1. Scope
Modern slavery is a crime and a violation of fundamental human rights. OASST Ltd has a zero-tolerance approach to this issue. We are committed to acting ethically and with integrity in all our business dealings and relationships, ensuring that modern slavery does not occur in our operations or supply chain. Modern slavery encompasses various forms, including slavery, servitude, forced and compulsory labour, and human trafficking—each involving the deprivation of a person’s liberty for exploitation.
2. Policy Statement
The Modern Slavery Act 2015 introduced significant changes in UK law aimed at increasing transparency in supply chains. Large businesses are required to disclose the steps they have taken to ensure their operations and supply chains are free from modern slavery.
This statement outlines the measures OASST Ltd has implemented to prevent slavery and human trafficking within our supply chains and operations. We apply these measures across all subsidiaries, even those that do not meet the Section 54(2) threshold, in compliance with section 54(1) of the Act.
3. Company Structure
OASST Ltd is a tour operator providing academic courses for students held at Oxford Colleges in the U.K to include excursions, visits, cultural experiences and distinguished guest speakers.
With a workforce of approximately 3 employees, our primary purchases include consultancy, tuition, professional advisory services, I.T & marketing services.
We maintain a strict zero-tolerance stance toward modern slavery, and we implement effective controls to safeguard against any forms of modern slavery within our business and supply chain.
4. Policy on Modern Slavery
OASST Ltd is dedicated to ensuring that modern slavery and human trafficking do not occur in any part of our operations or supply chains. We have established a Modern Slavery Policy that reflects our commitment to ethical practices and integrity in all business relationships.
Our zero-tolerance approach is communicated to all suppliers, contractors, and business partners from the outset and reinforced as necessary. Breaches of this policy by employees, directors, or officers may result in disciplinary action, which could include immediate dismissal for serious violations. All individuals covered by this policy are expected to cooperate fully in any investigations into suspected breaches.
The Modern Slavery Policy is reviewed annually by the OASST Ltd Executive Team, and all employees are urged to avoid activities that could lead to or suggest a policy breach. Our Whistleblowing Policy encourages the reporting of any concerns related to modern slavery, with access to an independent hotline for support.
5. Due Diligence in the Supply Chain
To identify and mitigate risks, OASST Ltd has established systems to:
5.1. Monitor potential risk areas within our supply chains.
5.2. Conduct due diligence on suppliers, including compliance assessments and on-site audits to review working conditions.
5.3. Include contractual terms in supplier agreements that mandate compliance with our modern slavery policy, including the right to terminate contracts if instances of modern slavery are identified.
5.4. Require suppliers to confirm that their operations align with our policy by:
a) Taking steps to eradicate modern slavery in their businesses.
b) Holding their own suppliers accountable for modern slavery.
c) Paying employees at least the minimum or national living wage applicable in their country.
6. Risk Assessment
This policy forms part of our broader risk management strategy. We continuously review and update our supply chain management processes to ensure compliance with our values and legal obligations.
Our standard trading terms require suppliers to adhere to all applicable anti-slavery and human trafficking laws. Key commercial supply arrangements already contain provisions addressing these issues, and contracts will be updated as necessary upon renewal.
7. Measuring Effectiveness
We have not identified any instances or indications of slavery or human trafficking within our supply chain. Consequently, we have not deemed it necessary to adopt formal performance indicators for measuring effectiveness in preventing these issues.
8. Training and Awareness for Staff
Our commitment to ethical practices is communicated to all OASST Ltd employees during the induction process. Training on the risks associated with modern slavery in our supply chains is provided as needed. Our zero-tolerance approach is also conveyed to all suppliers, contractors, and business partners at the beginning of our relationships.
9. Approval
This statement is made in accordance with section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending December 31, 2022.
Revised September 2024
