Sustainable Sourcing Policy
Fostering an environment of environmental and social responsibility is fundamental to Formative Pharma’s core principles of trust, integrity, and compassion. To that end, we preferentially partner with suppliers whose business practices are compatible with our policies and commitments regarding environmental and social performance. We recognize the significant impact that our work can have on communities and the environment. Our sustainable procurement system considers the core principles of environmental protection, social responsibility, and good governance to promote sustainability within our supply chain. Consistent with the International Organization for Standardization (“ISO”) 20400 guidance for sustainable procurement, we are committed to working closely with our key suppliers to monitor environmental, social, and economic risks, and seek opportunities for improvement in resource consumption, efficiency, and productivity. We expect our suppliers to engage with us on this journey, and to share relevant information and data with us, to the extent reasonable and practicable.
The purpose of this Sustainable Sourcing Policy (the “Policy”) is to outline Formative Pharma’s commitment to preferentially procuring goods and services from organizations that follow good international industry practice (GIIP) with regards to environmental and social performance.
Application and Review
This Policy applies to all suppliers that provide services, or goods / products that are being manufactured, processed, handled, or transported on behalf of Formative Pharma. This Policy shall be reviewed at least once every three years, or more frequently as stipulated by the approver, or whenever a significant change occurs, including changes to applicable laws or changes to Formative Pharma’s business operations, which may impact the content included herein.
Formative Pharma’s suppliers are expected to conduct their business responsibly, ethically, and act with integrity. Suppliers are expected to comply with all relevant and applicable international and domestic environmental, labour, health & safety, and human rights legislation, including but not limited to anti-trust laws to foster fair and vigorous competition. All forms of corruption, bribery, extortion, and embezzlement are prohibited. Suppliers are expected to be able to demonstrate the existence of procedures to prevent corruption, bribery, and conflicts of interest.
Suppliers are expected to safeguard confidential information to ensure that Formative Pharma, worker, and any patient privacy rights are protected. Suppliers are encouraged to implement adequate procedures and management systems to protect and prevent unlawful use of confidential information. Suppliers are expected to comply with applicable and relevant privacy and data protection laws.
To the extent applicable to work completed by a supplier on behalf of the Company, animals are to be treated humanely with pain and stress minimized. Animal testing should be performed after consideration to replace animals, to reduce the number of animals used, or to refine procedures to minimize distress. Alternatives should be used when scientifically valid and acceptable to regulators.
Formative Pharma’s suppliers are expected to uphold the human rights of workers and ensure that they are treated with respect and dignity. Suppliers should not use any form of forced or compulsory labour, including prison labour, bonded labour, indentured labour, child labour, or any form of human trafficking. Suppliers must comply with all applicable labour laws including adhering to the minimum legal age of employment. Furthermore, suppliers are expected to provide a workplace that is free of harassment and discrimination. We expect our suppliers to provide their employees with whistleblowing mechanisms where grievances related to labour rights can be received, logged, and addressed confidentially.
Formative Pharma believes that workers are entitled to a “Living Wage” defined by the Global Living Wage Coalition (“GWLC”) as: “the remuneration received for a standard workweek by a worker in a particular place sufficient to afford a decent standard of living for the worker and her or his family. Elements of a decent standard of living include food, water, housing, education, health care, transportation, clothing, and other essential needs including provision of unexpected events.” Formative Pharma’s suppliers are expected to be able to evidence commitment to providing a Living Wage to all their direct workers. Suppliers are expected to pay workers in accordance with applicable wage laws, including wages that meet or exceed the legal minimum wage, overtime hours, and mandated benefits.
Health, Safety, and the Environment
The health and safety of workers is a priority for Formative Pharma. Suppliers are expected to provide a safe and healthy working environment. Suppliers are to comply with all applicable health and safety laws and regulations. Suppliers are expected to implement processes and management systems to protect workers from workplace hazards including the implementation of emergency response procedures and providing safety information related to hazards in the workplace.
Formative Pharma expects that suppliers will operate in a manner that is environmentally responsible and to take reasonable steps to minimize environmental impacts. Suppliers are expected to comply with all applicable environmental regulations, obtain appropriate environmental permits, licences, and registrations, and complete mandatory reporting, to the extent required by law.
