Modern slavery act transparency statement

This Statement has been published in accordance with the UK Modern Slavery Act 2015 (the UK MSA 2015). It sets out the steps taken by Genesis Cancer Care UK Limited (“GenesisCare UK”) (registration number 05796994) and its subsidiaries in the UK whether in scope of the UK MSA 2015 or not. While not all of GenesisCare UK’s subsidiaries are considered to be reporting entities for the purposes of the UK MSA, we have adopted a “whole of business” approach to our modern slavery initiatives and voluntarily report on the activities of the GenesisCare UK subsidiaries on that basis.

GenesisCare UK’s Australian parent company also prepares an annual modern slavery statement in respect of its AU operations in accordance with the Modern Slavery Act 2018 (Cth) (“MSA”). GenesisCare publishes its modern slavery statement in respect of its Australian operations on its Australian website.

While we report separately to explain how we have addressed the respective reporting criteria under the Australian MSA and the UK MSA, our commitment to combatting modern slavery risks remains consistent across these jurisdictions.

At GenesisCare UK we recognise that risks of modern slavery are present throughout our value chain and in our operations. We understand that managing these risks requires collaboration with our suppliers, our workforce and other key stakeholders. Respecting human rights is one of our core values – integrity always. 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. We are continuing to develop and implement practices and processes that identify and mitigate the risk of our business and our external supply chains from being impacted or influenced by modern slavery.

GenesisCare UK is committed to preventing acts of modern slavery and human trafficking from occurring within its business and supply chains and imposes the same expectation on its suppliers. To this end, we undertake the following steps to ensure we comply with relevant UK legislation and to mitigate the risk of modern slavery and human trafficking in our supply chain, including:

• conducting due diligence on all our existing suppliers; to
• complying with our Modern Slavery Policy when executing our audit, monitoring, and reporting processes; and
• incorporating the key elements of our Modern Slavery Policy into our contractual approach in engaging new suppliers; and
• continuing to monitor and audit suppliers GenesisCare UK considers higher risk of having modern slavery or human trafficking present in their own supply chain, e.g., providers of single-use instruments, uniforms, PPE, cleaning contractors and other outsourced services.

In accordance with our values and our overarching commitment to acting ethically and with integrity in all our relationships, the prevention, detection and reporting of modern slavery and human trafficking is the responsibility of all those working for GenesisCare UK and any associated organisations.

GenesisCare UK is a UK-based business with 98% of our suppliers being U.K.-based where modern slavery and human trafficking is not classified as a high risk. However, the organisation takes this issue seriously operating a zero-tolerance approach.

The organisation, in its day-to-day business, operates to develop and implement practices and processes aimed at preventing the business and our supply chains from being impacted or influenced by modern slavery or human trafficking. We expect the same high standards of all our business partners, suppliers and contractors, and their own suppliers, wherever they are based.

Our procedures are designed to:

• established and assess areas of potential risk in our business and supply chains;
• monitor potential risk areas in our business and supply chains;
• reduce the risk of modern slavery and human trafficking occurring in our business and supply chains;and
• provide adequate protection for whistle-blowers

We are highly trained healthcare professionals, corporate and support staff with 16 treatment centres operating across the U.K. (including two subsidiary companies) designing and delivering innovative treatments and care for people with cancer.

We are a private limited company.

Our registered office address is Wilson House, Waterberry Drive, Waterlooville, Hampshire PO7 7XX.

Our financial year ends 30^th June.

GenesisCare is a global group of companies delivering treatment to people with cancer, one of the largest disease burdens globally. As a group, we are committed to leading the change in how care is given, including through participating in clinical trials. The global group employs or otherwise engages highly trained clinicians, healthcare professionals and support staff across Australia, UK, and Spain. That includes 38 locations in Australia, 16 in the UK and 21 in Spain, with more new centres under development. 

The GenesisCare Board is responsible for overseeing the performance and operation of the GenesisCare group. The Board and the Board’s sub-committees develop the group’s vision, values and governance framework and monitors the group’s culture and clinical and corporate risks.

