Modern Slavery & Human Trafficking

Last Updated July 2021

About this Statement
This Statement is made pursuant to Section 54 of the United Kingdom Modern Slavery Act 2015 (the Act). The Act requires companies operating in the United Kingdom (UK) to disclose information regarding the steps taken to eradicate slavery and human trafficking from their business and global supply chains. The statement describes our business structure, relevant policies, and ongoing efforts to reduce the possibility that slavery and human trafficking occur in our business or global supply chains. In addition to satisfying our obligations under the Act, we intend to use this statement to enable stockholders, customers, and suppliers to make informed choices about the companies they support.

About our Company
MRN is a Clinical Trial Support Organisation (CTSO) specialising in the provision of community-based, decentralised solutions to the clinical research sector. Specifically, MRN specializes in the conduct of clinical trial visits in the patient’s home and supporting clinical trial sites with nursing resources.

MRN operates in more countries than any other provider and works with many of the largest Pharma, Biotech and CRO companies in the world. Although not all the countries in which we operate nor all the MRN entities are subject to the requirements of the UK Act, MRN has taken a group-wide approach to advancing human rights and combatting slavery in all its forms. We rely on an extensive network of customers, partners and suppliers, all of whom impact the communities in which we live and work. In every business decision and transaction, we endeavour to do the right thing – for our people, our suppliers, and our communities. As a global organization, we recognize MRN has a responsibility to apply a strong and consistent approach to eliminating the risk of forced slavery and human trafficking in our business and in our supply chain.

Our values

• Human – Putting people first is our priority. People are at the front and centre of what we do; we are responsive, hard-working, dedicated and compassionate in equal measure, in our support of, and interactions with, our customers, patients and our colleagues.
• Ingenious – As innovators we are driven to find solutions, never ceasing to look for better, more agile, ways to deliver; we are pioneers in our field – constantly adapting and evolving to ensure that we continue to lead.
• Allies – We work together as teams and allies with all our stakeholders. Listening, sharing and collaborating are integral to all of our interactions – with our colleagues, our customers and our partners. We know that we are more than the sum of our parts – every contribution is important, and every voice is heard.
• Open – Being transparent and honest drives quality. Our communications with our customers and our colleagues are open and transparent; we encourage ideas and discussion, respecting others, operating ethically, and always staying true to our word.
• Challenging – Making a difference is what counts. As pioneers in our sector we will always challenge the standard view, and ourselves, if there is a better way of doing things. We are passionate about sharing our knowledge and expertise; we are proud to be part of our customers’ missions to improve and save lives. We are constantly striving to make a positive impact on the world.

Expectations of our people

All MRN staff are required to read and be familiar with the principles and laws surrounding anti-bribery and anti-corruption as detailed in MRN’s ABAC (Anti-Bribery and Corruption) policy, and have ongoing access to MRN’s global policy via our internal Learning Management System.

MRN has developed a policy which takes a zero-tolerance position with regards to forced labour, slavery and human trafficking. Further, our policy prohibits the use of child labour in line with ILO Convention 138 on the Minimum Age, and Convention 182 on the Elimination of the Worst Forms of Child Labour. As with MRN’s other ethical policies, all MRN staff are required to read and be familiar with our policy on Modern Slavery and Human Trafficking. MRN’s Policy is grounded in our purpose and values and sets out MRN’s standards and expectations for our employees’ behaviour and our business practices. We review our Policy regularly and in line with legislative changes. The current version of the Policy includes a statement on our approach to human rights and ethical labour practices. We expressly state in the Policy that our Company:

• Complies with local labour laws and practices and maintains our
  own high ethical standards of worker treatment;
• Does not condone or use forced or child labour or engage in human
  trafficking or slavery;
• Engages workers on the basis of a recognized employment or
  independent contractor relationship in accordance with local law;
• Provides workers with clear information about wages and benefits
  before they are hired; and
• Respects workers’ rights to associate freely, join or form unions or
  works councils, and bargain collectively in accordance with local
  law.

The Policy applies to our employees, directors, and officers. As part of our annual appraisal process all employees, directors, and officers are required to confirm that they have read and understood their obligations to comply with the principles and
guidelines outlined in it.

Expectations of our suppliers and partners

MRN expect all suppliers, third party vendors and partners to comply with the MRN Policy on Modern Slavery and Human Trafficking or their own ethical conduct policy where that policy is at least as robust as our own with regard to modern slavery and human trafficking. MRN obliges its suppliers, third party vendors and partners to adhere to applicable laws and mandatory policies to ensure that the following matters are covered in the supply chain or other third-party contractual relations. The code must:

• Prohibit suppliers from using, participating in, or benefiting from any form of human trafficking;
• Prohibit suppliers from using any form of non-voluntary work or child labour. Workers must be free to terminate their employment or other working relationship with the supplier at any time after reasonable notice without reprisal;
• Require suppliers to provide workers with written and understandable information about their wages and benefits before they enter employment;
• Require suppliers to ensure working hours are not excessive and do not exceed legal maximums;
• Prohibit suppliers from requiring workers to pay supplier or its agents recruitment fees or other fees;
• Prohibit suppliers from requiring workers to lodge “deposits” or identity papers with the supplier and from denying workers access to such identity papers; and
• Prohibit suppliers from physically abusing or disciplining workers or using other forms of intimidation against workers.

Training and ensuring awareness

We work to ensure all colleagues receive the appropriate level of training to raise awareness of modern slavery and human trafficking, and the knowledge to address any related issues which may arise.

We encourage openness and support anyone who raises genuine concerns in good faith, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. MRN take seriously any concerns communicated anonymously.

MRN encourages members of the public or people not employed by us to write, in confidence, to the Executive Director of People to raise any concern, issue or suspicion of modern slavery in any part of our business or related supply chain.

Responsibility

Ultimate responsibility for the prevention of modern slavery rests with the Company’s leadership. The Board has overall responsibility for ensuring this statement and its implementation comply with our legal, moral and ethical obligations.

Leaders at all levels are responsible for ensuring those reporting to them understand and comply with this statement and are given adequate and regular training on it and the issue of modern slavery.

Compliance and review

Following its initial adoption this statement will be kept under regular review by the Board and may be amended from time to time.