Sustainable Sourcing Policy
Human Rights Policy
Respecting human rights is fundamental to Formative Pharma’s core values of trust, integrity, and compassion. Our mission is to ensure that all Canadians receive the best possible care, and this means not only carrying out our business activities with absolute integrity and transparency, but also acting with compassion, dignity, and respect for all persons in all that we do.
Formative Pharma is committed to respecting human rights as set out in the Canadian Human Rights Act and the Ontario Human Rights Code. We are also committed to upholding the principles of the United Nations (“UN”) Universal Declaration of Human Rights and the International Labour Organization (“ILO”) Declaration on Fundamental Principles and Rights at Work.
The purpose of this Human Rights Policy (the “Policy”) is to establish and communicate Formative Pharma’s approach and commitment to respecting human rights and how this commitment is embedded in Formative Pharma’s procedures and processes.
Application and Review
This Policy applies to all employees of Formative Pharma, its contractors, and its suppliers who are engaged in business, business-related activities, or business-related relationships. All employees, contractors, and suppliers that conduct business activities on behalf of Formative Pharma are expected to understand and work in alignment with the commitments described within this Policy. If there are any inconsistencies between this Policy and applicable laws, this Policy will be interpreted to give effect to, and comply with, such applicable laws.
This Policy shall be reviewed at least once every three years, or more frequently as stipulated by the approver, or whenever a significant change occurs, including changes to applicable laws or changes to Formative Pharma’s business operations, which may impact the content included herein.
Accessibility for Persons with Disabilities
Formative Pharma is committed to ensuring equal access and participation for people with disabilities and treating people with disabilities in a way that allows them to maintain their dignity and independence. We believe in integration, and we are committed to meeting the needs of people with disabilities in a timely, efficient, and respectful manner. We will uphold this commitment by removing and preventing barriers to accessibility whenever and wherever practicable, and meeting our accessibility requirements under the Accessibility for Ontarians with Disabilities Act (“AODA”) and the Province of Ontario’s accessibility laws.
Non-Discrimination and Anti-Harassment
Formative Pharma is committed to meeting its current and ongoing obligations under the Ontario Human Rights Code respecting non-discrimination. We are committed to providing a safe, harassment- and violence-free workplace for all employees, contractors, suppliers, and visitors to our premises, and treating all employees, contractors, suppliers, and visitors to our premises with utmost respect, dignity, and care.
Formative Pharma prohibits all forms of workplace harassment, violence, and discrimination against any person based on race, national or ethnic origin, colour, religion, age, sex, sexual orientation, gender identity or expression, marital status, family status, genetic characteristics, disability, or any of the other prohibited grounds listed in the Canadian Human Rights Act. Any recruitment, hiring, placement, development, training, compensation, and advancement practice observed at Formative Pharma is non- discriminatory and strictly based on qualifications, performance, skills, and experience. All Formative Pharma employees are required to immediately report any known or suspected incidents of discrimination, harassment, or violence. We maintain a strict no- retaliation policy to protect any person making an allegation in good faith.
Diversity, Equity, and Inclusion
Formative Pharma is committed to establishing and maintaining a diverse, equitable, and inclusive workplace, especially for individuals who have historically been excluded from, and underrepresented in, the pharmaceutical supply chain. This includes, but is not limited to, Indigenous Peoples; people with disabilities; individuals from racialized groups; individuals of diverse faiths and creeds; and people with diverse gender identities or expressions.
We are committed to developing, implementing, and maintaining good practices to enhance diversity, equality, and inclusion at Formative Pharma. We will uphold this commitment throughout all stages and aspects of the employment cycle, including recruitment, retention, development, and advancement.
Healthy and Safe Working Conditions
At Formative Pharma, the physical, emotional, and mental well-being of our employees, contractors, and suppliers is a priority. We are committed to establishing and maintaining a physically, emotionally, and mentally safe, healthy, and productive workplace for all employees, contractors, and suppliers. We comply with applicable health and safety laws and regulations in the areas in which we operate, as well as with our internal health and safety requirements and procedures. We are committed to ensuring that any risks of accidents, injuries, or health impacts identified by our employees, contractors, or suppliers are promptly addressed and remediated.
Formative Pharma prohibits the use of child labour in both our operations and supply chain. We prohibit the hiring of any individual under the age of 15. We require the age of our employees to be verified at the time of hiring. We set clear expectations for our contractors and suppliers not to use child labour, which are further detailed in our Sustainable Sourcing Policy.
