Novavax Modern Slavery Statement 2024

The UK Modern Slavery Act is legislation that seeks to regulate and address the issues of modern-day slavery in business operations and their global supply chains. It states that companies with sales of more than £36 million or that conduct some, or all, of their business in the UK must publish an annual statement on their website related to their anti-slavery efforts. 

Companies must confirm the steps taken to ensure that slavery and human trafficking are absent from the business and supply chain, or they must declare that no steps have been taken. These rules apply to public and private companies and partnerships, wherever they are incorporated or formed and in whatever sector they operate. 

 Act Requirements: 

  • Identify and analyse the risks of human trafficking and slavery in the supply chain. 
  • Create and maintain internal accountability standards and procedures for employees and contractors, and taking action on those who fail to meet company standards regarding slavery and trafficking. 
  • Conduct audits of suppliers to evaluate supplier compliance with company standards for human trafficking and slavery in supply chains. 
  • Require direct suppliers to certify that materials incorporated into the product comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business. 
  • Provide company employees and managers, with direct responsibility for supply chain management, training on human trafficking and slavery, particularly with respect to mitigating risks within the supply chains of products. 

The Home Office’s statutory guidance recommends that we cover the following 6 areas in our statement: 

  • Organisation structure and supply chains 
  • Policies in relation to slavery and human trafficking 
  • Due diligence processes 
  • Risk assessment and management 
  • Key performance indicators to measure effectiveness of steps being taken 
  • Training on modern slavery and trafficking 

Novavax Modern Slavery Statement 2024 

In compliance with the UK Modern Slavery Act of 2015, the following describes the ongoing steps Novavax is taking to address and prevent modern slavery within our business and supply chains. 

About Novavax 

Novavax, a global company with headquarters in Gaithersburg, Md., U.S., is committed to protecting health of people worldwide by discovering, developing, and commercialising innovative vaccines for serious infectious diseases. 

Novavax has defined core values that guide our approach to doing business with the highest standards, as well as our culture of diversity, equity, and inclusion that taken together enable us to create, develop and fully leverage the strengths of our workforce to meet our growth objectives. 

Our Supply Chain 

Novavax UK purchases the product it sells from the parent company Novavax Inc. It also engages the services of several UK based consultancy services. 

Novavax Inc. built a global manufacturing and supply network during the 2020 pandemic.

Tier 1 – Novavax Inc. 

As well as a head office in the USA we also have a manufacturing network, which includes our wholly owned sites in Sweden and the Czech Republic. 

Tier 2 

Novavax Inc. have manufacturing partners and suppliers in multiple countries, including India, Germany, and the Netherlands.

We have reviewed the Modern Slavery Risk of our manufacturing network as listed above. The risk level is determined using the scale according to the global slavery index. https://www.globalslaveryindex.org and provides a score between 1 and 8 with 1 being low risk and 8 being high risk. The risk score for the Tier 1 sites is between 1-3 (low risk) and for Tier 2, two of the suppliers are scored 1 (low risk) and the other is scored a 5 (medium risk). Four of the suppliers is low risk – between 1-3 and there is one supplier with a score of 5 (medium risk). 

We utilise the services of various UK Consultancy services and the risk associated with these is identified as low. 

The NovaCode: Our Code of Business Conduct 

Our NovaCode (the Code) sets the highest standards for our ethical business conduct at Novavax and provides guidance to help our employees make the right decisions. It outlines expectations for our employees when dealing with strategic partners, healthcare professionals, and the communities we serve. Except as otherwise required by applicable laws, this Code applies to Novavax Inc., and all of its subsidiaries and other business entities worldwide. 

While the Code applies to all employees, officers and directors, certain business partners such as joint ventures, agents, consultants, distributors, suppliers, vendors, independent contractors, and temporary employees are also expected to live up to the principles of the Code. Managers who supervise our external partners are responsible for ensuring that they understand and adhere to our standards. 

Ethical Business Partners and expected Supplier Conduct 

Novavax only works with partners, including our suppliers, contract manufacturers, suppliers and distributors who conduct their business with integrity. Every vendor we hire must uphold our principles and may not engage in unethical or illegal business practices. Before entering into a business relationship, we work to ensure the appropriate due diligence screening has occurred, and that the vendor meets our standards of excellence. This includes a Supplier Sustainable Audit and our Master Service Agreement, which set the terms of our engagement. 

We have created mechanisms for employees to communicate any issues that are identified to appropriate Novavax personnel, including Legal, Corporate Compliance and Finance. 

Our UK suppliers are required to comply with our Supplier Code of Conduct and our Ethical Trading, Human Rights and Labour Standards Policy. 

