Our Values and Responsibilities

Thornton & Ross Ltd – Modern Slavery Act 2021

Introduction

This statement relates to actions taken during the financial year 1^st January 2021 to 31^st December 2021.

This statement details the actions taken by Thornton & Ross Ltd (T&R) to understand the modern slavery risks related to its business and to ensure that as far as possible there is no human trafficking or slavery in its own business and in its supply chain.

The Company acknowledges its responsibilities under the Modern Slavery Act 2015 (the Act) and seeks to ensure that conditions for its employees are of a good standard and that none of our practices infringe any legal or ethical requirements. The company takes a zero tolerance to slavery and human trafficking in its business activity and attempts, as far as is reasonably practical, to ensure that there is no slavery or human trafficking in the supply chain.

At the heart of the organisations’ culture are our values of Agility, Entrepreneurship, One STADA and Integrity which ensures we work to avoid working with organisations that may not comply with the Act.

Organisational Structure

T&R develop, manufacture, and supply a wide and growing range of branded over-the-counter medicines, dermatological products, generic medicines including biosimilars and other pharmaceutical and household products. The Company was originally a family-owned business until it was acquired in 2013 by STADA Arzneimittel AG (STADA Group). T&R was founded in 1922 and is one of the largest ‘over-the-counter’ manufacturers in the UK.

Our approach is to combine good, responsive customer service and quality products in a working environment that encourages innovation.

Our business operates in the UK with the majority of our employees based at our two Huddersfield sites – the UK Head Office in Slaithwaite and our manufacturing site in Linthwaite. The organisation is structured in two defined areas – Technical Operations (manufacturing and production) and Commercial (Consumer Dermatology, Home Hygiene, OTC, and Prescription Pharmaceuticals).

The responsibly for procurement lies in the procurement team which has a dual reporting function with a direct line to the VP of UK Technical Operations as well as the Global Procurement Team within the STADA Group.

Our suppliers are (where possible) local businesses, although due to the specialised nature of certain pharmaceutical products, ingredients and processes and the limitations to the number of suppliers in the pharmaceutical and consumer health market, we also buy from businesses around the world.

The procurement team that manages both the indirect and direct supply chain for our Company maintain close working relationships with our suppliers and working collaboratively with global procurement in the STADA Group.

Supply Chain Due Diligence

T&R purchase packaging materials, chemicals, and active pharmaceutical (API) ingredients from third party suppliers. Other brands are secured from contract manufacturing organisations for products that T&R holds the marketing authorization for or in some cases T&R buys in finished products for resale. In addition, we also outsource some packaging activity to contract manufacturers. Suppliers must complete and return an evaluation questionnaire before any contractual negotiations are entered into or enter into a formal contract. Each supplier is required to provide information on labour conditions, compliance with national laws, hygiene facilities, discrimination, and child labour as well as regulatory compliance.

As the Company purchases materials from around the world, we monitor our suppliers and the conditions for their staff, both by assessing the presence of human trafficking and slavery in their operations, and by visiting their plants to observe their business practices and local conditions. All suppliers are categorised, and risk reviewed on an on-going basis.

If concerns are raised, then we will review these with the supplier with the aim of raising awareness and making the required improvements. Ultimately if progress is not made, we will cease to trade with that supplier.

We do not have any supply agreements with any organisations within the 10 countries with the highest prevalence of modern slavery, as identified by the Global Slavery index.

Training

T&R ensures that all senior managers and employees within the procurement department are trained on the Modern Slavery Act 2015. This training is delivered via online digital training.

Approval

This statement has been approved by the Executive Vice President of Thornton & Ross Limited on behalf of the Company. The statement will be reviewed and, where necessary, updated on an annual basis.

Roger Scarlett-Smith

Executive Vice President UK & US

Thornton & Ross Ltd

Thornton & Ross Ltd – Modern Slavery Act 2022

Introduction

This statement relates to actions taken during the financial year 1st January 2022 to 31st December  2022. 

This statement details the actions taken by Thornton & Ross Ltd (T&R) to understand the modern  slavery risks related to its business and to ensure that as far as possible there is no human trafficking  or slavery in its own business and in its supply chain. 

