Modern Slavery Statement - May 2021
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Modern Slavery Statement May 2021
Introduction
Ooni Limited and our human rights abuses, including around the world to provide
subsidiaries, Ooni, Inc. and Ooni slavery, servitude, forced and greater protection to workers
GmbH (herein known as ‘Ooni’) compulsory labour and human against the threat of modern
are committed to ensuring the trafficking. slavery. Ooni’s Modern Slavery
human rights of people working Statement has been published
within our operations and We acknowledge that while in accordance with Section 54
supply chains around the world modern slavery can exist in all of the UK Modern Slavery Act
are respected and protected, in industries, our supply chains 2015. It explains the progress
alignment with the UN Guiding particularly have increased we have made in taking
Principles on Business and risks due to their geographical steps towards identifying and
Human Rights. locations, the types of preventing modern slavery and
vulnerable people working human trafficking within our
Ooni does not tolerate any within them and the kinds of business and supply chains for
form of modern slavery raw materials being sourced for the financial year ending 31
anywhere within our business our products. December 2020 and describes
or supply chains. Modern our 2021 commitments for
slavery encompasses the worst We support the ongoing tackling modern slavery.
forms of labour exploitation and introduction of legislation
Structure, business and supply chains
Our business
106
types of
3
offices
4
third-party
1
outsourced customer
products warehouses service operation
Our workforce
83 direct employees
8 outsourced workers (7 in The Philippines, 1 in Thailand)
2 summer interns
All graphic information is accurate as of the end of Ooni’s financial year, 31 December 2020.
Ooni Limited, founded in 2012, including one colleague in Ooni Limited is a privately
is a private limited company China. We use four third-party owned company, and its
registered in England and operated warehouses located shareholders are Kristian
Wales under the registration in the UK, Netherlands and the Tapaninaho, Darina Garland,
number 08316049. We are US. We also have an outsourced Simon Fry and Kevin Quinn.
headquartered in Broxburn, customer service operation Ooni, Inc. (USA) and Ooni
Scotland with offices in Austin, in the Philippines (employing GmbH (Germany) are 100%
US and Bonn, Germany. We seven workers) and Thailand owned subsidiaries of
employ 83 people globally, (employing one worker). Ooni Limited.
Ooni Modern Slavery Statement | May 2021 | ooni.com P2Structure, business and supply chains
Our products manufacturing the whole via our Tier 1 suppliers. We
finished Ooni product or are in the process of mapping
Ooni is a leading designer, where the majority of the these Tier 2 suppliers and
manufacturer and retailer assembly and packing of plan to complete this work by
of pizza ovens. We also sell products bearing an Ooni label September 2021.
accessories and groceries occur. Our Tier 1 suppliers are
(dough balls and pizza predominantly located in China, We recognise that our greatest
ingredients). Our products but also in Germany, Lithuania, modern slavery risks are located
are designed and engineered Slovenia, the UK, Ukraine and within our production supply
by our team in Scotland and the US. The map on P4 provides chain, so this is where we are
manufactured via contract further information on the currently focusing our efforts.
manufacturing partners in number of suppliers located in
factories predominantly located each country and the products Logistics and
in China. These are then they supply. operational suppliers
shipped to warehouses in the
Netherlands, the UK and the US. We have long standing We also use logistics and
We serve individual customers relationships with many of our operational suppliers who
in the EU, UK and US through Tier 1 suppliers and only our provide the following different
our own e-commerce website subscription food box suppliers types of services: shipping,
ooni.com, and we sell via online change seasonally. transport, warehousing,
marketplaces such as Amazon. couriers, waste management,
We also have a network of Tier 2 suppliers provide the professional services and office
retail and distribution partners raw materials, components cleaning. We will map these
around the world, who retail and services used in the suppliers in 2021 and will look
our products. manufacture of our products, to include them in our modern
such as stainless and carbon slavery prevention programme
Production suppliers steel, aluminium and gas in 2022.
