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Freshfields Sustainability

| 3 minutes read

ESG trends emerging from the UK’s new commitments to tackle AMR

Antimicrobial resistance (AMR) is a growing threat to public health, globally, with some studies linking it to as many as five million deaths annually. As such, there is no doubt that AMR is an important ESG focus for the life sciences sector (see our previous analysis on this topic here). 

In what is set to be an important year for international efforts to tackle AMR (for example, given its prominence at the UN High Level Meeting in September), the UK Government has recently set out some clear commitments. It has published its Second 5 year AMR National Action Plan for 2024 – 2029 (the Action Plan), which seeks to implement the UK’s 20 year vision for controlling AMR by 2040 and which forms an important component of the UK’s recently revised Biosecurity Strategy

The Action Plan sets out several commitments structured around four broad themes: (1) reducing the need for and unintentional exposure to antimicrobials; (2) optimising the use of antimicrobials; (3) innovation, supply and access; and (4) being a good global partner. 

Here, we draw out some of the key ESG trends relevant to the life sciences sector.

Market failures 

The Action Plan focuses on promoting R&D and overcoming historic market failures caused by high research costs and low returns. In this regard, the UK Government commits to a wider implementation of the world-first antimicrobial subscription model (in which the price paid for antimicrobials is de-linked from the volumes sold). This came on the same day as the Government released the positive results of its related consultation and published guidance for companies wishing to apply for the scheme. 

Pharmaceuticals in the environment 

The Action Plan contains several commitments designed to mitigate the effect of antimicrobial pharmaceuticals in the environment, including an emphasis on limiting the discharge of antimicrobial pharmaceuticals during the manufacturing process. The Action Plan supports the AMR Industry Alliance’s Antibiotic Manufacturing Standard published in June 2022 and the British Standards Institute’s (BSI) related antibiotic certification programme launched in June 2023. Through the programme, the BSI will provide recognised accreditations to antibiotic manufacturers who can demonstrate compliance with the antibiotic manufacturing standard. For pharmaceutical companies that outsource manufacturing of active ingredients, it is notable that the Action Plan commits to collaborate internationally to promote the development of these certification systems.

Equitable access to antimicrobials

An overarching theme of the Action Plan is “Being a good global partner”, with the UK committing to furthering this objective by supporting equitable access to antimicrobials. The plan acknowledges the need to ensure that individuals have access to antimicrobials regardless of their geographical location or socioeconomic status, and specifically notes the work of the Access to Medicine Foundation in creating an open-access AMR data register to facilitate research in low- and middle-income countries (LMICs) without government surveillance programmes. This will be of interest to pharmaceutical companies given the longstanding efforts of many to improve equitable access to medicine around the world.

Equitable access to antimicrobials is likely to be on the agenda for the upcoming UN High-Level Meeting on AMR in September 2024. In February 2024, the AMR Industry Alliance released a “call to action” in the fight against AMR specifically for this meeting. This was then followed by an Equitable and Responsible Access Roadmap. Both documents call on governments and the private sector to work together on strengthening data infrastructure in LMICs to improve surveillance of AMR, and call on the UN and member states improve access to antimicrobials in LMICs by removing market barriers and reforming procurement practices.

Health biases 

There is also a focus in the report on removing health inequalities and disparities. This comes as no surprise given the recent focus on this topic in the UK with, for example, the independent review into equity in medical devices publishing its report in March 2024 (see our analysis here), which found evidence of systemic bias in medical devices on the UK market. On antimicrobials specifically, the Action Plan urges better data on inequalities and commits to establishing mechanisms for annual reporting on infection incidence, AMR and antimicrobial use, including variation due to personal characteristics. This will feed into the creation of a toolkit for addressing health inequalities in order to help organisations develop suitable interventions.


  • The Action Plan is significant for the life sciences sector as it sets a five-year agenda for antimicrobial policy in the UK and, to a lesser extent, in international efforts through the UK’s advocacy.
  • Efforts to tackle AMR have the full support of the UK’s medicine regulator, the MHRA, which has also just announced a dedicated new team with the objective of providing regulatory scientific support for innovators seeking to create novel antimicrobials and diagnostics.
  • There has been a positive reaction from the UK industry with Richard Torbett, the Chief Executive of the Association of the British Pharmaceutical Industry (ABPI), remarking that “Expanding the pilot of the innovative antibiotic subscription model is a crucial next step with our industry's full support.
  • These policy developments are just one thread in the industry’s sustainability story, where progress is also being made to address other ESG challenges, including through regulatory change (for example with the EU’s proposed pharmaceutical reform).
The Action Plan is significant for the life sciences sector as it sets a five-year agenda for antimicrobial policy in the UK and, to a lesser extent, in international efforts through the UK’s advocacy.


environment, healthcare, life sciences, manufacturing