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Modern Slavery Statement

Status of this statement

This page records the current approach of Otterian and the Otterian network to modern slavery risk. Unless this page expressly states otherwise and includes the approvals required by law, it is published voluntarily and is not represented as a statutory statement under section 54 of the Modern Slavery Act 2015.

If an Otterian organisation becomes legally required to publish a section 54 statement, the statutory statement will identify the relevant financial year, describe the steps taken during that year, record the required approval and sign-off, and be reviewed and published in accordance with the applicable requirements.

Our operating model and supply chains

Otterian develops ventures that may use software, cloud, communications, professional-services, payment, app-store, manufacturing, logistics and on-demand fulfilment suppliers. The supplier mix varies by venture and country. We therefore assess modern slavery risk by the nature of the service, geography, workforce model, subcontracting chain and the degree of visibility we have over the supplier.

Our principles

  • We do not knowingly use or support forced labour, slavery, servitude or human trafficking.
  • We expect suppliers and partners to comply with applicable labour, employment and human-rights laws and to maintain equivalent standards in their own supply chains.
  • We do not treat a low price or fast delivery target as justification for ignoring labour or supply-chain risk.
  • Concerns should be raised and investigated without retaliation against a person who reports a concern in good faith.

Supplier due diligence

Supplier onboarding should be proportionate to risk. Depending on the supplier, this may include reviewing ownership and location, public compliance information, labour practices, subcontracting, security and privacy controls, contractual commitments, relevant certifications, audit rights and the supplier's own modern slavery disclosures.

Where a material concern is identified, Otterian may seek further evidence, require remediation, restrict new work, suspend the relationship or end it where appropriate. The response will take account of the seriousness of the risk and whether immediate termination could itself worsen outcomes for affected workers.

Higher-risk areas

Particular attention is appropriate where supply chains involve labour-intensive production, temporary or migrant labour, opaque subcontracting, recruitment fees, high-risk jurisdictions, warehousing, logistics or on-demand manufacturing and fulfilment. Risk is reviewed as ventures and suppliers change rather than assumed to be static.

Training and awareness

People involved in procurement, supplier management or higher-risk venture operations should understand how to recognise and escalate modern slavery indicators relevant to their role. The level of training should reflect the role and risk rather than rely on a one-size-fits-all exercise.

Measuring effectiveness

As the network develops, Otterian will use proportionate measures to evaluate the effectiveness of its approach. These may include completion of risk reviews, supplier evidence requested and received, remediation actions, concerns raised, outcomes of investigations and whether higher-risk suppliers have been reassessed within the required period. We will not publish invented performance figures where evidence does not yet exist.

Raising a concern

If you have a concern about slavery, trafficking or exploitative labour connected with Otterian or one of our suppliers, use the contact details on our Contact page and provide enough information for the concern to be assessed safely. If someone is in immediate danger, contact the appropriate emergency or law-enforcement service.

Review

We review this statement as the Otterian corporate structure, ventures, supply chains and legal obligations develop. We will replace voluntary wording with a formally approved statutory statement if and when the legal duty applies.