Introduction
At The Francis Crick Institute Limited (The Crick), our mission is discovery without boundaries: to carry out world-class research to understand how living things work and to drive benefits for human health.
We recognise that we have a role to play in identifying, preventing and mitigating the risk of modern slavery, human trafficking and forced labour through our activities.
We are committed to transparency in our supply chains and to upholding our responsibility to individuals working within them.
This statement covers our approach to reducing the risk within our supply chain, including the key activities we are pursuing, and tracking of progress against our stated objectives.
These procedures are the subject of ongoing review to ensure that we improve over time.
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Structure
Our structure, governance and management
The Crick is a company limited by shares and a registered charity. It was established by our six founding partners: Medical Research Council, Cancer Research UK, Wellcome, UCL (University College London), Imperial College London and King’s College London.
The Crick Group consists of the Crick and our subsidiaries:
- Crick Skyline Limited, a registered company in England and Wales, used to carry out commercial real estate activities.
- Francis Crick Trading Limited, a registered company in England and Wales and registered as an external company in Barbados, used to carry out trading and commercial activities.
- UKCMRI Construction Limited, a registered company in England and Wales, which undertook the design and construction of the building for the institute.
This statement covers the activities of the Crick as well as Francis Crick Trading Limited (FCT), due to a turnover exceeding £36m in the 2025/26 financial year for the latter. FCT has no employees and relies on the Crick Group’s policies, governance arrangements and operational processes, including those relating to modern slavery, to identify and manage relevant risks. The management and administration of the company is undertaken by the Crick.
Board of Trustees
Governs the institute and is comprised of independent members and representatives nominated by each of our founding partners. The Board sets the strategic direction of the institute and is responsible for ensuring that the charity’s aims are being met. This includes oversight and accountability for addressing and preventing modern slavery.
Executive Committee
Led by Professor Edith Heard, the Executive Committee is responsible for developing the Crick’s strategy and day-to-day management of the charity, including its scientific vision and research strategy, operations and activities.
The Crick’s workforce comprises highly educated professional occupations and we do not directly employ staff in categories typically deemed to be vulnerable to modern slavery in the UK. The focus of the Crick is, therefore, on our supply chains and ensuring there are appropriate safeguards in place in our relationships with suppliers and relevant third parties.
In 2025-26, work on modern slavery was principally led by the Sourcing team with support from the Legal and Governance team, Sustainability, and Facilities and Infrastructure teams.
Our approach
We consider the risk of human and labour rights abuses in our institute and supply chains to be low. However, we recognise that we have an important role to play in identifying and supporting prevention of such risks through our activities.
The Crick is committed to acquiring goods and services without knowingly causing any harm to others. Our approach is supported by policies, which are provided to employees as part of a comprehensive induction programme, training and ongoing communication updates, and to suppliers and third parties via their contracting and supplier onboarding processes.
Our people
Crick staff are located at the Francis Crick Institute in Central London for the majority of their working time. As such, they are at a low risk of human and labour rights abuses.
All staff at the Crick are paid at a minimum, the London Living Wage, following our accreditation by the Living Wage Foundation. Additionally, the Crick is the recipient of the Athena SWAN Bronze award in recognition of our work to support equality of opportunity and promotion of diversity across the organisation. This was successfully renewed in March 2025.
The Crick also has an Equality, Diversity and Inclusion strategy, which drives the creation and support of internal staff interest groups and specific workplace policies to ensure staff enjoy a safe, diverse and inclusive working environment.
Service Partners, Partner University Researchers and Commercial Partners may be located at other sites such as universities or third-party work sites unrelated to the Crick for a proportion of their working time. These organisations have undergone the Crick’s risk-based due diligence checks.
Figure 1: Crick staff split by worker groups.
Our policies
Our Code of Conduct and policies set the standards for everyone working at the Crick. Relevant policies include wording designed to raise managers’ awareness of potential human and labour rights risks and to signpost internal reporting routes where concerns arise.
Our policies are signposted to new starters during induction and remain accessible via our intranet site for all staff, including our partners.
The Crick Code of Conduct
The Code of Conduct sets the standards for everyone working at the Crick and outlines the expected behaviours required to align with the Crick’s values and vision. It also provides links to the Crick’s 10 Key Policies, which include:
- Health and Safety Policy
- Dignity at Work Policy
- Equality, Diversity and Inclusion Policy
- Whistleblowing Policy
The Crick Sourcing Policy (internal)
This policy governs how the Crick procures goods and services and provides instructions to Crick staff on compliance when undertaking procurement activities. It also encompasses Responsible Sourcing and the duties of staff to ensure that sustainability and social considerations, including human and labour rights risks, are carefully weighed up in purchasing decisions.
