Modern Slavery Statement

This statement sets out Oxford Global Resources (UK) Limited’s (“Oxford”) actions to understand potential modern slavery risks related to its business.

Oxford is opposed to modern day slavery in any form. We are committed to working to mitigate the risk of modern day slavery in all aspects of our business. The UK government has made a commitment to end modern slavery and in 2015 the Modern Slavery Act was passed; Oxford has established and implemented this Modern Slavery Policy in support of that. This policy applies to all Oxford employees, officers, directors, consultants, representatives, agents, subcontractors, suppliers or other intermediaries acting on behalf of Oxford.

2. Organisational Structure

Oxford delivers tailored solutions for any technical challenges our clients face and specializes in workforce mobilisations, digital transformation, and modern enterprise. Oxford works to place highly skilled consultants and employees with our clients in industries including Life Sciences, Consumer and Industrial, Technology and Communications, Engineering and Financial Services and Insurance.

Oxford employs in excess of 900 staff and has 35 offices in the United Kingdom, Europe and North America. We have supported over 50,000 clients with staffing and consulting services and have completed more than 75,000 projects in these areas.

Oxford’s supply chains include clients, consultants, service providers, and employees. We have appropriate processes and policies in place to mitigate the risk of modern slavery and human trafficking both inside our organization, and in our supply chains.

3. Responsibilities

Oxford’s management team take full responsibility for ensuring compliance with this policy and implementing its objectives. All internal Oxford employees receive training and support to help identify and prevent any form of forced labour.

Oxford Personnel are prohibited from:

• Engaging in any form of human trafficking during the period of their contract;
• Using forced labour in the performance of a contract;
• Destroying, concealing, confiscating, or otherwise denying access by an employee to the employee’s identity or immigration documents, such as passports or drivers’ licenses, regardless of issuing authority;
• Using misleading or fraudulent recruiting practices during the recruitment of employees or offering of employment, such as failing to disclose, in a format and language accessible to the worker, basic information or making material misrepresentations during the recruitment of employees regarding the key terms and conditions of employment, including wages and benefits, the location of work, the living conditions, housing and associated costs (if employer or agent provided or arranged), any significant costs to be charged to the employee, and, if applicable, the hazardous nature of the work;
• Using recruiters that do not comply with the local labour laws of the country in which the recruiting takes place; or
• Charging employees or potential employees recruitment fees.

Any violation of this policy could result in disciplinary action which may include but is not limited to, an employee’s or consultant’s removal from a contract, or termination of employment. For subcontractors, failure to comply with the requirements of this policy is grounds for Oxford to take any and all appropriate actions, to include immediate termination of that subcontractor’s contract with Oxford.

4. Policies and Procedures

Oxford’s internal policies include a Code of Business Conduct Ethics Policy, Environment Social and Governance Policy, Combating Trafficking in Persons Policy & Compliance Plan and an Anti-Harassment and Discrimination Policy to guide and support our employees in raising any concerns they may have across the business.

Oxford ensures strict compliance checks are carried out for all consultants supplied, for example, we verify their identity and right to work before placement, we conduct reference checks, we engage temporary and contract workers via formal contracts.

5. Policy Statement

This policy is currently in place and actively adhered to at all times.

To the best of Oxford’s knowledge and belief, neither Oxford nor any Oxford personnel are engaged in any slavery or human trafficking‐related activities, including human trafficking, the use of forced labour, or the procurement of commercial sex acts during contract performance.

No abuses have been found to date; however, if any abuses are reported, Oxford will take appropriate action(s) in response to the abuse(s).

Oxford considers that the nature of our business operations and the sectors within which we operate means that our risk of modern slavery is lower than in other sectors, however Oxford commits to reviewing and monitoring the risk annually.

Oxford Personnel are encouraged to report any activity or condition that may violate this policy confidentially and without retaliation to Oxford’s HR Director or Vice President of Legal.

6. Contact

Questions regarding Oxford’s policy and actions to combat trafficking in persons may be directed to:

Jennifer Cunnington
HR Director, Europe
Email: jennifer_cunnington@oxfordcorp.com

William Lee
Vice President of Legal, Europe
Email: william_lee@oxfordcorp.com