Modern Slavery Statement

 Scope & Purpose 

Modern slavery is a crime resulting in despicable abuse of human rights. It covers four activities: 

  • • Slavery;
  • • Servitude;
  • • Forced or compulsory labour;
  • • Human trafficking.

In all cases, some of the most vulnerable people in society are stripped of their dignity and basic freedoms and forced to work for someone else’s gain or benefit. The most common forms of modern slavery are sexual exploitation, labour exploitation including child labour and domestic servitude. 

The principal areas of risk we face, related to slavery and human trafficking, include, but are not limited to the following Business Partners: 

  • • Supply chains; 
  • • Outsourced activities; 
  • • Cleaning and catering suppliers; 
  • • Corporate hospitality; 
  • • Recruitment through agencies; 
  • • General recruitment. 

Omilia has a zero-tolerance approach to slavery and human trafficking. We are committed to ensuring that there is no modern slavery or human trafficking in any part of our business. Omilia’s anti-slavery policy reflects our promise to act ethically and with integrity in all our business relationships. We implement and enforce effective systems and controls to ensure slavery and human trafficking are not occurring anywhere in our supply chains. 


  1. Applicable Laws 

Omilia is active in numerous markets and must comply with Anti-Slavery laws of several jurisdictions. 

This Policy is meant to provide general principles and guidance with respect to Anti-Slavery. In some cases, the laws of the jurisdiction in which we do business might vary from what is included in this Policy. Therefore, you should also always consult and follow the applicable local laws. 


  1. Policy Elements 

Omilia has a responsibility to ensure all colleagues and Business Partners are safeguarded, treated fairly and with dignity. This policy must be observed and any serious concerns which are raised will be dealt with as appropriate and may trigger Omilia’s disciplinary procedures.


Identification of victims 

There is no typical victim, and some victims do not understand they have been exploited and are entitled to help and support. The following list of indicators, which is not exhaustive, could trigger suspicions that someone may be a slavery or trafficking victim. The person: 

  • • may not be in possession of their own passport, identification or travel documents; 
  • • will allow others to speak for them when spoken too directly; 
  • • will be withdrawn or appear frightened; 
  • • does not seem to be able to contact friends or family freely; 
  • • has limited social interaction or contact with people outside their immediate environment. 

A person may display a number of the indicators as set out above, but they may not necessarily be a victim of slavery or trafficking. 


Due diligence 
  • • Identify and assess potential risk areas when considering new suppliers and partners. 
  • • Regularly review existing supply chains. 
  • • Mitigate the risk of slavery and human trafficking occurring in our supply chains. 
  • • Monitor potential risk areas in our supply chains. 
  • • Protect whistleblowers. 
Omilia’s Responsibilities 

Omilia expects all its employees: 

  • • to work with Omilia in the implementation of this Policy; 
  • • to remain vigilant in identifying circumstances where there is a risk that modern slavery might be occurring in any part of Omilia’s business or in any of its supply chains; 
  • • to report any such circumstances to HR in full and without delay; 
  • • to conduct their own personal and domestic affairs in such a way to ensure that they are in no way connected with modern slavery, either through the commission of a criminal offence or through actions or omissions that might bring themselves and Omilia into disrepute. 

Omilia wishes to encourage openness and will support anyone who raises a genuine concern that modern slavery might be taking place in any part of its business or in any of Omilia’s supply chains, even if that concern ultimately turns out to be mistaken. 

Child labour 

International and local child labor laws are stricter today than they were years ago. But millions of children are still forced to work in bad conditions all around the world, even in developed countries. We refer to “children” as people who are younger than 18 years of age. “Young children” are people younger than 14. “Child labor” refers to work that deprives children of their childhood and affects their schooling, their potential and their dignity. It’s work that’s harmful to them mentally, physically and socially. 


We want to do business in a legal, ethical manner, adding value to society and the environment instead of doing harm. Helping stop child labor is fundamental to us. We want to make sure that our organisation doesn’t take part in children’s exploitation and also helps end it to the best of our ability. 


We always follow the stricter law if more than one law apply and require suppliers, partners and vendors to follow the stricter applicable laws and recognize children’s rights. They must also require their own suppliers, subcontractors and stakeholders to do the same. 

Young children 

When it comes to young children (younger than 14), we don’t want to stand in the way of their health, schooling or free time. That’s why we don’t and won’t employ anyone younger than 15 years of age and require our subsidiaries to do the same, regardless of the country they’re in. 


We’re also committed not to do business with any organization that employs children younger than 15. We’ll include this condition in every contract we sign and reserve the right to break the contract without penalty if our stakeholder violates this condition and refuses to agree on or follow through with an elimination plan.


