2025 M O D E R N S L AV E RY S TAT E M E N T
At OKA, we believe every person has the right to work in safe, fair and respectful conditions. Modern slavery, forced labour and human trafficking are serious abuses of human rights, and we maintain a zero-tolerance approach to these practices in our operations and supply chain. As a business with a global supply chain, we recognise our responsibility to understand where risks may exist and to take appropriate action to prevent, identify and address them. This requires strong governance, clear supplier expectations, effective due diligence and ongoing collaboration with our suppliers. During 2025, we continued to maintain and strengthen the foundations of our responsible sourcing approach. 100% of our Tier 1 product suppliers have now signed our Supplier Code of Conduct, and we continued our mandatory employee training on modern slavery and ethical conduct, with 95% of our team completing the training during the year. These measures have reinforced clear expectations across our business and supply chain, while strengthening awareness of modern slavery risks and responsibilities.
WHAT IS MODERN SLAVERY? Modern slavery refers to serious forms of exploitation where a person is unable to refuse or leave due to threats, coercion, deception, abuse of power, or violence. Today, more than 50 million people worldwide are estimated to be living in situations of modern slavery, highlighting the scale of this global human rights issue. It can take many forms, including forced labour, debt bondage, forced marriage, slavery and slavery-like practices, human trafficking, and the worst forms of child labour.
We recognise that tackling modern slavery requires ongoing commitment and continuous improvement. In 2026, our focus will be on strengthening our supplier risk assessment process, enhancing due diligence across our supply chain, increasing supplier audit coverage, and continuing to build internal capability to manage human rights risks effectively. We remain committed to operating responsibly and transparently, and to working with our suppliers and partners to uphold the rights, dignity and wellbeing of workers throughout our value chain.
Mark Saunders Chief Executive Officer This statement has been approved by the Board of Directors of OKA Direct Ltd on 2nd September 2026 and is signed on its behalf by Mark Saunders, Chief Executive Officer, in accordance with Section 54 of the Modern Slavery Act 2015.
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CEO STATEMENT
This Modern Slavery Statement covers the following areas: 1
OUR COMMITMENT
2
OUR BUSINESS & SUPPLY CHAIN
3
GOVERNANCE & POLICIES
4
RISK ASSESSMENT & MANAGEMENT
5
DUE DILIGENCE PROCESSES
6
TRAINING & AWARENESS
7
MEASURING THE EFFECTIVENESS OF OUR APPROACH
8
OUR PRIORITIES FOR 2026
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CONTENTS
At OKA, we are committed to upholding the basic rights and freedoms that belong to everyone, 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. We maintain a zero-tolerance approach to modern slavery and human trafficking and are committed to taking steps to prevent these practices within our own operations and wider supply chain. We work collaboratively with our suppliers to understand how our products are made, strengthen working conditions, and help raise standards. 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 our business, ensuring that sustainability informs both our day-today 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 sets out the steps taken by OKA for the financial year ending 31st December 2025 to identify, assess and manage modern slavery risks, in accordance with Section 54 of the Modern Slavery Act 2015.
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OUR COMMITMENT
Founded in 1999, OKA (OKA Direct Ltd) is a leading UK interiors and lifestyle brand, creating thoughtfully designed furniture and home accessories that celebrate effortless, timeless style. Our collections are designed to bring beauty, comfort and character into the home, creating pieces to be lived with and loved for years to come. We work with skilled artisans, makers and skilled artisans and makers around the world, combining global inspiration with quintessentially British style to create collections that are distinctive, practical and made to last. Long-standing supplier relationships and close collaboration with our partners are a critical part of bringing our products to life. Today, OKA operates an omnichannel business comprising 15 UK retail stores, a dynamic e-commerce platform, a well-established trade department, and a bespoke Interior Design Service. We employ 200 people in the UK, China and India across our head office, retail locations, warehouse, call centre, and support offices. This includes our Asian Central Services teams in Ningbo, China and Delhi, India, who provide vendor and order management support, conduct factory visits, and maintain close working relationships with our suppliers. Their presence on the ground provides valuable operational oversight and helps support responsible sourcing practices across our supply chain.
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ABOUT OKA
OKA HQ: DIDCOT Retail stores 1
BATH
2
BICESTER
3
BROADWAY
4
CHELSEA, LONDON
5
FROXFIELD
6
GUILDFORD
7
HARROGATE
8
KINGSTON
9
KNUTSFORD
10
MARLOW
11
SUNNINGHILL
12
TUNBRIDGE WELLS
13
SOUTH GODSTONE
14
REDBRICK
15
NEWSCASTLE
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OUR RETAIL STORES
We source our products and packaging from 89 suppliers across 9 countries. Our two largest sourcing regions are China and India, representing 47% and 29% of our suppliers in 2025 respectively.
