Modern Slavery Statement

At Eucalyptus, we believe everyone deserves access to better healthcare, whether you’re in a city, regional town or the other side of the world. As part of this mission, we strive to create a safe working environment for all of our staff and to work with suppliers that demonstrate a similar commitment to the prevention of modern slavery in supply chains globally.

Eucalyptus does not condone any form of modern slavery in our operations. We recognise that addressing modern slavery does not only mean the prevention of the exploitation of our direct employees, but also addressing the potential risk to our extended workforce and those of our suppliers in providing the products and services that we procure for our business operations. This statement serves to outline the modern slavery risks we have identified within our business operations and supply chain in the region, and the initiatives we are seeking or otherwise planning to implement in order to minimise such risks.

This Statement is published by Eucalyptus Management Pty Ltd ABN 54 631 013 860 (“Euc”) in accordance with section 54 of the Modern Slavery Act 2015 (“the Act”) and the Modern Slavery Act 2015 (Transparency in Supply Chains) Regulations 2015. For the purposes of this Statement, Eucalyptus Group or Eucalyptus refers to Euc and its wholly owned and controlled subsidiaries, including Fill Function UK Limited company number 13739688 (“Fill Function UK”) and Juniper Technologies UK Limited company number 13901454 (“Juniper UK”).

This Statement and its findings was approved by the Board of the Eucalyptus Group on 21 December 2023 for the purposes of the Act with respect to the financial year ending 30 June 2023 (“Financial Year”).

Tim Doyle
EUC Management Pty Ltd

Organisation structure and supply chain

Eucalyptus and its organisation structure

Eucalyptus has operated in Australia since 2019, the UK since 2022 and Germany since 2023.  We employ over 350 people across our operations, each of whom proudly delivers on our “high touch, high quality” mission. Eucalyptus has serviced over 1 million people through practitioner consultations as at the date of this Statement. Entities in the Eucalyptus Group are incorporated in Australia, the UK (being Fill Function UK and Juniper UK) and the Netherlands.  

Eucalyptus operates four health brands in Australia, however only its Juniper brand operates in the UK. Juniper uses scientifically proven GLP-1 medications alongside ongoing health coaching, health tracking, clinical consultations and a dedicated support team to deliver a new and highly effective method of  weight management. 

Juniper UK is the operating entity of the Juniper brand in the UK.  Fill Function UK is a services company supporting the Juniper brand in the UK, which manages labour hire, the operations of our pharmacy in Birmingham including procurement of medications for delivery to patients in the UK, and commercial contracting on matters including pharmacy, space and packaging. Fill Function UK employs approximately 40 employees in the UK.

Supply chain

The key supply component of our UK operations is the procurement and delivery of GLP-1 prescription medications and related goods (including packaging, sharp bins and needles) to patients from our Birmingham pharmacy. Fill Function UK procures these goods from third party suppliers. 

Fill Function UK’s direct suppliers of medications and other key goods are all located in the UK. The manufacturer of medications is located in Denmark. In some cases there are additional wholesalers and suppliers within the supply chain process that operate within the EU to repackage, procure and/or import medications into the UK.

Risk Assessment and Management

In assessing the modern slavery risks across our UK business in the Financial Year, we have focused on (A) risk to internal staff and (B) risks through external supply chain. We have also considered the key risk indicators identified in the International Labour Organisation’s report on modern slavery1.

1This report considers sectors in which modern slavery has been found to take place, including high-risk industries and work practices. According to the report, services (excluding domestic work) and manufacturing sectors account for two largest shares of adult forced labour exploitation. Global Estimates of Modern Slavery: Forced Labour and Forced Marriage Report 2022. International Labour Organisation:

Internal Staff

Our UK staff are employed by Fill Function UK and work across two key locations - our corporate office in London and our pharmacy & warehouse in Birmingham. Across all our workplaces, we understand the importance of implementing clear policies and operating procedures for employees to follow so they can identify modern slavery risk during their employment.

i. Risks 

We appreciate that a failure to educate employees on such procedures and policies, and/or empower them to utilise such policies and procedures without fear of adverse consequences, can result in inconsistency in supplier engagements and failure to escalate identified modern slavery risks, resulting in an inability for the business to assess and manage such risks.

ii. Policies

Below is a summary of Eucalyptus policies that operate to manage risks in our business, including modern slavery:

Code of Conduct

  • Outlines the behaviour expected out of employees and all associated with the business. 
  • Applies to all employees of the Eucalyptus Group. Eucalyptus expects members of its extended workforce (temps, vendors, and independent contractors) and others who may be temporarily assigned to perform work or services for the Eucalyptus Group to follow the Code in connection with their work for the business. Failure to do so can result in disciplinary action, including termination of employment.
  • Describes the Eucalyptus Group’s core values and practices as including equal opportunity employment, prohibition on harassment, discrimination & bullying, safety & healthy workplace, and obeying the law, all of which are relevant for mitigating modern slavery risks within a business.

