Modern slavery act transparency statement

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 (the Act) and sets out the steps taken by Genesis Cancer Care UK Limited (“GenesisCare UK”) and its relevant UK group companies, in preventing modern slavery and human trafficking in its business and supply chains. This statement covers GenesisCare UK’s financial year from 1 July 2023 to 30 June 2024 (“the Reporting Period”).

GenesisCare UK is standalone business delivering treatment to people with cancer, one of the largest disease burdens globally. We are committed to leading the change in how care is given, including through participating in clinical trials. We employ or otherwise engage highly trained clinicians, healthcare professionals and support staff.

We operate 14 treatment centres across the U.K. with more new centres under development. During 2023-24 and working in close partnership with experienced consultants, our centres delivered personalised care for over 14,250 patients across all of our operations.

GenesisCare UK is a private limited company and its registered office is at Wilson House, Waterberry Drive, Waterlooville, Hampshire PO7 7XX.

In the UK, GenesisCare UK relies on domestic and global supply chains to support our various activities.

We buy a wide range of goods and services, from diagnostic and radiotherapy instruments, medical consumables and medicines, through to laundry, clothing and waste disposal. Some of these products and services are used in the provision of healthcare to patients, whilst others will be used in day-today business operations, such as office supplies.

The main categories of our procurement spend are set out in the table below:

Overall, GenesisCare UK spent ~£70M on supplies during the Reporting Period, from ~1,000 different suppliers. However, in practice, our spend is relatively concentrated, with ~75% of our total being with our top 50 direct suppliers, all of whom are UK based. Whilst we, therefore, maintain good visibility and oversight of our tier one suppliers, we currently have limited visibility at tier-two level and below.

Respecting human rights is one of our core values – Caring for Everyone.

At GenesisCare UK we recognise that risks of modern slavery are present across global supply chain and that managing these risks requires collaboration with our suppliers, our workforce and other key stakeholders.    

We have committed to adopting a zero-tolerance approach to modern slavery both internally and in relation to the third-party suppliers with whom we engage.

Our Policies define our minimum requirements and expectations to ensure compliance with all applicable laws and regulations as well as effective risk management. They are located in our quality management platform, RADAR, and their principles are communicated to our people through employee inductions, online learning and briefings via our internal communications channels. Every Policy is subject to regular review as part of a rolling review cycle to ensure they comply with legal and regulatory requirements and align with our strategy.

Our Policies

Our Policies include the following:

• Code of Ethics and Conduct – which describes the high standards of conduct and ethics that are expected from all staff and which demonstrated our commitment to being a responsible business.  
• Anti-Slavery and Human Rights Policy – which explains GenesisCare’s approach to modern slavery and sets out what our staff should do they you believe that any form of modern slavery is taking place within our business or supply chain. This policy applies to all individuals working for GenesisCare in any form, including employees, agency workers, volunteers and contractors.
• Freedom to Speak Up Policy – Freedom to Speak Up - this is our whistleblowing service and can be used by anyone who has a concern about anything that may be harming our business or be inconsistent with our values. It ensures people can raise genuine concerns about wrongdoing, misconduct or risk of harm in confidence and anonymously, if preferred. We take concerns seriously and the people who raise them can be confident that they’ll be heard, protected from retaliation and supported. Every report is subject to appropriate action.
• Recruitment and Screening Policy - this policy provides guidance for the recruitment and selection of employees within GenesisCare UK, ensuring consistency, fairness, and compliance with legal obligations. It promotes equal opportunities and diversity, supporting the career development of current staff and ensuring that recruitment standards are free from discrimination or bias.

Training

At GenesisCare UK, all of our staff receive modern slavery and human trafficking information and awareness training. Our compliance obligations are reflected in our employee induction and training materials.

In addition, all clinical staff (and some relevant non-clinical teams) receive additional training in safeguarding which incorporates modern slavery and human trafficking as a form of abuse. Our Safeguarding Policies advise on how to recognise and report this abuse to relevant authorities and what channels to use.

Our Internal Operations

Within our workforce, we conduct a series of checks as part of our people screening and onboarding processes, including identity verification, seeking confirmation that individuals have the right to work in the UK, criminal record checks and, where appropriate, adverse financial screening checks. Our People & Culture team reviews, and takes the necessary steps to resolve, any adverse findings arising from pre-employment screening checks.   

Our Supply Chain

Prospective suppliers are subject to a segmentation process that assesses their level of risk by reference to a number of criteria, including country or region of operation and the nature of the product/service being supplied.     

Based on the profile of GenesisCare’s procurement spend and supplier base, we believe that the risk of modern slavery within our direct supply chain is very low. We are committed, however, to strengthening our controls, and will introduce the following additional measures in the 2025 financial year:

• Additional due diligence requirements for relevant suppliers to ensure that they are driving compliance through their own supply chains, assessing compliance with the UK Modern Slavery Act 2015 (where applicable), affirm whistleblowing mechanisms are in place and assure compliance with legal requirements relating to right to work, payment of the National Minimum Wage or equivalent, and age.
• Developing a GenesisCare Supplier Code of Conduct which sets out the minimum standards of business conduct that we expect from our direct suppliers and those within their supply chains, including complying with all applicable laws and regulations, conducting themselves to the highest ethical standards, meeting relevant Genesis Care standards and respecting all internationally proclaimed human rights, including the prevention of modern slavery, forced labour, human trafficking and child labour.
• Incorporating the key elements of our Modern Slavery Policy into our contractual approach in engaging new suppliers.

In order to assess the effectiveness of the measures taken by GenesisCare UK we will continue to review the following key performance indicators over the next year:

1. The number of high risk category suppliers identified through our due diligence.

2. The number of suppliers responding with positive responses to our due diligence questions and confirming that they have had no incidents of modern slavery (both as a real number and as a percentage of those suppliers requested to provide such confirmation).

3. The number of GenesisCare UK employees trained on modern slavery and human trafficking.

4. The number of reports of Modern Slavery and remedial actions taken as a result.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 for the financial year ending June 2024.

The Board of Genesis Cancer Care UK Limited has approved this statement.

Signed

Justin Hely
General Manager – United Kingdom