UK Modern Slavery Act Statement Financial Year 2021/22
The Oxford Analytical Modern Statement 2021/2022 is made pursuant to section 54 of the Modern Slavery Act 2015 and covers our financial year to 2021/22. It details the steps that Oxford Analytical Services Ltd has taken and will implement in our upcoming year to tackle modern slavery and human trafficking within our business and supply chains.
Organisation Structure and Supply Chains
Oxford Analytical Services Ltd is a leading analytical business operating in sectors such as chemical testing and storage stability. As part of QADEX we employ c.60 members of staff across locations in the UK and India. All on full and part-time contracts, honouring EU minimum wage and working time directives. We have over 50 core Tier 1 suppliers of goods and services such as IT, utilities and inputs.
Policies and Procedures
At Oxford Analytical Services Ltd we passionately believe in upholding the integrity of supply chains. In fact our sister business STAR Index holds this is core to the operations. They are active in the space of ESG, Sustainability and tackling issues such as Modern Slavery. We are therefore committed to living these values ourselves. We made a priority of eradicating any forms of slavery. This is at the heart of our drive for integrity. Oxford Analytical Services Ltd supports the basic and fundamental human rights of all individuals. It does not condone any form of modern slavery, human trafficking, child labour, or exploitation in any form. This is especially within its business and supply chains which is made clear through the Oxford Analytical Modern Statement 2021/2022.
We adopt a zero-tolerance policy to any human rights abuses. Furthermore we have worked extensively with NGOs such as Unseen UK to build capacity and ensure our employees understand and adhere to this policy.
We are therefore committed to tackling modern slavery and forced labour through a continuous improvement approach. This is in accordance with the Oxford Analytical Modern Statement 2021/2022. We have adopted the core 9 principles of the Ethical Trading Initiative (ETI) Base Code. (https://www.ethicaltrade.org/eti-base-code) and the 8 core conventions of the International Labour Organisation (ILO.) (https://www.ilo.org/global/standards/introduction-to-international-labour-standards/conventions-and-recommendations/lang–en/index.htm) to allow us to hopefully identify and mitigate the risk of modern slavery in our own organisations, and those of our suppliers and sub-contractors.
Due Diligence Processes
We have appointed our first ‘Social Compliance Officer’ at Director level within the business (Rick Sanderson FIFST). During this financial year we will be initiating our own Ethical Trading Policy and also a Supplier and Partner Code of Practice. This will be supported by an initial Self-Assessment Questionnaire (SAQ). It will require robust evidence against the core standards of the business. Also in addition those set out in the ETI and ILO Base Codes, with ongoing monitoring.
This information and commitment will be required retrospectively of all existing suppliers. It will be mandatory as part of our new vendor process hence forth. In addition, we will hold on file and scrutinise all suppliers of goods and services to STAR Index. Particularly those that are required to publish a Modern Slavery Act 2015 Statement. For example all those above the current threshold of £36m in turnover with operating Head Offices within the UK. Also any emerging legislation applicable to non -UK supply chains.
Risk Assessment and Management
Recognising that the risk of modern slavery is always present we will ensure that we review our internal strategic and operational approach annually.
We have carried out an initial risk assessment of our core Tier 1 supplier base and concluded that our exposure to issues around Modern Slavery are relatively low. However, we recognise that our role is to safeguard against exposure to this issue and play our part in its eradication.
We have analysed our FY20/21 annual spend and drawn up a target list of the Top 10 by turnover. This represents a mix of large global companies with compliant Modern Slavery Act Statements and published programs, and smaller to medium size UK businesses sub- £36m turnover, who in the main do not have statements.
We have classified those without a statement as ‘At Risk’, and we will be working with these businesses with a request to complete a Modern Slavery SAQ issued by STAR Index. This will be completed in the first half of FY21/22. We also recognise that risks can be ‘hidden’ in our supply chains and we commit to working on a program to map those we work with both across and down our supply chains. Where instances of modern slavery are uncovered, we will work to remediate effectively and ensure any workers are appropriately safeguarded and protected.
We have also established our own ESG scores and targets using our STAR Index platform, allowing us to soon set net-zero targets and wider Sustainability targets and goals.
Transparency in Supply Chains
We understand that the risks of Modern Slavery are just as high beyond our immediate supply base, and as such we be utilising our own platform www.supplychainmapper.com, an online supply chain mapping toolkit, for identified “at risk” suppliers to Oxford Analytical Services Ltd, providing a FREE tool for them to attempt to map their supply chains.
The results of these efforts will be reported in next year’s Modern Slavery Act statement, FY22/23.
Key Performance Indicators to Measure Effectiveness of Steps Being Taken
We commit to tracking and maintain progress against the following key criteria:
- Significant Tier 1 suppliers MSA Statements Tracked and Scrutinised
- Supply Chain Maps instigated for ‘At-Risk’ Suppliers
- All staff trained to build capacity and spot the signs of Modern Slavery Training on modern slavery and trafficking
Training
We are committed to training and raising awareness of our people and those who work for us so that we can better spot the signs of modern slavery and forced labour.
Working with leading NGO Unseen UK (https://www.unseenuk.org/) we have co-developed an e-learning platform to set the scene and offer guidance and tools to combat the issues . During the first half of this financial year we will give this training to all members of staff. This training will enable our employees to better understand and recognise modern slavery risks that might occur within our business and supply chains. It also informs them of the appropriate actions if such issues are discovered.
We will also be providing an impartial whistle-blowing facility. Our Human Resources officer will monitor completion of these front line remediations. The welfare of our people is paramount. We are therefore committed to ensuring our policies, practices and procedures reflect this and all appropriate employment regulations and legislation are fully adhered to.
Board Approval
This statement is made pursuant to section 54(1) of the Act, has been approved by the Board of Directors of Oxford Analytical Services Ltd and will be updated annually in line with the Modern Slavery Act’s reporting requirements.
Stephen Whyte
Managing Director – STAR Index
18.10.2021