Human Rights

Anthem is committed to conducting our business in a manner that respects the rights and dignity of all people. We will strive to prevent, mitigate, and remedy adverse human rights impacts throughout our workplace, business operations and in the communities in which we work. In order to fulfil this commitment, and in accordance with the United Nations Guiding Principles on Business and Human Rights (UNGPs), Anthem is required to identify, assess, and address any human rights risks or impacts in its operations and supply chains.

Anthem is committed to working with Third Parties who operate in a manner that is consistent with our values and ethical principles, including respect for human rights. In addition to the specific requirements set out under “Section 2. Labor Rights – Fair Employment Practices”, Third Parties are expected and strongly encouraged to conduct human rights due diligence, as set out in the UNGPs, on all internationally recognized human rights, and at a minimum, those expressed in the International Bill of Human Rights (i.e., the Universal Declaration of Human Rights, International Covenant on Civil and Political Rights, and International Covenant on Economic, Social and Cultural Rights) and the principles concerning fundamental rights set out in the International Labor Organization’s Declaration on Fundamental Principles and Rights at Work.

Human rights due diligence is the ongoing process through which Third Parties can “know and show” that they respect human rights. This includes assessing risks to human rights, integrating the findings into its decision-making and actions to mitigate the risks, tracking the effectiveness of these measures, and communicating its efforts internally and externally. The UNGPs recommend that all companies, regardless of size, sector or operational context, conduct human rights due diligence in order to prevent or mitigate any risks to human rights that they cause, contribute to or are directly linked to their operations, products or services through their business relationships; and to participate in the remediation, in whole or in part, of human rights impacts which they cause or contribute to.

In case of a perceived risk of a violation of human rights, Third Parties are required to notify us of this, and the steps being taken to avoid or mitigate such a breach, and where this is not possible, for the Third Party to provide for the remediation of the adverse human rights impact where they have caused or contributed to this. Any notification shall be sent to hroperations@anthembio.com

Labor Rights – Fair Employment Practices

Third Parties shall be committed to uphold human rights for Employees, as set out in the International Bill of Human Rights, and to promote decent work and the four pillars of the International Labor Organisation’s Decent Work Agenda. Third Parties are expected to nominate dedicated personnel with responsibility for Human Resources to oversee compliance with the labor elements of the Third Party Code.

Anthem expects Third Parties to implement a risk evaluation process for their own supply chain in line with the standards defined herein and to communicate the Third Party Code to its own suppliers and partners. Third Parties are expected to have visibility over their own supply chain and implement responsible sourcing and purchasing practices.

The Third Party Code is applicable to all stakeholders in the Anthem supply chain; including Employees onsite and offsite, directly employed by Third Parties or by agencies and other intermediaries.

Employment shall be freely chosen

Third Parties shall not use or engage in any form of Modern Slavery, including any form of prison labor. Employees are free to leave their jobs after reasonable notice and are paid their wages on time and in full upon leaving.

Employees are not required to hand over original versions of their personal documents to secure employment, unless permitted or required by local law. In any such event Employees must have access to their papers at all times.

Employees do not pay recruitment fees or deposits to secure their job, their employer-provided accommodation, or any training and equipment necessary to carry out their jobs.

Third Parties must recruit foreign migrant labor responsibly:

1. No Employee should pay recruitment fees or deposits to secure a job.
2. Third Parties shall oversee all steps of the recruitment process and carry out due diligence at every stage of the labor migration process.
3. Third Parties shall ensure foreign migrant Employees have access to grievance mechanisms in a language they understand throughout the entire labor migration process that give effective access to remedy.
4. Third Parties shall ensure the safe and dignified return of migrant Employees to their countries of origin at any time, without fear of reprisal or penalties and without incurring extraordinary debt. Third Parties shall ensure that private or public security forces engaged by Third Party for security or other purposes shall not violate the human and labor rights of any Employee.

No Child Labor

Children below the local minimum working age, the age of compulsory education or the ages set out in the International Labor Organization Core Conventions (whichever is higher) shall not be employed. No young Employee below the age of 18 shall be employed in hazardous or night work or any form of forced labor. Young Employees must be above a country’s legal age for employment and the age established for completing compulsory education.