Our supply chain
The majority of the Crick’s purchases encompass Science, Facilities and Infrastructure (F&I) and ICT related goods, equipment and services. As far as human and labour rights are concerned, these spend categories pose the greatest risks due to the volumes purchased and the complexity of the upstream supply chain. Our supplier spend is highly concentrated with 102 suppliers responsible for 80% of our spend. Therefore, our collective efforts are concentrated on closely monitoring these particular suppliers for compliance.
Figure 2 illustrates the distribution of spend within each category.
Expenditure involving collaborative partners is classified as non-addressable spend and is not subject to oversight by the Sourcing team. However, the Grants team conducts due diligence on these organisations to ensure that any unsuitable association or potential reputational damage is identified and mitigated.
Figure 2: Distribution of expenditure by spend category.
Due diligence
Sourcing – Assessing supply chain risks
Prospective suppliers are required to complete a series of due diligence questions, which contains a specific section on modern slavery. This is checked at the point of submission for any compliance requirements. Any new suppliers, at the point of onboarding to the Crick’s finance system, are also requested to confirm that they were not convicted of any offences related to the use of child labour or any other forms of human trafficking.
Additional regular checks are being performed by Sourcing on any new or existing suppliers who may carry the greatest risks within their respective supply chains.
Since 2024, the Crick has requested key suppliers to sign up to the Sustain Supply Chain Code of Conduct, which is now included in our supplier onboarding process with take-up being monitored and reported against.
Partner due diligence FCT
Given that FCT has no employees, modern slavery risks arise primarily through third-party and commercial partner relationships rather than direct operations. No specific questions relating to Modern Slavery are asked during the due diligence process for onboarding potential partners for FCTs activities. Due diligence focuses on organisation structure, financial health and necessary checks against sanction lists and negative press stories. While the latter may pick up issues already reported on, we do not ask questions that sufficiently allow us to analyse whether there is the risk of any current or future ethical issues arising. Accordingly, work has started to harmonise due diligence arrangements across the Crick Group to minimise risks and ensure a more consistent approach to third-party relationships. This activity will be coordinated by the Crick’s Risk and Compliance function through FY26/27. The project is still in its early stages and the timeline is dependent on the selected method.
Grants and Commercial – Assessing the risks associated with partnering with funders
The Crick participates in several strategic partnerships, receives funds from philanthropic organisations and grant givers, and pursues commercial operations. Each of these activities carries risk which, although minor in comparison to the supply chain, must be identified and managed.
The Grants function manages the Research Collaboration Review policy that incorporates a Due Diligence review assessing partners (funders and documented scientific collaborators) for potential reputational, financial, compliance and national security risks. Once a partner has been assessed, they pass through a formal approval workflow (including routes of escalation where necessary) that, in a majority of cases confirms approval to proceed, but in some cases may propose risk mitigation actions or, in very exceptional circumstances, prohibit further engagement with the partner
Key activities
Supplier relationship management (SRM)
The Crick Sourcing team, in collaboration with departmental leads, actively manages approximately 50 key Tier 1 suppliers under a comprehensive SRM programme. The approach differs depending on the supplier but typically includes regular review meetings, performance monitoring, occasional supplier site visits and a periodic refresh of standard due diligence compliance including human and labour rights. The contractual relationship with these suppliers is generally direct although, where appropriate, we also utilise consortia-led framework agreements through our membership of the London Universities Purchasing Consortium (LUPC).
Our LUPC subscription grants access to the various contracts, materials, training opportunities and partnerships available to assist with our supply chain activities including managing human and labour rights risks. The LUPC also promote the Supply Chain Code of Conduct with their suppliers.
In early 2026, the LUPC released the RPHUBTM, a tool for its affiliates which gathers key due diligence information in a single report. Each report identifies risks in a supplier’s response and makes recommendations for improvements. In more serious cases, suppliers can be issued with corrective action plans.
In 2026-27, the Sourcing team will seek to utilise this information in the Crick’s own processes, and where possible, support the LUPC in their work of influencing suppliers to improve their transparency.
Appendix 2 sets out the countries of origin of goods and services provided to the Crick.