Oversight and reporting regarding anti-slavery initiatives is provided by the Board’s Audit & Risk Committee and People & Culture Committee. Responsibility for the day-to-day implementation of the group’s vision and values is delegated to GenesisCare’s local Executive Leadership Team.

GenesisCare UK is the leading independent provider of outpatient cancer services in the U.K. Our purpose is to create care experiences that get the best possible life outcomes. We believe that care should be focused on the individual, not the condition, and are proud of our world-class patient satisfaction ratings.

Our five key values underpin everything we do:

1. Empathy for all

2. Partnership, Inside and Out

3. Innovation every day

4. Bravery to have a go

5. Integrity always

Our values embody a commitment to act ethically and with integrity in all our relationships; with our patients, our staff and with our suppliers.

GenesisCare’s values form the foundation of its policies and procedures, each of which seek to ensure that GenesisCare operates ethically and with integrity.

We operate a number of internal policies to ensure we are conducting business in an ethical and transparent manner. These include:

• Recruitment policies: We operate a robust set of recruitment policies, including undertaking eligibility to work in the UK checks for all directly employed staff, and agencies on approved frameworks provide assurance that pre-employment clearance has been obtained for agency staff, to safeguard against human trafficking or individuals being forced to work against their will;
• Equal opportunities: We have a range of controls to protect staff from poor treatment and/or exploitation, which comply with all respective laws and regulations. These include provisions for fair pay rates, fair terms and conditions of employment and access to training and development opportunities;
• Safeguarding policies: We adhere to principles inherent within both our safeguarding children and adults policies;
• Whistleblowing policy: All employees and contractors know that they can raise concerns about how colleagues or people receiving our services are treated, or about practices within our business or supply chain, without fear of reprisals;
• Terms of Business: These terms explain the manner in which we behave as an organisation and how we expect suppliers to act;
• GenesisCare UK has implemented an Anti-Slavery and Human Trafficking Policy with continuing efforts to update this policy. All staff, in whatever their role within the UK organisation, are required to comply with the UK corporate Anti-Slavery and Human Trafficking Policy which is reviewed and updated annually. This policy, first implemented in 2016, provides education on the subject, offers guidance on what to do if staff believe that any form of modern slavery is taking place within the business or supply chain, and how to manage any breach of the requirements of the policy. 

In the UK, our commercial teams receive modern slavery and human trafficking information and awareness training. Our compliance obligations are reflected in our employee induction and training materials.

In addition, in the UK our clinical staff and many other staff members in key roles, receive training in safeguarding which defines modern slavery and human trafficking as forms of abuse. Our Safeguarding Policies advise on how to recognise and report this abuse to relevant authorities and what channels to use.

GenesisCare UK introduced Freedom to Speak Up Guardians to its business model and training on our modern slavery obligations and the Modern Slavery Act was implemented for these individuals. Modern slavery training compliance is monitored and audited regularly.

As a global organisation, GenesisCare acquires a wide range of goods and services, covering products and services used in the provision of treatment to our patients and goods and services serving our corporate business needs. Multiple suppliers fulfil those needs, each of which has its own supply chain, resulting in a complex variety of end-to-end supply chains.

The key categories of goods and services procured by GenesisCare UK include: 

• medical equipment (including associated maintenance services) and medical consumables;
• corporate business products and technology, and professional services; and
• facilities management services, cleaning services and linen supply services.

Our suppliers range in size from those with a global footprint to local suppliers servicing local need. In all cases GenesisCare UK seeks to partner with suppliers that align with our values and commitments to mitigating the risks of modern slavery.

In order to ensure that supplier organisations comply with our own standards and values, we have put in place and will continue to develop a number of measures to assess and manage supply chain risk.  These include undertaking due diligence on our key suppliers, mandating key standards and expectations during procurement exercises, the use of mandatory compliance terms in our supply contracts, and the requirement to adhere to the organisation’s Anti-Slavery and Human Trafficking Policy. Our focus is identifying higher risk suppliers by category of product and services offered and/or the location of their operations.

We recognise that modern slavery risks can arise both internally within our organisation and within our external supply chains.