componentry. We do not have a
We have 29 Tier 1 production direct relationship with any Tier
suppliers, defined as sites 2 suppliers; they are contracted
Our supply
29 7 25%
chain
Tier 1 Tier 1 Tier 2
suppliers sourcing countries suppliers mapped
2021
Modern Slavery
Prevention
Commitments
Map and risk Map and risk Implement a
assess Tier 2 assess logistics supplier database,
suppliers and operational start to collect
suppliers relevant supplier
ethical information
Ooni Modern Slavery Statement | May 2021 | ooni.com P3Operations and supplier map
UK Lithuania
Netherlands
Germany Ukraine
Slovenia
USA
China
Thailand Philippines
Operations
UK HQ office at Broxburn and UK warehouse
Germany Bonn office
USA Austin Texas office and US warehouses
Netherlands EU warehouse
Philippines Outsourced customer service
Thailand Outsourced customer service
China 1 employee
Tier 1 Suppliers
China 17 suppliers Ovens, accessories
UK 5 suppliers Dough balls, firestarters, dough trays, subscription boxes, wood pellets (via Russia)
Germany 1 supplier Dough trays
Lithuania 1 supplier Solid firewood
Ukraine 1 supplier Charcoal
Slovenia 1 supplier Cookbook
USA 3 suppliers Wood pellets, cookbooks
Ooni Modern Slavery Statement | May 2021 | ooni.com P4Policies
Governance Business policies We are accredited as a UK real
living wage employer by the
The Chief Operating Officer We pride ourselves on creating Living Wage Foundation. All
(COO) is responsible for a positive work environment Ooni employees are paid at
overseeing Ooni’s approach for the people we employ. least the real living wage. At the
to human rights, ethical We do this by making our five end of 2020, we implemented
trade and modern slavery core values, one of which is a minimum salary of £25,000
prevention. The COO meets kindness, part of Ooni’s DNA or equivalent for all employees
with the Ooni Limited Executive and central to every decision globally.
Team quarterly to discuss we make.
sustainability related issues, We are also in the process of
including human rights risks We have several human rights producing a Diversity, Equity
and to review any significant related policies and procedures and Inclusion Policy and an
supplier non-compliances, or in place to protect our Impact Policy which references
more frequently as required. employees: the ten UN Global Compact
Principles, and includes a
• People handbook
On a day-to-day basis, our section on Social and Ethical
Impact and Manufacturing • Whistleblowing policy Impact, encompassing modern
teams are responsible for the • Grievance procedure slavery, ethical trade and human
management of our human • Discrimination and and labour rights.
rights and ethical trade harassment policy
programme, and for developing (“Valuing Diversity”) All new employees are required
and implementing our modern to read and sign these policies.
• Disciplinary procedure
slavery related policies and They are also available for
procedures. In 2021, they will • Anti-bribery and review on our HR portal.
meet with the COO quarterly corruption policy
to review business and supplier • Health and safety policy
performance against these • Living wage policy
policies and discuss any
emerging human rights issues.
Ooni Modern Slavery Statement | May 2021 | ooni.com P5Policies
Supply chain policies help us progress our modern of China. Through mapping
slavery prevention approach. our Tier 1 Chinese supply base,
We recognise we need to Our next step is to develop a we can confirm we do not
develop a more robust ethical Supplier Code of Conduct and source from factories in XUAR.
trade programme. During this roll this out to all manufacturing Over the coming year, we will
reporting period, we have Tier 1 and 2 suppliers and conduct further due diligence
been building human rights warehouses. to verify there are no Uyghurs
expertise and understanding working under forced labour
of our supply base within the Uyghur and other Turkic conditions in our Chinese
business to help us to do this. and Muslim-majority people factories.
We have focused our efforts on
mapping our supply chain and We are aware of reports of
risk assessing Tier 1 suppliers forced labour and trafficking
through collating and reviewing of Uyghur and other Turkic
existing third-party audits. and Muslim-majority people,
Over the coming year, we will particularly in Xinjiang Uyghur
work with external experts to Autonomous Region (XUAR)
2021
Modern Slavery
Prevention Create a Supplier Code of Conduct, translate into relevant
Commitments languages and roll out to all suppliers and warehouses
Update the Supplier Contractual Agreement to include a
clause on compliance with the Supplier Code of Conduct and
specific clauses on zero tolerance towards modern slavery
Develop a formalised child labour and remediation policy and
roll out to all suppliers and warehouses
Conduct due diligence on our Chinese suppliers to ensure
Uyghurs are not working under forced labour conditions
Establish a review process for human rights risks and supplier
performance across all relevant teams
Ooni Modern Slavery Statement | May 2021 | ooni.com P6Due diligence
We want to build relationships In 2021, we will develop a more Grievance mechanisms
with suppliers that reflect our thorough and formal supplier
values and show a genuine onboarding process which We have a Whistleblowing
commitment to providing safe, will include a requirement Policy in place for our
fair and respectful working to comply with our Code of employees. It provides a safe
conditions for all workers. Conduct as part of the supplier channel of communication
contractual agreement. We will for employees to identify and
Our supply base is also require new suppliers to report any potential concerns
predominantly located in provide us with an audit carried to appropriate managers or one
China where we have 17 Tier out in the last two years. of our Whistleblowing Officers.
1 suppliers, so this is where We encourage anyone within
we focused our initial due Existing suppliers the business to raise human
diligence efforts. rights concerns through these
We are now in the process channels.
