This annual statement is made in accordance with Section 54(1) of the UK Modern Slavery Act 2015 (“the Act”).
It is published on behalf of Indivior PLC, a company registered in England and Wales, and its relevant subsidiaries (Indivior Global Holdings Limited, Indivior UK Limited, and RBP Global Holdings Limited). Both Indivior PLC and its relevant subsidiaiaries are referred to as “Indivior” or “Group”. This statement sets out the steps Indivior has taken and will be taking to prevent modern slavery and human trafficking in its business and supply chain.
About Indivior
Our vision is that the millions of people across the globe suffering from substance use disorders (“SUD”), or overdose have access to evidence-based treatment to change lives.
Headquartered in the U.S. in Richmond, Virginia, Indivior employs more than 1,000 individuals globally and its portfolio of products is available in over 30 countries worldwide. The Group has offices in the U.K., several European countries , Canada, Australia, and Israel. Indivior also operates a Fine Chemical Plant (FCP) and a research and development facility in Hull, U.K., a research and development facility in Fort Collins, Colorado, and a manufacturing site in Raleigh, North Carolina.
Indivior’s primary listing was transferred to the Nasdaq Global Select Market in June 2024. Indivior is also listed on the London Stock Exchange in the Equity Shares (Transition) category.
Policy and Codes
Indivior believes that human rights are an absolute and universal standard. It is opposed to all forms of human slavery and trafficking and will not do business with any organisation that it knows to be involved in these activities.
Since September 2022, Indivior has been a participant in the United Nations (the “UN”) Global Compact. Principle 4 of the 10 UN Global Compact Principles is the elimination of all forms of forced and compulsory labor. Principle 5 is the effective abolition of child labor.
Indivior’s Code of Conduct, ‘Doing The Right Things Right’, includes a specific commitment to adhere to the provisions of the UN Universal Declaration of Human Rights, the OECD Guidelines for Multinational Enterprises, and the Act. All new employees receive induction training about these requirements.
Indivior has adopted a Third-Party Code of Conduct and this is available for download at the Group’s website (www.indivior.com). It aligns the prohibition of forced and child labor and slavery with the responsible business standards that it expects from its suppliers.
Supply chain
Indivior’s own product manufacturing operations are performed at the FCP and at a small number of contract manufacturers based in the U.K. and in the U.S. Nearly all raw materials and components are sourced from suppliers based in the U.S., European Union, and Australia. In addition, Indivior’s manufacturing site in Raleigh, North Carolina currently manufactures products that are made for other pharmaceutical companies; these activities will be discontinued in the near-term to enable Indivior to manufacture its own products. The U.K, European Union, the U.S. and Australia have strictly regulated business environments, with strong enforcement of anti-slavery laws.
Indivior’s supply chain also includes organisations and individuals that supply it with a variety of business, transport and administrative services.
Indivior believes that the risk of unidentified non-compliant behaviour by its supply chain manufacturing partners is low.
Indivior Global Integrity & Compliance Program
The main tenets of the Indivior Global Integrity & Compliance Program (IGICP) are ‘Prevent, Learn, Adjust’. This approach helps ensure that risks are promptly identified and mitigated proactively, and a learning organization approach helps guide informed evolution of the IGICP. It is further enabled by an annual Risk Assessment and Mitigation Plan (RAMP) process, a focus on RiskIQ (i.e. risk awareness and application) and a strong ‘Speak-Up’ culture as critical drivers of organization-wide ownership and accountability for compliance that is linked to enterprise-wide functional business strategy and related execution.
Key IGICP elements are:
- Maintenance of robust IGICP governance and the role of the Chief Integrity and Compliance Officer;
- Provision and maintenance of written IGICP Standards;
- Regular workforce training and education;
- Fostering a strong culture of compliance and integrity;
- Monitoring and auditing compliance adherence;
- Maintaining open lines of communication;
- Ensuring that prompt and corrective action and relevant education is taken in instances where IGCIP Standards have not been adhered to; and
- Investigation and disciplinary enforcement.
Further information can be found on pages 40 to 42 of Indivior’s 2024 Annual Report and Accounts.
Compliance reporting
Indivior has in place various resources that enable our workforce, suppliers, and other stakeholders to raise ethics questions and compliance concerns about Indivior’s business activities or the conduct of its employees and contractors. Questions or concerns can be raised directly with the Chief Integrity & Compliance Officer at Compliance@indivior.com.
Another resource is the Indivior EthicsLine, an external telephone and web-based resource available 24 hours a day, seven days a week. Any matter reported to Integrity & Compliance or through the EthicsLine is treated as confidentially as possible and is shared only with workforce members who need to know about these matters for the purposes of an investigation and, if appropriate, corrective action.
Risk and response
Indivior’s Enterprise Risk Management (ERM) process is designed to identify, assess, manage, report, and monitor risks and opportunities that may impact the achievement of the Group’s strategy and objectives. This includes adjusting the risk profile in line with the Group’s risk appetite and tolerances to respond to new threats and opportunities. Further information about Indivior’s ERM can be found on pages 61 to 70 of Indivior’s 2024 Annual Report and Accounts.
Indivior considers that the risk that slavery and human trafficking is taking place within its business or supply chain is low and has uncovered no evidence to indicate otherwise. Indivior will act immediately to redress any matter that indicates that this sort of activity is taking place.
Responsibility
The Directors and Executive Committee of Indivior PLC are ultimately responsible for;
- Implementing this statement;
- Providing adequate resources and investment to minimize the risk of slavery and human trafficking taking place within the business or its supply chain;
- Ensuring Indivior’s approach is regularly reviewed, and
- Ensuring that the commitments outlined in this statement are adhered to.
Review publication and feedback
This statement is reviewed and published annually. Indivior welcomes feedback from any of its stakeholders concerning this statement and its approach to the issues that it addresses. This can be submitted through the contact details provided on the Indivior global website (www.indivior.com).
Approval
This statement was approved by the Board of Directors on May 8, 2025.
Joe Ciaffoni
Chief Executive Officer
Indivior PLC
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