Modern Slavery Statement
Modern Slavery Act 2015 Statement
Introduction
This Modern Slavery Act 2015 Statement (“the Statement”) is made in accordance with Section 54 of the Modern Slavery Act 2015 (the “Act”) and outlines the steps taken by Optimal Monitoring Limited (“OML”, “the Company”, “we”, “our”) to prevent modern slavery and human trafficking in our business and supply chains. We are committed to acting ethically and with integrity in all our business dealings and relationships, and to implementing and enforcing effective systems and controls to ensure that modern slavery is not taking place anywhere in our supply chains.
Organisational Structure and Supply Chains
OML operates in the energy efficiency sector in the UK, and our business includes the supply of software to record energy use and detect opportunities to reduce consumption through the application of analysis. We have a largely local supply chain that includes servers in the UK with some electronic components for AMR sensors acquired from non UK sources through UK distributors. Our suppliers and business partners are a crucial part of our operations, and we acknowledge that modern slavery and human trafficking may occur within our supply chains. Therefore, we take steps to ensure that we only work with suppliers who share our commitment to preventing these practices.
Policies in Relation to Modern Slavery
To support our commitment to preventing modern slavery, we have implemented the following policies:
1. Anti-Slavery and Human Trafficking Policy: This policy sets out our zero-tolerance stance towards modern slavery and human trafficking in all forms. It outlines the roles and responsibilities of employees and suppliers to identify and address any risks related to modern slavery.
2. Code of Conduct: Our Code of Conduct establishes expectations for ethical business practices and outlines our commitment to fair treatment, non-discrimination, and the prohibition of slavery or human trafficking within our business operations.
3. Whistleblowing Policy: We have a Whistleblowing Policy that encourages employees, contractors, and suppliers to report any concerns related to modern slavery or unethical business practices without fear of retaliation.
Due Diligence and Risk Assessment
As part of our commitment to preventing modern slavery, we conduct thorough due diligence on all new suppliers and review the practices of existing suppliers on a regular basis. Our due diligence process includes:
1. Supplier Risk Assessment: We assess the risk of modern slavery in our supply chains based on geographic location, industry, and the nature of the goods or services being provided. Suppliers in higher-risk regions or sectors are subject to more rigorous scrutiny.
2. Supplier Audits: We carry out audits and assessments of suppliers to evaluate compliance with our anti-slavery standards. These audits may be conducted directly by our internal teams or through third-party auditors.
3. Contractual Safeguards: Our contracts with suppliers include specific clauses that require compliance with applicable laws, including the Modern Slavery Act 2015. These clauses mandate that suppliers have measures in place to prevent modern
slavery and human trafficking within their operations and supply chains.
4. Ongoing Monitoring: We continuously monitor our suppliers for compliance with our anti-slavery standards and take action where necessary, including terminating relationships with suppliers who fail to meet our expectations.
Training and Awareness
We provide training to our employees and supply chain partners to raise awareness of modern slavery risks and ensure they understand how to identify and report any concerns. Our training programs cover:
• The principles of the Modern Slavery Act 2015 and our commitment to compliance.
• How to identify potential signs of modern slavery or human trafficking.
• Reporting mechanisms for employees and suppliers to raise concerns.
Training is mandatory for key employees in procurement, HR, and compliance roles, and is reviewed and updated regularly.
Effectiveness of Our Actions
To assess the effectiveness of our efforts to combat modern slavery, we take the following actions:
1. Regular Monitoring and Reporting: We track the effectiveness of our due diligence processes, audits, and training programs through regular reporting and review mechanisms.
2. Continuous Improvement: We actively seek ways to improve our systems and practices. This includes reviewing our policies, engaging with industry groups, and staying informed about emerging risks and trends in modern slavery.
3. Feedback Mechanisms: We encourage employees and suppliers to provide feedback on our anti-slavery measures and to report any concerns they may have.
Our Commitment
OML is committed to maintaining an environment where human rights are respected, and modern slavery is not tolerated. We will continue to review and strengthen our policies, procedures, and controls to prevent any form of modern slavery in our business and supply chains. We believe that it is our collective responsibility to ensure that modern slavery does not exist in our operations or supply chains, and we are committed to making a meaningful contribution to the global fight against modern slavery.
Approval
This statement has been approved by the Board of Directors of OML and will be reviewed annually.
Signed by:
Duncan Everett, MD, Feb 2026
Consequences of Non-Compliance
The Business takes compliance with this Policy very seriously and failure to comply with this Policy puts both Staff and the Business at significant risk. Staff who fail to comply with this Policy may commit a criminal offence and the criminal law relating to bribery and corruption carries several penalties.
Due to the importance of this Policy, failure to comply with any of its procedures and requirements may result in disciplinary action and/or dismissal for gross misconduct. Any non-Staff who breach this Policy may have their contract terminated with immediate effect. If you have any questions or concerns about anything in this Policy, contact Duncan Everett at duncan.everett@optimalmonitoring.com.