Modern Slavery Statement

Modern slavery is a grave violation of human rights, and we are committed to preventing it in every part of our operations and supply chain. This modern slavery statement sets out the principles, controls, and responsibilities that guide our approach. We maintain a zero-tolerance policy toward forced labour, bonded labour, human trafficking, child labour, and any form of exploitation. These standards apply to employees, contractors, agency workers, and all business partners associated with our activities.

Our commitment is embedded in governance and daily practice. We expect all personnel to act ethically, follow internal procedures, and escalate concerns without delay. We also require suppliers and service providers to meet the same standards. Slavery and human trafficking have no place in our business model, and we continually review our controls to ensure they remain effective. By setting clear expectations, we aim to reduce risk and promote fair, lawful working conditions throughout our operations.

To reinforce this commitment, we conduct due diligence before entering into supplier relationships and at regular intervals thereafter. This includes assessing country risk, sector risk, labour practices, and ownership structures. Where appropriate, we may request policy documents, audit evidence, workforce records, and corrective action plans. Modern slavery risks are not always visible, so our review process is designed to identify warning signs early and address them decisively.

Supplier Oversight and Audit Controls

Supplier audits are a key part of our prevention strategy. We use both scheduled and risk-based audits to evaluate working conditions, recruitment practices, wage compliance, working hours, and freedom of movement. These audits may be carried out internally or by qualified third parties. Non-compliance is documented, and suppliers are expected to implement corrective actions within agreed timeframes. In serious cases, failure to improve may result in suspension or termination of the relationship.

We also recognise that responsible sourcing requires continuous engagement. Suppliers are informed of our expectations through contractual provisions and policy acknowledgements. They must not use forced or involuntary labour, must retain lawful employment records, and must ensure workers understand the terms of their employment. We encourage suppliers to apply the same standards to their own subcontractors and labour providers, creating a consistent approach across the supply chain.

Training supports these measures by helping relevant teams recognise indicators of exploitation, including document retention, excessive recruitment fees, debt bondage, intimidation, and deceptive hiring practices. Managers involved in procurement, onboarding, and supplier management receive guidance on how to respond when concerns arise. Our modern slavery policy is reviewed alongside these controls to ensure it remains practical, proportionate, and aligned with current legal expectations.

Reporting Channels and Concern Handling

Any individual who suspects a concern may raise it through established reporting channels. Reports may be made through internal management routes, compliance escalation processes, or whistleblowing mechanisms where available. We expect concerns to be treated seriously, handled confidentially where possible, and investigated promptly. Retaliation of any kind is prohibited, and individuals who raise concerns in good faith are protected under our internal standards.

When a report is received, it is assessed to determine the appropriate response. This may include immediate risk mitigation, enhanced audit activity, worker interviews, document review, or collaboration with the supplier to address the issue. If evidence suggests modern slavery or related exploitation, we will act in line with legal obligations and operational requirements. Our aim is not only to respond effectively but also to support meaningful remediation wherever feasible.

We recognise that transparency is essential to effective prevention. For that reason, incidents, investigations, and corrective actions are recorded and reviewed to identify patterns or recurring vulnerabilities. Lessons learned inform updates to policies, supplier requirements, and training materials. This ensures our anti-slavery framework remains responsive and capable of dealing with evolving risks across different business areas.

Annual Review and Continuous Improvement

As part of our commitment to continuous improvement, this statement and the underlying controls are reviewed annually. The review considers changes in legislation, business structure, sourcing regions, supplier performance, and emerging risks. Findings from audits, incident reporting, and due diligence are used to strengthen the approach for the following year. This annual cycle helps ensure accountability and keeps our response relevant and effective.

The review is overseen by appropriate management leadership and supported by operational teams responsible for procurement, human resources, legal compliance, and supplier management. Where gaps are identified, corrective actions are assigned, tracked, and monitored to completion. Ongoing vigilance is essential, because modern slavery can take many forms and may be hidden within complex supply chains. We therefore remain committed to improving controls, raising awareness, and maintaining a culture of integrity.

In summary, our modern slavery statement reflects a clear commitment to ethical business conduct, responsible sourcing, and worker protection. Through a zero-tolerance policy, supplier audits, accessible reporting channels, and annual review, we seek to prevent exploitation and respond swiftly to concerns. We will continue to strengthen our safeguards and uphold the dignity and rights of every person connected to our business.