Modern Slavery Act Statement
OCFR-Gemba™ is committed to conducting business with integrity, respect for human rights, and in accordance with all applicable laws and global standards. This Modern Slavery Act Statement (“Statement”) sets out the steps OCFR-Gemba has taken, and continues to take, to prevent modern slavery and human trafficking in our business operations and supply chains.
This Statement is made pursuant to Section 54 of the UK Modern Slavery Act 2015 and reflects our commitment to ethical practices and human rights.
1. Our Structure and Business
OCFR-Gemba is a governance, risk management, and operational alignment platform designed to support organizations in achieving performance, compliance, and strategic outcomes through integrated operational and audit intelligence.
Our operations span multiple regions and jurisdictions and include internal functions, technology services, and work with a diverse set of third-party partners and suppliers. We employ people directly and engage with contractors and vendors to support our operations.
2. Our Policies on Modern Slavery and Human Trafficking
OCFR-Gemba has established policies and practices that reflect our commitment to ethical behaviour, including:
- Code of Conduct – Outlining expectations for ethical behaviour and compliance with laws and human rights standards
- Supplier Code of Conduct – Encouraging responsible business conduct throughout our supply chain
- Anti-Corruption and Ethics Policy – Reinforcing our zero-tolerance approach to unethical practices
- Whistleblower and Reporting Procedures – Providing mechanisms for confidential reporting of concerns
- Transparency – Communicating clearly and openly when appropriate
These policies promote respect for human rights, fair treatment, and lawful employment conditions.
3. Supply Chain and Risk Assessment
OCFR-Gemba recognizes that modern slavery and human trafficking can occur in complex global supply chains. While our core operations are technology and services-based, we engage with a variety of suppliers and partners globally.
We undertake risk-based assessments to identify and evaluate potential areas of concern, including:
- Supplier location and labour standards
- Nature of services or goods provided
- Labour practices and contractual requirements
We prioritise engagement with responsible suppliers and encourage them to uphold standards aligned with international human rights principles.
4. Due Diligence and Ongoing Monitoring
OCFR-Gemba recognizes that modern slavery and human trafficking can occur in complex global supply chains. While our core operations are technology and services-based, we engage with a variety of suppliers and partners globally.
Our approach to due diligence includes:
- Incorporating ethical and compliance expectations into supplier agreements
- Reviewing supplier and partner practices where appropriate
- Incorporating contractual language that supports respect for human rights and lawful labour practices
- Monitoring compliance with applicable laws and policies
Where suppliers do not meet acceptable standards, we work with them to improve practices or reevaluate the business relationship.
5. Training and Awareness
OCFR-Gemba provides training and awareness initiatives for employees and relevant stakeholders to:
- Understand the risks of modern slavery and human trafficking
- Recognise potential signs of unethical labour practices
- Report concerns through appropriate channels
Our goal is to ensure that our team members are informed and equipped to support responsible business conduct.
6. Further Steps and Continuous Improvement
OCFR-Gemba remains committed to enhancing its efforts to combat modern slavery. We will continue to:
- Review and strengthen policies and procedures
- Engage with suppliers on ethical and human rights expectations
- Monitor developments in global standards and best practices
- Improve training and awareness across the organization
These efforts support our commitment to responsible corporate citizenship and ethical operations.
7. Board Approval
This statement has been approved by OCFR-Gemba’s leadership and Board of Directors and reflects our ongoing commitment to address and prevent modern slavery and human trafficking risks in our operations and supply chains.
8. Contact Information
For questions or concerns related to this statement or OCFR-Gemba’s approach to human rights and ethical conduct, please contact: