Modern Slavery Statement

Our modern slavery statement reflects a clear commitment to ethical business conduct, human rights, and responsible operations. We recognise that modern slavery, human trafficking, forced labour, debt bondage, child labour, and other forms of exploitation can occur in global supply chains and within workplaces if robust controls are not in place. As a matter of policy, we maintain a zero-tolerance approach to any form of slavery or servitude. This statement sets out the measures we use to prevent, identify, and address these risks across our activities.

Our modern slavery policy applies to all employees, contractors, agency workers, and business partners. We expect everyone acting on our behalf to uphold lawful, fair, and respectful treatment of workers. To support this expectation, we embed modern slavery due diligence into onboarding, procurement, and risk management processes. Where concerns arise, we act promptly and proportionately, using investigation, remediation, and, where necessary, termination of relationships. Our core principle is that no commercial benefit can justify exploitation.

We maintain a structured governance framework to oversee the effectiveness of this statement. Senior management reviews risks, approves actions, and monitors progress against our responsible sourcing priorities. Training is provided to relevant teams so they can recognise warning signs such as withheld documents, excessive recruitment fees, restricted movement, or unsafe working conditions. By reinforcing awareness, our slavery and human trafficking statement becomes a practical operational control rather than a purely formal document.

Supplier oversight is central to our approach. We conduct risk-based supplier audits to assess labour practices, working hours, wage compliance, recruitment methods, and worker welfare. These audits may include document reviews, site visits, interviews, and corrective action tracking. Where suppliers fail to meet our standards, we require timely improvement plans and evidence of remediation. Repeated or serious breaches may result in suspension or disengagement. This audit process helps strengthen our anti-slavery statement and improve accountability throughout the supply chain.

We also use contractual safeguards to reinforce expectations. Suppliers are required to confirm compliance with applicable labour laws and to cascade equivalent standards to their own subcontractors. We ask for transparency regarding labour brokers, migrant worker arrangements, and high-risk geographies. In higher-risk categories, we apply enhanced scrutiny and may request additional declarations or independent verification. Our modern slavery commitment is therefore supported by preventative controls as well as corrective action.

Reporting channels are available to help identify concerns early. Employees and external stakeholders may raise suspicions of exploitation, unsafe recruitment practices, retaliation, or coercion through internal reporting routes and escalation procedures. Reports are treated seriously, investigated confidentially where appropriate, and handled without victimisation. We encourage the reporting of even small concerns, as early disclosure can prevent harm. The integrity of our modern slavery framework depends on accessible, trusted, and responsive channels.

When a concern is reported, we follow a structured response process. This may include preserving evidence, interviewing relevant parties, engaging suppliers, and coordinating remediation with appropriate specialists. If individuals are found to be at risk, we seek to prioritise their safety and dignity. Corrective actions may include worker reimbursement, recruitment fee repayment, contract remediation, or enhanced monitoring. Our modern slavery statement emphasises that remediation should focus on practical protection and lasting prevention.

We recognise that modern slavery risks evolve over time, particularly as markets, sourcing models, and labour patterns change. For that reason, we review our approach annually and update our controls as needed. The annual review considers audit findings, reported concerns, supplier performance, training completion, regulatory developments, and any emerging risk indicators. This ensures that our modern slavery policy statement remains current, relevant, and effective in practice.

Our annual review is not limited to compliance checking; it is also a planning mechanism for continuous improvement. Following the review, we identify priority actions, assign responsibilities, and track progress against measurable objectives. These may include expanding supplier audits, improving due diligence questions, refreshing training content, or strengthening escalation pathways. Through this process, our anti-modern slavery statement supports ongoing vigilance and better outcomes across the organisation.