Anti-bribery
OXB’s policy on preventing and prohibiting bribery is in full accordance with the UK Bribery Act 2010 as well as other relevant overseas legislation. OXB does not tolerate any form of bribery by, or of, its employees, agents or consultants or any person or body acting on its behalf. The CET is committed to implementing effective measures to prevent, monitor and eliminate bribery. During 2024, all UK employees were required to complete anti-bribery training annually through an online learning portal.
In addition, the Anti-Bribery and Corruption policy was redrafted for roll-out to OXB US and OXB France. Effective measures for monitoring compliance with the policy at all sites will be rolled out in 2025.
Whistleblowing
OXB’s compliance activities include the prevention and detection of misconduct through policy implementation, training and monitoring. As part of this effort, employees are encouraged to report suspected cases of misconduct in confidence and without fear of retaliation to the 24 Hr Whistleblowing Service on 0800 028 0199. Concerns and allegations are thoroughly investigated with disciplinary action taken where necessary, up to and including dismissal and reporting to relevant authorities.
An anonymous confidential reporting channel is available for all employees and there are procedures in place to protect whistleblowers.
Clinical trials
In line with its strategy to become a pure-play CDMO, OXB discontinued work on internal product development in the second half of 2023. As a pure-play CDMO, the Group will not be initiating any further clinical trials. However, OXB is committed to the necessary long term safety follow up of patients in an existing study. Procedures will remain in place under its Quality Management System to ensure compliance with appropriate legislation and guidance.
Human rights and anti-slavery
OXB operates with responsibility at the forefront of its business, fully respects human rights and conducts its business in accordance with the letter and spirit of UK Human Rights legislation and the UK Modern Slavery Act 2015. All OXB employees are trained on whistleblowing, responsible purchasing, contract process underpinning responsible supply chain management (which includes human rights) where required, management of responsible interactions with counterparties as well as being trained and required to adhere to internal expectations aligned with personal objectives on ethical values and behaviours. As part of the procurement solicitation process and due diligence of suppliers, all suppliers are asked to comply with the OXB Supplier Code of Conduct or provide their own equivalent code which demonstrates compliance with Modern Slavery legislation. As part of a condition of on-boarding, all counterparties are asked to confirm that they comply with the laws regarding slavery and human trafficking of the country or countries in which they do business. Such expectations are anchored in the OXB Supplier Code of Conduct which details OXB’s overall approach to ethical standards and responsible supply chain management showing respect for sustainable and resilient business practices. 2024 Modern Slavery Statement, approved by the Board in March 2025 in accordance with Section 54 of the UK Modern Slavery Act, is available to view and download.
Post period-end, the Group plans to enhance the OXB Supplier Code of Conduct for all major suppliers and continues to develop tools and processes to educate its employees on how to engage with new and existing suppliers.