Modern Slavery Statement
Voluntary statement under section 54 of the UK Modern Slavery Act 2015. We are below the £36m turnover threshold for mandatory publication, but operate in India and consider the disclosure appropriate.
1. Organisation structure and supply chain
OFORO LTD is a UK-registered company providing AI evaluation and physical-AI training data services through a network of contributors based primarily in India. Our supply chain comprises:
- Individual contributors who provide evaluation work remotely.
- Filming sites (Indian workshops, studios, and approved client sites) for Nxted Capture engagements.
- Cloud, payment, and SaaS sub-processors as listed in our Data Processing Agreement.
2. Policies
We maintain the following policies relevant to modern slavery and human trafficking:
- Contributor Agreement - sets out fair pay, lawful working conditions, and the right to withdraw at any time.
- Acceptable Use Policy - prohibits work that could expose contributors to coercion or harm.
- Anti-Bribery Policy - extends to recruitment and engagement of contributors.
- Whistleblowing Policy - independent channel for raising concerns.
3. Due diligence
For Capture filming sites we conduct on-site verification before the first engagement at any new location. We require: workers are paid above the relevant local market rate; workers retain control over their identification documents at all times; participation is genuinely voluntary with no penalty for withdrawal; minors are excluded; the site complies with applicable Indian labour law.
4. Risk assessment
The highest-risk area is informal labour at Capture filming sites. We mitigate this by working only with sites that have an identifiable owner of record, a payroll system, and a willingness to allow independent verification.
5. Training and KPIs
All staff receive onboarding training on modern slavery red flags. We track: number of new filming sites audited; number of contributor reports of coercion or unfair conditions (target: zero); time to investigate any such report (target: 5 business days).
6. Approval
This statement was approved by the Board of OFORO LTD on 28 May 2026 and will be refreshed annually within 6 months of the financial year end.
OFORO LTD · Registered in England & Wales · Company No. 16787568 · Unit 8 Lyon Road, Milton Keynes, England, MK1 1EX
Questions: legal@nxted.ai · DPO: dpo@nxted.ai