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Modern Slavery Statement 2020/21


This statement is made pursuant to section 54 of the Modern Slavery Act 2015. It constitutes Cancer Research UK’s (“CRUK”) slavery and human trafficking statement for the financial year ending 31 March 2021. Of our wholly owned subsidiaries, this statement covers the activities of Cancer Research UK Trading Limited and Cancer Research Technology Limited, which procure goods and services from and form part of CRUK’s supply chain.

Introduction (Chief Executive)

Cancer Research UK is the world’s leading cancer charity dedicated to saving lives through research, influence and information. Our pioneering work is changing lives on a global scale. We have set ourselves the mission of beating cancer, but we also have a responsibility to all our staff, volunteers, researchers, supporters, suppliers and partners – to ensure that everyone within our business and supply chain is treated fairly, and that we operate ethically and responsibly.

Modern slavery is a part of this responsibility, and one that we take seriously. We recognise the growing challenge that modern slavery presents, and we have robust plans in place to regularly review and update our processes. We strive to make sure all those we interact with through our business and supply chain are treated fairly – to mitigate risks of human trafficking, forced, bonded and child labour – and we aim to source our services and goods in a responsible and ethical manner.

This has been a difficult year. The pandemic has made our mission harder to achieve, and has disrupted all parts of our operations – including some of our planned activity in this area. However, I am pleased that we have continued to make progress this year, have maintained our core compliance and monitoring activities, and have maintained our standards. During the year no incidents of modern slavery have come to light from across our supply chain.

We have also made progress in the development of a new Supplier Code of Conduct, to demonstrate the ethical and responsible standards expected as well as maintaining our core compliance and monitoring activities.

I hope that in the year ahead we will build on this progress. We aim to lead the charity sector in our approach to sustainability, and next year we will be working towards publishing our first cross-organisational strategy. We will increase our emphasis and our resource, to place ourselves at the forefront of charity sustainability – as well as the fight against cancer.

Our Management Structure and Staff

Cancer Research UK is a company limited by guarantee and is a registered charity. It is governed by a Council of Trustees who set the CRUK’s strategic direction, monitor the delivery of the CRUK’s objectives to uphold its values and governance and guide, advise and support the Chief Executive Officer, who leads the Senior Management Team in achieving the CRUK’s vision and purpose. It is supported by several Committees. The day-to-day running of CRUK is the responsibility of the Executive Board.

As of 30 March 2021, CRUK employed 3,823 people, most of whom are based in the UK and work in our offices, shops, research institutes, and warehouses. We also employ casual workers throughout the year who mainly assist with our fundraising events. All are directly employed, paid a living wage and are not considered vulnerable to modern slavery.


Our Policies

We have several policies which underpin our approach to tackling the risk of modern slavery in our supply chains. These include our:

  • Working with Suppliers and Partners Policy which sets out internal requirements for buying goods and services to ensure risks are managed appropriately.
  • Supplier Code of Conduct which sets out our standards and the standards expected of our suppliers in relation to the responsible, sustainable and ethical sourcing of goods and services.
  • Whistleblowing Policy which encourages staff and volunteers to report concerns including any related to modern slavery, trafficking and child or forced labour.

In addition, our HR policies include our:

  • Safeguarding Policy which sets out our approach to safeguarding and the actions that staff are required to take in dealing with safeguarding concerns.
  • Dignity at Work Policy which sets out our position on bullying and harassment and covers all those who work for us including employees, secondees, contractors, agencies, fixed term and temporary workers to ensure everyone is supported and safe.
  • Equality, Diversity and Inclusion Policy which sets out CRUK’s commitment to building a diverse, equal and inclusive environment for all our employees and volunteers through our employment and people practices.

Our Supply Chains

We use a wide range of suppliers who, for example, supply goods for sale, provide services at events and support our operations.

We have a Central Procurement team that supports the procurement of goods and services, and procedures in place which require different tendering, due diligence, and approval sign off levels depending on the value of the goods or services being procured, the nature of the supplier, and the relative risks involved.

