Modern Slavery Act

Introduction from Frank Millar, Chief Executive Officer

Centre for Process Innovation (CPI) understands that modern slavery and human trafficking are growing concerns, and risk is present in every country, whether industrialised, developed or in transition. CPI has a zero-tolerance approach to modern slavery and human trafficking of any kind, and we continue to work to prevent modern slavery or human trafficking in our operations and supply chains. We understand the importance of being aware of potential risks, however small they may be, in our business.

This statement sets out the steps CPI has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chains and relates to actions and activities during the financial year 1 April 2023 to 31 March 2024.

Our business structure

CPI is a UK based technology innovation centre and the process arm of the High Value Manufacturing Catapult. Established to support the UK process manufacturing industry, CPI collaborates with universities, SMEs and large corporates to help overcome innovation challenges and develop next generation products and processes. Operating across a broad range of technologies, we support our partners at every step of the way; from concept to market; business support to technology development; from scale-up to supply chain intervention. CPI is part of the CPI group of companies (Group), and the ultimate parent company is Centre for Process Innovation Limited. CPl’s head office is in England. The Group has over 600 employees and operates within the United Kingdom.

Our business

CPI operates across two core sectors, Healthcare and Materials and is organised into 5 technology teams: Biologics, Formulation, Photonics and Electronics, Biotechnology and the Medicines Manufacturing Innovation Centre. These technology teams are situated across 5 different sites in the North East and Scotland, namely Darlington, Sedgefield, Wilton, Newton Aycliffe and Glasgow. Our activities mostly take place within the United Kingdom, although we do carry out some services within the United Kingdom for international clients.

Our supply chains

Our operations and procurement activities take place within the United Kingdom and our contractors and suppliers are predominately UK and EU based.

We have zero tolerance to slavery and human trafficking. To ensure that our contractors and all those in our supply chains comply with our values, we include a provision within our standard tender documentation to incorporate the discretionary exclusion of any bidder who has been convicted of an offence under section 1, 2 or 4 of the Modern Slavery Act 2015. In addition, all suppliers that accept our terms and conditions are required to comply with all applicable laws including the Modern Slavery Act 2015.

Where significant procurement activity is concerned, we set our expectations clearly during the tender process, which include a condition that our contractors comply with the Modern Slavery Act 2015 and are transparent, accountable and auditable. Furthermore, CPI acts in accordance with public tendering requirements and contractors’ completed tender questionnaires are therefore publicly available and auditable. 

Our policies on slavery and human trafficking

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Anti-slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls, to mitigate the risk of slavery or human trafficking taking place in our business or supply chains. The Group also maintains effective policies which underpin the principles of the Modern Slavery Act 2015 including Fraud and Bribery, Whistleblowing and Procurement Policies, all of which are easily accessible to staff and are reviewed on a regular basis.

Risk mitigation for slavery and human trafficking

CPI evaluates the nature and extent of exposure to and risk of modern slavery or human trafficking occurring in its business and supply chains. As part of our initiative to identify and mitigate risk of modern slavery or human trafficking occurring across our business or in our supply chains we have:

• Ensured that we operate a vigorous recruitment policy, including right to work in the UK checks, carried out by an external provider, preventing human trafficking or individuals being forced to work against their will;

• Ensured the requirements of the Modern Slavery Act 2015 are highlighted to all employees during induction and by way of a maintained Anti-slavery Policy, available via CPI’s quality management system, which is implemented by the Group’s appointed Modern Slavery Officer;

• Established a maintained Whistleblowing Policy available via CPI’s quality management system, which allows employees to raise concerns confidentially internally to CPI’s designated Whistleblowing Officer and provides recourse to an external party outside of CPI; and

• Ensured the Group’s standard commercial terms and conditions specifically require compliance with the Modern Slavery Act 2015, as opposed to compliance with applicable laws generally, ensuring that the issue is specifically drawn to our customers’ and suppliers’ attention.

In addition to the above procedures, which serve to mitigate the risk of slavery and human trafficking, we will:

• Identify and assess potential risk areas in our supply chains;

• Use supplier relationship management to assess other risks;

• Monitor potential risk areas in our supply chains; and

• Protect whistleblowers.

Training and awareness

To ensure a high level of understanding of the risks of modern slavery and human trafficking throughout our business and supply chains, we highlight the risks to our new employees upon joining the business, and also require all employees to undertake mandatory regular training on modern slavery and human trafficking by an accredited external provider. Employees are also required to undertake regular mandatory training on Whistleblowing.

Further Steps

We will continue to review the risks of modern slavery and human trafficking at our Risk Register Review meetings and will report progress to the Group’s Executive Leadership Team and the Board.

We will join the UN Global Compact which, amongst other things, will provide access to wider experience and benchmarking enabling the review of our current practices in areas such as Modern Slavery, Anti-corruption, and Supply Chain management, and to consider potential enhancements where appropriate.

To promote high standards of diligence in our supply chains, we will introduce a Supplier Code of Conduct requiring additional obligations on our suppliers in relation to modern slavery and human trafficking (amongst other things) which all relevant suppliers will be required to sign up to when supplying goods and services to CPI.

We also plan to introduce a ​‘Procurement App’ which will require a risk assessment (which includes Modern Slavery) to be undertaken on each relevant contract for the purchase of goods and services within the Group.

We will also look to join the Modern Slavery Registry to demonstrate our commitment to tackling the risk of modern slavery and human trafficking to our business and supply chains.

We will act promptly where an issue with compliance with this statement has been flagged or identified.

This statement, signed by Frank Millar, is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Group’s slavery and human trafficking statement for the financial year ending March 2024 and has been and approved and endorsed by CPl’s Board of Directors on 27 September 2024.