Slavery and Human Trafficking Statement

Financial Year end 31 March 2025

 

Introduction

This statement is made by Halcyon Topco Limited, Sciensus Pharma Services Limited and Sciensus Logistics Limited, which are all part of the Sciensus group of companies (the “Sciensus Group”) pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our modern slavery and human trafficking statement for the financial year ending 31 March 2025.

 

Our position:

We recognise that modern slavery and human trafficking are crimes and a violation of human rights. Modern slavery may take on various forms, including slavery, servitude, compulsory labour, and human trafficking for exploitation, and that any aspect can have a significant adverse impact on individuals, families, and communities across the world.

As a business we have a zero-tolerance approach to modern slavery and human trafficking in both our organisation and supply chain. We address this by ensuring that our staff are appropriately trained to identify issues and to raise any concerns; that we have policies and procedures in place for dealing with any issues arising; and that we have robust procurement processes which can identify potential risks in our supply network.

 

Our Background:

The Sciensus Group is a European life sciences services group supporting patients, health care providers and the pharmaceutical industry with medicines access, through digital tools, technology and market insight. Specialising in providing services for Chronic, Cancer, plus Rare & Speciality therapies for over 30 years we have proudly sat at the intersection of patients and their medicines, helping patients make the most of their medicine.

The Sciensus Group’s unique portfolio of services combines the scale and operational strength needed to reach patients across Europe with the hunian expertise that ensures treatments are delivered safely, effectively and with compassion. Our integrated hub of services includes digitally enabled, clinician-led care, patient support programmes and compliance, patient insight and analytics, pharmacy services, market access and reimbursement, clinical logistics, inventory management, business process outsourcing services, nurse supported medication, and aseptic compounding.

We partner with healthcare providers including the NHS, health insurers, life science companies and physicians to optimise the medicine and healthcare outcomes and experience for over 300,000 patients a year across the UK and Europe.

The Sciensus Group employs over 1,600 people including our specialist teams and support staff.

We maintain a governance and risk management framework with ongoing review of risk throughout the year. This process covers all our business areas and is reportable at Board level.

 

Our supply chains and how we are managing risk

The Sciensus Group operates in a highly regulated industry and given the nature of our business, we believe there is a low risk of slavery, human trafficking or child labour having a connection with our commercial activities. Many of our key suppliers are members of the Pharmaceutical Supply Chain Initiative (PSCI) and this body has established a set of principles to support suppliers in establishing sustainable, ethical, and responsible labour practices. Further details relating to the PSCI are available at https://pscinitiative.org/home.

We, however, recognise that there may be areas of our business where the risk of slavery is greater; for instance, business operations which are outsourced, for example, security and cleaning or where parts of our supply chain may involve workers in countries which have a low record of human rights or low paid staff. We use the Global Slavery Index, produced by the human rights group Walk Free which identifies countries with the highest prevalence of modern slavery to help us identify where there may be a risk of slavery in our supply chain. To our knowledge our supply chain does not includes countries classified as medium or high risk. The list of countries of concern is reviewed in respect of each tender process we undertake.

Although we consider the Sciensus Group has a low risk of direct involvement with modern slavery and human trafficking we continue to apply a risk and assurance-based approach to mitigate risks.

We recognise there could be a risk of slavery or child labour being part of our wider supply chain. All new suppliers are required to provide assurance around their ethical business practices, including confirmation of anti-bribery policies, anti-fraud and corruption policies, and confirmation that they have published their modern slavery statement, where relevant, including checking that relevant training for staff has been provided. We require all new suppliers to complete our supplier questionnaire form. Responses are checked by our trained team before we enter into any contracts. Non-compliance is escalated and we may either require further assurances or refuse to contract with a supplier.

For existing direct suppliers of medicines, we undertake monthly licence checks to ensure relevant licences continue to be held before submitting orders. The Medicines & Healthcare Products Regulatory Agency has stringent guidelines to be followed by suppliers of medicines and medical devices. If a supplier’s licence is revoked the issue is escalated to our Director of Pharmaceutical Governance and Compliance for further advice.

Our commercial team manage the contracts and relationships with our key pharmaceutical company supply chain partners. All new contracts include provisions which require adherence to ethical conduct principles including anti-slavery and human trafficking.

We have established safe recruitment practices in respect of our direct employees and where we use agency staff or consultants, we require confirmation from the agency of their recruitment arrangements including checking the right to work in the UK. All non-compliance is escalated.

