Modern Slavery Statement

Oncologica UK Limited – Modern Slavery Statement – 2022

Introduction

This Modern Slavery Statement relates to actions and activities during the financial years 01/11/2020 – 31/12/2021 and ongoing financial year 01/01/22 to 01/31/22.

The statement sets down Oncologica UK Limited (“Oncologica”) commitment to preventing slavery and human trafficking in our business activities and the steps we have put in place with the aim of ensuring that there is no slavery or human trafficking in our own business and supply chains. We all have a duty to be alert to risks, however small. Staff are expected to report their concerns and management to act upon them. We understand our responsibilities and are committed to improving our practices to combat slavery and human trafficking.

Our Business

Oncologica UK Limited (“Oncologica” or ”the Company”) is a leading precision medicine and Covid-19 genomics laboratory providing clinical testing and contract research services based in the Chesterford Research Park, Cambridge, UK.

The Company, formed in 2014, was one of the first clinically approved laboratories in Europe to harness the power of genomic profiling to deliver personalised cancer medicine.

In addition, Oncologica functions as a Contract Research Organisation (CRO) to support biomarker and drug development programmes. Our proven portfolio of comprehensive genomic profiling and tumour based assays are used to support theranostic programmes at all stages of the cancer development, from discovery through preclinical development to clinical trials.

The Company runs its own in-house R&D programmes focusing on the development of novel diagnostic and therapeutic intervention strategies to improve the clinical management of patients with advanced cancer.

The Company also provides COVID-19 testing services and viral sequencing.

Since the start of the pandemic, Oncologica has been contracted by the DHSC/UKHSA to provide high volume Covid-19 PCR testing and sequencing as part of the UK National Testing Programme and delivered up to 40k tests per day representing the largest surge laboratory in the UK.

Organisation’s structure

As an organization Oncologica is committed to meeting high ethical standards and observing all applicable local, national and international laws wherever we do business. The group HR function is centrally controlled and managed with appropriate controls and policies to safeguard the rights and welfare of employees and allow them to safely report any abuses. Policies include:

Anti- Bribery

Bullying and Harassment

Grievance

Slavery and Human Trafficking


Oncologica complies fully with employment law applicable across the United Kingdom. The right for migrant workers to lawfully live and work in the UK is closely scrutinised as part of our UK recruitment process. We work closely with and are compliant to all regulations set out by UK Visas and Immigration. For all operations, adherence to and compliance with local employment law and migration issues is closely supervised throughout the recruitment processes.

Oncologica also have systems and controls for managing the quality, efficiency and proficiency processes within its supply chain under its Quality Management System (QMS).

Oncologica has zero tolerance to slavery and human trafficking. The Company undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The Company’s due diligence process includes building long-standing relationships with suppliers and making clear our expectations of business partners and evaluating the modern slavery and human trafficking risks of each new supplier and invoking sanctions against suppliers that fail to improve their performance in line with an action plan provided by us, including the termination of the business relationship.

To ensure all those in our supply chain and contractors comply with our values the Company, we impose contractual obligations on our Suppliers so that they are required to warrant that their business and, to the best of their knowledge, their own supply chain do not use forced labour

Oncologica’s supply chain partner Agreements incorporate anti-slavery and human trafficking terms as part of its agreements and contractual processes. Contracts also include obligations to comply with all applicable local, national and international laws, including new legislation introduced during the term of the contract.

We do not believe that Oncologica’s operations or supply chain carry a high risk of modern salary or that they are causing modern slavery practices. Oncologica screens suppliers under the due diligence process for risks and supplier identified as potentially high risk will undergo further assessment.

We use the following key performance indicators (KPIs) to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains:


- Completion of audits by the Procurement and Commercial managers

- Use of staff monitoring and payroll systems; and

- Level of communication and personal contact with next link in the supply chain and their understanding of, and compliance with, our expectations.

Our policies on slavery and human trafficking

Oncologica have appropriate policies in place that underpin the Company’s commitment to ensure that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Oncologica continuously review and update all our policies.

Oncologica’s Anti-slavery Policy reflects the Company’s commitment to acting ethically and with integrity in all of Oncologica’s relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in the Company’s supply chains.

Oncologica also has the Code of Conduct in pace that sets down the actions and behaviour expected of employees when representing the Company and Whistleblowing policy the Company encourages all its workers, customers and other business partners to report any concerns related to its direct activities or its supply chains.

Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to our staff. Oncologica staff engage in training upon induction into the company, and ongoing training is part of staff development. On the first day of induction training, a new member of staff learns of the company’s zero tolerance approach to Modern Slavery per our HR policy. Information regarding the company’s commitment to raising awareness of Modern Slavery and Human Trafficking is further provided in the Company Handbook, provided to all employees. Oncologica will continue to monitor and review this policy in light of any changes to legislation. This slavery and human trafficking statement is available to all staff via the intranet.

Conclusion

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Oncologica’s slavery and human trafficking statement for the financial years ending 2021 and 2022.

It was approved by the Board on 31st March 2022

Kitty Williams
Commercial Director

28th March 2022