Modern Slavery Policy - ON THE MARK

Modern Slavery and Human Trafficking Statement


This Modern Slavery and Human Trafficking Statement is a response to Section 54(1), Part 6 of the Modern Slavery Act 2015 and relates to actions and activities for the financial year ending 31 December 2021.

ON THE MARK-UK Ltd. (‘the Company’, ‘we’, ‘us’ or ‘our’) is committed to preventing slavery and human trafficking violations in its own operations, its supply chain, and its products where possible. We have zero-tolerance towards slavery and require our supply chain to comply with our values.

Organisational Structure

ON THE MARK-UK LTD has business operations in the United Kingdom. We operate in the Business Consulting sector.

The nature of our supply chains is as follows: We work with key vendors and suppliers who provide us with support, supplies, tools and equipment for our premises and services. These vendors and suppliers include insurance vendors, payroll, accounting and IT software and support, training materials, marketing services.

For more information about the Company, please visit our website:


We follow and enforce the following internal policies and procedures to ensure that we are conducting business in an ethical and transparent manner.

These include the following:

Recruitment and selection policy – We conduct civil and criminal background checks on all prospective employees to verify that they are eligible to work in the UK. We pay all employees through a registered bank account to ensure money reaches them direct. Certain roles require a Disclosure and Barring Service (DBS) check where employees may be working on public sector contracts.

Whistleblowing policy – We provide this policy in cases that employees are able to raise concerns about how staff are being treated or practices within our business or our supply chains without fear of reprisal.

Staff code of conduct – We are committed to the fair treatment of all staff and ensure our staff follow our code of conduct. Our staff code of conduct reflects our core values and expected behaviours. The code of conduct makes it clear that we have a zero-tolerance approach to modern slavery.

We ensure our suppliers are aware of our policies and adhere to the same standards.

Due Diligence

As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring in our own business as well as our key vendors and suppliers, we have adopted the following due diligence procedures:

Identify, communicate, and action potential risks in our business and vendor/supplier supply chains.

Annually review potential risks in our business and supply chains. Provide protection for whistleblowers if needed.

Risk and Compliance

The Company has evaluated the nature and extent of its exposure to the risk of slavery and human trafficking occurring in its UK supply chain through:

Ensure each new supplier and vendor have a Modern Slavery and Human Trafficking Policy Statement on file.

Avoid doing business with any company not formally registered as a business in the UK. Regular review aspects of our supply chain based on supply chain mapping.

We do not consider that we operate in a high-risk environment because OTM engages with vendors, suppliers and customers of well-established, well-known businesses, with the majority of businesses based in the UK in low-risk industries, such as payroll, accounting and IT software, legal counsel and marketing services.

We do not tolerate slavery and human trafficking in our customers, vendors, and suppliers. Where there is evidence of failure to comply with our policies and procedures, we will require them to remedy their non-compliance.

Effectiveness and Next Steps

The Company uses Key Performance Indicators (KPIs) to measure its effectiveness and ensure that slavery and human trafficking is not taking place in its business and supply chains. These KPIs are as follows:

Number of Modern Slavery and Human Trafficking Policy Statement on file. We currently ask our customers, suppliers, and vendors to provide us a copy of their Modern Slavery and Human Trafficking Policy Statement and keep on file.

We plan to do so every 12 months or annually effective Dec 2022.

We plan to carry out spot audit of selected customers, suppliers and vendors each year starting by Dec 2022.