Slavery and Human Trafficking Statement – 2017
Jazz Pharmaceuticals plc and its subsidiaries (“Jazz” or “the Company”) are committed to operating our global business with integrity and upholding a high level of ethical conduct among our employees and business partners. We expect that suppliers which provide materials for use in our tangible goods for sale (“Product Suppliers”) to adopt sound human rights practices, to treat workers fairly, with dignity and respect and in all cases to eliminate human trafficking and slavery in their workplace.
Verification: Jazz has existing procedures for assessing our Product Suppliers and has enhanced these procedures to include steps for evaluating whether our Product Suppliers comply with applicable laws related to eradication of human trafficking, slavery and illegal child labor. Our Supply Chain and Quality Assurance teams oversee these verification procedures using an internally-developed multi-part assessment. In addition, Jazz has adopted written Standards of Conduct for Supply Chain and will request that our Product Suppliers certify that they comply with applicable laws concerning human trafficking, slavery and illegal child labor in the countries in which they do business.
Audits: Jazz conducts periodic and regular announced audits of its Product Suppliers to evaluate their compliance with Jazz’s policies and applicable legal and regulatory requirements. Jazz typically conducts such audits using its own personnel, although it reserves the right to engage an independent third party auditor. Jazz’s current Contract Manufacturer Assessment Guidelines establish procedures for audits of potential and existing Product Suppliers, including their training, experience and qualifications, adherence to legal and regulatory requirements, and evaluation of the suppliers’ compliance with quality systems. Jazz tracks any observations and/or non-compliance in its Audit Follow Up & Close-Out procedures to ensure that instances of non-compliance are properly remediated. Jazz has updated its Contract Manufacturer Assessment Guidelines to expressly address human trafficking, slavery and illegal child labor in its auditing protocol.
Materials: Jazz is in the process of implementing procedures that will require Product Suppliers to certify that materials incorporated into Jazz’s products comply with the laws regarding human trafficking, slavery and illegal child labor in applicable countries.
Accountability Standards: Jazz is in the process of establishing internal accountability standards and procedures, including disciplinary action for its employees and contractors with procurement responsibilities who fail to meet Jazz’s standards regarding identification and elimination of human trafficking, slavery and illegal child labor in its supply chain.
Training: Jazz has developed and conducts training for its employees and management who have direct responsibility for supply chain management, particularly with respect to mitigation risks of human trafficking, slavery and illegal child labor within the supply chain.