All Formative Pharma employees are required to immediately report any known or suspected incidents of child labour without fear of retaliation. We maintain a strict no- retaliation policy to protect any person making an allegation in good faith. We similarly expect our contractors and suppliers to provide their employees with whistleblowing mechanisms where grievances related to child labour can be received, logged, and addressed confidentially.
Forced or Compulsory Labour
The Forced Labour Convention is one of eight fundamental conventions of the International Labour Organization (“ILO”). Its purpose is to suppress the use of forced labour in all forms irrespective of the nature of the work or the sector of activity in which the work may be performed. The ILO Forced Labour Convention defines “forced labour” as: “All work or service which is exacted from any person under the threat of a penalty and for which the person has not offered himself or herself voluntarily.”
The ILO Indicators of Forced Labour were established to assist with the identification of persons who are possibly trapped in a forced labour situation and who may require urgent assistance. The 11 indicators are as follows:
- Abuse of vulnerability
- Restriction of movement
- Physical and sexual violence
- Intimidation and threats
- Retention of identify documents
- Withholding of wages
- Debt bondage
- Abusive working and living conditions
- Excessive overtime
Formative Pharma rejects and prohibits the use of all forms of forced or compulsory labour, including prison labour, indentured labour, bonded labour, military labour, modern forms of slavery, and any form of human trafficking. All employment decisions must be based on free choice and no employee may be coerced to work or subjected to punishment or threats of violence or abuse as a means of discipline or control. All employment agreements must be freely agreed to, in writing, by the employee and their employer. We set clear expectations for our contractors and suppliers not to use any form of forced or compulsory labour, which are further detailed in our Sustainable Sourcing Policy. All Formative Pharma employees are required to immediately report any known or suspected incidents of forced or compulsory labour without fear of retaliation. We maintain a strict no-retaliation policy to protect any person making an allegation in good faith. We similarly expect our contractors and suppliers to provide their employees with whistleblowing mechanisms where grievances related to forced or compulsory labour can be received, logged, and addressed confidentially.
The Global Living Wage Coalition (“GWLC”) defines a “Living Wage” as: “The remuneration received for a standard workweek by a worker in a particular place sufficient to afford a decent standard of living for the worker and her or his family. Elements of a decent standard of living include food, water, housing, education, health care, transportation, clothing, and other essential needs including provision of unexpected events.”
At Formative Pharma, we believe that all our employees, contractors, and suppliers are entitled to be paid a Living Wage sufficient to afford a decent standard of living and are committed to providing a Living Wage and equitable benefits for our employees, contractors, and suppliers and their families.
All wages paid to employees must meet or exceed the legal minimum wage. Overtime, if applicable, must be compensated at the appropriate minimum rate required by applicable law and all wages must be paid on time and in full. All employees must receive a statement of pay for each pay period that clearly outlines the components of their compensation, including hours worked, benefits received, and any deductions. We prohibit the deduction of wages as a disciplinary measure and require that all deductions be made in accordance with applicable law.
Human Rights Policy
Commitment to the Environment
At Formative Pharma, we recognize how integral the health of our planet is to current and future generations. As a responsible company, we are committed to leading by example and being good environmental stewards.
Since our inception, we have continuously looked to implement initiatives to reduce waste and minimize our carbon footprint:
- As the primary source of our carbon emissions is through transportation of our products to and within Canada, we collaborate with a global logistics provider to implement sustainable practices and future energy efficiencies and emissions reduction.
- Initiatives have been implemented to increase our packaging quantities for certain high-volume products to drastically cut down on packaging waste.
- As a virtual company, our driving-related carbon emissions are minimized as employees primarily work from home and are encouraged to carpool or use public transportation to all off-site meetings and events.
- We have recently transitioned to electronic software for key operational and quality processes, eliminating unnecessary printed and signed documentation.
- We volunteer with local conservation groups on various environment initiatives, such as removing invasive species to protect native ecosystems and planting trees near streams to contribute to the health of river systems.
On an annual basis, we work diligently with sustainability experts to measure our CO2 emissions and determine our overall carbon footprint with the goal of reaching net-zero greenhouse gas emissions by the end of 2030. Our plan includes supporting Carbon Offset Initiatives while a full supply chain analysis is performed to identify opportunities for emissions abatement.