Anti Slavery Policy

1. Introduction
Ondeck ("the Company") is committed to conducting business in an ethical, responsible, and socially conscious manner. We recognise the abhorrent nature of modern slavery and human trafficking and are dedicated to preventing its occurrence within our operations and supply chains. This Anti-Slavery Policy outlines our commitment to combatting slavery and human trafficking in all its forms and sets forth our approach to ensuring compliance with relevant legislation and international standards.

2. Policy Statement

Ondeck  condemns all forms of slavery, human trafficking, forced labor, and exploitation. We uphold the principles of freedom, dignity, and human rights for all individuals, and we are committed to fostering a workplace environment and business practices that are free from exploitation and coercion.

3. Compliance with Legislation
We are committed to complying with all applicable laws and regulations related to modern slavery and human trafficking, including but not limited to the Modern Slavery Act 2015 in the United Kingdom.

4. Responsibilities
4.1 Management Responsibility: The management team at Ondeck  is responsible for ensuring the effective implementation of this Anti-Slavery Policy throughout the organisation. They are accountable for providing the necessary resources, support, and oversight to uphold our commitment to combatting modern slavery.
4.2 Employee Responsibility: All employees of Ondeck  are expected to familiarise themselves with this policy and adhere to its principles in the course of their duties. Employees are encouraged to report any concerns or suspicions of modern slavery or human trafficking promptly and confidentially to their line manager or designated point of contact.
4.3 Supplier and Partner Responsibility: Ondeck  expects all suppliers, contractors, and business partners to share our commitment to preventing modern slavery and human trafficking. We will endeavour to work only with entities that uphold ethical labor practices and demonstrate compliance with relevant laws and regulations.

5. Risk Assessment and Due Diligence
We recognise the importance of assessing and mitigating the risk of modern slavery within our operations and supply chains. We will conduct regular risk assessments to identify potential vulnerabilities and areas of concern, taking into account factors such as geographical location, industry sector, and nature of business relationships.Furthermore, we will implement due diligence procedures to assess the labor practices of our suppliers, contractors, and business partners. This may include reviewing supplier codes of conduct, conducting site visits, and engaging in dialogue with key stakeholders to ensure compliance with our anti-slavery principles.

6. Training and Awareness
We are committed to raising awareness and understanding of modern slavery and human trafficking among our employees, suppliers, and partners. We will provide training and educational resources to ensure that all stakeholders are equipped with the knowledge and skills necessary to identify, prevent, and report instances of modern slavery effectively.

7. Reporting and Monitoring
Ondeck  encourages open communication and transparency regarding modern slavery and human trafficking issues. We have established procedures for reporting concerns or suspicions of slavery or human trafficking, and we will investigate all reports promptly and impartially. Additionally, we will monitor and evaluate our anti-slavery efforts regularly to identify areas for improvement and ensure ongoing compliance with this policy.

8. Continuous Improvement
We are committed to continuous improvement in our efforts to combat modern slavery and human trafficking. We will regularly review and update this Anti-Slavery Policy to reflect changes in legislation, best practices, and emerging risks. Furthermore, we will engage with stakeholders, including employees, suppliers, and partners, to solicit feedback and input on our anti-slavery initiatives and drive positive change.

9. Conclusion
Ondeck  is steadfast in our commitment to preventing modern slavery and human trafficking in all aspects of our business operations and supply chains. We recognise that eradicating these heinous practices requires collective action, and we are dedicated to playing our part in building a more just, equitable, and humane society.
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3. Compliance with Legislation
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We are committed to complying with all applicable laws and regulations related to modern slavery and human trafficking, including but not limited to the Modern Slavery Act 2015 in the United Kingdom.

4. Responsibilities
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4.1 Management Responsibility: The management team at Ondeck  is responsible for ensuring the effective implementation of this Anti-Slavery Policy throughout the organisation. They are accountable for providing the necessary resources, support, and oversight to uphold our commitment to combatting modern slavery.
4.2 Employee Responsibility: All employees of Ondeck  are expected to familiarise themselves with this policy and adhere to its principles in the course of their duties. Employees are encouraged to report any concerns or suspicions of modern slavery or human trafficking promptly and confidentially to their line manager or designated point of contact.
4.3 Supplier and Partner Responsibility: Ondeck  expects all suppliers, contractors, and business partners to share our commitment to preventing modern slavery and human trafficking. We will endeavour to work only with entities that uphold ethical labor practices and demonstrate compliance with relevant laws and regulations.

5. Risk Assessment and Due Diligence
We recognise the importance of assessing and mitigating the risk of modern slavery within our operations and supply chains. We will conduct regular risk assessments to identify potential vulnerabilities and areas of concern, taking into account factors such as geographical location, industry sector, and nature of business relationships.Furthermore, we will implement due diligence procedures to assess the labor practices of our suppliers, contractors, and business partners. This may include reviewing supplier codes of conduct, conducting site visits, and engaging in dialogue with key stakeholders to ensure compliance with our anti-slavery principles.

6. Training and Awareness
We are committed to raising awareness and understanding of modern slavery and human trafficking among our employees, suppliers, and partners. We will provide training and educational resources to ensure that all stakeholders are equipped with the knowledge and skills necessary to identify, prevent, and report instances of modern slavery effectively.

7. Reporting and Monitoring

Ondeck  encourages open communication and transparency regarding modern slavery and human trafficking issues. We have established procedures for reporting concerns or suspicions of slavery or human trafficking, and we will investigate all reports promptly and impartially. Additionally, we will monitor and evaluate our anti-slavery efforts regularly to identify areas for improvement and ensure ongoing compliance with this policy.

8. Continuous Improvement

We are committed to continuous improvement in our efforts to combat modern slavery and human trafficking. We will regularly review and update this Anti-Slavery Policy to reflect changes in legislation, best practices, and emerging risks. Furthermore, we will engage with stakeholders, including employees, suppliers, and partners, to solicit feedback and input on our anti-slavery initiatives and drive positive change.

9. Conclusion

Ondeck  is steadfast in our commitment to preventing modern slavery and human trafficking in all aspects of our business operations and supply chains. We recognise that eradicating these heinous practices requires collective action, and we are dedicated to playing our part in building a more just, equitable, and humane society.