Modern slavery act

This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and sets out the steps Covetrus, Inc. (“Covetrus” or the “Company”) is taking on behalf of its subsidiaries to ensure that slavery and human trafficking are not taking place in its supply chains or in any parts of its business.

Modern Slavery & Human Trafficking Statement

This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and sets out the steps Covetrus, Inc. (“Covetrus” or the “Company”) is taking on behalf of its subsidiaries to ensure that slavery and human trafficking are not taking place in its supply chains or in any parts of its business.

Organisational Structure
Covetrus is a global animal-health technology and services company. Founded in February 2019 through the merger of Vets First Choice and Henry Schein Animal Health, Covetrus is bringing together products, services, and technology into a single platform that connects our customers to the solutions and insights they need to work best. Our passion for the well-being of animals and those who care for them drives us to advance the world of veterinary medicine. Covetrus is headquartered in Portland, Maine (USA), with more than 5,000 employees, serving over 100,000 customers around the globe.

Within the United Kingdom, Covetrus primarily supplies goods and services through a wholly-owned subsidiary called AH UK Animal Health (PVT) Ltd. (“Covetrus UK”).

Our Policies
Covetrus takes the issues of slavery and human trafficking very seriously and is committed to maintaining the highest level of integrity, ethical standards, and legal principles in every aspect of its business.

Code of Business Conduct and Ethics
The Company’s Code of Business Conduct and Ethics (“Code”) requires all employees, executive officers, directors and other third parties acting on its behalf (each, a “Company Party”) to comply with the laws, rules and regulations of the cities, states and countries in which the Company operates, including the United Kingdom. Each Company Party is responsible for abiding by the regulations and policies governing his or her conduct and that of the Company in the countries in which he or she is doing business.

The Code also reaffirms the Company’s commitment to equal employment opportunities for its employees, to providing a workplace that is free from discrimination and harassment, and to maintaining a workplace that is safe and healthy.

Supplier Code of Conduct
Covetrus UK originally adopted the legacy Henry Schein Group Global Supplier Code of Conduct in 2016, which was replaced post-merger by the Covetrus Global Supplier Code of Conduct (collectively, “Supplier Code”). The Supplier Code sets out the Company’s expectations of suppliers in relation to human rights. It requires suppliers to ensure they provide an environment where employment decisions are based on free choice and do not involve forced or prison labour, physical punishment or threats of violence or other forms of physical, sexual, psychological or verbal abuse as a method of discipline or control. The Supplier Code also prohibits child labour and demands adherence to the minimum employment age limit as defined by applicable laws.

Reporting Mechanisms
Company Parties are encouraged to report any known or suspected violations of law, regulation, or policy to the Company’s General Counsel, Chair of the Audit Committee, or via the Company’s Ethics & Compliance Line (“Hotline”), as further described in the Code. The Hotline is operated by an independent third party, and is available worldwide 24 hours a day, 7 days of week, via telephone and the internet. Company Parties may report anonymously, where permitted by local law. All reports to the Hotline are treated confidentially to the extent possible. The Company has in place additional policies and procedures to protect whistle blowers, including a strong non-retaliation policy.

Supply Chains
Covetrus expects its suppliers to conduct their business in a lawful manner and in compliance with the highest standards of integrity and ethics.
Covetrus UK has over 500 active suppliers for animal healthcare products, many of which have long-standing relationships with the Company and therefore have clear expectations with regard to compliance and social
accountability. Furthermore, all new suppliers must confirm in writing their adherence to the Supplier Code, which forms an important part of the Company’s due diligence process.

Covetrus UK has provided all existing suppliers with a copy of the Supplier Code and is working to obtain written confirmation of their adherence to the principles set forth in the Supplier Code. Covetrus UK has conducted a risk review of existing suppliers based on SA8000 standards, which it plans to conduct periodically going forward.

The Code is publicly available on the Company’s website and is further made available to employees (both in English and other languages) on the Company’s intranet. Covetrus is currently rolling out electronic training on the Code to all employees globally.

Further Measures
Although the Company is not aware of any forced labour or child labour within our supply chain at this time, it is actively reviewing existing policies and procedures as part of the ongoing integration of Vets First Choice and Henry Schein Animal Health into Covetrus, and will update those policies and procedures, as appropriate, to reinforce the Company’s zero-tolerance for slavery and human trafficking.

This statement constitutes Covetrus UK’s slavery and human trafficking statement for the last financial year up through the time of the merger, and has been approved on 16 July 2019 by Jamie Tattersfield, Managing Director, AH UK Animal Health (PVT) Ltd.

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