AMERISOURCEBERGEN’S UK MODERN SLAVERY ACT DISCLOSURE STATEMENT
AmerisourceBergen, on behalf of its subsidiaries in the Alliance Healthcare business, World
Courier Group, Inc. and MWI Veterinary Supply Co. and their respective subsidiaries listed
below (collectively, “AmerisourceBergen”), which supply goods and services in the UK, is
committed to prohibiting modern slavery and human trafficking in its business and supply chain.
This disclosure statement under Section 54 of the UK Modern Slavery Act 2015 (the “Act”)
describes the steps that AmerisourceBergen is taking in support of that commitment.
Code of Ethics and Business Conduct
AmerisourceBergen’s Code of Ethics and Business Conduct provides the foundation for our
business culture and underscores our commitment to conducting our business with integrity,
accountability and respect for applicable laws. Our Code provides guidance for our employees,
suppliers and other business partners on the ethical principles that apply to all of our business
activities and relationships. The Code reflects our zero-tolerance policy on ethical violations, and
compliance with the Code and all applicable laws and regulations is a condition of employment
at AmerisourceBergen.
Our Code reflects AmerisourceBergen’s strong commitment to providing an equal opportunity
work environment where associates are treated with fairness, dignity and respect. Our managers
are expected to create a work environment free from harassment and intimidation and where
integrity and ethical business conduct are recognized and valued. The foundation of our Code is
the obligation to comply with all applicable legal requirements, including those relating to
workplace safety and human rights.
AmerisourceBergen expects all of its third-party suppliers, vendors and other business partners
to comply with similar fundamental principles. Many of our suppliers are required by contract to
comply with applicable laws and ethical principles set forth in our Code of Ethics and Business
Conduct. AmerisourceBergen is engaged in various initiatives to expand the number of third
party suppliers that are required to provide such contract commitments and certifications.
AmerisourceBergen’s Code of Ethics and Business Conduct includes specific references to the
prohibitions against modern slavery and human trafficking.
Ethics and Compliance Training and Reporting Mechanisms
AmerisourceBergen employees receive training on the Code of Ethics and related ethics and
compliance policies, including our policies relating to a respectful and safe work environment.
In addition to the resources available to employees through the Code and its underlying
compliance policies, AmerisourceBergen has established various mechanisms through which
employees and business partners can report concerns about compliance issues to the company
without fear of retribution. One such mechanism is an ethics reporting hotline managed by an
outside vendor which enables employees and third parties to report concerns about compliance
issues relating to AmerisourceBergen’s activities on an anonymous basis. All reports are
investigated in a timely manner.
AmerisourceBergen regularly assesses whether its training materials should be updated to reflect
its commitment to combating modern slavery and human trafficking.
Due Diligence and Audits
AmerisourceBergen has devoted substantial resources to conducting due diligence and
compliance audits of its key business partners, including certain third-party suppliers and other
vendors. In certain circumstances, these procedures include background checks by
AmerisourceBergen’s Corporate Security and Regulatory Affairs Department. As noted above,
we also require many of our suppliers to confirm in writing their commitment to abiding by
applicable laws and ethical principles established in our Code of Ethics.
We continue to evaluate the extent of any exposure we may have to modern slavery or human
trafficking risk in our supply chain. Based on the results of that risk assessment, we will
establish appropriate due diligence and auditing procedures with third-party suppliers that
present an unacceptable level of risk.
This disclosure statement is issued pursuant to section 54(1) of the Modern Slavery Act 2015 for
the financial year ended 30 September 2021.
This disclosure statement is issued on behalf of the following subsidiaries in the Alliance
Healthcare business, World Courier Group, Inc. and MWI Veterinary Supply Co.: AH UK
Holdco 1 Limited (formerly known as WBA UK Holdco 1 Limited), Alcura UK Limited,
Beachcourse Limited, Alliance Healthcare (Distribution) Limited, Alliance Healthcare Management
Services Limited, Alliance Healthcare Technology Services Limited, Alliance UniChem IP Limited,
Alloga UK Limited, Almus Pharmaceuticals Limited, AmerisourceBergen UK Holdings Ltd., OTC
Direct Limited, World Courier Ground (Europe) Limited, W. C. International Limited, World
Courier Logistics (UK) Limited, World Courier Management Limited, World Courier (U.K.)
Limited, Vetswest Ltd., Centaur Services Ltd., Vetspace Ltd., Labpak Ltd., MWI Supply (UK
Acquisition) Limited, MWI Supply (UK Holdings) Limited, MWI Supply (UK) Limited and
MWI Buying Group Limited (formerly St. Francis Ltd.).
