)
- Diversity, Equity, and Inclusion Policy (NOV-CORP-POL-009)
- Health and Safety Policy (NOV-CORP-POL-011)
- Whistleblowing Policy (NOV-CORP-POL-012)
Measuring our effectiveness in combating slavery and human trafficking
Novus Clinical will review the effectiveness of its modern slavery processes and controls through its established risk management program and will action any issues identified. This will include assessing those systems and controls in place to detect and mitigate modern slavery risk within the supply chain.
Novus Clinical recognise that as a complex issue, modern slavery requires more effort to uncover, particularly in lower tiers of supply. As such, the company will continue to develop its onboarding and due diligence activities of suppliers and will consider the need for additional ways to assess the effectiveness of its actions.
Modern slavery statement
The Board of Novus Clinical Limited continues to work with management to ensure the company is effective in combatting modern slavery. This commitment forms part of the Company’s wider sustainability strategy.
The Board can confirm that in the last 12 months:
- No slavery or human trafficking issues have been identified;
- No reports were made under the Modern Slavery Act Policy or under the Freedom to Speak Up Policy with respect to modern slavery and human trafficking; and,
- No remedial actions have been required.
This statement is made pursuant to section 54 of the Modern Slavery Act 2015 and constitutes the Company’s slavery and human trafficking statement for the financial year ending 31 August 2024. It is approved by the directors of the Novus Clinical Limited Board and signed by its Managing Director below.
Signed and Approved on behalf of Novus Clinical Limited:
Jonathan Waring-Hughes
Managing Director