Many laws make the distinction between agricultural and non-agricultural jobs. Agricultural job requirements for minors may be less strict, especially if a child works at a family-owned farm. In these cases, we’ll follow the law when doing business with agricultural businesses, and we’ll make sure that children involved aren’t placed in danger via regular audits and official documentation. 


We might occasionally do business with family-owned businesses. Those businesses are usually allowed to employ the owner’s young children as long as the work isn’t too hazardous (e.g. mining, manufacturing). We accept this regulation, but we’ll still dissolve our contract if it comes to our attention that these children are exposed to danger or are working consistently during school hours. 


Occasional work. Sometimes, parents bring their children to work to teach them skills and introduce them to a work environment. This is an acceptable practice, as long as it doesn’t deprive children of school on a consistent basis or puts them in any danger. 


Older children 

When it comes to employing children who are older than 15, we’ll always follow the local and international laws. As a general rule, these children can have a job, but they should never do work that jeopardises their health and safety or affects their schooling and development. These are mandatory conditions when forming partnerships or other business relationships. We’ll refuse to do business with anyone who employs children of any age in hazardous or exhausting jobs or doesn’t follow applicable laws on working hours or pay. We also expect them to communicate and enforce the no child labor policy to their own contractors. 


  1. Grievance Procedure 

If you have any concerns, you should raise them with Omilia’s HR, who will decide a course of action and provide any further advice. If you believe the victim may be in immediate danger, please call the police. Please be aware though, that not all victims may want to be helped and there may be instances where reporting a suspected trafficking case puts the potential victim at risk. It is therefore important that in the absence of an immediate danger, you should discuss your concerns first with HR before taking any further action. 


If you believe or suspect a breach of this policy has occurred or that it may occur, you must notify your manager and HR as soon as possible. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform HR immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Whistleblowing procedure. 


  1. Disciplinary Consequences 

Any breach of this Policy by any employee, including in respect of his or her duties for Omilia or in respect of his or her personal and domestic affairs may be dealt with Omilia’s disciplinary procedures and could result in dismissal. Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.


In the event that Omilia has a reasonable belief that modern slavery is occurring in any part of its business will:

  • put in place remedial action as soon as reasonably practical, with a view to ensuring that such modern slavery ceases to occur and that the victims of that modern slavery are appropriately safeguarded; 
  • • monitor the effectiveness of the remedial action taken, including the actions taken to safeguard the victims;
  • • deal with the matter under its disciplinary procedures, which could result in the dismissal of any member of staff found to be responsible. 

In the event that Omilia has a reasonable belief that modern slavery is occurring in the business or supply chains of any contractors, suppliers and other business partners, it will expect the relevant contractor, supplier or other business partner:

  • to be fully transparent and supply such information as Omilia may reasonably request in relation to the issue;
  • • to put in place remedial action as soon as reasonably practical with a view to ensuring that such modern slavery ceases to occur and that the victims of that modern slavery are appropriately safeguarded; 
  • • to monitor the effectiveness of the remedial action taken, including the actions taken to safeguard the victims; and
  • • to report to Omilia at reasonable intervals on the effectiveness of that remedial action and safeguarding, and any further steps taken to ensure that such modern slavery ceases to occur; 

Depending on the facts and the terms of the contract with the relevant contractor, supplier or other business partner, Omilia may terminate or suspend the relationship or otherwise cease, reduce or minimise business contact with the relevant contractor, supplier or other business partner. 


Any disciplinary measures will be decided by the Compliance and Ethics Committee, after taking into consideration all available information at the time. The Committee will keep minutes and full record of its decision and report each case to the Board of Directors. 


  1. Awareness and training 

You are expected to be familiar with this Policy. If you are uncertain about whether a particular activity is improper, you are encouraged to submit questions about this Policy to the HR department, which will respond accordingly on behalf of the Committee. 


Omilia engages in various means of communication and training to make employees, senior management and directors aware of this Policy. As part of our overall ethics training, all Company officers and employees will be provided training regarding anti-slavery. In addition, focused ethics and anti-harassment training will be provided periodically to applicable professional functions. 


  1. Policy Revision 

Omilia’s Anti-Slavery Policy will be reviewed annually, according to the following process: 

  1. 1. The Compliance & Ethics Committee decides on the procedure for the Policy’s revision. It decides on the timing, the tools and the parties that will be involved in submitting proposals for changes in this Policy. 
  2. 2. The HR department initiates the review process and submits the revision proposals to the Committee.
  3. 3. The Committee, after thorough examination of the input received, makes the final decision on the accepted changes and presents the revised Policy to the Board of Directors. 

The HR department ensures that the revised policy is published internally and informs Omilia employees and contractors of its update.