Modern Slavery Statement

Modern Slavery Statement for Financial Year 2021/22


Introduction

This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets out the steps that Oxford Products Ltd has taken, and is continuing to take, to ensure that modern slavery is not taking place within our business and anywhere within our supply chain.

Modern slavery encompasses slavery, servitude, human trafficking and forced labour.

Oxford Products Ltd has a zero-tolerance approach to any form of modern slavery.

We are committed to acting ethically and with integrity and transparency in all business dealings and are committed 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.


Our Business

Oxford Products Ltd designs, sources, develops and distributes a range of motorcycle and cycle accessories to retailers and wholesalers in the UK and around the world.

All design, development, purchasing and distribution is conducted from our Head Office in Witney, Oxfordshire (UK).

Oxford branded products are primarily sourced from the Far East (including China, Taiwan and Indonesia) and Asia (predominantly Pakistan & Bangladesh).

Oxford Products Ltd also buys and distribute third party branded product from EU based suppliers that can originate from many different countries. These suppliers all have strong ethical policies with systems and controls in place to safeguard against any form of modern slavery.


High Risk Areas

Oxford Products Ltd has approximately 100 suppliers who provide services and office consumables and supplies. These are all provided to the Witney head office and are not considered high risk.

Oxford Products Ltd has approximately 100 tier 1 suppliers of Oxford-branded products for distribution. All tier 1 suppliers are known and, travel restrictions permitting, are visited and a high proportion have some form of ethical audit. The high-risk areas are the factories in China, Pakistan and Bangladesh and the cornerstone of the company’s policy must be to seek out and verify through this branch of the supply chain that modern slavery is not occurring.


Our Policies

We operate several internal policies to ensure that we are conducting business in an ethical and transparent manner.
These include:
Recruitment Policy.
We operate a robust recruitment policy, including conducting eligibility to work in the UK checks for all employees to safeguard against human trafficking or individuals being forced to work against their will.
Whistleblowing Policy.
We operate a whistleblowing policy so that all employees know that they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisal.
Supplier audits.
We believe that any factory producing Oxford-branded goods should be visited and assessed by an officer of the company who is appropriately trained to confirm that modern slavery is not taking place.


Our Next Steps

Anti-slavery policy

We will continue to develop a policy which sets out the organisation’s stance on modern slavery and explains how employees can identify any instances of this and where they can go for help.

Our anti-slavery policy will form part of our contract with all suppliers and they will be required to confirm that no part of their business operations contradicts this policy.

We will conduct due diligence on all suppliers before allowing them to become a supplier. This due diligence includes an online search to ensure that particular organisation has never been convicted of offenses relating to modern slavery and on-site audits which include a review of working conditions.

In addition to the above, we will require that they confirm to us that:

• They have taken steps to eradicate modern slavery within their business.
• They hold their own suppliers to account over Modern Slavery.
• They pay their employees any prevailing minimum wage applicable within their country of operations.
• Understand that we may terminate the contract at any time should any instances of modern slavery come to light.


Training

We regularly conduct training for our procurement/buying teams so that they understand the signs of modern slavery and what to do if they suspect that it is taking place within our supply chain.

Our Performance Indicators

We will know the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain if:
• No reports are received from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified.


Approval for this statement

This statement was approved by the Board of Directors on 29th March 2022.