Modern Slavery Statement

This Modern Slavery Statement sets out the approach taken to prevent slavery, servitude, forced labour, and human trafficking within our operations and supply chains. We recognise that modern slavery can occur in many forms, and we are committed to acting ethically, responsibly, and transparently in all areas of our business. Our zero-tolerance policy applies to every level of the organisation and to all suppliers, contractors, and business partners. Any breach of this commitment is treated as a serious matter and may result in immediate corrective action, suspension, or termination of the relationship.

Our approach is grounded in risk awareness, accountability, and continuous improvement. We assess where vulnerabilities may exist across our activities and work proactively to reduce those risks. This includes reviewing labour practices, recruitment methods, working conditions, and supplier controls. By maintaining strong oversight, we aim to ensure that our modern slavery statement reflects practical action rather than principle alone.

We expect all individuals acting on our behalf to uphold the same standards. Training, internal oversight, and clear responsibility at leadership level help ensure that anti-slavery obligations are understood and embedded across the business. We also encourage a culture in which concerns can be raised early and addressed without delay.

Supplier due diligence is a central part of our commitment. Before engaging new suppliers, we seek to understand their employment practices, ownership structures, and labour controls. Where appropriate, we request declarations, evidence of policy compliance, and information on recruitment and working conditions. Our supplier standards require lawful employment, fair treatment, and the prohibition of coercion, debt bondage, child labour, and exploitation.

We conduct supplier audits on a risk-based basis, prioritising higher-risk sectors, geographies, and categories of spend. These audits may include document reviews, site visits, interviews, and follow-up assessments. Where a concern is identified, we require a remediation plan with clear deadlines. If meaningful improvement is not achieved, we may disengage from the supplier relationship. This ensures that our modern slavery policy is supported by measurable enforcement.

In addition to audits, we monitor supplier performance through periodic reviews and targeted checks. This helps us identify warning signs such as excessive working hours, retention of identity documents, restricted freedom of movement, or unexplained wage deductions. We take such indicators seriously and investigate them promptly, using a proportionate and evidence-based approach.

Reporting channels are available to support early identification of concerns. Employees, contractors, and other stakeholders are encouraged to report any suspected violation of our standards, including concerns relating to labour exploitation or unethical recruitment. Reports may be made confidentially, and whistleblowing arrangements are designed to protect individuals from retaliation. We make it clear that raising a concern in good faith will never result in unfair treatment.

Where a report is received, it is assessed promptly and escalated where necessary. Investigations are carried out with discretion and fairness, and findings are documented to support appropriate action. This may include supplier engagement, remediation, training, enhanced monitoring, or referral to external authorities where required. Our zero-tolerance stance means that substantiated abuse is not accepted under any circumstances.

We recognise that a modern slavery statement must remain current in order to be effective. For that reason, we review our controls regularly and update them to reflect emerging risks, legal developments, and operational changes. Annual review is a key part of our governance process, ensuring that lessons learned are captured and improvements are implemented across the business and supply chain.

Each year, senior leadership reviews the effectiveness of our anti-slavery measures, including due diligence outcomes, audit findings, training activity, and reported concerns. This review informs future priorities and helps strengthen our response to modern slavery risks. Where gaps are identified, we assign owners, set deadlines, and monitor progress until completion. We believe this disciplined approach is essential to maintaining a credible modern slavery statement.

We also communicate expectations to suppliers through contractual provisions and ongoing engagement. By making our standards clear from the outset, we reduce the likelihood of non-compliance and reinforce the importance of ethical sourcing. Our aim is to build long-term partnerships based on trust, transparency, and respect for human rights.

This statement reflects our ongoing commitment to identify, prevent, and address modern slavery in all parts of our operations. Through supplier audits, effective reporting channels, and annual review, we continue to strengthen our governance and uphold our zero-tolerance policy. We will keep improving our controls to ensure that dignity, fairness, and legal compliance remain at the centre of everything we do.