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Modern Slavery and Human Trafficking

This policy is made pursuant to s.54 of the Modern Slavery Act 2015 and sets out the steps that OEE Consulting has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.

Modern slavery encompasses slavery, servitude, human trafficking and forced labour. OEE Consulting has a zerozero-toleranceroach to any form of modern slavery or human trafficking. We would not work with any organisation where it was known they were non-compliant to UK legislation.

We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain. OEE Consulting is also an accredited living wage employer which is a voluntary program supporting responsible pay over and above the national minimum wage.

Although committed to carrying out proper due diligence, as a Professional Services supplier, OEE Consulting considers the risk of modern slavery occurring within its business to be low due to the nature of its business and limited supply chain.

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, interns, agents, contractors, external consultants, suppliers, third-party representatives and business partners.

The Directors of OEE Consulting have overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it. The Operations 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.

Line and Project managers at all levels are responsible for ensuring those reporting to them 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.

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. We are 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.

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. We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.

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