Modern Slavery Statement

Modern slavery statement sets out our firm commitment to preventing exploitation in all forms across our operations and supply chains. We recognise that slavery, servitude, forced labour, debt bondage, and human trafficking are serious violations of human rights. Our approach is grounded in zero tolerance, practical controls, and continuous improvement. We expect every employee, contractor, and business partner to act with integrity and to respect the dignity, safety, and freedom of all individuals.

Our modern slavery statement is supported by a clear governance framework. Senior leaders oversee risk management, policy implementation, and corrective action where needed. We assess risks based on geography, sector, workforce profile, and procurement category. This helps us focus resources on areas where the potential for modern slavery risks is greatest. We also require appropriate training so that teams can recognise warning signs and respond swiftly and responsibly.

We apply a zero-tolerance policy to modern slavery and human trafficking. Any confirmed breach of this policy may result in termination of employment, suspension of a supplier relationship, or other corrective measures. We communicate these expectations through internal policies, supplier standards, and contractual clauses. By doing so, we aim to make our commitment to ethical conduct clear, measurable, and enforceable throughout the business.

Supplier due diligence is a core part of our modern slavery framework. Before engaging new suppliers, we evaluate ownership structures, labour practices, subcontracting arrangements, and compliance history. Higher-risk suppliers may be subject to additional scrutiny, including document reviews, interviews, and site visits. We reserve the right to request evidence of worker protections, wage practices, recruitment controls, and grievance mechanisms.

Our supplier audits are designed to verify that expectations are being met in practice, not only on paper. These audits may be announced or unannounced depending on the level of risk. Where concerns are identified, we require a corrective action plan with clear deadlines. If a supplier fails to make adequate progress, we may reduce business, pause new orders, or end the relationship. This measured response reinforces the seriousness of our anti-slavery commitments.

We also work to support responsible procurement decisions by sharing guidance on ethical recruitment, document retention, age verification, and worker freedom of movement. In doing so, our modern slavery statement reflects both prevention and remediation. We recognise that prevention is most effective when expectations are built into the sourcing process from the outset and monitored continuously throughout the contract lifecycle.

Reporting concerns is essential to an effective modern slavery response. We maintain multiple reporting channels so that employees, workers, and suppliers can raise concerns safely and without fear of retaliation. Reports may relate to forced labour, withheld identity documents, recruitment fees, threats, coercion, or unsafe living conditions. All concerns are treated seriously, handled sensitively, and investigated promptly.

We are committed to protecting whistleblowers and supporting anyone who raises a genuine concern in good faith. Retaliation of any kind is not tolerated. Where a concern is substantiated, we will take appropriate action, which may include supporting affected individuals, engaging specialist expertise, strengthening controls, or working with suppliers to improve conditions. Our objective is to address harm responsibly and prevent recurrence.

Training and awareness are key to the success of this policy. Relevant teams receive periodic guidance on identifying risk indicators, documenting concerns, and escalating issues appropriately. We also review recruitment practices to help ensure that all labour is freely chosen, fairly treated, and lawfully managed. These measures strengthen our broader modern slavery and human trafficking prevention strategy.

We conduct an annual review of this modern slavery statement to ensure it remains effective, relevant, and aligned with current legal and operational requirements. The review considers audit findings, supplier performance, training completion, incident trends, and changes in risk profile. Where improvements are identified, we update policies, strengthen controls, and refine due diligence practices.

Our annual review also helps us measure progress over time. By tracking key actions and outcomes, we can assess whether our modern slavery statement is driving meaningful change. This includes reviewing the effectiveness of supplier audits, the accessibility of reporting channels, and the consistency of follow-up actions. Continuous improvement is central to our approach.

We are committed to maintaining a robust, ethical, and transparent framework that helps prevent exploitation in every part of our business. Through clear accountability, proactive monitoring, and regular review, we seek to uphold human rights and promote fair working conditions. Our zero-tolerance policy remains the foundation of this commitment, and we will continue to strengthen our response wherever risk is identified.