Modern Slavery Policy

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, including slavery, servitude, forced and compulsory labour, and human trafficking - all of which involve the deprivation of a person’s liberty for personal or commercial gain.

Ostratto Ltd (“Ostratto”, “we”, “our”, “us”) adopts a zero-tolerance approach to modern slavery. We are committed to acting ethically and with integrity in all our business dealings and relationships, and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place in our business or our supply chains.

This policy applies to all persons working for Ostratto or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, consultants, third-party representatives, and business partners.

This policy does not form part of any employee’s contract of employment and may be amended at any time.

We are committed to ensuring transparency within our business and throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015.

We expect the same high standards from all our contractors, suppliers, and other business partners. As part of our contracting processes, we include specific prohibitions against the use of forced, compulsory, or trafficked labour, or anyone held in slavery or servitude, whether adults or children.

We also expect our suppliers to hold their own suppliers to these same standards.

4.1 Overall responsibility for ensuring this policy complies with legal and ethical obligations rests with the Company’s leadership.

4.2 The Managing Director has primary and day-to-day responsibility for implementing this policy, monitoring its effectiveness, dealing with any related queries, and auditing internal controls to ensure they remain effective.

4.3 Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are provided with regular training on identifying and preventing modern slavery.

4.4 All employees are encouraged to comment on this policy and suggest improvements. Comments and queries should be addressed to the Managing Director.

5.1 You must read, understand, and comply with this policy.

5.2 The prevention, detection, and reporting of modern slavery in any part of our business or supply chains is the responsibility of everyone working for or under Ostratto’s control.

5.3 You are required to avoid any activity that might lead to or suggest a breach of this policy.

5.4 You must notify your line manager or a Company Director as soon as possible if you believe or suspect that a conflict with this policy has occurred or may occur in the future.

5.5 You are encouraged to raise concerns about any issue or suspicion of modern slavery in any part of our business or our supply chains, at the earliest possible stage.

5.6 If you believe or suspect that a breach has occurred, you must report it immediately to your line manager or a Company Director, or via our Whistleblowing Policy.

5.7 Ostratto will, where appropriate, provide support and guidance to suppliers to help them address coercive, abusive, or exploitative practices in their operations or supply chains.

5.8 If you are unsure whether a particular act, treatment of workers, or working condition may constitute modern slavery, you must raise it with your line manager or a Company Director.

6.1 Ostratto is committed to encouraging openness and will support anyone who raises genuine concerns in good faith, even if they turn out to be mistaken.

6.2 We are committed to ensuring that no one suffers any detrimental treatment as a result of reporting a suspicion of modern slavery in good faith.

6.3 Detrimental treatment includes dismissal, disciplinary action, threats, or other unfavourable treatment connected to raising a concern.

6.4 If you believe you have suffered any such treatment, you should inform your line manager immediately. If the matter is not resolved, employees may raise the issue formally through the Grievance Procedure detailed in the Employee Handbook.

7.1 Training on this policy, and on the risk of modern slavery in our business and supply chains, forms part of the induction process for all individuals working for Ostratto.

7.2 Our zero-tolerance approach must be communicated to all suppliers, contractors, and business partners at the start of our business relationship with them and reinforced where appropriate thereafter.

8.1 Any employee who breaches this policy will face disciplinary action, which may include dismissal for misconduct or gross misconduct.

8.2 Ostratto may terminate its relationship with any individual, supplier, or organisation working on its behalf if they breach this policy or fail to provide evidence of compliance.

This policy will be reviewed annually by the Managing Director to ensure it remains relevant, effective, and compliant with current legislation.