Modern Slavery Statement

This Modern Slavery Statement sets out our commitment to preventing slavery, servitude, forced labour, and human trafficking in our operations and across our supply chains. We recognise that modern slavery can take many forms, including debt bondage, deceptive recruitment, withholding of identity documents, and exploitative working conditions. Our organisation adopts a zero-tolerance policy toward any practice that undermines human dignity, and we expect the same standard from all partners, contractors, and suppliers.

We are committed to acting ethically and with integrity in all business relationships. To support this commitment, we carry out risk-based assessments across our activities and continuously review the controls in place to identify and address areas of vulnerability. Our modern slavery approach is embedded in procurement, supplier onboarding, and internal governance. We also provide training so that employees can recognise warning signs and understand how to respond appropriately to potential concerns.

Our supplier due diligence process is central to this statement. Before engaging new suppliers, we assess their labour practices, ownership structures, and compliance records. Higher-risk suppliers may be subject to enhanced scrutiny, including document reviews, site visits, and follow-up questions. Where appropriate, supplier audits are conducted to verify working conditions, recruitment practices, wage arrangements, and the treatment of workers. Findings from these audits are recorded, actioned, and monitored until closure.

If concerns arise, we encourage prompt reporting through established reporting channels. Employees, workers, and business partners may raise issues confidentially and without fear of retaliation. Reports may be made anonymously where permitted, and every concern is treated seriously. Allegations are reviewed by the relevant internal team, and corrective action is taken where needed. This may include remediation, supplier suspension, contract review, or termination of the relationship if risks cannot be resolved.

We expect all suppliers to uphold the principles set out in our code of conduct and contractual terms. These requirements include lawful recruitment, fair pay, safe conditions, freedom of movement, and respect for workers’ rights. Any supplier found to be in breach of these expectations must implement immediate corrective measures. Persistent non-compliance may result in removal from our approved supplier list. In this way, our modern slavery statement reflects not only our values but also our operational standards.

To strengthen oversight, we maintain internal accountability for modern slavery risks at management level. Key functions, including procurement, human resources, and compliance, work together to identify risk indicators and ensure consistent decision-making. Risk assessments are informed by geography, sector, labour model, and known industry concerns. We also monitor emerging risks linked to subcontracting, labour brokers, and temporary employment arrangements, where exploitation may be less visible.

Our commitment extends to remediation and continuous improvement. Where an issue is identified, we seek to support affected individuals and address root causes rather than relying only on enforcement. Actions may include revising supplier expectations, improving audit frequency, strengthening due diligence, or increasing awareness training. By learning from incidents and near misses, we improve the resilience of our controls and reinforce our zero-tolerance approach across the organisation.

We also recognise the importance of transparency in assessing progress. As part of our governance cycle, the effectiveness of controls, audit outcomes, and reporting trends are reviewed at regular intervals. This helps us identify whether our measures remain proportionate and whether additional safeguards are required. The statement is prepared in alignment with applicable legal and ethical expectations and is intended to demonstrate our ongoing commitment to responsible business conduct.

This statement is reviewed annually to ensure it remains current, relevant, and effective. During the review, we consider changes in legislation, business structure, operational risk, and supplier performance. Any updates are approved through the appropriate governance process and reflected in our internal policies and procedures. Through annual review, diligent supplier audits, accessible reporting channels, and unwavering enforcement of our zero-tolerance policy, we aim to help prevent modern slavery in all forms.