Countries we source from China / 42 Germany / 1 India / 26 Indonesia / 5 Italy / 5
Myanmar / 1 Netherlands / 2 United Kingdom / 5 Vietnam / 2
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OUR SUPPLY CHAIN
MODERN SLAVERY GOVERNANCE Overall accountability for sustainability, including human rights, ethical sourcing and modern slavery, sits with OKA’s Board of Directors and Chief Executive Officer. Implementation is led by our senior leadership team, including our Chief Customer Officer, alongside our Product Development, Quality Assurance, Sourcing and People teams. Potential human rights and labour-related risks are raised through appropriate internal management channels, with actions agreed and clear responsibilities assigned to ensure issues are addressed effectively. Within our operations, the People team is responsible for ensuring appropriate safeguards are in place for employees, while our Product Development, Quality Assurance and Asian Central Services teams work closely with suppliers to support engagement, oversight and due diligence.
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GOVERNANCE & POLICIES
We recognise that our greatest exposure to modern slavery risk lies within our product supply chain, where complex international sourcing networks can create heightened labour and human rights risks. To help manage this, OKA has internal and external policies in place that set clear expectations for our employees and suppliers. These policies support our approach to identifying, preventing and addressing modern slavery risks across our operations and supply chain. They are reviewed periodically to ensure they remain, effective and aligned with evolving best practice.
SUPPLIER CODE OF CONDUCT We have a Supplier Code of Conduct in place, which outlines our zero-tolerance approach to unethical practices within our supply chain and sets clear standards for the practices we expect suppliers to uphold within their own operations and wider supply chains. All new Tier 1 suppliers are required to agree to our Supplier Code of Conduct before entering a business relationship with OKA, and 100% of our Tier 1 product suppliers have signed the Code, a significant increase from 17% in 2024. The Supplier Code of Conduct covers key labour, human rights and responsible business topics including: — Forced and child labour — Working conditions — Health and safety — Discrimination, harassment and fair treatment — Subcontracting — Environmental protection — Animal welfare — Governance processes Our suppliers, their workers and subcontractors also have access to OKA’s Ethics Hotline, an independent confidential whistleblowing service through which concerns, including breaches of our Code of Conduct, can be raised safely and confidentially.
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OUR 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 clear standards for conduct, workplace behaviour and employee rights. These include our: — Code of Business Conduct — Anti-Bullying and Harassment Policy — Diversity, Equity and Inclusion Policy — Disciplinary Policy — Whistleblowing Policy — Grievance Policy — Health and Safety Policy — Anti-Bribery and Corruption Policy — Family Friendly Policy — Flexible Working Policy These policies provide employees with clear guidance on our expectations while working for and representing OKA, as well as their responsibilities to the business, colleagues, customers and partners. Above all, employees are expected to comply with the law, act with integrity in all matters, and be accountable for their actions. We encourage a culture of openness and speaking up across the business. Employees have various channels to raise concerns including to their line manager, the People team, directly with our CEO, or through our independent third-party whistleblowing hotline, where all reports are documented and escalated appropriately for review and action.
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PEOPLE POLICIES
OKA takes a risk-based approach to our due diligence, focusing our efforts on higher-risk sourcing geographies and supply chains where risks may be elevated due to factors including: — Subcontracting arrangements that reduce supply chain visibility — Use of temporary, contract or migrant labour — Variations in labour protections and enforcement across sourcing regions — Limited transparency beyond Tier 1 suppliers — Weak recruitment, employment or worker grievance controls within upstream supply chains While labour protections and regulatory oversight are generally stronger in the UK, US and Europe, modern slavery risks can still occur in all geographies. As a result, we maintain expectations across our entire supplier base while focusing enhanced due diligence where risks may be elevated, particularly in our key sourcing countries of China and India. We recognise that visibility beyond our Tier 1 suppliers currently remains limited and improving supply chain transparency remains an area of future focus.
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RISK ASSESSMENT & MANAGEMENT
Our due diligence efforts are centred on two key areas, our employees and our 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 directly employed by OKA in the UK and internationally. Whilst we consider the risk of modern slavery within our direct operations to be relatively low, we recognise the importance of raising awareness of modern slavery issues, helping employees understand key indicators, and ensuring they know where to seek support or raise concerns. Our Employee Handbook sets out our policies and expectations for all team members. These policies are provided to new starters as part of their onboarding, referenced during inductions, and made available to employees through our internal HR systems. In addition, our annual Code of Conduct training refreshes employees on our expectations in relation to ethical conduct, modern slavery and reporting concerns, with 95% of employees completing this training in 2025.
