Responsible procurement

Purpose and scope

We consider actual and potential human rights and environmental impacts when buying or renewing services and equipment. This procedure applies to OYNK Ltd (company number 15844748) and Swynx Ltd (company number 17021186). Ashley Gallagher, Director of both companies, is accountable for its implementation.

Our purchasing includes hosting, cloud services, software and computer equipment. Swynx has never traded; it will apply this procedure before making purchases when it begins operating. Purchases and decisions are recorded against the company responsible.

Which purchases we review

We identify and review at least three material purchasing decisions in each annual review period. We consider spending, operational importance and the severity and likelihood of potential impacts. Serious human rights risks receive priority even where spending is small.

We use purchase and renewal records to identify the decisions reviewed. We record when impacts were considered. A review completed after a purchase is described as retrospective, so it does not suggest that checks occurred earlier than they did.

Human rights considerations

Our review considers relevant risks such as forced and child labour, working conditions, discrimination, privacy, surveillance and effects on communities. We consider the supplier, the service or product, relevant locations and the wider supply chain.

We review credible disclosures, identify gaps and raise material questions where necessary. A supplier policy or certification is useful evidence but does not, by itself, establish that every potential impact has been addressed.

Environmental considerations

We consider energy and computing demand, greenhouse gas emissions, water use, resource extraction, pollution, durability, repairability and end-of-life treatment.

We prefer credible, verifiable information and record uncertainty where information is unavailable. Renewable-energy-backed hosting is relevant to our choices, while its remaining infrastructure and operational impacts still need consideration.

Decisions and follow-up

We record the evidence, potential impacts, alternatives, reasons for the decision and any actions needed. Keeping a supplier may be appropriate where it meets a necessary business need and the identified risks can be responsibly managed.

Our procedure includes seeking improvements, considering suitable alternatives and avoiding or replacing suppliers where serious risks cannot be responsibly addressed. Unresolved concerns have an owner and a review date. We retain the review records and supporting evidence.

Raising a concern

Concerns about our purchasing practices can be raised through our stakeholder grievance procedure.

Approval and review

Approved by Ashley Gallagher, Director of OYNK Ltd and Swynx Ltd.

Effective date for both companies: 15 September 2026.

Next review: by 15 September 2027, or earlier if activities materially change.

Published on this website: 15 September 2026.