Modern Slavery Report US

MODERN SLAVERY STATEMENT 2023

At OKA, we acknowledge the basic rights and freedoms that are inherent to all human beings regardless of race, sex, nationality, ethnicity, language, religion, or any other status. Human rights include the right to life and liberty, freedom from slavery and torture, freedom of opinion and expression, the right to work and education, and many more. Across both our own operations and our supply chain, we aim to positively impact the communities in which we operate—our stakeholders and customers that we serve, through how we work as a business.

As a signatory of the United Nations Global Compact since 2019, OKA is committed to respecting internationally recognized human rights. Our commitment is supported by our governance structure and policies, which embed sustainability throughout our business and supply chain in both day-to-day and strategic decisions.

WHAT IS MODERN SLAVERY?

Modern slavery is a growing global problem that directly affects over 50 million people today. Modern slavery refers to situations of exploitation in which a person possesses or controls another person in such a way as to significantly deprive that person of their individual liberty, with the intention of exploiting that person through their use, profit, transfer or disposal.

Modern slavery is an overarching term used to describe its various forms:

• Slavery - a situation where a person exercises (perceived) power of ownership over another person.

• Human trafficking - a process of bringing a person into a situation of exploitation through a series of actions, including deceptive recruitment and coercion.

• Forced and compulsory labor - any work or services which people are not doing voluntarily, and which is exacted under a threat of some form of punishment.

• Bonded labor - any work or services demanded as a means of repayment of a debt or a loan.

As part of our continued commitment to ensuring ethical working conditions in our supply chain and operations, we fully support the legislation put in place for the prevention of modern slavery and human trafficking, including UK legislation: Transparency in Supply Chains Provision Section 54 of the Modern Slavery Act (2015), and USA California legislation: The California Transparency in Supply Chains Act SB 657. Our annual Modern Slavery Statement addresses these requirements, and outlines the steps taken by OKA during the financial year ending 2023 to prevent modern slavery and human trafficking.

We recognize that this is an important issue and are committed to driving continuous improvements within our supply chains and operations, and to supporting stakeholder and industry level activity to eradicate modern slavery. We are aware that modern slavery is too widespread and complex

for any business to tackle alone, and we are committed to collaborating with other organizations to address the highest potential risk areas and improve standards for workers in our value chain. This is a long-term issue with no quick solutions and a journey to which we are committed.

We work hard to ensure that all departments of our organization work together to uphold our commitments, which will serve to protect our teams and the people working in our supply chain around the world.

We look forward to sharing our continued progress with you.

Mark Saunders, CEO

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 and risk assessment

4. Training on modern slavery and human trafficking

Our Company Structure & Supply Chain

OKA (OKA Direct Ltd) is a global furniture and homeware omnichannel retailer. Founded in 1999, it is a leading high-end interiors lifestyle brand in the UK and US, creating exquisite collections of furniture and décor that are designed to inspire practical living and effortless entertaining. We employ over 250 people across our offices, warehouses, and stores. We also have a small team of employees working in regional offices in China who visit local supplier factories in the regions.

The business model includes:

1. 13 strategically located UK stores as well as 3 US stores.

2. A well-established online platform.

3. A mail-order catalogue, which is printed seasonally and digitized across multiple platforms.

4. A Trade department servicing property developers, interior designers and hotels across the world.

Supply Chain

We source our products and packaging from over 130 suppliers in the following countries, with 49% from China and 33% from India.

The countries that we work with are listed below.

Current suppliers: 136

1 CHINA

2 INDIA

3 UK

4 INDONESIA

5 LITHUANIA

6 VIETNAM

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 understand that our biggest exposure to Modern Slavery is in our product supply chains and we have taken actions to minimize the risk of Modern Slavery. The responsibility for human rights due diligence sits with our board members which includes our CEO, Chief Financial Officer and the executive board. Their work is supported by our Global Operations Director. Any potential risks to the business are discussed at meetings with the Senior Leadership team and action plans agreed.

We have developed and distributed our Supplier Code of Conduct emphasizing our commitment to doing business with zero tolerance for unethical practices in our supply chain. Our Code is based on best practice standards relating to ethical trade, human rights, and decent working practices. We have set high standards of responsible and ethical behaviors in our own operations and expect a similar commitment from our suppliers. Our code of conduct includes sections on human rights, child labor, working conditions, health and safety and environmental protection. We are continuously reviewing our policies and

processes against the best practice from peers and guidance from expert organisations.

We work closely with our direct suppliers (1—product manufacturers) to build long term relationships to support the transparency of our supply chain. We currently audit our Tier 1 suppliers utilizing the SMETA methodology and will be looking to expand our audit program to Tier 2 suppliers in the future. It is also a requirement that all our Tier 1 suppliers commit to our Supplier Code of Conduct.

