Modern Slavery Statement

This statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015 and applies to the financial year 1 January 2026 to 31 December 2026. It is published by ORRJO Limited, a company registered in England and Wales (Companies House 13925853), registered office 86-90 Paul Street, London EC2A 4NE, VAT GB 406 990 969, ICO Data Protection Registration CSN3566949.

1. Organisational structure

ORRJO Limited is a privately owned B2B growth agency operating across the United Kingdom. The company is registered in England, with a trading office in Glasgow and team members working both on-site and remotely. ORRJO does not operate any overseas branches or subsidiaries at this time.

The business is led by a senior leadership team and governed by its Board of Directors. ORRJO delivers ORRJO Intelligence, Creative Studio, Demand Generation, and Lead Generation services to clients across financial services, technology, professional services, and other regulated B2B sectors.

All labour engaged by ORRJO to deliver its services is based in the United Kingdom, with limited travel to client sites where the engagement requires it.

2. Definitions

ORRJO considers that modern slavery encompasses:

• Human trafficking
• Forced or bonded labour through mental or physical coercion
• Control through abuse or threats
• Dehumanisation or commodification of individuals
• Physical constraint or restriction of freedom of movement

3. Commitment

ORRJO recognises its responsibilities under the Modern Slavery Act 2015 and is committed to full compliance with it. We review internal practices and supplier relationships on at least an annual basis to confirm they meet our ethical standards.

ORRJO does not knowingly enter into business with any organisation involved in slavery, servitude, or forced or compulsory labour. All labour involved in the delivery of ORRJO's services is freely given, lawfully employed, and fairly compensated in accordance with UK employment law, which ORRJO often exceeds in practice (including paying above the Real Living Wage and providing private healthcare to all permanent staff).

4. Supply chains

To deliver its services ORRJO engages suppliers primarily based in the UK and the EU. These include:

• Software providers (CRM, sales engagement platforms, data enrichment tools, AI tools, communications platforms)
• Marketing technology platforms
• Recruitment partners
• Professional advisers (legal, accounting, insurance)
• Office service providers

ORRJO does not manufacture or trade in physical goods. Some first-tier suppliers (such as SaaS providers or media agencies) may engage sub-processors of their own. ORRJO seeks written assurance that all supply chain partners operate in accordance with ethical labour practices and applicable law, and reserves the right to remove any supplier whose practices fall short.

5. Risk exposure

Given the nature of ORRJO's operations (UK-based knowledge work, no physical manufacturing, no consumer-facing goods), ORRJO considers its exposure to the risks of modern slavery to be low. The areas where indirect risk could arise are:

• Recruitment partners and contractor agencies
• Office service providers (cleaning, security, facilities)
• Sub-processors of our software suppliers

We conduct due diligence on each of these supplier types proportionate to the risk.

6. Actions taken

In line with Section 54(4) of the Modern Slavery Act 2015, ORRJO has taken the following steps to prevent modern slavery and human trafficking in our business and supply chain:

• Embedded anti-slavery clauses in supplier contracts, with provisions for termination on breach
• Carried out supplier due diligence and annual compliance reviews
• Maintained a Supplier Code of Conduct setting out expectations around ethical practices
• Provided awareness training to key staff on modern slavery indicators and ethical sourcing
• Appointed a Slavery Compliance Officer to receive and act on any concerns raised
• Integrated right-to-work, identity, and welfare checks into employee and contractor onboarding
• Maintained a confidential whistleblowing channel for staff and suppliers to report concerns

7. Key performance indicators

ORRJO measures the effectiveness of these steps through the following indicators, reviewed annually:

• Annual supplier compliance confirmations (target: 100% of in-scope suppliers)
• Training completion rates on ethical business conduct (target: 100% of staff within 30 days of joining)
• Reported concerns relating to modern slavery (target: zero, with any concern investigated)
• Routine reviews of supplier risk and contract adherence (at least annually)

8. Related policies

The following ORRJO policies reflect our stance on modern slavery and ethical operations:

• Modern Slavery and Human Trafficking Policy (this statement)
• Equality and Diversity Policy
• Information Security Policy
• Acceptable Use Policy
• Privacy Policy
• Terms of Service
• Recruitment and Onboarding Policy (available on request)
• Whistleblowing Policy (available on request)

9. Slavery Compliance Officer

ORRJO has appointed a Slavery Compliance Officer responsible for receiving any concerns related to modern slavery in ORRJO's business or supply chain and for ensuring appropriate action is taken in line with the company's obligations. To raise a concern, email hello@orrjo.com with the subject line "Modern Slavery". All reports are treated confidentially.

10. Review and approval

This statement is reviewed annually and approved by the Board of Directors. The next review is due on or before 1 January 2027.