The Company acknowledges its responsibilities under the Modern Slavery Act 2015 (the Act) and  seeks to ensure that conditions for its employees are of a good standard and that none of our  practices infringe any legal or ethical requirements. The company takes a zero tolerance to slavery  and human trafficking in its business activity and attempts, as far as is reasonably practical, to ensure  that there is no slavery or human trafficking in the supply chain. 

At the heart of the organisations’ culture are our values of Agility, Entrepreneurship, One STADA and  Integrity which ensures we work to avoid working with organisations that may not comply with the  Act.

Organisational Structure

T&R develop, manufacture, and supply a wide and growing range of branded over-the-counter  medicines, dermatological products, generic medicines including biosimilars and other  pharmaceutical and household products. The Company was originally a family-owned business until  it was acquired in 2013 by STADA Arzneimittel AG (STADA Group). T&R was founded in 1922 and is  one of the largest ‘over-the-counter’ manufacturers in the UK. 

Our approach is to combine good, responsive customer service and quality products in a working  environment that encourages innovation. 

Our business operates in the UK with the majority of our employees based at our two Huddersfield  sites – the UK Head Office in Slaithwaite and our manufacturing site in Linthwaite. The organisation  is structured in two defined areas – Technical Operations (manufacturing and production) and  Commercial (Consumer Dermatology, Home Hygiene, OTC, and Prescription Pharmaceuticals). 

The responsibility for procurement lies with the Procurement team who have a dual reporting  function with a direct line to the VP of UK Technical Operations as well as the Global Procurement  Team within the STADA Group. 

Our suppliers are (where possible) local businesses, although due to the specialised nature of certain  pharmaceutical products, ingredients and processes and the limitations to the number of suppliers  in the pharmaceutical and consumer health market, we also buy from businesses around the world. 

The procurement team that manages both the indirect and direct supply chain for our Company  maintain close working relationships with our suppliers and working collaboratively with global  procurement in the STADA Group.

Since our last statement, Thornton & Ross has developed a Strategic Compliance Framework and  introduced a Compliance Committee that maintains oversight of its compliance obligations. The  Committee, made up of senior employees have gone through Compliance training and have also  introduce a Compliance Charter. 

Supply Chain Due Diligence

T&R purchase packaging materials, chemicals, and active pharmaceutical (API) ingredients from third  party suppliers. Other brands are secured from contract manufacturing organisations for products  that T&R holds the marketing authorization for or in some cases T&R buys in finished products for  resale. In addition, we also outsource some packaging activity to contract manufacturers. Suppliers  must complete and return an evaluation questionnaire before we enter into any contractual  negotiations or enter into a formal contract. Each supplier is required to provide information on  labour conditions, compliance with national laws, hygiene facilities, discrimination, and child labour  as well as regulatory compliance. 

As the Company purchases materials from around the world, we monitor our suppliers and the  conditions for their staff, both by assessing the presence of human trafficking and slavery in their  operations, and by visiting their plants to observe their business practices and local conditions. All  suppliers are categorised, and risk reviewed on an on-going basis. 

If concerns are raised, then we will review these with the supplier with the aim of raising awareness  and making the required improvements. Ultimately if progress is not made, we will cease to trade  with that supplier. 

We do not have any supply agreements with any organisations within the 10 countries with the  highest prevalence of modern slavery, as identified by the Global Slavery index.

Training 

T&R ensures that all senior managers and employees within the procurement department are  trained on the Modern Slavery Act 2015. This training is delivered via online digital training.

Approval 

We are committed to continuous improvement in our efforts to identify, prevent and remedy  human rights abuses in our supply chain. As we make further progress in the above areas, we will  report on that progress through subsequent versions of this statement. 

This statement has been adopted and approved by the Thornton & Ross Leadership team (SEC) on  the 7th June 2023.

Kathryn Heywood 

Director 

Thornton & Ross Ltd

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Introduction

In accordance with the requirements of paragraph 16(2) of Schedule 19 of the Finance Act 2016, STADA UK Holdings Limited presents the UK Tax Strategy for STADA UK Holdings Limited and its UK subsidiaries (“UK Group”) for financial year to 31 December 2022.  This tax strategy applies to all taxes applicable to the UK Group and has been approved by the Board of Directors (“the Board”). A list of subsidiary companies is included in the Company’s Annual Report and Financial Statements

References to ‘tax’, ‘taxes’, or ‘taxation’ are to UK taxation and to all corresponding worldwide taxes and similar duties in respect of which the Group has legal responsibilities. 

