2024 MODERN SLAVERY STATEMENT
OUR COMMITMENT
At OKA, we are committed to upholding the basic rights and freedoms that belong to all human beings, regardless of race, sex, nationality, ethnicity, or any other status. These include the right to life and liberty, freedom from slavery and torture, freedom of opinion and expression, and the right to work and education.
Across our operations and supply chain, we recognise our responsibility to identify and address human rights risks. We work collaboratively with our suppliers to understand their craft and processes, aiming to raise standards and working conditions across our entire value chain.
Since 2019, as a signatory of the United Nations Global Compact, OKA has aligned itself with globally recognised principles on human rights, labour, the environment, and anti-corruption. This commitment is embedded across all levels of our business, ensuring that sustainability informs both our day-to-day practices and long-term strategic decisions.
We fully support legislation designed to prevent modern slavery and human trafficking, including the Transparency in Supply Chains Provision (Section 54) of the UK Modern Slavery Act (2015). This Statement outlines our approach to preventing modern slavery in our operations and supply chain for the financial year ending December 31st 2024. It allows us to share the progress we’ve made, the challenges we face, and the improvements we strive for.
This Modern Slavery Statement covers the following areas:
1 OUR COMPANY STRUCTURE AND SUPPLY CHAIN
2 POLICIES IN RELATION TO SLAVERY AND HUMAN TRAFFICKING
3 DUE DILIGENCE PROCESSES
4 RISK ASSESSMENT AND MANAGEMENT
5 TRAINING ON MODERN SLAVERY AND HUMAN TRAFFICKING
WHAT IS MODERN SLAVERY?
Modern slavery affects over 50 million people worldwide. It is an umbrella term that refers to situations of exploitation that a person cannot refuse or leave because of threats, violence, coercion, deception, and/or abuse of power.
The impact of modern slavery is vast, and it impacts on us all, while often being hidden in plain sight. It includes forced and compulsory labour, debt bondage, child labour, forced marriage, slavery and slavery-like practices, and human trafficking.
CEO STATEMENT
Modern slavery has no place in society or business, yet it remains a global challenge, particularly within complex supply chains that span multiple regions and industries. At OKA, we recognise that the responsibility to prevent modern slavery is fundamental to how we work.
This year, I’m proud of the work we have done to enhance our due diligence process. Having become a Sedex member, we now have access to a robust platform to track our suppliers’ ethical performance. This allows us to take a more proactive approach in identifying and addressing risks, ensuring that we are continuously working towards higher standards with our suppliers.
We know that tackling modern slavery requires collaboration, accountability and long-term commitment. We will continue to embed these principles across our business, working closely with suppliers, partners, and other stakeholders to protect workers’ rights and promote fair and safe working conditions.
We will continue to work hard to ensure that all departments work together to uphold our commitments, safeguarding the well-being of our teams and those in our global supply chain.
We look forward to sharing our continued progress with you.
Mark Saunders CEO
ABOUT OKA
Founded in 1999, OKA (OKA Direct Ltd) is a leading UK high-end interiors and lifestyle brand. Synonymous with good taste and excellent style, we design unique collections of furniture and accessories that inspire practical living and effortless entertaining. For over two decades we have furnished homes all over the world.
Our omnichannel business model combines a dynamic ecommerce platform, a portfolio of retail stores, a well-established trade department, and a bespoke Interior Design Service. Headquartered in Oxfordshire, OKA employs 211 people in the UK, China and India across our head office, retail locations, warehouse, distribution centre, call centre, and support offices.
We maintain a presence on the ground through our Asian Central Services (ACS) teams in Delhi (India) and Ningbo (China). These teams provide vendor and order management support services, including conducting factory visits and fostering strong relationships with our suppliers.
Our business includes:
— 12 UK stores supported by an Interior Design Service
— A well-established online platform
— A seasonal mail order magazine, available in both print and digital formats
— A Trade department servicing property developers, interior designers and hotels worldwide
OUR RETAIL STORES
OUR SUPPLY CHAIN
We source our products and packaging from 144 suppliers in 14 countries. Our two largest sourcing regions are China and India, which accounted for 38% and 34% of our productrelated purchases in 2024 respectively.