New suppliers of developing a more
comprehensive ethical trade We investigate all reports
During the early stages of programme that will initially fairly and confidentially,
building our ethical trade encompass all our Tier 1 where possible and providing
programme, we have production suppliers and remediation in the best
been selecting Chinese selective Tier 2 suppliers based interests of those affected
manufacturing partners based on risk. These suppliers will be when required. Whistleblowers
on their capabilities, previous required to supply Ooni with a will not be subjected to any
products manufactured and SMETA audit undertaken in the reprisals, threats or any other
past audit history. Prior to last two years. Any Tier 1 and detrimental treatment as a
COVID-19, our Chief Executive 2 suppliers whom we identify result of raising a genuine
Officer, Product Team, Senior as high risk, following a review concern.
Operations Manager and Chief of the audit findings, will also
Operating Officer would visit be required to undergo an
suppliers up to two times a additional audit annually against
year and discuss social audit Ooni’s own Code of Conduct.
history and labour conditions.
2021
Require SMETA audits from all Tier 1 and key Tier 2 suppliers,
Modern Slavery
commission additional audits for all suppliers deemed to be
Prevention
high risk and set improvement targets
Commitments
Develop ethical trade programme processes and procedures
Develop a more formal new supplier on boarding process
Ooni Modern Slavery Statement | May 2021 | ooni.com P7Risk assessment
We are currently in the While we believe the risk of Over the coming year, we
process of formalising our modern slavery is low within will also expand our supply
risk assessment approach. our direct business operations chain risk assessments to
Our initial investigations have as all of Ooni’s employees are cover specific modern slavery
determined that our highest risk employed directly by us and are indicators, raw materials,
modern slavery risks lie within on permanent contracts, our product and service type,
our production supply chain. outsourced customer service worker type, including
We have mapped our Tier 1 team and the agency workers at vulnerable worker groups and
suppliers and risk assess them, our third party warehouses, may the likelihood of involvement of
primarily based on location. Our be at greater risk of modern recruitment or labour agencies.
Head of China Manufacturing slavery due to the nature of
is in regular direct contact with their employment. We will
suppliers and implements our focus our efforts on better
programme on the ground. understanding the employment
circumstances of these workers
in 2022.
Modern
Slavery Risks
HIGH MEDIUM LOW
Product supply chain, Logistics and operational Ooni employees
including raw materials, suppliers, workers recruited directly
outsourced customer recruited through agencies
service workers at our warehouses
2021
Modern Slavery Formalise supply chain modern slavery risk assessment
Prevention process and map where vulnerable workers may be at risk
Commitments
Training and capacity building
We plan to develop and roll out specific modern slavery training to key employees, the Senior
Leadership Team and the Board in 2021.
2021
Modern Slavery Develop modern slavery training with external experts and train
Prevention key employees, the Senior Leadership Team and the Board
Commitments
Ooni Modern Slavery Statement | May 2021 | ooni.com P8Effectiveness of our approach
Through our risk assessment received any grievances related approach and will continue to
process and following reviews to modern slavery and labour build knowledge internally, with
of supplier audits, we have not rights through our grievance input from external experts, to
found any incidents of potential mechanisms. However, we give us the best possible chance
modern slavery indicators recognise that we are in the of identifying and preventing
within our business and supply early stages of developing our modern slavery within our
chains. We have also not modern slavery prevention sphere of influence.
2021 Supply chain mapping • Map and risk assess Tier 2 and logistics and operational suppliers
Modern Slavery
Prevention Database
• Implement a supplier database to capture relevant supplier ethical
Commitments information
Summary
• Create a Supplier Code of Conduct, translate into relevant languages,
roll out to all suppliers and warehouses
Policies
• Develop a Child Labour and Remediation Policy and roll out to all suppliers
and warehouses
• Update the Supplier Contractual Agreement to include a clause on
Contracts compliance with the Supplier Code of Conduct and specific clauses on
zero tolerance towards modern slavery
• Establish a review processes for human rights risks and supplier
Governance
performance across all relevant teams
• Develop ethical trade programme processes and procedures
• Develop a more formal new supplier onboarding process
• Formalise supply chain modern slavery risk assessment process and map
where vulnerable workers may be at risk
Due Diligence and
Risk Assessment • Require SMETA audits from all Tier 1 and key Tier 2 suppliers, commission
additional audits for all suppliers deemed to be high risk and set
improvement targets
• Conduct due diligence on our Chinese suppliers to ensure Uyghurs are not
working under forced labour conditions
Training • Develop modern slavery training and train key employees
This statement was approved by Ooni Limited Board of Directors on 12 May 2021.
Signed:
Darina Garland
Co Chief Executive Officer
12 May 2021
Ooni Modern Slavery Statement | May 2021 | ooni.com P9This document forms part of our commitment to social responsibility and transparency. For more information For more information on our impact roadmap, please see ooni.com/impact
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