Modern Slavery Act (2022)

Introduction from Frank Millar, Chief Executive Officer

Centre for Process Innovation (CPI) understands that modern slavery and human trafficking are all growing concerns, and the 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 in our operations and supply chain. We should be alert to the potential risks, however, small they may be in our business.

This statement relates to actions and activities during the financial year 1 April 2021 to 31 March 2022.

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 is organised into 5 business units: Biologics, Formulation, Electronics, Biotechnology and the Medicines Manufacturing Innovation Centre. These business units 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 all those in our supply chain and contractors comply with our values we have in place a provision within our standard tender documentation to include 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 sign up to our terms and conditions are required to comply with all laws which extends to the Modern Slavery Act 2015.

For any significant procurement activity, during the tender process we set out our expectations that our contractors fully comply with the Modern Slavery Act 2015 and be transparent, accountable and auditable. Furthermore, as CPI follows the rules regarding public tendering, tender questionnaires completed by contractors are 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 ensure slavery and human trafficking is not taking place anywhere in our supply chains. The Group also maintains policies which underpin the principles of the Modern Slavery Act 2015 including Fraud, Bribery and Whistle-blowing 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 its exposure to the risk of modern slavery occurring in its supply chain. As part of our initiative to identify and mitigate risk of modern slavery occurring across our business and in our supply chains we have:

1. Ensured the requirements under the Modern Slavery Act 2015 are highlighted to all employees during the general legal induction.
2. Ensured the Group’s standard commercial terms and conditions specifically require compliance with Modern Slavery Act 2015, opposed to compliance with laws generally to ensure this matter is specifically drawn to our customers’ and suppliers’ attention.

In addition to the above procedures we have in place 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 if they become apparent;
• Build our management capacity on anti-slavery to assess and mitigate risk across the organisation; and
• Protect whistle-blowers.

Training and awareness

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we have highlighted the risk of modern slavery and human trafficking to our staff on joining the business, we have highlighted the risk of modern slavery and human trafficking to our staff through publications on our intranet as well as produced an Anti-Slavery Policy and wider suite of supporting policies. Our procurement team who directly deals with our supply chains have also been trained by an external provider in respect of the Modern Slavery Act 2015. The legal function continues to commit to undertaking all relevant training and awareness sessions.

Further Steps

We will secure an electronic training package on modern slavery that we will require all employees to complete during induction and as an annual refresher thereafter to ensure this matter remains a constant consideration of our people.

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

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 2022 and has been and approved and endorsed by CPl’s Board of Directors on 23 June 2022.