Electronics Watch affiliation
Through our membership of the LUPC, we are affiliated with Electronics Watch, an NGO responsible for monitoring global electronics supply chains. This gives us access to specialist information and resources not available elsewhere. We have further enhanced this relationship by supplying information on products that we purchase, enabling Electronics Watch to provide targeted information on areas of risk within our specific supply chain.
This initiative will be reviewed regularly and updated with new suppliers and products as part of our business-as-usual SRM process.
Our progress and 2026/27 financial year objectives
Theme A - Supplier engagement
| Objective | 2025/26 target | 2025/26 progress | 2026/27 target |
| A1 | Refresh the Tier 1 supplier list and request updated due diligence information for continuous assessment of perceived risks. Potentially augment the Top 50 list to include new suppliers based on spend or risk. | The list was reviewed at the beginning of the period to ensure that the supplier list was appropriate. Information was requested for the Top 50 suppliers which included some lower spend, high risk suppliers. | We will monitor the Top 50 suppliers, with updates requested for expiring documents (e.g. insurance cover) or new suppliers being onboarded. |
| A2 | 50% of Tier 1 suppliers signed up to the Code of Conduct by 31 March 2026. | This information was gathered during our SRM process with 54% of suppliers agreeing to comply with the code. | We will continue to request our Tier 1 suppliers sign up to the code aiming for 70% compliance by the 31 March 2027. |
| A3 | Adoption of a third-party supply chain/risk management reporting tool by 31 March 2026 if the cost-benefit of the proposed solution is justified. | This work was paused due to the implementation of similar systems for our Risk and Sustainability teams to avoid any duplication. Additionally, the cost of the preferred solution was prohibitive. | No further action at this time. |
| A4 | Conduct 6 supplier site visits covering the standard audit questionnaire by 31 March 2026. | We visited three supplier sites this year, both as part of our contract management. Further details are available in Appendix 3. | Conduct four supplier site visits covering the standard audit questionnaire by 31 March 2027. |
Theme B - Internal policies and processes
| Objective | 2025/26 target | 2025/26 progress | 2026/27 target |
| B1 | Attend the 2025 Crick Sustainability Day and other staff engagement activity related to responsible procurement together with the 2025 annual MRC Sustainability Conference in Edinburgh. | Both events were attended together with other relevant opportunities. | Continue to engage with staff including attendance at Crick Sustainability Day with a specific emphasis on Modern Slavery, and continued collaborative work with other institutions as opportunities arise. |
| B2 | The Sourcing Policy is due for renewal in December 2025. Any new or emerging legislation and best practice will be considered accordingly. | This is postponed pending a strategic review of the Crick Finance Delegation of Authority and other governance processes. | Renew the Sourcing Policy by the end of the 26/27 financial year if wider review progresses within the timeframe. |
| B3 | Legal Terms and Conditions update: Transition to business as usual and monitor best practice for appropriate changes to core terms. | No major terms updates through the year. Transitioned to BAU monitoring and updates as necessary in line with legislative or best practice recommendations. | Complete. |
| B4 | The Modern Slavery training programme will be rolled out to additional cohorts of staff with dayto- day involvement in purchasing activities. Target of 200 staff to have passed the training by 31 March 2026. | 164 staff completed training to 31 March 2026. A request has been submitted to make the training part of the Crick Essential Training programme. A decision for this will be made in Q1 2026. | Achieve a total of 200 staff trained by 31 March 2027. |
| B5 | Repeat communications to all staff relating to Speak-up, whistleblowing, and other mechanisms for reporting Modern Slavery concerns, at least annually. Participate in any other staff engagement activity relevant to responsible procurement. | An article including signposting to our training was sent to all staff following the publication of last year’s statement. We also communicated with staff at the Crick Sustainability Day. | Annual prompt to be sent via internal communications regarding training availability to coincide with launch of approved 2025-26 statement (expected in September 2026). |
Approval
This is a group statement for the purposes of section 54 of the Modern Slavery Act 2015 and applies to The Francis Crick Institute Limited and Francis Crick Trading Limited.
This statement has been formally approved by The Francis Crick Institute Ltd Board of Trustees and signed on their behalf.
