Modern Slavery Statement

Our organisation

Novogene delivers unsurpassed data quality to support our customers’ research goals. We are a world-leader in NGS services, with around 2000 employees and multiple locations across the globe. Novogene has strong scientific expertise and experience with 32 NGS-related patents, as well as over 580 research papers with total impact factor at more than 4090, including publications in first tiers journals such as Cell, Nature and Science.

A privately-owned institution headquartered in Beijing with branches in Hong Kong China, US, UK, Singapore, Netherlands and Japan, Novogene was founded in 2011 and has been growing rapidly over the past few years. Novogene has genomic sequencing labs in the US (at The University of California at Davis campus), China, Singapore, and the UK (Cambridge).

This statement covers: Novogene Co., Ltd., Tianjin Novogene Bioinformatic Technology Co., Ltd.,Tianjin Novogene Med LAB Co., Ltd., Tianjin Novogene Technology Co., Ltd., Nanjing Novogene Bio Technology Co., Ltd., Novogene (HK) Company Limited., Novogene Netherlands B.V., Novogene (NL) International Holding B.V., and Novogene (UK) Company Limited.

Our policies and procedures

We operate a number of policies and procedures which reflect our commitment to acting properly in all of our business relationships and to implementing and enforcing effective systems and controls. They apply to all our employees and to anyone engaged on a temporary basis.

Our key policies and procedures which contribute to minimising the risk of modern slavery and human trafficking in our organisation and our supply chains include our:

• Bullying and harassment policy – which is designed to help ensure that all of our staff and anyone that we fund is treated with both dignity and respect.
• Risk management policy – which is designed to keep all our activities in line with all applicable laws, regulations and codes of governance (including in relation to slavery and human trafficking).
• Health, safety and environment policy – a key aim of which is to ensure the wellbeing of all our employees and anyone else who may be affected by our activities.
• HR procedures – we check that all our staff have appropriate right to work documents and ensure that they are paid fairly and enjoy a competitive remuneration package. We have procedures in place to safeguard the interests of young people and any unpaid work experience volunteers working at Novogene.
• Procurement policy – which sets out a number of factors to be considered when selecting our suppliers, including whether the supplier will be a good business partner for Novogene. This in turn involves considerations of supplier reputation and compliance with laws and ethical procedures.
• Agreements policy – our template agreements and standard terms and conditions require suppliers to comply with the law and include specific provisions in relation to modern slavery and human trafficking.
• Fraud and corruption policy – which reminds our people to take account of any improper or suspicious behaviour or situations, and to report and deal with the risk of fraud and corruption.
• Whistleblowing policy – as outlined in our corporate employee handbook, it aims to encourage any employee who has serious concerns about any aspect of work to come forward and voice those concerns via the appropriate company representatives.

Our policies are monitored by a relevant policy owner within our organisation and reviewed at least every two years. We will continue to review our policies to ensure that they are effective and appropriate.

In particular, our procurement team continues to review and strengthen our centralised procurement processes and policy, taking into account a range of risks, including slavery and human trafficking.

In addition to those policies referenced we have in place systems to:

• Identify and assess potential risk areas in our supply chains.
• Mitigate the risk of slavery and human trafficking occurring in our supply chains.
• Monitor potential risk areas in our supply chains.
• Protect whistle blowers.

Our supply chain

We use suppliers to support the operations of our organisation. The key areas in which we engage suppliers are:

• Facilities Management
• Information technology
• Finance
• Legal and investment

Our supply chain due diligence

We have zero tolerance to slavery and human trafficking. To ensure all those in our supply chain and contractors comply with our values we have in place a supply chain compliance programme. This consists of:
vetting the appropriate policies of all suppliers including the steps they have in place to minimise the risk of slavery and human trafficking in their business.

Due diligence and monitoring is ongoing and under review to improve supplier vetting and to minimise further a range of risks, including slavery and human trafficking. We have a dedicated compliance team led by our procurement team, assisted by our legal team.

Our procurement team is also looking to foster long-term relationships with suppliers, through which policies aimed at minimising a range of risks (including the risk of slavery and human trafficking) can be advanced.

Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to all our employees, contractors or visitors on all relevant matters. Here are some examples of the information and training we provide:

• All new joiners attend an induction session which includes information and training on our policies
• Managers are provided with a range of leadership training and are assisted by our HR team in HR-related matters including recruitment, remuneration and employee wellbeing
• Our procurement team, assisted by our legal team, routinely seek out information and training to help identify and address risks in both our organisation and supply chain (including in relation to slavery and human trafficking) and will continue to do so.

We have appointed the Novogene HR Director to monitor and review our internal and external processes and to bring insights on ways we can tackle slavery and human trafficking in any part of our business or supply chains.

This statement is made pursuant to section 54 of the Modern Slavery Act 2015 and constitutes Novogene’s modern slavery and human trafficking statement for the financial year 1 January 2020 to 31 December 2020.