We work closely with our suppliers to champion our sustainability vision, keeping people and the planet at front of mind from designing collections, to sourcing materials, and producing, packaging and delivering our products into our customers’ homes.
POLICIES
IN RELATION TO SLAVERY AND HUMAN TRAFFICKING
As a certified B Corp, OKA Direct Ltd’s Articles of Association commit us to benefiting people and the planet, not just shareholders. We recognise that our greatest exposure to modern slavery lies within our product supply chains, and we are taking steps to minimise this risk.
We have internal and external policies in place to support our human rights risk management processes. These policies are continuously reviewed against best practices from industry peers and guidance from external organisations.
SUPPLIER CODE OF CONDUCT
We have a Supplier Code of Conduct in place, which outlines our zerotolerance approach to unethical practices within our supply chain and sets out our expectations and the principles that we expect our suppliers to follow in their business and supply chain. Our Supplier Code of Conduct is based on best practice standards relating to ethical trade, human rights and decent working practices.
We set high standards of responsible and ethical behaviour in our own operations and expect the same commitment fromour suppliers.
All new Tier 1 suppliers are required to agree to our Supplier Code of Conduct before entering into a business relationship with us. The Code covers key people-related areas such as forced and child labour, working conditions, health and safety, subcontracting and discrimination. It also covers environmental protection and animal welfare practices, and governance processes. 19% of our Tier 1 suppliers have signed our Code of Conduct.
Our suppliers, their workers, and subcontractors have access to OKA’s Ethics Hotline, an independent, confidential whistleblowing service to raise any concerns confidentially, including any breaches of our Code of Conduct.
PEOPLE POLICIES
At OKA we believe that everyone has a part to play in operating with integrity, honesty and fairness.
The principles outlined in our Employee Handbook and core People Policies establish minimum standards in key areas. These policies include our Anti Bulling and Harassment Policy, Disciplinary Policy, Whistleblowing Policy, Grievance Policy, and Health and Safety Policy. Our People Policies are shared with all employees and are available via our Internal Communications Platform.
The policies provide clear guidelines to all employees regarding our expectations while working for and representing OKA, as well as their responsibilities to the company, customers, and business partners. Above all, employees are expected to comply with the law, act with integrity and honesty in all matters, and be accountable for their actions.
We encourage a culture of openness within the business. OKA employees have various channels to voice concerns, including through their line manager, The People Team or directly to our CEO. Additionally, we offer an independent whistleblowing hotline, managed by a third party, where all reports are documented and escalated to a member of the OKA Senior Leadership team.
The Board regularly monitors the effectiveness of these policies and reviews their implementation, ensuring that they remain suitable and adequate. Internal control systems and procedures are subject to regular audits to provide assurance that they effectively manage adherence to the Code of Business Conduct.
DUE DILIGENCE PROCESSES
Our due diligence efforts are focused across two key groups, our internal team and direct product suppliers, to assess and address the potential risks of slavery and human trafficking within our operations and supply chain.
OUR TEAM
This includes everyone who is directly employed by OKA in the UK and around the world. Whilst our risks are relatively low in this area, our priority is raising awareness of modern slavery issues, indicators and information on where to seek support.
Our Employee Handbook sets out our policies and expectations of all our team members. These policies are provided to new starters with contracts and are referenced in inductions as well as being available on our accessible HR system. Our annual Code of Conduct training refreshes employees on our expectations in relation to modern slavery.
DIRECT PRODUCT SUPPLIERS
We have an extensive supply chain for our products and recognise that this is where our greatest risk to modern slavery and trafficking exists. We expect our product suppliers to operate to the same standards that we uphold ourselves. Our focus is on ensuring that we set out clear expectations, and engage and collaborate with our suppliers.
