Modern Slavery Statement

Our Modern Slavery Statement sets out the principles, controls, and responsibilities that guide our approach to preventing modern slavery and human trafficking in every part of our operations. We are committed to maintaining a zero-tolerance policy toward all forms of forced labour, bonded labour, child labour, servitude, and exploitation. This commitment applies across our business activities, our workforce, and our supply chains, where we expect the same high standards of conduct. We recognise that modern slavery can take many forms, and it may be hidden within complex labour arrangements, subcontracting chains, or the sourcing of goods and services. For that reason, our modern slavery commitment is embedded in governance, procurement, training, and risk management.

Our anti-slavery framework is designed to identify, prevent, and address risks before they escalate. We conduct regular risk assessments to understand where exposure may arise by geography, sector, product category, and working practice. Where higher-risk indicators are identified, we apply enhanced oversight and require corrective action plans. This approach ensures that our slavery and human trafficking statement is not merely symbolic, but an active part of our operational discipline. Senior leadership holds accountability for oversight, while managers are responsible for implementing controls in their respective areas.

We also expect all employees and contractors to act ethically and to support the goals of this modern slavery statement through informed vigilance. Training is provided to help teams recognise warning signs such as restricted movement, withheld wages, retention of identity documents, unsafe accommodation, or threats and intimidation. By promoting awareness and responsibility, we strengthen the effectiveness of our modern slavery policy and reinforce our shared duty to protect vulnerable people.

Our supplier standards are central to this modern slavery declaration. Every supplier is required to comply with our code of conduct, which includes explicit prohibitions on forced labour, involuntary prison labour, exploitative recruitment fees, and underage work that interferes with education or wellbeing. We carry out supplier audits to verify compliance, especially in higher-risk supply chains. These audits may include document reviews, site inspections, worker interviews, and checks on payroll, age verification, and recruitment practices. Where issues are identified, we require timely remediation and reserve the right to suspend or terminate relationships if standards are not met.

In addition to audits, we assess suppliers before onboarding and during contract renewal. This due diligence process considers labour practices, subcontracting controls, grievance mechanisms, and evidence of ethical sourcing. Our procurement teams are trained to identify risk indicators and to escalate concerns promptly. We also encourage suppliers to adopt their own robust slavery and human trafficking controls, helping extend the reach of this modern slavery approach throughout the wider value chain.

Should any concerns arise, we provide clear and accessible reporting channels so that workers, colleagues, and business partners can raise issues without fear of retaliation. Reports may be made through internal management routes, ethics functions, or designated safeguarding pathways, depending on the nature of the concern. We treat every report seriously, investigate promptly, and apply proportionate action. Confidentiality and non-retaliation are fundamental to our reporting process, ensuring that people can speak up safely when modern slavery risks are suspected.

We understand that effective governance requires continual improvement. For that reason, this modern slavery statement is subject to an annual review to assess its effectiveness, update risk profiles, and reflect changes in legislation, operations, and supply chains. The review considers audit findings, training completion, reported concerns, remediation outcomes, and any emerging risks. This cycle helps ensure that our anti-slavery statement remains current, practical, and aligned with our business reality.

As part of the annual review, we evaluate the quality of supplier engagement and the success of corrective actions. If recurring concerns are found, we adjust our controls, strengthen contractual requirements, or introduce more targeted monitoring. Our aim is not only to detect non-compliance, but to build resilience against modern slavery risks over time. Continuous improvement is therefore a key principle of our modern slavery commitment, reflecting the belief that ethical business conduct must be actively maintained.

The responsibility for delivering this modern slavery and human trafficking statement is shared across the organisation. Leadership sets the tone, operational teams apply the controls, and all personnel are expected to uphold our standards. We will continue to invest in awareness, supplier oversight, and practical safeguards that support a transparent and responsible supply chain.

In summary, this Modern Slavery Statement confirms our unwavering commitment to prevent exploitation, protect dignity, and hold ourselves and our suppliers to account. Through zero tolerance, supplier audits, accessible reporting channels, and annual review, we aim to maintain a strong and credible response to modern slavery risks. We recognise that vigilance must be sustained, and we will continue to strengthen our practices wherever necessary to help ensure that exploitation has no place in our business or supply chain.