Modern Slavery Statement 2024

Venture Life Group plc (“VLG” or the “Company”) is committed to preventing acts of modern slavery and human trafficking from occurring within its business and supply chains and imposes the same high standards on its suppliers.

We do this by:

  • Mapping human rights and modern slavery risks inside our organisation and along our supply chain.
  • Continuing to take steps to find effective methods to eliminate slavery and human trafficking practices.
  • Ensuring that we review and communicate our policies and procedures regularly.
  • Respecting human rights and ensuring, that the people who provide products and services to us are treated fairly and that their fundamental human rights are protected and respected.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 (the “Act”) and constitutes the slavery and trafficking statement for VLG plc.

Information about the organisation and its supply chains

VLG is an international consumer self-care company focused on developing, manufacturing and commercialising products for the global self-care market. With operations in the UK, Italy, The Netherlands, Sweden and Spain, the Group’s product portfolio includes key products in the areas of oral care, women’s intimate healthcare, hypoglycaemia, oncology support, ear wax removal, fungal infections and proctology, and dermo-cosmetics for addressing the signs of ageing. The Group is headquartered in the UK and its products are sold in over 90 countries worldwide.

The products, which are typically recommended by pharmacists or healthcare practitioners, are available primarily through pharmacies and grocery multiples. In the UK and The Netherlands these are primarily supplied direct by the company to retailers, elsewhere they are supplied by the Group’s international distribution partners, as well as direct to consumer selling through online channels.

The Group’s key supply chains cover the procurement of raw materials, packaging and finished components through our network of approved suppliers, including the logistics, warehousing and distribution to our partners.

To find out more about the nature of our business, please see the “about us” section of the corporate website About Us | Venture Life (venture-life.com).

Policies relating to modern slavery

At VLG we are committed to ensuring the prevention of modern slavery and human rights abuses is upheld, in particular, through the establishment of clear policies available to all our employees, regularly updated and shared on our internal systems.

In addition to a specific Anti-slavery and human trafficking Policy and a Human Rights Policy, we have in place a Child Labour Policy, a Code of Ethics, a Personnel Management Policy, a Privacy Policy and a Recruitment Policy, which define the guiding principles of our organisation and all the mechanisms to protect workers, both in terms of working practices and work-life balance (working hours, remuneration, welfare, non-interference in private life, etc.) and in terms of actions aimed at their health and safety. A specific policy on this issue is also present (Safety Policy).

Relations with our suppliers are regulated by a Supplier Code of Conduct, which we ask each of our suppliers to accept and sign when signing a contract. The Code identifies what VLG expects from and how it intends to honour its commitments to its suppliers, in terms of quality of the products and services offered and in terms of relationship, but also in terms of controlling the risks associated with modern slavery.

Non-discrimination and the absolute protection of diversity is a founding part of our values and practices, and it is reflected in our Personnel Management Policy. By choice, we do not have in place policies specifically dedicated to minorities or employees with disabilities: we want these people to feel treated exactly the same as other people working with us. We believe that policies explicitly dedicated to them can achieve the opposite result of emphasising their uniqueness.

Due diligence processes in place to manage and prevent risks of modern slavery

The due diligence process carried out during the year started with an internal observation of the organisation and the first Tier of our supply chain, to take an initial snapshot of the risk of modern slavery and human rights violations within the group.
The organization risk analysis was conducted through a series of interviews with the HR manager, the HSE manager and the Procurement manager, focusing on company’s stakeholders, policies and practices.

A mapping of the main suppliers was then carried out to investigate:

  • potential geographical risks,
  • risks linked to specific sector and/or industry,
  • possible risks related to the supply of goods considered potentially at risk of being produced by Child Labor or Forced Labor.

Ad hoc questionnaires were then submitted to suppliers to investigate their knowledge and control of the issues in question.

Here are the details of how the analysis was carried out:

  • Step 1. Corporate stakeholders, both internal and external, were mapped to observe the possible presence of groups most at risk of human rights violations and modern slavery (vulnerable groups), such as women, children, migrants, people with disabilities, minorities, unskilled and hazardous workers.
  • Step 2. The policies produced by the organisation, both for internal collaborators and for relations with suppliers, were analysed together with their contents, to investigate the level of control over these issues.
  • Step 3. Both internal and external business practices were investigated, in order to observe potential practices at risk of modern slavery (e.g. unclear requests to suppliers at too tight deadlines, too strict policies towards employees, etc.).
  • Step 4. Relevant KPIs were collected (e.g. number of human rights and modern slavery incidents occurred or discovered in the last 12 months). It should be emphasised that there have been no known incidents of human rights violations or modern slavery in the last 5 years, neither within VLG nor in the first Tear of our supply chain.

  • Step 5. The main suppliers of products and services were mapped, collecting information on the type of product or service offered, their geographical origin and industry. This was done to verify the existence of different levels of risk of modern slavery
    depending on the context in which a company operates, which is also linked to the level of workers’ protection ensured in certain countries.
  • Step 6. Multiple-choice questionnaires were administered to the mapped suppliers. Questionnaires were specifically designed to investigate their level of control of modern slavery issues and the level of protection of human rights.
  • Step 7. All the information gathered was aggregated to identify the main hot spots to be monitored to reduce the risk of violations. This analysis will be taken into consideration during the following year, to implement further monitoring actions to prevent modern slavery and human rights accidents and to implement a medium-to-long term plan of actions.

The parts of its business and supply chains where risks of modern slavery are highest

The due diligence analysis conducted revealed that there are no particular risks of modern slavery or human rights violations within the organisation, however:

  • Particular types of workers were identified who, if not carefully trained, could face increased risks. There are workers in the Company and along the supply chain who work with chemicals that could be hazardous to their health in the long term if not properly managed. However, the risk has been identified as low.
  • The greatest risks were identified along the supply chain, at deeper levels (Tier 2 and above). This is particularly due to Chinese sub-suppliers, although they account for a small part of the purchase volume. China has been identified by the Global Slavery Index2 as a country potentially at risk of human rights violations and with labour practices often associated with modern slavery, also due to the absence of specific protections provided by national regulations. Moreover, for the types of products we handle (food supplements, health and personal care products) our retailers often need to turn to manufacturers in the agricultural and chemical-pharmaceutical sector, sectors identified as potentially risky in terms of modern slavery. It is therefore our intention to set up a Tier 2 analysis plan for next year.

Training and capacity building of staff around modern slavery

We are aware of the importance of continuous training to ensure prevention of modern slavery risks within the organisation. Our intention is to develop a structured training path to be made available to our employees during the following years. The training will be conducted by third-party experts, starting with topics of a more general nature (protection of human rights in the company, prevention of risks related to modern slavery, etc.) and then going on to vertical insights into diversity and inclusion, violence and harassment, debt bondage and more.

In any case, the due diligence process itself conducted this year with external experts, represented a moment of training for some specific figures of the company: the Group HSE Manager followed the entire process in all its phases, in an “on-the-job” training operation allowing him to learn about the main possible modern slavery and human rights violations risks within the organisation and along the supply chain. In addition, the HR Manager and the Procurement Manager followed some key steps of the analysis, which enabled them to become more aware of the potential risks to be guarded against.

Sources for the analysis

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Group’s slavery and human trafficking statement for the current year. It was approved by the board on 25/10/2024

For and on behalf of Venture Life Group PLC

Paul McGreevy
Executive Chairman, Venture Life Group PLC
Date: 25/10/2024

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