The policy will be published annually on www.thorntonross.com

Approach to risk management and governance arrangements

The UK Group is risk averse in managing tax and as such all significant tax decisions are agreed by the Senior Accounting Officers and reviewed, monitored and endorsed by the Board.

The Group’s internal structure is set up to ensure that the Board understand the importance of tax as a Group function, and how the risk associated with the delivery of a compliant tax strategy is managed. There is a regular dialogue between the Board and those individuals tasked with the operation of the tax function regarding the way the business manages its tax risk. Risk issues identified as part of this continuous cycle are reported to the Corporate Risk Management at the headquarters of STADA Group according to the Group’s risk procedures. Internal systems, processes and controls are reviewed regularly to ensure that they are robust and continue to be fit for purpose.

STADA Group supports global trends and standards on tax transparency and coordination of national tax systems.

The relevant teams have the skills and knowledge required and are kept up to date on changes to tax legislation, where applicable, by the in-house tax team. The in-house tax team are supported by external tax advisers where required, including the preparation of UK tax returns and advising on compliance with tax related obligations generally and in relation to significant transactions.

Attitude towards tax planning

When entering into commercial transactions, the UK Group seeks to take advantage of available tax incentives, reliefs and exemptions which are consistent with the spirit as well as the letter of the tax law and takes external advice to confirm this if necessary.

The UK Group’s policy is to not enter into any artificial tax planning arrangements that are not underpinned by a commercial transaction.

The Group manages its tax affairs in line with its core values, its strong focus on corporate responsibility, and its commercial reputation and brand.

The level of risk in relation to UK taxation

The UK Group seeks to comply fully with its regulatory obligations and ensures the tax arrangements are consistent with a low tax risk approach to conducting its business.

The UK Group does not seek to structure transactions in ways that give tax results inconsistent with their underlying economic consequences.

Where the tax treatment of any particular and/or material transaction is uncertain, external tax advice will be sought before proceeding with the transaction.

The approach towards dealings with HMRC

The Group act in an honest and fair manner when dealing with tax authorities. Our approach is to have an open and transparent relationship, and, in the event of a disagreement, we shall endeavour to resolve this through provision of information and constructive dialogue.

30 September 2024

THORNTON & ROSS LIMITED’s Gender Pay Gap Data

Thornton and Ross Ltd is an environmentally conscious organisation accredited to ISO 14001:2015, which acknowledges the impact that our operations may potentially have on the environment.

The Company will minimise any impact on the environment by:

• Preventing pollution, reducing waste and ensuring, wherever practicable, that measures are
  implemented to protect and preserve natural habitats, flora and fauna.
• Using all sources of energy and water efficiently.
• Considering the effects that our operations may have on the local community.
• Taking action to eliminate or reduce, as far as practicable, any potentially adverse environmental
  impacts.
•  Promoting environmental awareness amongst our suppliers, contractors and partners by
  implementation of operational procedures.
• Seeking to work in partnership with the community by behaving in a considerate and socially
  responsible manner.
• Ensuring effective and expedient incident control, investigation and reporting.
  Managerial and supervisory staff have responsibilities for the implementation of the policy and must ensure that environmental issues are given adequate consideration in the planning and day-to-day supervision of all work. Thornton and Ross Ltd will fully comply with all legislation requirements; being aware of guidance, as issued by the Environment
  
  Agency and other organisations as part of the company’s commitment to maintaining the high levels of environmental compliance. All employees and sub-contractors are expected to co-operate and assist in the implementation of this policy, whilst ensuring that their own works, so far as is reasonably practicable, are carried out without risk to themselves, others or the environment. This includes co-operating with management on any environment related matter. Thornton and Ross Ltd will take all practical steps to ensure that potential hazards and risks to the environment are identified and that appropriate preventive and control measures are implemented. The Directors have overall responsibility for all environmental matters.
  
  The operation of this policy and the associated procedures will be monitored and reviewed on a regular basis to ensure that they remain current and applicable to the company’s activities, thereby demonstrating continual improvement. This policy has been endorsed by the Senior Management Group, which gives full support to its implementation and adherence.
  
  
• Please view our commitment to achieve Net Zero by 2050 and Carbon Reduction Plan here.