Modern Slavery and Human Rights Policy
A voluntary policy: NovaPharm has not established that the section 54 turnover threshold currently applies and does not present this as a mandatory statutory statement.
Applicability
NovaPharm is a UK commercial organisation preparing to supply goods and services, but verified evidence does not currently show consolidated global turnover of at least GBP 36 million. Applicability will be reassessed annually and after a material transaction. If the duty applies, a financial-year-specific statement will require board approval and director signature.
Supply-chain risks
Risk review covers manufacturing and raw-material labour, packaging, overseas sourcing, warehousing, temperature-controlled logistics, transport subcontractors, cleaning, facilities, recruitment and temporary labour, CMO/CDMO relationships and subcontractor visibility.
Due diligence and response
Planned onboarding records ownership, licence, site, labour-practice and subcontracting evidence proportionate to risk. NovaPharm will not claim audits, training or remediation that records do not verify. Response may include clarification, corrective action, suspension, termination or lawful reporting, with worker safety prioritised.