Modern Slavery & Human Trafficking Statement
Introduction
This Modern Slavery and Human Trafficking Statement relates to actions and activities during the financial year 1 April 2024 to 31 March 2025.
The statement sets out the commitment of Oxford8 Ltd (‘the Company’) to preventing slavery and human trafficking in our business activities and the steps we have put in place with the aim of ensuring that there is no slavery or human trafficking in its own business and supply chains. All employees have a duty to be alert to risks, however small. Staff are expected to report their concerns and management to act upon them.
Organisational Structure and Supply Chains
This statement covers the business activities of the Company, which are the provision of consultancy services to both the public and private sectors globally. In so doing, the Company engages with third parties either as suppliers or as partners.
The Company assesses whether particular activities or countries are high risk in relation to modern slavery or human trafficking by the appropriate due diligence. Responsibility for the creation, review and executing of policy rests with the Managing Director of the Company.
Training
To ensure a good understanding of the risks of modern slavery and human trafficking in its business and supply chains, the Company requires Directors, HR and Operational employees to be aware of the criteria and risks in relation to modern slavery and human trafficking, reviewed annually.
Policies
The Company is committed to ensuring that there is no modern slavery or human trafficking in our business or our supply chains. This Statement affirms its intention to act ethically in its business relationships.
The following policies set down our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in our operations insert links to the relevant Company policy:
Whistleblowing Policy – Oxford8 encourages all its workers, customers and other business partners to report any concerns related to its direct activities or its supply chains.
Ethical Policy – through its business practices, the Company seeks to protect and promote the human rights and basic freedoms of all its employees and agents.
Corporate Social Responsibility (CSR) Policy – summarises how we manage our environmental impacts and how we work responsibly with suppliers and local communities.
Due Diligence Processes for Slavery and Human Trafficking
The Company undertakes due diligence when considering taking on new suppliers and regularly reviews its existing suppliers and partners. The Company’s due diligence process includes building long-standing relationships with suppliers and making clear our expectations of business partners, undertaking independent verification of suppliers and partners wherever possible, and invoking sanctions against suppliers that fail to meet such expectations, including the termination of the business relationship.
How Risks in the supply chain are Identified, Managed and Mitigated
Modern slavery risks vary by industry, geography and supplier.
Risk Identification;
Geographical Risks – Identifying regions a supplier operates, sources products and labour from to assess the risk of systematic labour issues (using sources such as the Global Slavery Index).
Sector Specific Risks – Identifying industries or roles with higher vulnerability such as construction, agriculture and clothes manufacturing.
Operational Risks – Identifying supply chains and recognising tier 1 suppliers may be supplied by subcontractors who may have unmonitored practices.
Risk Management;
Supplier Engagement – Oxford8 requires suppliers to adhere to a code of conduct that includes anti-slavery standards.
Auditing and Monitoring – Oxford8 requires suppliers to comply with unannounced audits as well as on going monitoring of activities.
Risk Mitigation;
Remediation – Oxford8 would require a supplier to implement an agreed remediation plan on discovery of non-compliance including changing hiring policies and improving worker protections.
Contractual Obligations – Oxford8 includes termination clauses in supplier contracts for breaches of modern slavery policies.
Informing Authorities – Oxford8 would engage with relevant authorities and support any action taken in the protection of a vulnerable person.
Corporate Governance
This Modern Slavery and Human Trafficking Statement will be annually reviewed and updated as necessary. The Directors endorse this policy statement and are fully committed to its implementation.
This Modern Slavery and Human Trafficking Statement has been approved and authorised by:
Damian Fessey
Managing Director
Last Review Date: 14th November 2024