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DUE DILIGENCE PROCESSES
We have an extensive global supply chain for our products and recognise that this is where our greatest exposure to modern slavery and human trafficking risk exists. We expect our suppliers to operate to the same high ethical standards that we uphold ourselves. Our focus is on setting clear expectations, maintaining strong supplier relationships, and working collaboratively with suppliers to promote responsible business practices. Our due diligence is currently focused on our direct, Tier 1 product suppliers and, as our responsible sourcing approach matures, we aim to broaden our visibility and understanding of risks further upstream in our supply chain over time. Before beginning trading with a new supplier, our vendor onboarding process requires completion of a Modern Slavery Questionnaire to help us understand supplier management practices and performance in key areas, alongside agreement to our Terms and Conditions and Supplier Code of Conduct. In 2024, we introduced the Sedex platform to support our supplier due diligence processes and strengthen visibility of ethical risks within our supply chain. We continued working to onboard suppliers onto the platform in 2025, providing a strong foundation for future supplier engagement and risk management. In 2025, 40% of our top 25 suppliers have been audited, and a key focus for 2026 is increasing audit coverage. Where non-compliances or areas of concern are identified through supplier engagement, factory visits or audit findings, we work collaboratively with suppliers, our regional teams and, where appropriate, independent specialists to support corrective action and improvement. Our Asian Central Services teams in India and China play an important role in managing supplier relationships on the ground, carrying out factory visits, and supporting suppliers in meeting our expectations.
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DIRECT PRODUCT SUPPLIERS
As part of our commitment to preventing modern slavery, all employees are required to complete mandatory annual Code of Conduct training, which includes a dedicated module on modern slavery and human rights. This training is designed to build awareness of what modern slavery is, highlight key warning signs and risk indicators, and ensure employees understand how to raise concerns through the appropriate reporting channels. In 2025, 95% of employees completed this training, an increase from 77% in 2024, reflecting our continued focus on strengthening awareness and accountability across the business. We also continue to build internal understanding of supplier due diligence and supply chain risk management within teams involved in supplier engagement and oversight, including our Product Development, Quality Assurance and Asian Central Services teams.
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TRAINING & AWARENESS
To monitor the effectiveness of our approach, we track key indicators, including: — Percentage of Tier 1 product suppliers who have signed our Code of Conduct: 100% — % of top 25 suppliers with a SMETA audit: 40% — Annual Code of Conduct training completion rate: 95% — Number of whistleblowing reports relating to labour rights or modern slavery concerns: 0 — Number of calls made to OKA’s Ethics Hotline: 0 These indicators help us to understand where controls are working effectively and where further improvements are needed.
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MEASURING EFFECTIVENESS
rights requires ongoing focus, collaboration and continuous improvement. In early 2026, we refreshed our Sustainability Strategy and set the following As part of our commitment to combating modern slavery, all goals under our Human Rights and Labour Standards focus area: employees are required to complete a mandatory annual Code of Conduct compliance training, which includes a dedicated module — Maintain 100% Supplier Code of Conduct coverage across all Tier 1 on modern slavery. This module is designed to raise awareness product suppliers. about the definition of modern slavery, its key indicators, and the correct procedures to follow if any concerns arise. In 2024, 77% of — By the end of 2026, ensure 100% of our top 25 product suppliers have our employees successfully completed this training. undergone a SMETA audit and closed any identified non-compliances. In addition, we have been focusing on building out skillsets in our To support delivery of these goals, we will focus on strengthening our due Product Development, Quality Assurance, and ACS teams around diligence approach across the supply chain. This includes increasing audit Sedex and our due diligence processes. Looking ahead to 2025, we coverage, improving supplier management processes and enhancing our plan to run responsible sourcing training for these teams to further visibility of supplier practices to support greater transparency. strengthen our internal capabilities. We will also continue working closely with suppliers to address noncompliances and drive ongoing improvement, helping ensure our standards are clearly understood and consistently applied. These actions will strengthen oversight of our supply chain and continue raising standards across our entire business.
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PRIORITIES FOR 2026 SLAVERY TRAINING ON MODERN AND HUMAN TRAFFICKING We recognise that addressing modern slavery and protecting human