Anti-slavery and human trafficking policy

Policy Statement 

This policy applies to all persons working for Oldeani or on its behalf in any capacity, including employees at all levels, directors, officers, agency workers, secondary workers, volunteers, age agents, contractors and suppliers. 

Oldeani prohibits the use of modern slavery and human trafficking in its operations and supply chain. Oldeani is and will continue to be committed to implementing systems and controls aimed at ensuring that modern slavery is not taking place anywhere within the organisation or in any of its supply chains. Oldeani has received ISO9001 accreditation for its quality management systems. Oldeani expects that its suppliers will hold their own suppliers to the same high standards.  



Modern slavery is a crime and a violation of fundamental human rights. Oldeani expects everyone working with it or on its behalf to support and uphold the following measures to safeguard against modern slavery: 

Oldeani has a zero-tolerance approach to modern slavery within its organisation and supply chain.  

The prevention, detection and reporting of modern slavery in any part of the organisation or supply chain is the responsibility of all those working for Oldeani or on its behalf. Workers must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this policy. 

Oldeani is committed to engaging with its suppliers to address the risk of modern slavery in its operations and supply chain.  

Oldeani takes a risk based approach to its contracting processes and regularly reviews these processes. Oldeani assesses whether the circumstances warrant the inclusion of specific prohibitions against the use of modern slavery and trafficked labour in its contracts with third parties. Using its risked based approach Oldeani will assess the merits of writing to suppliers requiring them to comply with its Code of Conduct, which sets out the minimum standards required to combat modern slavery and trafficking. 

Consistent with its risk based approach Oldeani may require: 

  • all suppliers engaging workers through a third party to obtain that third parties’ agreement to adhere to the Code;  
  • as part of Oldeani’s ongoing risk assessment and due diligence processes Oldeani will consider whether circumstances warrant it carrying out audits of suppliers to ensure they comply with its Code of Conduct. 

If Oldeani finds that other individuals or organisations working on its behalf have breached this policy Oldeani will ensure that it takes appropriate action.