Anti-Slavery and Human Trafficking Statement / Policy

CPi Biotech operates in the Republic of Ireland. We are guided by The Criminal Law (Human Trafficking) Act 2008, as amended by the Criminal Law (Human Trafficking) (Amendment) Act 2013 and also the EU Charter of fundamental rights, where Article 5, states that no one will be held in slavery or servitude, Article 5.2 asserts that no one will be required to perform forced or compulsory labour and Article 5.3 states that trafficking in human beings is prohibited.

Modern slavery is an international crime and transcends age, gender and ethnicities. “Modern slavery” refers to the offences of human trafficking, slavery, servitude, and forced or compulsory labour.

“Human trafficking” is a global crime that trades in people and exploits them for profit. “Human trafficking” is defined in the UN Trafficking in Persons Protocol, which supplements the United Nations Convention against Transnational Organised Crime, as “the recruitment, transport, transfer, harbouring or receipt of a person by such means as threat or use of force or other forms of coercion, abduction, fraud or deception for the purpose of exploitation”. Although human trafficking oen involves an international cross-border element, it is also possible to be a vicLm of modern slavery within your own country. There are several broad categories of exploitation linked to human trafficking, including sexual exploitation, forced labour, domestic servitude, organ harvesting, child related crimes, forced marriage and illegal adoption.

CPi’s policy is to conduct all of our business in an honest and ethical manner, and to comply with all applicable legislation. We strive to ensure that neither modern slavery nor human trafficking supports our supply chain or our businesses; this objective is implicit in our policies and procedures. We aim for a zero-tolerance approach to violations of anti-slavery-slavery and human trafficking laws. If breaches of these laws are found within our supply chain, we will look to support organisations in their efforts to comply with the applicable legislation.

CPi will review the continuation of business with individuals and organisations found to be involved in slavery, human trafficking, forced or child labour and retains the right to cease business with such individuals and organisations on this basis.

CPi is committed to acting professionally and with integrity in all its business dealings and relationships whether in The Republic of Ireland or abroad. We will review this policy and its operation in practice, at least on an annual basis.

All employees within the company have a statutory obligation to report knowledge or suspicion of slavery or human trafficking. Any genuine suspicion or knowledge of slavery or human trafficking (including knowledge or suspicion of money laundering or terrorist financing) is to be immediately reported to the managing Director, who will decide what further action, if any, is deemed necessary. Employees who raise concerns of slavery or human trafficking in good faith may do so without fear of discrimination or reprisal. These provisions do not replace any legal reporting or disclosure requirements. Where statutory reporting requirements and procedures exist, these must be fully complied with.

In the Republic of Ireland, if you are a victim of modern slavery or human trafficking, or you spot a suspected case, you can contact the Migrant Rights Centre Ireland at (00353) (0) 1 889 7570, or email info@mrci.ie.

Our staff are employed through ethical practices overseen by a Human Resource Expert, to ensure the highest of standards set down by regulations are respected and implemented. We have procedures in place pertaining to our employment practices in line with Republic of Ireland employment law, including “right to work” document checks, contracts of employment, and checks to ensure all employees are above minimum working age (16). We provide market-related pay and reward.

We recognise that our company is exposed to a greater slavery and human trafficking risk when dealing with suppliers of products and services, particularly those who have operations and suppliers in other territories. However, CPi Biotech considers that we, and the majority of our suppliers, are not in industries with a high risk of modern day slavery. In addition, our supply chains are primarily confined to Ireland, European and North American countries with a relatively lower risk of modern-day slavery and human trafficking.

We want to help our employees, clients and suppliers to understand more about these issues and understand how to report any suspicions they may have related to modern slavery and human trafficking.

The topic of Modern Slavery, and our associated Anti-Slavery and Human Trafficking Policy, is flagged in the induction training undertaken by new staff members starting with CPi Biotech.

We flag each update of this Statement and of the associated Anti-Slavery and Human Trafficking Policy to all staff members. This commitment is shared by the Managing Director and Leadership Team who will support and oversee the activity described in this policy by ongoing review at each meeting held by the Sustainable Procurement Committee. The sustainability team along with management are committed to measuring our performance as part of our management review meeting process, ensuring the initiatives are progressed in line with aims. This policy will be reviewed annually.

Adrian Giltinan

Managing Director

Date: 29th September 2023