 

Compliance, awareness and training

The Boards of the Sciensus Group companies and the Executive Leadership Team have overall responsibility to ensure that the Group maintains and is compliant with our legal and ethical obligations.

We have appointed an Executive Board Director as lead for Environmental Social and Governance matters within Sciensus and these matters are regularly reported at Board level.

All staff are required to complete Modern Slavery Awareness Training, together with other relevant training regarding our code of conduct and social responsibility including Safeguarding, Anti Bribery and Whistleblowing. The training includes guidance on what factors may raise concerns that a person is subject to a form of Modern Slavery and how to report issues. All training is by e-learning and requires participants to pass an assessment of their understanding of the training. Our training is reviewed to take account of any legislative or regulatory changes and is updated as necessary.

Completion of training and the required post training assessment is actively monitored. Any delay in undertaking training or non-compliance by an employee is referred to the relevant line managers for further action.

Our staff are also required to familiarise themselves annually with relevant policies which are available via our internal Document Management System. Policies are reviewed and updated bi-annually, or as required. Our current Policies and procedures include the following list:

 

Modern Slavery related policies and SOP:
  • Human Rights Policy (includes reference to Modern Slavery)
  • Whistleblowing Policy
  • Grievance Policy
  • Disciplinary Policy
  • Managing Violence and Aggressive Behaviour Policy
  • Recruitment and Selection Policy
  • Equality and Diversity Policy
  • Safeguarding Adults Policy
  • Safeguarding Children and Young People Policy
  • Code of Conduct for employees
  • Employment Checks Policy
  • Fit and Proper Persons Policy
  • Corporate Social Responsibility Policy
  • Supplier Code of Conduct
  • Supplier Questionnaire Form (for completion by all new suppliers)
  • SOP for the Approval of Suppliers (for use by Procurement staff)

At an operational level, line managers are responsible for engaging with their teams to implement and maintain the processes; and ensure that all colleagues have completed the appropriate training in accordance with the relevant policy and procedures.

 

The Sciensus Group operates an open culture and colleagues can report concerns to their line manager and/or other relevant personnel and are encouraged to use the independent whistleblowing help line. In the event that a whistleblowing concern is raised our process includes escalation to nominated senior managers for investigation and, where appropriate, reporting, concerns to the relevant Sciensus Boards.

 

2025-2026 and next steps

The Sciensus Group will continue to invest in its processes, procedures and awareness training for relevant staff to support its zero-tolerance approach to modern slavery, and ensure our approach remains proportionate to any identified risk.

We have been working to gain a better understanding of our suppliers and their supply chain and continue to use this information to classify all suppliers as either low, medium or high risk to support a targeted approach to reviewing our suppliers’ continued compliance.

Our procurement team has an ongoing objective to conduct Environmental Social and Governance Audits across our Direct Supply base to support the sustainability goals of Sciensus by improving the environmental, social and economic impact of procurement activity across third party expenditure. Part of this work includes validating that our direct suppliers and indirect suppliers are low risk on the basis that they have mature ESG policies in place covering the end-to-end supply chain which incorporates human trafficking prevention and Modern Slavery compliance.

We have introduced self-audit questionnaires for completion by our suppliers to confirm their compliance with modern slavery and human trafficking legislation, as well as other areas of business ethical compliance, and require copy statements and policies to be provided to us for review to verify the responses to the questionnaires.

Although we have not to date identified any of our suppliers as being at high risk of non- compliance, in the event that we do assess a supplier as being at high risk we have processes in place to review their compliance, identify any concerns, walk them through our Supplier Code of Conduct and carry out regular audits of their compliance. We continue to review our new existing contractual relationships and develop opportunities for ongoing monitoring and review.

 

Conclusion

As an organisation we continue to work to tackle the risk of modern slavery. Our engagement with our suppliers, both new and existing, includes robust processes to identify potential risks of modern slavery and human trafficking being present which we keep under review. We will continue to seek ways in which to reduce this risk and to take effective action in the event that non-compliance is identified.

This statement has been approved by the Boards of Halcyon Topco Limited and Sciensus Pharma Services Limited.

 

Christian Tucat
Chief Executive Officer

 

John Bradshaw
Group Company Secretary & Director

 

Please click here to view the current statement or click here to view the previous statement.