If Children are found engaged in prohibited Child Labor, Third Parties shall put in place a suitable plan to support the child, which may involve removing the child from the workplace while continuing to pay salary and the cost of formal or vocational training, accommodation or other costs as necessary, to the child until adulthood. These policies and programmes shall conform to the provisions of the relevant ILO standards.

No Discrimination

Discrimination at any time from recruitment to leaving employment for reasons such as race, national or ethnic minority status, ethnicity, color, age, sex, sexual orientation, gender, gender identity or expression, social origin, disability, religion, political affiliation, union or association membership, pregnancy, marital status, family status or any other protected category as defined by local laws is not tolerated.

Disciplinary and grievance procedures to deal with discrimination are in place and all Employees are made aware of how they can report incidences of discrimination or any unfair employment practices. Third Parties must enforce a non-retaliation policy that permits Employees to express their concerns about the workplace without fear of retribution or losing their jobs.

Fair Treatment must be given

Third Parties shall treat Employees with dignity and respect and provide a workplace free of harassment and with no threat of harsh and inhumane treatment. Employees neither face nor are threatened with bullying, sexual harassment, corporal punishment, any verbal, sexual, physical or psychological abuse or coercion of any kind.

Employees understand disciplinary and grievance procedures, and fines imposed on Employees as part of a disciplinary action are legal and fair. Supervisors, managers or co-Employees found abusing Employees are disciplined accordingly.

Employees are not subject to unreasonable body searches. Physical security searches are only carried out by authorized bodies, according to local legal standards, and by same-sex security guards. Employees do not have to pay supervisors, managers or co-Employees to avoid victimization or receive preferential treatment.

Regular Employment shall be provided

Employment relationships should be established through contract on the basis of national law and best industry practice. Employment terms are communicated to Employees in writing (paper or electronically) in a language they understand before they commence employment.

Obligations to employees under labor or social security laws and regulations arising from the regular employment relationship shall not be avoided through the use of labor-only contracting, sub-contracting, or home-working arrangements, or through apprenticeship schemes where there is no real intent to impart skills or provide regular employment, nor shall any such obligations be avoided through the excessive use of fixed-term contracts of employment.

Fair Wages and Benefits shall be paid

Wages and benefits should be fair and adequate. Wages and benefits for standard hours, excluding overtime, should meet national minimum requirements or industry benchmarks, whichever is higher. We strongly encourage all Third Parties to pay Employees a living wage, benchmarked in the local market. Payment terms are communicated to Employees in writing (paper or electronically) in a language and format they understand before they commence employment and each time they are paid. Deductions as a disciplinary measure are only taken in accordance with local law.

Equal pay for equal work must be ensured – temporary Employees, contractors or Employees on probation shall be entitled to the same compensation as their directly employed, permanent peers. Overtime shall be compensated at a premium rate, in accordance with national law or collective agreements. Where these do not exist, overtime pay shall be no less than 1.25 times regular pay.

Working Hours must not be excessive

Third Parties shall have a system in place to monitor the hours and wages paid to all staff, and complete hours and payroll records must be kept for all Employees.

Standard working hours shall not exceed eight hours per day or 48 hours per week (or 56 hours per week on average for shift work processes).

Overtime hours shall not exceed the limits established in national law or under collective agreements, whichever offers more protection to the Employee. Where these do not exist, overtime hours shall be limited to the degree necessary to ensure the health and safety of Employees. All overtime work must be consensual and not used to replace regular employment.

Employees are given time off, breaks and appropriate leaves in accordance with local laws, ILO standards, collective agreements and/or industry benchmarks, whichever offers more protection to Employees.

The right to Freedom of Association and Collective Bargaining must be respected

Third Parties shall respect the rights of Employees to freely form labor unions, seek representation and/or join Employees’ councils of their own choosing. Employees understand how to raise issues if they wish. Where collective agreements are in place, they are communicated to all Employees in a language they can understand.

Employees and representatives shall be able to communicate openly with management regarding working conditions without threat of reprisal, intimidation, or harassment. Employees are able to bargain collectively and understand how to raise issues if they wish. Where collective agreements are in place, they are communicated to all Employees in a language they can understand.

Where the right to freedom of association and collective bargaining is restricted under law, the employer facilitates, and does not hinder, the development of parallel means for independent and free association, bargaining and grievance raising.