Introduction

Avara Pharmaceutical Services (Avara) is committed to eliminating modern slavery and human trafficking both within the company and in third party suppliers that support our supply chains. Put simply, modern slavery is a crime and a violation of fundamental human rights. It can take various forms, including slavery, servitude, forced and compulsory labor and human trafficking, all of which have in common the deprivation of one person's freedom in order to exploit them for another person’s personal or commercial gain.

Avara has a zero-tolerance policy towards modern slavery, and we are committed to acting ethically, transparently, and with integrity in all our business dealings and relationships. In addition, we are committed to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

This statement sets out Avara’s actions to understand and address potential modern slavery and human trafficking risks related to its business and supply chain and to ensure it is doing all it can to prevent them.

Our Business and Group Structure

Avara is a Contract Manufacturing Organization supplying large-scale, commercial Oral Solid Dose and Sterile Fill-Finish manufacturing services, and integrated packaging services to clients within the biopharmaceutical industry. Avara Pharma Services Ltd. is a United Kingdom privately held company with over 700 employees worldwide, with the following entities within the group: Avara Holdings Ltd., Avara International Holdings Ltd., Avara International Ltd., AIAC International Pharma LLC, Avara Liscate Pharmaceutical Services S.p.A., Avara US Holdings LLC, Avara Aiken Pharmaceutical Services Inc., Avara Pharmaceutical Services Inc., and Avara Pharmaceutical Technologies Inc. The company’s four facilities are in the following locations:

• Norman, Oklahoma, US (Headquarters).

• Aiken, South Carolina, US.

• Arecibo, Puerto Rico.

• Liscate, Italy.

Our Supply Chain

Avara has direct relationships with a number of suppliers which offer a wide range of services to the company. Avara’s existing relationships with its suppliers have been established for some time and are built upon mutually beneficial and collaborative business endeavors. To date, we have not been made aware of or discovered any human trafficking or slavery activities within our supply chain. However, if we were to learn of any such activities, Avara would act immediately, in accordance with our legal and moral obligations.

Our supply chains include: Suppliers of raw materials, excipients and packaging materials; third party laboratory analytical services (where required); logistics services to distribution and import/export of supplies, and other outsourced support functions including IT and HR. In all dealings with such entities, Avara is committed to ensuring that modern slavery is not taking place anywhere in any of our supply chains. We expect that our suppliers will hold their own suppliers to the same high standards.

Our Policies

Avara has various policies in place which aim to minimize the risk of modern slavery or human trafficking, and encourage reporting of any related concerns, including:

Corporate Code of Conduct

Our corporate Code of Conduct is an important part of Avara’s culture and states that Avara is committed to conducting its business with the highest integrity in all activities including relationships with customers, shareholders, employees, suppliers, and the communities in which we operate. We require all Avara employees and contractors to act in a way that is consistent with the highest ethical and professional standards and do not tolerate behavior that deviates from those standards. Colleagues are expected to act with integrity, honesty, courage, and to promote mutual respect.

Whistleblowing Policy

Respect and a culture of openness in the workplace is a key aspect of the Avara Code of Conduct. Avara encourages colleagues and other business partners to report any workplace-related concerns, including any concerns relating to modern slavery or human trafficking.

To facilitate this, Avara’s whistleblowing procedure utilizes a “Red Flag Reporting Line” (administered by a third party) which makes reporting easy and confidential.

Further steps

Avara recognizes that the fight against modern slavery requires an ongoing commitment and diligence and will continue to review, implement, and improve procedures to help identify and prevent the risks of modern slavery or human trafficking. To facilitate this, following a review of the effectiveness of the current steps we are taking this year to ensure that there is no slavery or human trafficking in our supply chains, we intend to take the following further steps to combat slavery and human trafficking:

• Develop and implement awareness training for relevant employees on the recognition and mitigation of slavery and human trafficking

• Develop and implement a questionnaire focused on modern slavery activities/signals in initial negotiations with new suppliers. The questionnaire will be deployed on a risk basis, according to the nature of services provided. Our compliance team will review the responses received and, if necessary, elevate certain responses to the Chief Executive Officer and Board of Directors for further review. In completing this questionnaire, suppliers will be required to report what steps they are taking regarding the identification of the risk of modern slavery within their business and their own supply chain.

• Develop and implement a specific requirement for compliance with modern slavery legislation as part of our contracting processes.

This statement is made and published pursuant to section 54(1) of the Modern Slavery Act 2015 in respect to the year ending December 31, 2021 and has been approved by the Board of the Company on April 1, 2021.

 Avara Board of Directors / Bertrand Talabart