Modern Slavery Statement

This Modern Slavery Statement sets out our commitment to preventing slavery, servitude, forced labour, and human trafficking in all areas of our operations and supply chains. We recognise that modern slavery can occur in many forms and may be hidden within complex business relationships. For that reason, we maintain a zero-tolerance policy toward any practice that exploits workers or undermines basic human rights. Our approach applies to employees, contractors, agency workers, suppliers, and other business partners, and it is supported by our internal governance, training, and due diligence processes.

We expect everyone acting on our behalf to uphold the same standards. As part of our modern slavery framework, we assess risk across procurement, recruitment, logistics, and subcontracted services. Where risk is identified, we take prompt action to investigate, remediate, and, if necessary, end the relationship. We also require relevant staff to understand warning signs such as debt bondage, withholding of identity documents, excessive working hours, or restrictions on movement. These measures help us strengthen our modern slavery compliance and protect vulnerable individuals.

Our policy is reinforced through clear responsibilities at management level. Senior leaders review compliance performance and ensure that anti-slavery controls remain embedded in business decisions. This statement reflects our ongoing responsibility to identify, prevent, and address risks across the organisation. We also encourage a culture in which ethical conduct is expected and any concern can be raised without fear of retaliation.

Supplier Due Diligence and Audits

A key element of our modern slavery statement is robust supplier oversight. Before engaging a supplier, we undertake risk-based due diligence that considers geography, sector, labour practices, and subcontracting arrangements. Suppliers are asked to confirm their own compliance with anti-slavery principles and to demonstrate the controls they use to protect workers. Where appropriate, we include contractual commitments requiring lawful recruitment, fair wages, and freedom of movement.

We also conduct supplier audits on a planned and responsive basis. These audits may include document review, site visits, worker interviews, and checks on subcontractor arrangements. Findings are recorded and tracked until corrective actions are completed. If a supplier fails to meet our standards, we may require an improvement plan, increase monitoring, or suspend business activity until compliance is restored. This disciplined process supports the credibility of our modern slavery policy and helps reduce exposure in higher-risk categories.

Our audit programme is strengthened by collaboration with suppliers. We aim to improve standards through clear expectations, practical guidance, and measurable corrective actions. Where necessary, we require evidence that recruitment fees have not been passed to workers and that labour brokers operate lawfully. By combining assessment with remediation, we seek to create a supply chain that is both resilient and respectful of human dignity.

Reporting, Escalation, and Review

Any suspicion of slavery, trafficking, or labour exploitation may be reported through our internal reporting channels. Reports are reviewed promptly and handled confidentially where possible. We encourage workers and third parties to raise concerns about recruitment practices, pay, movement restrictions, intimidation, or unsafe living conditions. All reports are escalated through established safeguarding and compliance procedures, and the organisation takes reasonable steps to investigate every credible concern.

Where an allegation is substantiated, we act decisively. Responses may include immediate protection measures for affected individuals, engagement with suppliers, referral to authorities where required, and revision of internal controls. Our zero-tolerance stance means that repeated or serious breaches can result in termination of contracts. We also monitor the effectiveness of our controls to ensure our modern slavery framework remains practical, responsive, and aligned with legal and ethical expectations.

This statement is reviewed annually to ensure it remains current and effective. The review considers incident trends, supplier audit outcomes, emerging risks, and changes in legislation or best practice. Updates may lead to additional training, revised contractual clauses, or stronger monitoring in higher-risk areas. Annual review is essential to keeping our modern slavery statement relevant and to demonstrating continuous improvement across the organisation.

Commitment to Continuous Improvement

We recognise that eliminating modern slavery requires persistence, vigilance, and accountability. Our commitment is not limited to written policies; it is reflected in procurement decisions, workforce practices, and management oversight. By maintaining a zero-tolerance policy, strengthening supplier audits, supporting reliable reporting channels, and completing an annual review, we aim to uphold human rights and promote ethical business conduct in every part of our operations.