Modern Salvery Policy
Modern Slavery Statement for Orangutan UK
Financial year ended 31/03/2025 Approved by the Board of Trustees / Governing Body on 31/03/2025
Organisation’s structure, business and supply chains
Orangutan TM Ltd is a UK-based registered company whose mission is to be a leading provider of growth services for private companies, public sector bodies and not for profits. Our operations include sales incentive, customer loyalty programmes, charity fundraising, training, events,lead generation. We source goods and services domestically and internationally to support our work, including (but not limited to) equipment, stationery, travel arrangements, promotional materials, and field supplies. In some instances our programmes and partners may engage with suppliers and contractors in other jurisdictions, including areas where risk of forced labour may be elevated.
Our policies on slavery and human trafficking
We are committed to ensuring that modern slavery and human trafficking do not take place in any part of our organisation or supply chains. We expect all our staff, volunteers, contractors and suppliers to adhere to high standards of ethical conduct and comply with applicable laws. We have adopted a policy on modern slavery as part of our code of conduct / procurement policy, which sets out our expectations of suppliers, contractors and partners to demonstrate that they operate ethically and fairly, with respect for human rights. Suppliers are required to confirm they do not engage in slavery, servitude, forced or compulsory labour, or human trafficking.
Due diligence processes
To identify and assess the risk of modern slavery and human trafficking, we:
Conduct a review of our supply chains and procurement practices, with particular focus on higher-risk goods or services (for example, goods manufactured in jurisdictions with weaker labour protections).
Include modern slavery considerations in our supplier onboarding and contract terms, where applicable.
Request that suppliers represent and warrant that they have not engaged in any form of slavery or human trafficking and that they will notify us immediately if any such issue arises.
We plan to monitor/audit supplier performance with respect to labour standards, and maintain a register of key suppliers for periodic review.
Encourage the reporting of concerns by staff, volunteers, partners or third parties, and provide a whistle-blowing mechanism (or equivalent) to raise issues confidentially and without fear of reprisal.
Risk assessment and management
We recognise that our exposure to modern slavery risk arises primarily through lower-tier supply chains overseas, subcontracting, and international travel/field-based operations where local labour and procurement standards may vary. Key risks identified include:
Procurement of goods (e.g., printed materials, promotional merchandise, field equipment) manufactured in jurisdictions with limited transparency in labour practices.
Local contracting in field operations where oversight may be more challenging.
Travel and logistics support suppliers engaged in countries with weaker labour protections.
To mitigate these risks, we:
Prioritise suppliers who can demonstrate audited labour standards or recognised ethical accreditation.
Where feasible, source goods and services from UK or EU providers with robust labour rights frameworks.
Include clauses in our contracts explicitly prohibiting forced labour, and request evidence of compliance.
Maintain open dialogue with our field partners about labour standards, and include modern slavery awareness in partner training and induction.
Effectiveness and performance indicators
We measure our performance and effectiveness in combating modern slavery by monitoring:
The number of suppliers who have signed our modern slavery compliance terms.
The number of procurement contracts reviewed for modern slavery risk during the year.
Whether any supplier has reported a modern slavery incident, and how promptly we responded and took corrective action.
The number of staff/volunteers who have received training or awareness-briefing on modern slavery and human trafficking.
Any audits or site visits carried out in high-risk jurisdictions, and findings thereof.
We commit to reviewing our policies and procedures annually and updating our statement accordingly.
Training and awareness
All staff and volunteers involved in procurement, contracting, partnerships or field operations are provided with training or briefing on modern slavery, human trafficking and how to recognise and respond to indicators of risk. We include modern slavery awareness in partner induction and require key suppliers to confirm receipt of our policy and expectations. We will continue to develop our training programme and incorporate feedback from stakeholders and external experts where appropriate.
Future commitments
In the coming year we intend to:
Extend our supplier due diligence totop 10 suppliers based on spend and map their labour practices more fully.
Conduct a survey of material supply chains in our next international field operation to benchmark labour conditions and identify improvement opportunities.
Review and enhance our contract templates to include updated modern slavery clauses, preferred language, and stronger enforcement / remediation provisions.
Increase staff/volunteer awareness by holding at least one dedicated session or workshop focussed on modern slavery and human trafficking across our field operations.
Publish our modern slavery statement online and link it to our procurement and supplier pages to increase transparency.
Approved by:
Name: Tim Peniston-Bird
Position: Managing Director
Date:31/02/2025
Signature: TH Peniston-Bird