Modern slavery is a serious crime that violates basic human rights. It can take various forms such as forced labour, servitude, slavery, and human trafficking. All of these involve a person's liberty being taken away by another to exploit them for personal or commercial gain
At Oxwash, we are committed to fighting against slavery and human trafficking by following the guidelines of the Modern Slavery Act 2015. This statement outlines the measures we take to prevent modern slavery and human trafficking in our supply chain.
Organisational structure
Oxwash provides sustainable laundry and dry cleaning to commercial customers nationwide in the UK, with operations in Swindon and London.
Oxwash has no ownership interests in the supply chain but cooperates with approximately 20 key suppliers and 10 subcontractors across the UK and Europe. Our Supplier Code of Conduct sets out our requirements to our suppliers, and we regularly audit our suppliers to ensure they comply with our requirements.
Oxwash recognises that a collaborative approach is needed, we work directly with our suppliers to build capacity and to make long-term improvements at their factories and organisations.
Policies concerning Slavery and Human Trafficking
Our Supplier Code of Conduct sets high standards for our suppliers and subcontractors. These standards ensure that human rights and labour rights are respected and upheld in their organisations. We require our suppliers to comply with regulations regarding living wages, child labour, working conditions, and labour rights.
Our Human rights and Modern slavery policy applies to all employees, workers, and suppliers, adhering to international standards. We strive to avoid causing harm, address violations, and actively promote human rights throughout our reach. From safe working conditions to fair wages and equal treatment, Oxwash prioritises the dignity of every individual. Both these policies are constantly reviewed and openly accessible, showcasing our commitment to ethical and responsible business practices.
Due Diligence Process
We seek to minimise the adverse impacts of our business in our operations as well as our supply chain. Our due diligence procedures are based on the UN Guiding Principles on Business and Human Rights and the International Labour Organisation principles.
Identify, prevent and mitigate any risk of adverse impact on human rights in all our operations and business relationships
Consider any adverse impact we may cause or contribute to through our supply chain practices, as well as the adverse impact we may cause or contribute to within our business
Remediate any direct or indirect adverse impact that our business operations have on human rights
Promote respect for human rights among our employees, partners, suppliers and other business relations
Report on and account for our work with human rights continuously and once a year
Based on our due diligence process we have identified that the highest risk of violating human rights is in some areas of our supply chain. We have identified forced labour, discrimination and child labour to be forms of slavery and human trafficking that could occur.
Key Performance Indicators:
In addition to our due diligence process, we employ key performance indicators to measure progress in tackling modern slavery. These indicators include:
% of suppliers audited against our Code of Conduct: 70% (target)
# of identified breaches of our Code of Conduct related to modern slavery: 0 (target)
# of suppliers provided with capacity-building training on modern slavery: 10 (target)
% of employees trained on modern slavery: 90% (target)
# of reported incidents of modern slavery: 0 (target)
Identification of High-Risk Areas in the Business and Supply Chains
Within our supply chain, the highest risks are associated with the procurement of materials and services. The complexity and global nature of our supply chain, which involves approximately 20 key suppliers and 10 subcontractors across the UK and Europe, pose challenges in monitoring and ensuring adherence to ethical standards. The highest-risk areas include regions where labour regulations may be less stringent, increasing the likelihood of forced labour, discrimination, and child labour.
Moreover, our engagement with subcontractors in the supply chain, especially those involved in the manufacturing and transportation of materials, represents another critical risk area. These subcontractors may operate independently, making it essential for us to strengthen oversight and ensure compliance with our Supplier Code of Conduct.
In addition, the procurement, recruitment, and supply chain management processes within our own operations are identified as high-risk activities. These activities demand heightened vigilance to prevent any inadvertent contribution to or complicity in modern slavery. It is crucial to focus on training and capacity building for staff members involved in these activities, equipping them with the knowledge and tools to identify and address potential risks effectively.
Prevention and effectiveness training
To prevent any negative impact on human rights in our supply chain, we take necessary steps to improve working conditions for workers and protect their rights. We conduct third-party audits or our audits by visiting our suppliers to ensure that they comply with our Code of Conduct. This way, we can identify any issues that need to be prevented, mitigated, or remedied, and strengthen our knowledge about where and how to engage further. Our goal is to create a strong foundation for management and workers, which they can use in their joint efforts to ensure workers' rights in factories, hubs, and organisations in our supply chain.
Training and Capacity Building
Oxwash is committed to providing training for all staff members on slavery and human trafficking. This training will cover:
What slavery and human trafficking are
The signs of slavery and human trafficking
How to report slavery and human trafficking
Oxwash's policies and procedures on slavery and human trafficking
When new staff members join Oxwash, they will receive training as part of their induction process. Regular training will also be provided to existing staff members. Staff members who carry out high-risk activities, such as procurement, recruitment, and supply chain management, will also receive specific training.
To ensure that the training is accessible and effective, Oxwash will make it available to all staff members, monitor the effectiveness of the training and make necessary improvements.