Lord Browne of Madingley
Chair
The Francis Crick Institute
10 September 2026
Professor Edith Heard
Director and CEO
The Francis Crick Institute
10 September 2026
Appendix 1 – Indicators for measuring progress
The table shows our key performance indicators (KPIs) used to measure the success of our approach to managing human and labour rights risks within our supply chain.
| Indicators | Achieved 2024/25 | Target 2025/26 | Achieved 2025/26 | Target 2026/27 |
| Total number of Crick staff completed the online “Introduction to Modern Slavery” learning module | 124 | 200 | 164 | 200 |
| Number of key Tier 1 suppliers1 undertaking enhanced due diligence as part of our SRM programme | 50 | 55 | 50 | 55 |
| Percentage of key Tier 1 suppliers signed up to the Sustain Supply Chain Code of Conduct or equivalent | 20% | 50% | 54% | 70% |
| Number of supplier site visits2 | 4 | 6 | 3 | 4 |
1 Top 50 suppliers responsible for c70% of total addressable spend
2 Site visits might be undertaken by Sourcing, departmental leads or contract owners and typically focus on FM suppliers
Appendix 2 – Country of origin of our key products
| Spend category | Country |
| Scientific consumables and chemicals | Canada, China, Estonia, France, Indonesia, India, Latvia, Malaysia, Mexico, Nether-lands, Pakistan, Poland, Ukraine, Thailand, UK, USA |
| IT hardware, networking equipent and print solutions | Brazil, Cambodia, China, Czech Republic, Germany, India, Indonesia, Ireland, Israel, Japan, Laos, Malaysia, Mexico, Netherlands, Philippines, Poland, Singapore, South Korea, Taiwan, Thailand, UAE, USA, Vietnam |
| Scientific services including maintenance and support (on-and off-site) | France, Germany, Japan, Latvia, UK, Ukraine, USA |
| Soft facilities maintenance services (cleaning, security, catering etc.) | UK, Italy, France, Spain, Greece, USA, Belgium, Sweden |
| Office supplies and equipment and other non-scientific goods | Austria, Belgium, China, Estonia, France, Germany, India, Indonesia, Ireland, Italy, Japan, Norway, Poland, Philippines, Sweden, UK, USA |
| Office and laboratory furnishings | Poland, Republic of Ireland, UK, USA |
| Construction and design works | UK |
Source: LUPC and Crick Sourcing Team Data
Appendix 3 – A summary of activity in FY25/26
Below is a summary of some of the work that has been undertaken as part of our new business-as-usual approach to Modern Slavery.
Electronics Watch
We have previously submitted information to Electronics Watch on relevant purchases of IT equipment. Electronics Watch uses this to monitor the associated supply chains on our behalf and raise any emerging concerns or risks with us.
This year, we have had two major risks highlighted to us which required further intervention. The first was completed via our LUPC partners, who interacted with suppliers at a framework agreement level. This was advantageous as they act on behalf of all affiliates covered by the framework. LUPC has written to the affected suppliers to request an action plan. We are continuing to monitor this in our quarterly reports from Electronics Watch and will take further action, where required.
In the second instance we were notified that some of the factories that manufacture a small number of servers were implicated in potential human rights contraventions. As a result, we reviewed any ongoing need for this equipment. Fortunately, this equipment has already been decommissioned and is being held for redundancy/back-up purposes. The ITO team has agreed that no further units, replacements or spare parts will be purchased from this product line to minimise any ongoing risk. More importantly, this case has also subsequently been closed by Electronics Watch after several improvements by the supplier in question.
Site visits
A total of three site visits were carried out in the 25/26 financial year as part of our sourcing and supplier engagement processes. The Facilities and Infrastructure team visited our waste supplier for their joint annual contract review, which identified no issues. This visit included brief informal interviews with randomly selected staff.
A reference site of the Crick’s Hard FM supplier was also inspected during the retendering of the requirements, which is the Crick’s highest value and most complex contract. As part of this visit, we evaluated a broad range of submitted information, including matters such as health and safety and modern slavery. We were able to verify all the relevant information provided in the tender submission.
Finally, we also visited a second-tier supplier, who is a wholesaler of fresh foods (including vegetables, meats and cheeses) to our on-site catering partner. We reviewed their working practices at the premises and gained insights into their supplier selection and management methods. Again, no issues were found during the inspection, which is particularly reassuring given that this supplier works directly with producers in the upstream supply chain, where exposure to human rights abuses are deemed to be significant.
Supplier Relationship Management activity
This financial year we renewed our due diligence information with our top 50 key suppliers. The focus was on enhanced compliance and, from an ESG viewpoint, the ability to demonstrate a basic level of compliance with the Sustain Code of Conduct. Follow ups with suppliers are continuing in 26/27 with the next full refresh of information due in 27/28, which ideally will involve a more automated process via the use of third-party tools or enhanced collaboration and information sharing with partner institutions.
