VIVUS strives to conduct our business with high ethical standards.  We expect our product suppliers to operate and adopt fair labor practices and in all cases to eliminate human trafficking, slavery, and illegal child labor in their workplace. 

Verification: As a manufacturer of pharmaceutical products, VIVUS operates in a highly regulated industry.  Our product suppliers are routinely audited by FDA and other regulatory agencies.  VIVUS has existing procedures for assessing our product suppliers (procurement procedure, supplier selection process, and quality procedures) and is in the process of enhancing these procedures to include steps for evaluating whether our product suppliers comply with applicable laws related to eradication of human trafficking, slavery and illegal child labor. Our Supply Chain and Quality Assurance teams oversee these verification procedures.

Audits: In compliance with our quality procedures and FDA regulations, VIVUS conducts periodic announced audits of our product suppliers to evaluate their compliance with VIVUS’ policies and applicable legal and regulatory requirements. Whenever possible, VIVUS conducts these audits using its own personnel, although it has engaged independent third-party auditors in the past and reserves the right to use third party auditors in the future as appropriate, based on the then current business resource landscape. As part of the VIVUS audit protocol, each audit includes review of the product supplier’s training, experience and qualifications, adherence to legal and regulatory requirements, and evaluation of the supplier’s compliance with its and VIVUS’ quality systems. VIVUS’ current quality audit program does not specifically address human trafficking, slavery or illegal child labor as part of the auditing procedures for product suppliers. VIVUS does not have any future plan to include fair labor practices in our quality audit program; however, VIVUS intends to address fair labor practices in our supply contracts and procurement policies.

Certification: VIVUS has not adopted procedures that require product suppliers to certify that materials incorporated into products comply with the laws regarding human trafficking, slavery and illegal child labor in applicable countries.  However, VIVUS is in the process of evaluating its procurement policies in this regard.

Accountability Standards: VIVUS is in the process of establishing internal accountability standards, procedures, and disciplinary actions for our employees and contractors in order to address and prevent any human trafficking, slavery and illegal child labor in its supply chain.

Training: VIVUS is in the process of evaluating the incorporation of training regarding human trafficking, slavery and illegal child labor to our annual quality system training programs for our employees and supply chain management.