Supplier Code of Conduct

The Supplier Code of Conduct sets out our values, responsibilities, and obligations with regards to the handling of certain ethical situations commonly faced by the company and employees. This policy was updated in 2022. The board will monitor the effectiveness and review the implementation of this policy, regularly considering its suitability, adequacy and effectiveness. Any improvements identified will be made as soon as possible. Internal control systems and procedures will be subject to regular audits to provide assurance that they are effective in managing the Supplier Code of Conduct effectively.

People Policies

At OKA we believe that everyone has a part to play in upholding our commitment to respecting human rights and tackling modern slavery. Our commitment is to operate with integrity, honesty and fairness, including our compliance with all applicable laws, and for all employees to be accountable for their actions.

Our aim is to identify any concerns or issues employees might have and take the appropriate measures to remedy the situation. We believe that encouraging a culture of openness within our organization will help to prevent malpractice. There are various ways for OKA employees to voice their concerns, including internally through their line manager, the People Team, their manager or directly to our CEO. We have an independent whistleblowing hotline manned by a third party with all data being captured and assigned to a member of the OKA Senior Leadership team.

Our People Policies detail the expected standards of conduct and behavior within the organization that all employees are expected to observe. Our People Policies are shared with all employees and are available via our Internal Communications Platform. In 2023, we reviewed and relaunched our core People Policies (Anti Bullying and Harassment, Grievance, Disciplinary, Performance & Development, Whistleblowing, Health and Safety) to ensure they reflected best practice and inclusivity for all employees.

In 2023 we rolled out mandatory training on our Supplier Code of Conduct which all employees are required to complete annually.

Due diligence processes, risk assessment and management

We set out to identify the extent of any slavery and human trafficking in our supply chains by looking at the following groups:

OUR TEAM

This includes everyone who is directly employed by OKA globally. While our risks are relatively low in this area, our priority is to raise awareness of modern slavery issues, indicators, and information on where to seek support.

DIRECT PRODUCT SUPPLIERS

We have an extensive supply chain for our products and recognize that this is where our greatest risk to modern slavery and trafficking exists. To mitigate this risk, we seek to partner with suppliers who carry out their manufacturing in accordance with the highest ethical standards and comply with all relevant laws, regulations, and licenses.

All current suppliers and potential new suppliers are issued, and are expected to comply with, our Supplier Code of Conduct, prior to them commencing a working

relationship with OKA. This Supplier Code of Conduct sets out our expectations and fundamental principles that we expect each supplier to extend into their business and their own supply chain.

In addition, we use we use third-party auditors to carry out social audits (SMETA) of our factories. We currently work with 136 suppliers to produce OKA products. By the end of 2023, 84% of our top 25 suppliers by spend currently hold a third-party audit (accounting for 88% of our product purchases).

We regularly visit our factories to ensure we are monitoring our suppliers. If we identify any areas of concern through our supplier audits and assessments, we immediately work with our local regional teams, suppliers and sometimes also independent specialists if required to address them. In 2021 we introduced annual supplier appraisals. These appraisals conduct a systematic review of all relevant aspects of OKA’s supplier performance and relationships globally, improving supply chain transparency and enabling OKA to strengthen relationships with suppliers by creating a forum for discussion, identifying performance gaps, and working on resolution plans together.

Training on modern slavery and human trafficking

To assess the effectiveness of our modern slavery measures we will continue to monitor our factories moving forward. In 2023 we rolled out mandatory online training modules on modern slavery to all our staff globally; they will be required to complete this annually thereafter.

We understand that it is important to listen to and offer workers the opportunity to have their views heard. We are focused on improving transparency in our supply chain; we are holding regular review meetings to improve communication, as well as to build and maintain a strong supplier base by structuring and streamlining the entire supplier lifecycle. We are committed to working with each of our suppliers on this issue to support them with training where it is required.

Conclusion

We are committed to operating ethically and sustainability, and this is woven into our core brand values. We believe transparency is key to ensuring the public that we are doing our best as an ethical corporate citizen. In publishing our annual statement for slavery and human trafficking, made in compliance with Section 54 of the Modern Slavery Act (2015) and the California Transparency in Supply Chain act SB 657, we are ensuring we are playing a key role in the fight against it. This statement is intended to fulfil the legal requirement for a slavery and human trafficking statement on behalf of all companies within the OKA group. Our efforts against slavery and human trafficking complement our broader Sustainability Policy.

We are focused around continuing to develop the following areas:

• Continuing our program of supplier auditing in line with internal targets.

• Gaining further knowledge of key areas of improvement in both awareness and risk in our supply chain.

• Developing Supplier Code of Conduct and it into languages that are specific to countries that we work with.

• Improving our knowledge of both our direct and indirect suppliers to ensure improved transparency and reporting in the future.

• Establishing a framework for organization accountability to allow for raising issues, making suggestions, voicing grievances and reporting slavery and human trafficking.