Modern Slavery Statement

Our modern slavery statement reflects a clear commitment to preventing exploitation in every part of our operations and supply chain. We maintain a zero-tolerance policy toward modern slavery, human trafficking, forced labour, debt bondage, child labour, and any form of coercion. This policy applies to employees, contractors, agency workers, and all third parties acting on our behalf. We expect the highest standards of ethical conduct and uphold respect for human rights as a core principle of our business.

To support our anti-slavery approach, we embed due diligence into recruitment, onboarding, procurement, and supplier management. Risk-based assessments help us identify areas where labour exploitation may be more likely, including high-risk sectors, regions, and subcontracting arrangements. Where concerns arise, we require immediate remediation, escalation, and, if necessary, termination of relationships that do not meet our standards. Our commitment to a slavery-free workplace is reinforced through training, governance, and accountability.

We also work to ensure that our sourcing practices do not create conditions that enable modern slavery. Procurement teams are instructed to consider labour standards alongside quality, cost, and delivery when selecting suppliers. Contract terms include expectations around lawful employment, wage compliance, freedom of movement, and the prohibition of passport retention or excessive recruitment fees. By embedding these requirements, our modern slavery policy becomes an active control rather than a statement of intent.

Supplier oversight is a key element of our programme. We conduct supplier audits and reviews using a risk-based methodology, with increased scrutiny for higher-risk categories and geographies. Audits may include document checks, worker interviews, site inspections, and verification of payroll, working hours, and age records. Where issues are identified, suppliers must provide corrective action plans with clear deadlines. Repeat non-compliance may result in suspension or removal from our approved supplier list.

We also expect suppliers to extend these standards throughout their own supply chains. Subcontracting must be disclosed where relevant, and suppliers are required to ensure that downstream partners comply with equivalent labour and human rights expectations. This shared responsibility helps create a more resilient and ethical supply network. Our anti-slavery controls are therefore not limited to first-tier suppliers but are designed to address hidden risks deeper in the chain.

Training and awareness are essential to the effectiveness of our modern slavery statement. Employees involved in hiring, procurement, logistics, and supplier management receive guidance on recognising warning signs such as restricted freedom, unusual recruitment practices, withholding of identity documents, or signs of intimidation. Managers are encouraged to foster open discussion and respond promptly to concerns so that potential exploitation is addressed early and responsibly.

We provide multiple reporting channels so concerns can be raised safely and in confidence. Individuals may report suspected misconduct through internal escalation routes, line management, compliance functions, or designated whistleblowing mechanisms. Reports are handled sensitively, and retaliation against anyone raising a genuine concern is strictly prohibited. This reporting structure helps ensure that issues linked to modern slavery, labour abuse, or unethical recruitment can be identified without delay and investigated thoroughly.

All allegations are assessed promptly, with appropriate action taken according to the seriousness of the issue. Investigations may involve document review, supplier engagement, worker protection measures, and consultation with specialist advisers where necessary. Where credible evidence is found, we act decisively to protect affected individuals and prevent recurrence. Our ethical sourcing framework depends on the confidence that concerns will be heard, evaluated, and resolved fairly.

We review performance against our modern slavery policy through internal governance processes and management reporting. Key indicators may include audit findings, corrective action completion, training uptake, and the number and type of concerns raised. This information helps leadership understand emerging risks and improve controls over time. The aim is not only compliance, but the creation of a responsible culture in which exploitation has no place.

Our statement is subject to an annual review so that it remains current, relevant, and effective. Each year we assess changes in legislation, business activity, supplier risk, and industry best practice. This review informs updates to policies, audit priorities, training content, and escalation procedures. By revisiting our approach regularly, we strengthen our anti-slavery commitment and ensure it continues to reflect real-world risks.

We recognise that eliminating modern slavery requires sustained effort, vigilance, and collaboration. Through robust governance, supplier audits, clear reporting channels, and an annual review cycle, we aim to uphold a zero-tolerance policy across all operations. Our modern slavery statement is a public expression of that responsibility and a practical framework for action, helping us protect people, improve standards, and support a more ethical future.