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Modern Slavery Act Transparency Statement

Financial year ended 31 December 2025

This statement is made pursuant to section 54 of the Modern Slavery Act 2015 and constitutes the slavery and human trafficking statement for the financial year ended 31 December 2025 of Oakbrook Finance Limited, Oakbrook Loans Limited and O6K Limited (together, Oakbrook).

Oakbrook is committed to acting ethically and with integrity in all of its business dealings and relationships and to taking appropriate steps to help prevent modern slavery and human trafficking in its business and supply chains. We recognise that modern slavery can take many forms, including slavery, servitude, forced or compulsory labour and human trafficking, and that businesses have an important role in identifying, preventing and mitigating these risks.

Our business and structure

Oakbrook Finance Limited, Oakbrook Loans Limited and O6K Limited are wholly owned subsidiaries of Oakbrook Holdings (UK) Limited.

Oakbrook Finance Limited, trading as OakbrookAdvance, was established in 2011 and Oakbrook Loans Limited, trading as Oakbrook Loans and OakbrookOne, was established in 2012. Both businesses provide unsecured personal loans to individuals residing in the UK. O6K Limited provides technology and analytics capability to the Oakbrook businesses.

As at 31 December 2025, Oakbrook had approximately 50 employees in the UK and 65 employees in India employed by its wholly owned subsidiary, OBF Services India Private Limited.

Governance and accountability

Responsibility for Oakbrook’s approach to modern slavery sits with senior management and the Compliance function, with oversight from the Board of Directors. This includes oversight of relevant policies, supplier due diligence, risk assessment and the annual review of this statement.

The Board expects Oakbrook’s operations to be conducted in a lawful, ethical and responsible manner. Our approach is informed by the nature of our business, our operational footprint and the profile of our supplier base.

Recruitment and employment practices

We apply controls within our recruitment and employment processes designed to support lawful employment and reduce the risk of exploitative practices within our own business. These include, where appropriate:

  • identity and right to work checks;
  • employment verification and other pre-employment screening, including credit reference and DBS checks where relevant to the role;
  • use of third-party advisers and service providers where required to support compliance; and
  • employment practices aligned to our values and expected standards of conduct.

We expect our people to act with integrity and to escalate concerns where they identify behaviour inconsistent with our policies or legal obligations.

Policies and whistleblowing

Our commitment to preventing modern slavery and human trafficking is supported by a range of policies and internal controls, including:

  • Whistleblowing Policy – enabling employees and relevant third parties to raise concerns confidentially;
  • Anti-Money Laundering Policy – supporting lawful and transparent business activity;
  • Anti-Bribery Policy – addressing bribery and corruption risks across our operations; and
  • Failure to Prevent Fraud Policy – supporting governance and controls in relation to third-party relationships and associated misconduct risks; and
  • Human Resources policies and procedures – supporting fair treatment, equality, diversity and inclusion, and expected standards of conduct.

These policies are communicated to employees as part of onboarding and ongoing compliance arrangements and help to maintain a culture of integrity, accountability and transparency.

Supply chain due diligence

As a UK-based provider of unsecured personal loans, Oakbrook’s supply chains are relatively straightforward. Our supplier base includes, among other things:

  • IT and software providers;
  • legal and professional advisers;
  • marketing and advertising agencies;
  • office equipment and stationery suppliers;
  • outsourced collections and administrative services;
  • introducers and intermediaries;
  • premises and facilities management; and
  • recruitment agencies.

While we consider the overall risk of modern slavery in many parts of our supply chain to be relatively low, we recognise that risk may still arise in certain sectors and service models, particularly where services involve outsourced operations, recruitment intermediaries, subcontracting arrangements, facilities management, lower-paid labour or delivery from higher-risk jurisdictions.

Our supplier due diligence procedures are designed to identify, assess, monitor and, where appropriate, mitigate modern slavery risk in our business relationships. These procedures include, where appropriate:

  • assessing suppliers during onboarding and renewal processes;
  • considering the nature of the goods or services provided and the jurisdictions in which suppliers operate;
  • requesting information about suppliers’ policies, controls and approach to preventing modern slavery;
  • carrying out proportionate desk-based reviews and, where appropriate, further enquiry or site visits;
  • documenting material changes in supplier scope or service arrangements and considering whether these alter the risk profile; and
  • escalating concerns through internal governance channels where issues are identified.

Where appropriate, we also seek to include contractual provisions requiring suppliers to comply with applicable law and to maintain standards consistent with Oakbrook’s expectations in relation to ethical business conduct, including modern slavery.

Training and awareness

Oakbrook seeks to maintain awareness of modern slavery risks through employee training and policy communication, particularly for colleagues involved in compliance, supplier oversight, recruitment and operational management. This supports a culture in which concerns can be identified and escalated appropriately through line management, Compliance or whistleblowing channels.

Assessing effectiveness

Oakbrook reviews the effectiveness of its approach to modern slavery risk management through ongoing review of relevant policies and procedures, supplier due diligence activity, training and awareness measures, and the operation of escalation and whistleblowing processes. We recognise that modern slavery is often a hidden risk and that our approach must therefore remain proportionate, risk-based and subject to regular review.

Continuous improvement and review

Oakbrook is committed to continuously improving its approach to modern slavery risk management by:

  • keeping relevant policies and procedures under review;
  • maintaining oversight of supplier due diligence and focusing attention on areas of relatively higher risk;
  • continuing to promote awareness of modern slavery through training and internal communications; and
  • reviewing this statement annually and updating it to reflect any material developments in the business or supply chains.

Approval

This statement was approved by the Board of Directors of Oakbrook Finance Limited, Oakbrook Loans Limited and O6K Limited and will be reviewed annually to ensure ongoing compliance with the Modern Slavery Act 2015.

Jonathan Painter
Chief Executive Officer
Oakbrook Finance Limited, Oakbrook Loans Limited and O6K Limited