Novavax conducts periodic and regular reviews of Suppliers to evaluate their compliance with our policies and applicable legal and regulatory requirements including a Sustainability Audit. 

Our Human Rights Policies 

Novavax supports and will champion fundamental human rights. We will not work with business partners who employ children or forced labour. We will not tolerate violence or abuse. In every country where we operate, Novavax follows all laws, regulations and international conventions related to human rights. Our medical and research activities follow the principles outlined in the Declaration of Helsinki. 

Accountability Activities 

All employees are required to sign an acknowledgement annually that they have read and will adhere to the Code. In addition, Novavax invests in training for its employees and management, including those who have direct responsibility for supply chain management, particularly with respect to mitigation risks of human trafficking, slavery, and illegal child labour within the supply chain. 

To date, Novavax has not received any reports from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified, either at Novavax or in its supply chain. 

Novavax UK have provided employees third party independent training on Modern Slavery through ‘Tick the Box Compliance Solutions’ to all employees. 

The training covers: 

  • The ILOs Forced labour indicators 
  • The training ensures that recipients understand 
    • Indicators of modern slavery 
    • How to report suspicions of modern slavery 
    • The modern slavery statement requirements 
    • How to consider modern slavery risks in procurement 
    • How to be better equipped to undertake modern slavery due diligence for the organisation. 

The training is delivered via e-learning and participants are required to pass the course using a competency-based exam. The training is mandatory and is provided on induction and then every 12 months. 

Our Commitment to the Future 

Novavax understands that tackling modern slavery requires a year-over-year commitment and will continue rigorous due diligence of our supply chain as well as review and improve procedures to help identify and prevent the risks of modern slavery or human trafficking. During the next year, Novavax is committed to establishing additional internal standards, procedures, and systems, including diligence around identification and elimination of human trafficking, slavery and illegal child labour in its supply chain as well as accountability measures for its employees and contractors who fail to meet these standards. 

Finally, Novavax is committed to creating a workplace conducive to the open discussion of its business practices. We encourage our employees to share their concerns with the manager or another member of our Leadership, Corporate Compliance, Human Resources, Legal or Finance teams. 

We encourage all of our stakeholders, including suppliers, distributors, consultants, service providers and other partners to contact us at [email protected] for general compliance questions, for questions relating to raising a concern or our Human Resources team for any concerns related to policies, procedures or regulations or matters regarding personal conduct. 

Helpline 

Our helpline is available to anyone 24 hours a day and language translation is available. All calls and reports submitted are handled promptly and discreetly, and Novavax will review and investigate each matter promptly and accordingly. Confidentiality will be maintained to the fullest extent possible and Novavax strictly prohibits any form of retaliation. 

  • US: 844-612-0252 
  • SWEDEN: 020-12 72-95 
  • CZECH REPUBLIC: 800-144-499 
  • CANADA: 844-612-0252 
  • BELGIUM: 0800-71-203 
  • SINGAPORE: 800-492-2617 
  • SWITZERLAND: 0800-103-453 

Reporting 

If a case of Modern Slavery is suspected, then the following is advised. A suspected victim of modern slavery is not to be confronted directly as this may endanger them. If an immediate risk to life, then call 999. If there is no immediate risk to life, then the Modern Slavery Helpline is to be called 08000 232 700 or it will be reported online. 

Employees are required to take their suspicions to their line manager. 

If modern slavery is identified or suspected abroad, they will engage with local Non-Governmental Organisations, industry bodies, trade unions or other support organisations to attempt to remedy the situation. If warranted, we will contact local government and law enforcement bodies. Our approach will always consider the safest outcome for the potential victims while also remember the economic influence and control which the organisation holds over those who may be committing these crimes. 

If the response from any of our suppliers, here in the UK or abroad to concerns seems inadequate and adequate measures are not put in place to address coercion, threat, abuse, and exploitation of workers, then we would look to give that company more support, guidance, and incentives to tackle the issue. This could include working with at-risk suppliers to provide training, messages and business incentives or guidance to implement anti-slavery policies. 

If, after receiving support, the supplier is not taking the issue seriously, and it remains unresolved, then we will reconsider our commercial relationship with that supplier. These actions could then be included in the next statement produced. 

Review and Communication 

This statement will be reviewed by senior management, signed by a director or equivalent and then published on our website, and also uploaded to the Modern Slavery Statement Registry.

Internally it will be sent to all employees and sent to our supply chain and other interested stakeholders. 

Responsibility 

Paul McIntosh; Country Director UK and Ireland has overall responsibility for this policy. 

Senior Management Approval 

Signed: 

 

NAME: Paul McIntosh 
JOB TITLE: Country Director UK & Ireland 
DATE: 22/3/2024