Modern Slavery and Human Trafficking Statement
for the financial year ending 31 December 2026
(issued pursuant to Section 54 of the UK Modern Slavery Act 2015)
1. About this Statement
This Statement sets out the steps taken by Lumanity Limited and its Affiliates (the “Group”, “Lumanity”, “we”, “us”, “our”) for the financial year ending 31 December 2026 to prevent modern slavery and human trafficking in our business and supply chains.
This Statement is intended to meet the transparency requirements of the UK Modern Slavery Act 2015. It is also designed to align, where applicable, with expectations under similar legislation and regulations in other jurisdictions in which we operate or support clients (for example, Australia’s Modern Slavery Act 2018, the California Transparency in Supply Chains Act, and Canada’s Fighting Against Forced Labour and Child Labour in Supply Chains Act). Requirements vary by jurisdiction; Lumanity will comply with local requirements where they apply to the Group.
2. Our Business, Structure, and Operations
Lumanity is a global life sciences consultancy supporting pharmaceutical and biotechnology organizations across end-to-end commercial initiatives. We provide advisory and analytical services across medical, commercial, regulatory, evidence generation, strategy, and related professional services.
We operate through a group of entities with offices in North America, the United Kingdom, the European Union, and Asia, and we conduct work in more than 50 countries. Our workforce includes employees and, where needed, independent contractors/consultants engaged to support client projects.
3. Our Supply Chains
As a professional services organization, our supply chain is primarily services-based rather than manufacturing-based. Key categories include:
- Professional services (e.g., independent consultants/contractors, specialist advisory partners, research vendors)
- Data, software, and technology (e.g., SaaS providers, data providers, IT services)
- Facilities and office services (e.g., office leasing, cleaning, security, catering)
- Corporate services (e.g., legal, accounting, recruitment agencies)
- Travel and event services (e.g., travel management, hotels, venues)
We recognize that modern slavery risks can still exist in service supply chains, including in cleaning, security, catering, recruitment, and certain offshore/outsourced service arrangements.
4. Our Commitment
Modern slavery is a grave violation of human rights and includes slavery, servitude, forced or compulsory labour, and human trafficking.
Lumanity has a zero-tolerance approach to modern slavery and human trafficking. We are committed to:
- Acting ethically and with integrity in all business relationships
- Implementing proportionate and risk-based measures to help prevent, identify, and address modern slavery risks
- Expecting our suppliers, subcontractors, and business partners to uphold similar standards
- Supporting effective reporting and remediation where concerns are identified
This commitment applies to all Lumanity personnel, including employees, officers, directors, temporary workers, and contractors, and it extends to our suppliers and subcontractors.
5. Governance and Accountability
Oversight and accountability for our modern slavery approach sits with senior leadership. Day-to-day responsibility for implementing and maintaining our program is assigned to Compliance, supported by local management.
We will:
- Maintain internal ownership for the modern slavery compliance program
- Keep this Statement under annual review
- Escalate credible concerns to senior leadership for timely action
6. Due Diligence and Risk Management Approach
We take a proportionate, risk-based approach to due diligence that is appropriate for a global professional services business.
6.1 Supplier Onboarding and Contracting
When engaging new suppliers (and when renewing higher-risk suppliers), Lumanity aims to:
- Understand what the supplier provides, where services are performed, and whether subcontracting is used
- Request supplier confirmation that they comply with applicable anti-slavery/anti-trafficking laws and do not knowingly use forced, bonded, or trafficked labour
- Include appropriate contractual expectations, as proportionate to the engagement, which may include:
-
- Compliance with applicable modern slavery laws
- A right to request information related to labour practices
- Requirements to notify Lumanity of credible modern slavery concerns involving the supplier’s business or relevant supply chain
6.2 Ongoing Supplier Management
Lumanity’ s ongoing approach includes:
- Periodic review of supplier risk
- Targeted requests for updated confirmations or documentation where risk justifies it
- Risk-based audits or assessments where appropriate and feasible (noting that, as a services business, audits may often be questionnaire-based or conducted via supplier interviews and evidence review rather than on-site inspections)
6.3 Internal Operations and Recruitment
We take steps intended to reduce the risk of modern slavery within our own operations, including:
- Hiring and onboarding processes designed to support lawful working arrangements (e.g., right-to-work checks where applicable)
- Use of reputable recruitment channels and agencies, with expectations around ethical recruitment
- A clear expectation that workers should not pay recruitment fees to obtain work with Lumanity, where prohibited by law or where such fees raise exploitation concerns
7. Risk Areas and How We Address Them
Because Lumanity is not a manufacturer, our highest modern slavery risk exposure is most likely to be indirect, through certain suppliers and service categories.
Potential higher-risk areas may include:
- Facilities-related services (cleaning, security, catering) that can involve low-wage or vulnerable labour pools
- Recruitment and labour intermediaries
- Certain offshore, outsourced, or highly subcontracted services
- Travel and events supply chains in some jurisdictions
Key controls we use to address these risks include:
- Risk-based supplier screening at onboarding
- Contractual expectations and supplier confirmations
- Escalation procedures and follow-up when concerns are raised
- Prioritizing additional scrutiny for higher-risk supplier categories and geographies
8. Reporting Concerns and Remediation
All employees and workers are expected to raise concerns if they suspect modern slavery or human trafficking in:
- Our business
- A client engagement where we are operating as a supplier
- Our supply chain or a supplier’s subcontracting arrangements
Concerns should be raised through management or established internal reporting channels. We will:
- Assess reports promptly and sensitively
- Take appropriate action where concerns are credible, which may include supplier engagement, requiring corrective action plans, suspending new work, or terminating supplier relationships where warranted
- Where appropriate, cooperate with law enforcement or relevant authorities
We aim to support a speak-up culture and do not tolerate retaliation against individuals who raise concerns in good faith.
9. Approval
This Statement was approved by the Lumanity Board of Directors/Managers and the original is signed by an authorized director/senior executive officer and on file at Lumanity.
10. Publication
This Statement will be made available to employees and published externally in accordance with applicable legal requirements.
Jon Williams
CEO