Modern Slavery and Human Trafficking Statement

Introduction from the CEO of Onebright Ltd

It continues to be a priority for Onebright to ensure that we trade ethically, source responsibly and work to prevent slavery and human trafficking throughout our organisation and in our supply chain. This statement highlights the key activities we have undertaken during this financial year to combat slavery in our organisation and supply chain.

Our understanding is that the risk of any part of our business and supply chains being involved in slavery and human trafficking is low, in light of several factors including our business model, but we continue to monitor potential risk areas across our business.

Our company

Onebright Ltd is a healthcare provider of occupational health, psychological health, wellbeing and specialist training services for corporates and individuals, based in the UK and the Republic of Ireland.

Our policies on slavery and human trafficking

We have policies in place that underpin our commitment to ensuring there is no slavery or human trafficking in our supply chains or in any part of our business. We are implementing new procedures this year to ensure we continually review and update such compliance policies in line with changes to legislation and identified risks.

Onebright’s Anti-Slavery and Human Trafficking Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking does not take place anywhere in our operations and supply chain. We also have the following policies in place which support this commitment:

• External Supplier Management Policy
• Environmental, Social and Governance Policy
• Safeguarding Policy

Due diligence processes for slavery and human trafficking

At Onebright, the compliance team involved in monitoring and enforcement includes Compliance, HR, Safeguarding and the Executive Team. Any risks identified are documented in our corporate risk register. This will be reviewed by the Onebright Executive Team quarterly with appropriate mitigants assigned to relevant employees.

We encourage all staff members to report on matters relating to slavery or human trafficking and have a robust Whistleblowing Policy to support this.

We expect all individuals and businesses that supply goods and services to us to conduct due diligence on their own supply chains and evaluate risks relating to slavery and human trafficking. We will take appropriate action within the legal and regulatory framework if our suppliers fail to prevent slavery and human trafficking in their supply chains.

Further steps

To ensure we continue to be effective in preventing slavery and human trafficking in our business and supply chain, in the next financial year we intend to implement new training modules to further support our staff in understanding and spotting the warning signs of slavery and human trafficking. We are also working on a new Supplier Code of Conduct which will set out in more detail the standards we expect of our suppliers.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 31 December 2023. It was approved by the board on 7th November 2024.

Donald Fowler
CEO of Onebright Ltd