Anti-Slavery Statement

Introduction from Frank Millar, Chief Executive Officer

This statement is made in accordance with section 54(1) of the Modern Slavery Act 2015 and constitutes CPI group’s slavery and human trafficking statement for the financial year ending 31 March 2025. 

Centre for Process Innovation Limited (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. It is structured in line with the Home Office’s statutory guidance as updated at July 2025 and covers the following six key areas:

1. Organisation structure and supply chains;
2. Policies in relation to slavery and human trafficking;
3. Assessing and managing risk;
4. Due diligence;
5. Training; and
6. Monitoring and evaluation.

1. Organisation structure and supply chains

Our business structure

CPI is a UK based technology innovation centre and a member 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. CPl’s head office is in England. The Group has over 600 employees and operates within the United Kingdom. CPI operates as a ​‘social enterprise’ and undertakes triple bottom line reporting.

Our business

CPI operates across two core sectors, Healthcare and Materials and is organised in to 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 of England 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.

In November 2024, CPI collaborated with the National Chemistry Laboratory in Pune, India to create a ​‘living lab’ and is in the early stages of engaging in further exploratory activities with the intention to extend its activities in India. 

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. As CPI is government funded, we are a contracting authority for the purpose of the Procurement Act 2023. This means that we are required to procure the majority of our goods and services through a regulated process. The breadth of our activities mean that we require a relatively large and complex supply chain.

We have zero tolerance to slavery and human trafficking within our supply chains. 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 Procurement Act 2023 and bidders are required to self-declare compliance with the Modern Slavery Act 2015.

2. Our policies and processes in relation to modern 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.

We have a clear chain of accountability for the prevention of modern slavery where the overall responsibility falls to our Board of Directors, whilst day to day activity is the responsibility of our Executive Leadership Team. All of our employees are trained on identifying modern slavery and are required to raise any concerns to either their line manager or CPI’s designated Modern Slavery Officer. Any concerns regarding modern slavery are reported to the Modern Slavery Officer and a full investigation conducted promptly. 

We have several policies and procedures to demonstrate our zero tolerance to modern slavery and human trafficking:

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 and whistleblowing policies which are easily accessible to staff and are reviewed on a regular basis. 

Our procurement policy sets out how we undertake procurement activity and how we ensure sustainable procurement and responsible purchasing practices. 

CPI is also committed to fair recruitment and payment practices for our employees and implements a recruitment and selection policy and a reward and recognition policy to ensure that all employees have the appropriate right to work and receive payment at least equivalent to the ​‘real living wage’ and never fall below minimum wage. 

All of our policies are reviewed regularly and updated where necessary to reflect best practice and continuous improvement.

3. Assessing and managing risk for modern slavery and human trafficking

CPI evaluates the nature and extent of exposure to and risk of modern slavery and human trafficking occurring in its business and supply chains on a regular basis using self-assessment tools. We manage this risk by integrating it into our broader risk management framework which is prepared by the Executive and presented to the Board on a quarterly basis.

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 and reviewed on a regular basis;
• Ensured that all employees understand the concept of modern slavery, the risks associated with it and how to report it as part of their mandatory standard risk and compliance training;
• 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;
• Ensured the Group’s standard 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; and
• Ensured our procurement process allows for the responsible exit from contracts where modern slavery is identified as a risk.

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.

We have joined the UN Global Compact which, amongst other things, provides 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.

We have also obtained Ecovadis accreditation, building on our ability to benchmark our activities and to help understand the sustainability of our supply chain which extends to anti-slavery. 

4. Due diligence

The due diligence undertaken by CPI primarily focuses on our critical suppliers on which we rely to deliver our business operations.

Our due diligence is based on selecting appropriate suppliers through our procurement processes and the use of external standards including, but not limited to, Ecovadis accreditation. 

Suppliers contracted under the Procurement Act 2023 are subject to a formal selection process to vet them and their products to ensure that they are suitable to meet our needs. The evaluation considers the capability and capacity of organisations to supply what we require and includes an assessment of, amongst other things, their supply chain practices and adherence to modern slavery legislation. 

Our priority is to contract with responsible and sustainable suppliers. 

5. 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 every new employee upon joining the business and also require all employees to undertake bi-annual mandatory regular training on modern slavery and human trafficking by an accredited external provider. Employees are also required to undertake regular an internally developed, mandatory training on Whistleblowing. Training is reviewed by the Modern Slavery Officer on a bi-annual basis and updated as appropriate. 

6. Monitoring and Evaluation

We continue to review the risks of modern slavery and human trafficking at our Risk Register Review meetings and report progress to the Group’s Executive Leadership Team and the Board. A specific Risk Assessment for Modern Slavery will also be introduced.

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.

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

The following key performance indicators will be put in place over the next financial year to assist in the monitoring and evaluation of our actions taken in regards to Modern Slavery:

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 31 March 2025 and has been and approved and endorsed by CPl’s Board of Directors on 1 October 2025.