Our due diligence is currently focused on our direct, Tier 1 suppliers, and as we mature our approach we will seek to map and broaden our due diligence to Tier 2 suppliers.
Before beginning trading with a new supplier, as part of our vendor on boarding programme we require completion of our Modern Slavery questionnaire to understand their management practices and performance in key areas, and for our Terms and Conditions and Supplier Code of Conduct to be signed.
This year we started using the Sedex platform to improve our risk identification and assessment of our supply chain, and more effectively manage audit compliance of our factories on an ongoing basis.
We are currently working to onboard all our suppliers onto the platform. We have 98 suppliers onboarded to date, which is 68% of our total supplier base. Our target is for all high-risk suppliers to be audited with a third-party SMETA audit. 44% of our top 25 suppliers by spend currently hold a third-party audit.
If we identify any non-compliance or areas of concern through our supplier audits and factory visits, we work with our local regional teams, suppliers and also independent specialists if required to address them. Our Asian Central Services team operates on the ground in India and China to manage and support our suppliers in these countries.
RISK ASSESSMENT AND MANAGEMENT
We take a risk-based approach to due diligence, focusing our efforts on suppliers with the highest risk levels based on their location, industry, and our business spend.
Suppliers based in the UK, US, and Europe generally present a lower risk. Therefore, our due diligence and supplier engagement efforts are primarily concentrated in China and India, where we source a significant portion of our materials.
As we integrate Sedex into our responsible sourcing programme we will be utilising insights from the platform to enhance our understanding of supply chain risks and implement more targeted due diligence and supplier management processes.
TRAINING ON MODERN SLAVERY AND HUMAN TRAFFICKING
As part of our commitment to combating modern slavery, all employees are required to complete a mandatory annual Code of Conduct compliance training, which includes a dedicated module on modern slavery. This module is designed to raise awareness about the definition of modern slavery, its key indicators, and the correct procedures to follow if any concerns arise. In 2024, 77% of our employees successfully completed this training.
In addition, we have been focusing on building out skillsets in our Product Development, Quality Assurance, and ACS teams around Sedex and our due diligence processes. Looking ahead to 2025, we plan to run responsible sourcing training for these teams to further strengthen our internal capabilities.
CONCLUSION
We are committed to operating ethically and sustainably, principles that are woven into our core brand values and affirmed by our B Corp certification. Transparency is central to our approach, creating accountability and demonstrating our progress.
This annual statement, prepared in compliance with section 54 of the Modern Slavery Act 2015, highlights our ongoing efforts to combat slavery and human trafficking.
We look forward to continuing to build on our foundations, driving meaningful change and strengthening our practices in the years ahead.
TRAINING ON MODERN SLAVERY AND HUMAN TRAFFICKING
As part of our commitment to combating modern slavery, all employees are required to complete a mandatory annual Code of Conduct compliance training, which includes a dedicated module on modern slavery. This module is designed to raise awareness about the definition of modern slavery, its key indicators, and the correct procedures to follow if any concerns arise. In 2024, 77% of our employees successfully completed this training.
WHAT’S NEXT?
In addition, we have been focusing on building out skillsets in our Product Development, Quality Assurance, and ACS teams around Sedex and our due diligence processes. Looking ahead to 2025, we plan to run responsible sourcing training for these teams to further strengthen our internal capabilities.
As part of our Sustainability Strategy, we have set a goal to work with our suppliers and artisans on collaborative programmes to continually improve working conditions, focusing on areas of non-compliance by 2030. This is an ongoing goal, with progress towards it demonstrated within this statement.
For 2025, we are focused on the following areas:
— Embedding the use of Sedex across our supply chain to enhance transparency and monitor supplier practices
— Conducting regular audits, managing non-compliances, and supporting suppliers to implement necessary improvements
— Strengthening our risk assessment process and effectively targeting our due diligence efforts on areas of greatest risk
— Upskilling our Asian Central Services (ACS) team on social compliance issues while expanding our on-the-ground presence in key sourcing regions to better support and oversee our supply base