- This statement highlights OxFORD Asset Management’s approach to understand all potential modern slavery risks related to its business, and the steps it has taken to ensure that slavery is not taking place in any of its supply chains or in any part of its business, in compliance with s54 of the Modern Slavery Act 2015.
- OxFORD Asset Management (the “Firm”) is based in the UK, and is an investment adviser to a fund based outside the UK. However, a number of the Firm’s regular suppliers are UK based. They include companies involved in catering, facilities management, building management, floristry, security, electrical and mechanical contracting, workplace hygiene and textiles manufacturing. It is recognised that these industries may be susceptible to modern slavery and human trafficking to varying degrees.
- The Firm recognises its responsibility to prevent slavery and human trafficking, and seeks to ensure there is no slavery or human trafficking in its own business or in its supply chains.
- The Firm has conducted a survey of its regular suppliers to check that there is no modern slavery or human trafficking in its supply chain. All ten of these suppliers responded to the survey by completing a questionnaire.
- None of the Firm’s suppliers is required themselves to prepare its own transparency in supply chains statement.
- Three of the ten suppliers were members of at least one construction industry federation. All suppliers confirmed that they pay their UK staff at least the national minimum wage.
- None of the suppliers has overseas branches, including any bases in high-risk countries such as Slovakia, Romania, Poland, Lithuania or Hungary.
- Each of the suppliers that does use sub-contractors checks the identity of the sub-contractors’ employees working on-site.
- Although only two out of ten suppliers had previously asked their own suppliers if they have anti-modern slavery or anti-human trafficking provisions in their own organisations or supply chains, of the remaining eight, one has now added that question to its approved supplier questionnaire. Half of the suppliers have ethical or Corporate Social Responsibility policy standards for suppliers.
- The vast majority of the Firm’s suppliers do have anti-modern slavery or anti-human trafficking measures in their procurement policies.
- None of the suppliers has any reason to suspect that there is slavery or trafficking in its supply chain.
- The responses to the questionnaire, combined with the organisation’s relationships with and knowledge of its suppliers, have satisfied the Firm that there is no slavery or human trafficking in its supply chain. It is further satisfied that there are effective procedures in place to check that any occurrence of slavery or human trafficking could be identified by the Firm or by its suppliers.