Last year CRUK had approximately 1,800 suppliers that were used across the following categories:

  • Creative Media
  • Fundraising and Events
  • Goods for Resale
  • Human Resources
  • Media Buying
  • Professional Services & Consultancy
  • Property and Facilities Management
  • Research and Innovation
  • Technology
  • Warehousing & Distribution


Risk Assessment

The Corporate Social Responsibility team (“CSR team”) manage the day-to-day processes and supplier due diligence to mitigate modern slavery risks in our key supply chains. They work in partnership with the Procurement and Legal teams to develop responsible ethical standards, policy and contractual provisions for all suppliers eg onboarding processes, tenders and contracts.

We carried out a desk-based supply-chain mapping exercise which identified the categories, and the associated suppliers, with higher potential risks of modern slavery.

Procurement Category 

  • Goods for resale, promotional items, clothing and merchandise

 43 suppliers, approximately £5m. Locations include China, India, UK

  • Facilities Management:

2 Suppliers (cleaning and catering), approximately £500,000. Locations all UK

Due Diligence

We continuously review our due diligence processes and seek to mitigate risks across those of our suppliers which present higher potential risks of modern slavery as set out below.

Direct Suppliers (Tier 1)

Direct suppliers are those with whom CRUK holds a direct contractual relationship. They are predominately UK-based, procure goods and merchandise on behalf of CRUK and hold the relationship with the manufacturing sites. These are referred to as our Tier 1 suppliers.

Suppliers who source goods which fall into our higher-risk categories are required to complete CRUK’s online Modern Slavery Due Diligence Questionnaire. This asks for information about their business, their operational processes and polices in relation to ethics and modern slavery and their supply chain management. The responses are reviewed and assessed by the CSR team.

43 Tier 1 suppliers were used to source goods and merchandise predominately for resale in our high-street shops, superstores and online during the reporting year.

Manufacturing Sites (Tier 2)

These are the factories which produce CRUK goods and merchandise. They are predominately located in the Far East and are sourced through our Tier 1 suppliers. These are referred to as our Tier 2 suppliers.

All manufacturing sites are required to hold membership with either Supplier Ethical Data Exchange (SEDEX) or the Business Social Compliance Initiative (BSCI) and provide CRUK with direct access to annual independent ethical audits. We are members of both platforms which allows us to access audit reports from across all manufacturing sites used by our suppliers, giving us transparency in relation to ethical practices. We have set out minimum requirements they must meet.

Minimum requirements:

  • Sites must provide an annual independent ethical audit from either SEDEX or BSCI, and all audits must be uploaded and accessible via the platforms.
  • This ethical audit must have been carried out and verified by an independent auditor during the reporting year.
  • All issues arising from the audit are addressed and closure verified by independent auditors on an ongoing basis.
  • There must no evidence of child, forced or bonded labour.

76 sites were used to manufacture goods and merchandise for CRUK during the reporting year.

All ethical audits in relation to those sites were reviewed via the SEDEX or BSCI platforms and verified by independent auditors. No issues in relation to modern slavery were flagged by auditors in relation to the sites assessed, including child, forced or bonded labour.

We are mindful of the limitations of independent ethical audits, but we think these audits are the most effective tool for assessing modern slavery risks across CRUK’s supply chain.

Should a manufacturing site fail to provide the information requested or meet our minimum requirements we will take appropriate action. In the first instance, we will red-flag and raise concerns with the internal team holding the supplier relationship, giving them a timeframe to resolve any issues. Where we are unable to resolve issues or gain transparency, we would instruct our Tier 1 supplier to remove the factory from our supply chain.


Training and Advice

This year, due to the external disruption of COVID-19 and the internal restructures, we have not been able to roll out the level of communications and training we had hoped to deliver, this has been deferred to 2021-22.

Next Steps

Our key focus for 2021-22

  • Communications and awareness: as above we will increase internal awareness of CRUK’s existing ethical and responsible processes and standards, the risks

of modern slavery and our Supplier Code of Conduct

  • Training: we will develop a dedicated training module
  • Continuously reviewing and improving our supply chain processes to ensure sustainable and ethical standards are further integrated and embedded across tendering and contract management taking steps to mitigate modern slavery risks in our supply chain.


This statement has been formally approved by the Trustees of Cancer Research UK and the Directors of Cancer Research UK Trading Limited and signed on their behalf.

Professor Sir Leszek Borysiewicz  
Cancer Research UK