Modern Slavery Statement

Modern slavery statement sets out our commitment to preventing exploitation in every part of our operations and supply chain. We recognise that modern slavery can take many forms, including forced labour, human trafficking, debt bondage, child labour, and other abuses of vulnerability. Our zero-tolerance policy is central to this commitment and applies to all employees, contractors, agency workers, and business partners. We expect everyone connected with our organisation to act with integrity, respect human rights, and uphold lawful and ethical working practices.

Our approach is guided by prevention, detection, and continuous improvement. We assess risk across our activities and take proportionate action where concerns arise. This modern slavery statement reflects our responsibility to maintain robust controls, promote transparency, and ensure that our commercial relationships are built on fairness and accountability. We do not tolerate any practice that could facilitate exploitation, and we will act decisively where a breach is identified.

In order to support the anti-slavery statement, we include human rights expectations in relevant contractual terms and procurement decisions. Suppliers are informed that compliance with applicable labour, immigration, and employment laws is mandatory. We also expect them to cascade similar standards through their own operations and subcontractors. Where necessary, we provide guidance on acceptable working conditions, wage practices, recruitment standards, and record-keeping to help strengthen supplier compliance.

Supplier Due Diligence and Audits

Supplier oversight is an essential part of our modern slavery statement. We conduct risk-based due diligence before entering into relationships and continue monitoring throughout the life of the contract. Higher-risk suppliers may be subject to enhanced checks, including verification of labour practices, recruitment processes, worker accommodation, and document controls. Supplier audits may be announced or unannounced, depending on the risk profile and the nature of the concern.

During audits, we review payroll information, working hours, identity and age verification, grievance records, and evidence of freedom of movement. We also look for indicators such as withheld passports, excessive fees, intimidation, coercion, or unsafe living conditions. Where findings require corrective action, suppliers must implement remediation within agreed timescales. Continued non-compliance may result in suspension, reduced business, or termination of the relationship.

Our modern slavery statement is supported by training and internal awareness activities that help staff identify warning signs. Procurement, HR, and management teams are encouraged to challenge suspicious practices and escalate concerns promptly. We maintain a culture in which ethical behaviour is expected, and we seek to ensure that commercial pressure never overrides human dignity. This commitment applies equally to direct operations and extended supply chains.

Reporting, Escalation, and Governance

We provide multiple reporting channels so that employees, workers, and suppliers can raise concerns about possible exploitation or misconduct. Reports may be made anonymously where permitted, and all concerns are treated seriously and investigated promptly. We prohibit retaliation against anyone who raises a genuine concern in good faith. Protecting whistleblowers is vital to ensuring that hidden abuse can be brought to light and addressed effectively.

Incidents are escalated through our governance process and reviewed by relevant senior leaders. If a risk is identified, we may pause transactions, restrict access, increase monitoring, or require an independent review. Remediation is prioritised for the welfare of affected workers. In cases involving severe abuse, we cooperate with appropriate authorities and take steps to prevent recurrence. Our modern slavery statement is therefore not only a declaration of intent, but a practical framework for action.

We understand that modern slavery risks can evolve with changes in sourcing, geography, labour markets, and subcontracting structures. For this reason, our controls are reviewed regularly and adapted where needed. We continue to strengthen due diligence, supplier engagement, and internal accountability so that our standards remain effective and relevant. The objective is to identify vulnerabilities early and respond before harm occurs.

Annual Review and Continuous Improvement

Annual review is a key element of this modern slavery statement. Each year, we assess the effectiveness of our policies, procedures, training, supplier audits, and reporting mechanisms. We examine emerging risks, analyse cases and trends, and identify opportunities to improve controls. The review informs updates to our procurement standards, contractual requirements, and governance arrangements.

We also evaluate whether our approach is achieving measurable outcomes, such as better supplier transparency, stronger awareness among staff, and faster resolution of concerns. Where gaps are identified, we develop action plans with clear responsibilities and timelines. This ongoing cycle of review and improvement helps ensure that our anti-slavery commitments remain active, relevant, and aligned with ethical business practice.

This modern slavery statement reflects our determination to act responsibly and consistently. Through zero tolerance, supplier audits, clear reporting channels, and annual review, we aim to reduce risk and protect vulnerable people from exploitation. We will continue to strengthen our systems, learn from experience, and uphold the highest standards of conduct across our organisation and supply chain.