Introduction

This statement sets out OpSec Security Group’s (“OpSec”) actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year 1st April 2019 to 31st March 2020.

OpSec recognises that it has a responsibility to take a robust approach to slavery and human trafficking. The organisation is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.

Organisational structure and supply chains

This statement covers the activities of the OpSec Security Group (covering Orca Bidco Limited, OpSec Security Group Limited and all of its subsidiaries).

  • OpSec designs, manufactures and supplies anti-counterfeiting and authentication products and services to a range of customers globally including Brands and Governments.  OpSec also provides technology platforms enabling customers to exceed their brand enhancement and protection needs.  OpSec has manufacturing sites in the UK and USA, fulfilment centres in Hong Kong and Malta, and offices in Germany, Dominican Republic, UK and USA.
  • OpSec procures materials, consumables, equipment, subcontracted manufacturing services, software development and support and other services as required from its global offices and from a range of countries and territories. These include USA, United Kingdom, Germany, Turkey and China.

Relevant Policies

OpSec operates the following policies and procedures which cover its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations.

  • Anti-Bribery Policy and Code of Ethics: OpSec’s policy makes it clear to employees the actions and behaviour expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.
  • Whistleblowing: OpSec encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. OpSec is in the process of updating its whistleblowing procedure to make it easier for workers to make disclosures, without fear of retaliation. Employees, customers or others who have concerns can contact the Compliance Committee as set out in the Anti-Bribery Policy referred to above.
  • Recruitment Policy OpSec uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency.

Due Diligence

OpSec is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. OpSec works with suppliers to ensure that they meet the standards expected and improve their worker's working conditions. However, identification of any issues with respect to the above could lead to the termination of the business relationship. OpSec will be implementing a programme over the next 12 months where initial due diligence questionnaires and risk assessments are completed for our suppliers. T Audits are to be conducted on suppliers as part of the follow up actions, using either internal teams or contracting 3rd parties to conduct such audits This programme will include an assessment of the risks associated with slavery and human trafficking in a supplier’s operations which could be deemed to be medium to high risk based on geographical location, industry sector or commercial transaction nature. As part of this programme, OpSec will introduce a supplier code of conduct by 30 June 2019 to further tighten up its procedures with its key suppliers.

Controls

OpSec expects all of its suppliers to apply prohibition on slavery, human trafficking and child labour.  OpSec plans to review its standard supplier terms of business during the period to 31st March 2020 and update to comply with the Modern Slavery Act. This will include clauses which require suppliers to notify OpSec immediately if they become aware of slavery or human trafficking in their supply chains. Suppliers who breach these obligations will face appropriate actions which could include contract termination.

Board Approval

This statement has been approved by OpSec’s board of directors, who will review and update it annually.

Rich Cremona, Chief Executive Officer

Date: 1st April 2019