Whistle Blower Policy

  • Describes Eucalyptus Group’s commitment to ensuring regulatory compliance and promoting ethical work culture by observing the highest standards of fair dealing, honesty and integrity in our business activities and amongst our people.
  • Encourages the reporting of any instances of suspected unethical, illegal, corrupt, fraudulent or undesirable conduct involving the business and provides protections and measures to individuals who make a disclosure in relation to such conduct without fear of victimisation or reprisal. 
  • Provides a mechanism for employees to safely report modern slavery concerns. We have not received any reports to date relating to modern slavery risks in our business or supply chain. We understand that this doesn’t mean that modern slavery issues don’t exist.

Prevention of Sexual Harassment Policy

  • Commits to providing a safe environment for employees, free from discrimination on any ground and from harassment at work (whether within company premises or outdoors), including sexual harassment.
  • Seeks to protect employees against sexual exploitation, a core manifestation of modern slavery.

Grievance Policy

  • Commits to maintaining a workplace that encourages collaboration, trust, cooperation and communication, and where all behaviours are consistent with contributing to an environment that is harmonious, where all people are treated with dignity and respect.
  • Provides a process for reporting bullying, harassment, discrimination, health & safety issues among other concerns.

Health & Safety Risk Assessment & Action Plan 

  • Applicable to Fill Function UK employees operating out of the Birmingham pharmacy or warehouse. 
  • Ensures safety for staff operating in the Birmingham pharmacy and warehouse. It incorporates guidance on safe warehousing and storage processes in compliance with the Health and Safety Executive government agency standards. 
  • Seeks to protect employees against unsafe working conditions and forced labour.

iii. Training

Eucalyptus also provides education and training materials as part of the onboarding process for new employees. New employees are required to review the policies set out above to ensure they are familiar with their obligations including with respect to modern slavery.

On 18 October 2023, recognised as Anti - Slavery Day across the UK, Fill Function shared educational materials with its employees to raise awareness of modern slavery practices and highlight the organisation’s commitment to generating this Statement.

External supply chain

i. Risks 

Fill Function UK’s top suppliers of medications and related goods, such as Alliance Healthcare, are reputable companies that have a demonstrated interest in protecting against modern slavery, evidenced for example through modern slavery statements on their websites. We consider the modern slavery risks of contracting with these top suppliers to be low. However, Fill Function UK does not have full visibility over the practices of intermediaries in the supply chain process that operate within the EU.

Additionally, due to a global shortage of GLP-1 medications, Fill Function UK is required to seek alternative sources of medication from a broader range of suppliers, and has less negotiating power with suppliers regarding their supply chain processes. This environment creates less visibility over supply chain processes, and therefore heightened risk of modern slavery in the supply chain of GLP-1s. Workers that may be at higher risk of modern slavery may include those at pharmacies, distribution centres, transport companies and manufacturing facilities. 

ii. Due diligence controls 

Fill Function UK has introduced more robust diligence processes for assessing our suppliers, including reviewing their licences and financial position, acquiring customer references, undertaking site visits, reviewing contract terms for modern slavery obligations and conducting test orders. These processes are designed to assess the legitimacy and professionalism of the supplier, and increase our comfort that we are engaging with reputable partners that are less likely to engage in modern slavery practices or partner with organisations that do so.

Key performance indicators that measure effectiveness of approach 

In this Financial Year, we did not become aware of any incidents or concerns relating to modern slavery or forced labour. 

  • No reports were made under the Whistleblower or Grievence policies with respect to modern slavery and/or human trafficking.
  • No remedial actions were required in the last 12 months.

We are committed to further developing our modern slavery governance to improve identification and mitigation of these risks as our business matures. This may include:

  • Ongoing monitoring on a risk-based approach as part of the further development of our processes.
  • Building on our existing work to gauge effectiveness of our policies, processes and controls.
  • Remedial action if any issues are identified. 
  • Continuing to monitor modern slavery legislative developments and prepare for anticipated amendments to the Act.