The majority of our suppliers are based in countries where modern slavery is not classified as high risk based on geography. However, for the few that do operate in a higher risk jurisdiction, there is an inherent increased risk that modern slavery may be present in the extended external supply chain. Our standard contractual clauses and supplier terms and conditions contain modern slavery provisions. Examples are:

• Warranties from the third-party supplier in respect of its business operations and activities
• Requirement that the supplier undertakes investigations into the activities of its own suppliers; and
•  Reporting and notification requirements in relation to modern slavery risks and incidents that become known to the supplier during the course of their engagement with GenesisCare.

We are not currently aware of any realised material issues relating to modern slavery risks or practices impacting a supplier engaged by GenesisCare UK. If such an issue were to arise, we would assess alternative suppliers and either (depending on the circumstances and nature of the non-compliance) immediately cease dealings with the supplier, or work with that supplier to obtain appropriate assurances before determining whether it is acceptable to continue working with them.

Internally, GenesisCare UK has implemented and continues to develop systems and processes to manage the raising of grievances and whistleblowing which allow us to identify and mitigate potential risks of modern slavery. Given the level of control we exercise over our day-to-day operations and the increasing maturity of our internal policies and procedures, we consider that our internal risk of modern slavery is relatively low.

The majority of GenesisCare UK staff are engaged directly by a GenesisCare entity, which also reduces the risk of modern slavery within our workforce. As such, our focus remains on identifying and addressing any material risks of modern slavery which may exist in our external supply chains.

1. Refining the Due Diligence Process: GenesisCare UK will continue to develop its supplier due diligence process to ensure that it is current and effective. This will include developing and reviewing the content of modern slavery questionnaires for suppliers and staying abreast of best practice within the industry. We will expand the due diligence undertaken in respect of existing suppliers with a focus on strategically important suppliers and those that are considered to operate within a higher risk category having regard to the sector or geography in which they operate.

2. Training Our People and Increased Employee Engagement: GenesisCare UK will seek to ensure modern slavery training delivered to all existing employees and all new employees joining the organisation is up-to-date. GenesisCare UK will seek to provide meaningful and practical modern slavery training to the Procurement team and provide the participants with an understanding of modern slavery including: what modern slavery is, categories and countries where we may have risks, an outline of why managing modern slavery risks is important, an overview of our approach and clear actions that can be taken, in order to ensure that participants understand how the risk management approach applies to their everyday roles. 

3. Standard Contract Clauses: GenesisCare UK will seek to update its standard contractual clauses and supplier terms and conditions in respect of modern slavery to reflect the latest developments and regulation relating to modern slavery.

4. Update Policies and Procedures: In 2023, we intend to release a revised procurement policy to align our expectations and management of modern slavery risks in our supply chains and to ensure compliance with relevant regulation, including the modern slavery legislation. The policy will:

• Outline GenesisCare’s position in relation to business conduct risks including human rights, bribery and corruption, corporate fraud, money laundering, trade sanctions or denied party transactions; and
• Provide the framework for identifying potential risks of engaging, renewing or extending a supplier relationship

5. Contract Governance Tool: GenesisCare UK plans to engage a procurement specialist to assist in our management of contracts and associated risks. 

6. Modern Slavery Working Group: GenesisCare UK intends to implement an internal Modern Slavery Working Group to formally include representation from key teams to ensure there is appropriate input received from all key stakeholders across the business. GenesisCare UK also intends to formalise the Working Group’s terms of reference, objectives and reporting commitments to senior management.

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.

All new or updated supply contracts continue to include mandatory anti-slavery compliance terms and all construction projects incorporate adherence to the GenesisCare UK Anti-Slavery and Human Trafficking Policy as a term of the contract awarded.

We recognise the importance of monitoring and assessing the effectiveness of the measures we are implementing to manage and mitigate the risk of modern slavery in our business operations.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 for the financial year ending June 2023. The Board of Genesis Cancer Care UK Limited has approved this statement.

Signed

Justin Hely
General Manager – United Kingdom
On behalf of the Board of Directors of Genesis Cancer Care UK Limited July 2023
Date of signing of statement: 12^th December 2023