This statement has been published in accordance with the Modern Slavery Act 2015. It sets out the steps taken by Biocair International Limited (known as Biocair) during the year ending 31st August 2020 to prevent modern slavery and human trafficking in its business and supply chain.
Introduction
Biocair has a zero-tolerance approach to modern slavery, and we strive to act ethically and with integrity in all our business dealings and relationships to ensure that modern slavery is not taking place anywhere in our organisation. We are equally committed to ensuring that we do not deal with suppliers or partner with organisations who engage in modern slavery or human trafficking. While this statement focuses on the actions we have taken to prevent Modern Slavery in our supply chains, Biocair recognises the scope of poor labour practices, exploitation, and human rights abuses within supply chains which are often referred to interchangeably with the term ‘modern slavery’. These poor practices are also indicators that robust management systems are not in place which would prevent modern slavery occurring.
Our group structure
Founded in 1986 as a specialist logistics provider to the pharmaceutical, biotechnology and life sciences sectors, in 2002 Biocair made its first moves abroad, establishing an office in the US in Boston. This has been followed by expansion across the US, Asia, Europe, and Africa, so that we are now a truly global company. In 2012 Biocair was acquired by GeoPost SA, owners of the DPDgroup, the largest parcel delivery network in Europe, and part of Le Groupe La Poste. As a result, Biocair benefits from enhanced supplier relationships and access to advanced technologies, networks, and routes across the globe, enabling our logistics experts to implement industry-leading supply chain solutions for the life sciences sector.
The Board of Directors comprises:
- Chris Cooke (CEO) – Biocair
- Vincent Howard (COO) – Biocair
- Cédric Favre-Lorraine – GeoPost
- Benjamin Demogé – GeoPost
Governance of human rights in Biocair is delegated to the Strategic Leadership Team (SLT) which reports to the Biocair Board. The Strategic Leadership Team comprises:
- Chris Cooke – Chief Executive Officer
- Vincent Howard – Chief Operating Officer
- Bruce Kennedy – Chief Commercial Officer
- Jeremy Thomas – Chief Finance Officer
- Michelle Watson – Chief People Officer
Our operations
Biocair is a global GDP logistics specialist with nearly 35 years of experience in the pharmaceutical, biotechnology and life sciences sectors. The company has built up a unique, client-centric approach by employing scientists in front-line logistics positions and assembling a team of best-in-class industry experts in quality, cold chain, and regulatory compliance. Biocair focuses on providing the most comprehensive time-sensitive and temperature-controlled logistics services available whilst delivering flexible, tailored, cost effective solutions to all clients. The Biocair network operates 24/7 in over 160 countries across Europe, Africa, Asia and the Americas.
Our supply chains
Biocair categorises supply chain suppliers and contractors into two groups:
1. Operational suppliers / contractors - comprising airlines, couriers, agents, customs brokers, packaging houses, transport providers and specialist storage providers.
These suppliers are centrally selected and managed and, apart from the airlines, they all are required to complete the Supplier Code of Conduct Declaration which includes a section on modern slavery, human trafficking, and general labour standards.
2. Non-logistics suppliers/contractors - comprising HR and recruitment service providers, buildings and office maintenance, cleaning, and security service providers, business consumables suppliers, and suppliers of professional services such as lawyers, accountants, marketing, and other advisers.
Most suppliers and contractors in this second category are locally selected and are required to complete the Supplier Code of Conduct Declaration unless sole traders. We have identified that our due diligence follow-up with this group of suppliers and contractors is not as robust as it could be, and we plan address this in 2021 as part of our new procurement and responsible business strategies.
Our policies on modern slavery and human trafficking
We are committed to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls that ensure modern slavery and human trafficking are not taking place anywhere in our business or our supply chains.
In support of this commitment, Biocair have the following policies and procedures in place which include modern slavery and human trafficking requirements:
- Corporate Social Responsibility Policy
- Corporate Compliance Manual
- Supplier Code of Conduct Declaration
- Supplier Audit Procedure
- Supplier Management Manual
- Supplier Selection Scoring Matrix
- Supplier Contract
We have reviewed these policies and procedures and have identified they could be more robust and detailed in their approach, and we will update all the policies in 2021, as well as filling any policy gaps we identify.
Due diligence processes for modern slavery and human trafficking
The Supplier Code of Conduct Declaration is used to gather appropriate information for use in evaluation of supplier risk. These are required from all suppliers acting under contract/agreement or providing a bespoke service. The supplier will complete a new declaration as part of each new tender process, which is usually once every three years.
This declaration includes questions regarding the supplier’s own controls which enables completion of the due diligence procedure. The completed declaration is held by the Compliance Team for checking.
Biocair operates a risk-based due diligence procedure, whereby the level of screening required for a supplier or contractor is dictated by the risk they represent to the business. Therefore, suppliers and contractors are prioritised in relation to modern slavery depending on the likelihood of the risk being present based on their geographic location and the prevalence within the sector in which they operate. While we expect all suppliers and contractors to complete a declaration, we will take particular care to check that suppliers or contractors at higher likelihood of modern slavery have the appropriate controls in place.
All suppliers and contractors can only be used once all due diligence checks are complete, and only in exceptional cases can the CEO or COO approve use of a supplier or contractor prior to the completion of all due diligence checks. There were no instances of this in 2020.
Supplier adherence to our values and ethics
Biocair monitors, reviews, and manages supplier performance on an ongoing basis in terms of commercial, compliance and ethical performance in the following ways:
- Supplier KPI Reporting
- NCR’s and the Supplier Service Failure Form
- Supplier Visits and Audits
- Supplier Service Evaluation -
- Scheduled Review Meetings
Our Compliance teams are involved in ensuring this process works effectively and monitor it regularly, adapting as necessary to the changing needs of our business.
Training
Until now, Biocair has focused on ensuring compliance in the supply chain. In 2022, we plan to introduce training on modern slavery and the requirements of the Act for teams and individuals most directly involved with selecting and managing suppliers. This will ensure a high level of understanding of the risks of modern slavery and human trafficking in our business and in our supply chains. Where appropriate, we will ask our suppliers and contractors to provide training to their staff and suppliers.
Continued commitment
Biocair recognises the importance of maintaining constant vigilance to identify and address any issues associated with slavery and human trafficking in Biocair’s own operations and in our supply chains. We are committed to enhance continually our capacity to identify, prevent and mitigate any actual or potential risks in these areas.
This statement has been approved by the Board and signed on their behalf by Chris Cooke, Chief Executive Officer, Biocair International Ltd on 6th August 2021.
Signed
