Modern Slavery (Anti Slavery and Human Trafficking) Policy


Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such
as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in
common the deprivation of a person’s liberty by another in order to exploit them for personal or
commercial gain.

The OAK Network has a zero-tolerance approach to modern slavery and we are committed to
acting ethically and with integrity in all our business dealings and relationships and to
implementing and enforcing effective systems and controls to ensure modern slavery is not taking
place anywhere in our own business or in any of our supply chains.

The OAK Network is also committed to ensuring there is transparency in our own business and in
our approach to tackling modern slavery throughout our supply chains, consistent with our
disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from
all of our contractors, suppliers and other business partners. As part of our contracting processes, we
include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone
held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold
their own suppliers to the same high standards.

This policy applies to all persons working for the The OAK Network or on our behalf in any
capacity, including employees at all levels, directors, officers, agency workers, seconded workers,
volunteers, interns, agents, contractors, external consultants, third-party representatives and
business partners.

This policy does not form part of any employee’s contract of employment and The OAK network
may amend it at any time.

This Modern Slavery (Anti-Slavery and Human Trafficking) Policy interacts with the following
workplace policies and procedures which can be found in Sharepoint. You are encouraged to
familiarise yourself with the policies detailed below. If you have any queries about this policy
please contact the Legal and Compliance Director.
– Whistleblowing policy

The OAK Network’s director has overall responsibility for ensuring this policy with senior
management; and managers have a day to day responsibility to ensure compliance with our legal
and ethical obligations.

The Legal and Compliance Director has primary and day-to-day responsibility for implementing
this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing
internal control systems and procedures to ensure they are effective in countering modern slavery.

Management at all levels are responsible for ensuring those reporting to them understand and
comply with this policy and are given adequate and regular training on it and the issue of modern
slavery in supply chains.

You must ensure that you read, understand and comply with this policy.

The prevention, detection and reporting of modern slavery in any part of our business or supply
chains is the responsibility of all those working for us or under our control. You are required to
avoid any activity that might lead to, or suggest, a breach of this policy.

You must notify your manager OR the legal and Compliance Director as soon as possible if you
believe or suspect that a conflict with this policy has occurred, or may occur in the future.

You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of
our business or supply chains of any supplier tier at the earliest possible stage.

If you believe or suspect a breach of this policy has occurred or that it may occur you must notify
your manager or the Legal and Compliance Director or you may report it in accordance with our
Whistleblowing Policy as soon as possible.

If you are unsure about whether a particular act, the treatment of workers more generally, or their
working conditions within any tier of our supply chains constitutes any of the various forms of
modern slavery, raise it with your manager or the Legal and Compliance Director.

We aim to encourage openness and will support anyone who raises genuine concerns in good faith
under this policy, even if they turn out to be mistaken. The OAK Network is committed to ensuring
no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that
modern slavery of whatever form is or may be taking place in any part of our own business or in
any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or
other unfavourable treatment connected with raising a concern. If you believe that you have
suffered any such treatment, you should inform the compliance manager immediately. If the matter
is not remedied, and you are an employee, you should raise it formally using the Grievance
Procedure which can be found in Sharepoint or from the HR department.

Training on this policy, and on the risk our business faces from modern slavery in its supply chains,
will be provided as necessary. Our zero-tolerance approach to modern slavery must be
communicated to all suppliers, contractors and business partners at the outset of our business
relationship with them and reinforced as appropriate thereafter.

Any employee who breaches this policy will face disciplinary action, which could result in
dismissal for misconduct or gross misconduct. The OAK Network may terminate our relationship
with other individuals and organisations working on our behalf if they breach this policy.