This OCM policy is approved by the OCM Board and represents the Board’s direction to the business on this topic. Compliance with this policy is mandatory, through aligning OCM management system processes and people behaviours to the commitments below.

OCM is committed to the principles of the Modern Slavery Act 2015 and the abolition of modern slavery and human trafficking. OCM’s annual turnover is below the £36 million threshold set out in section 54 of the Modern Slavery Act 2015. We are not currently required to publish a slavery and human trafficking statement under the Act, but we choose to publish this policy voluntarily as a reflection of our commitment to these principles.

Policy

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, agents, contractors and suppliers.

As an equal opportunities employer, OCM is committed to creating and ensuring a non-discriminatory and respectful working environment for our staff. We want all our staff to feel confident that they can expose wrongdoing without any risk to themselves.

Our recruitment and people management processes are designed to ensure that all prospective employees are legally entitled to work in the UK and to safeguard employees from any abuse or coercion.

We do not enter into business with any organisation, in the UK or abroad, which knowingly supports or is found to be involved in slavery, servitude and forced or compulsory labour.

OCM strictly prohibits the use of modern slavery and human trafficking in our operations and supply chain. We have and will continue to be committed to implementing systems and controls aimed at ensuring that modern slavery is not taking place anywhere within our organisation or in any of our supply chains. We expect that our suppliers will hold their own suppliers to the same high standards.

OCM will undertake right to work checks on any applicants and new starters, in line with the government guidance.

Our Supply Chain

We assess ourselves to have a low risk of modern slavery in our business and supply chains. OCM has a supplier code of conduct setting out the standards we expect suppliers to meet.

What Modern Slavery and Human Trafficking Means

Modern slavery is a term used to encompass slavery, servitude, forced and compulsory labour, bonded and child labour and human trafficking. Human trafficking is where a person arranges or facilitates the travel of another person with a view to that person being exploited. Modern slavery is a crime and a violation of fundamental human rights.

Our Commitments

We expect everyone working with us or on our behalf to support and uphold the following measures to safeguard against modern slavery:

  • We have a zero-tolerance approach to modern slavery in our organisation and our supply chains.
  • The prevention, detection and reporting of modern slavery in any part of our organisation or supply chain is the responsibility of all those working for us or on our behalf. Workers must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this policy.
  • We are committed to engaging with our stakeholders and suppliers to address the risk of modern slavery in our operations and supply chain.
  • We take a risk-based approach to our contracting processes and keep them under review, assessing whether circumstances warrant specific prohibitions against modern slavery and trafficked labour in our contracts with third parties. We also assess the merits of writing to suppliers requiring them to comply with our Code of Conduct, which sets out the minimum standards required to combat modern slavery and trafficking.
  • Consistent with our risk-based approach, we may require employment and recruitment agencies and other third parties supplying workers to our organisation to confirm their compliance with our Code of Conduct, and suppliers engaging workers through a third party to obtain that third party’s agreement to adhere to the Code.
  • As part of our ongoing risk assessment and due diligence processes, we will consider whether circumstances warrant us carrying out audits of suppliers for their compliance with our Code of Conduct.
  • If we find that other individuals or organisations working on our behalf have breached this policy, we will take appropriate action. This may range from remediating the breach, where that represents the best outcome for those impacted, through to terminating the relationship.

Supporting Policies

OCM has several supporting policies:

  • Harassment, Sexual Harassment and Bullying Policy
  • Equality, Diversity & Inclusion Policy
  • Illegal Workers Policy
  • Supplier Code of Conduct
  • OCM Employment Handbook

Embedding the Principles

OCM will continue to embed the principles through continual improvement:

  • providing awareness training to staff on the Modern Slavery Act 2015 and informing them of the appropriate action to take if they suspect a case of slavery or human trafficking
  • ensuring staff involved in procurement activity are aware of and follow modern slavery procurement guidance on GOV.UK
  • ensuring consideration of modern slavery risks and prevention is added to OCM’s policy review process as an employer and procurer of goods and services
  • carrying out risk assessments
  • making sure OCM procurement strategies and contract terms and conditions include references to modern slavery and human trafficking
  • continuing to take action to embed a zero-tolerance policy towards modern slavery
  • gathering supplier assessment and performance data
  • ensuring that staff involved in buying, procurement, and the recruitment and deployment of workers receive training on modern slavery and ethical employment practices

Jennine Gilbert Woods, Director

Issue date: September 2026, for the financial year ending 31 March 2026. This policy will be reviewed and updated every year.