Modern Slavery Statement

Our modern slavery statement sets out the principles, controls, and responsibilities we apply to prevent modern slavery and human trafficking in any part of our operations. We recognise that forced labour, servitude, bonded labour, child labour, and other forms of exploitation are grave violations of human rights. As a matter of zero-tolerance, we do not accept such practices in our business or in the businesses we work with.

We are committed to upholding ethical conduct across our organisation and supply chain. This commitment is embedded in our policies, procurement practices, and governance processes. Modern slavery risks are reviewed as part of our broader approach to responsible business conduct, with the aim of identifying, preventing, and addressing any potential breaches before they cause harm.

All employees, contractors, and relevant partners are expected to act with integrity and to comply with our anti-slavery requirements. Training and awareness activities support this expectation by helping teams understand warning signs, escalation routes, and the importance of due diligence. We expect the same standards from suppliers, service providers, and other third parties who contribute to our operations.

Our anti-slavery policy is built on the principle that exploitation has no place in our workplace or supply chain. This policy is supported by risk-based controls that guide procurement, onboarding, and supplier management. Where higher-risk categories are identified, we apply enhanced checks to better understand labour conditions, recruitment practices, and ownership structures.

Supplier audits are an important part of our assurance framework. Depending on the risk profile of the supplier, audits may include document reviews, on-site assessments, worker interviews, and verification of subcontracting arrangements. Findings are recorded, monitored, and followed up through corrective action plans where necessary. Where a supplier fails to meet our standards, we may suspend, restrict, or terminate the relationship.

Our approach to the modern slavery policy also requires continuous improvement. We review contractual clauses, onboarding questionnaires, and due diligence questionnaires to ensure they remain relevant and effective. In doing so, we aim to strengthen transparency and accountability across the supply chain while encouraging responsible sourcing and ethical labour practices.

We provide multiple reporting channels so that concerns about modern slavery can be raised safely and in confidence. Employees and workers are encouraged to report suspected misconduct, unusual recruitment fees, document retention, restricted movement, intimidation, or any other indicators of exploitation. Reports can be made without fear of retaliation, and all concerns are assessed promptly and sensitively.

Underlined escalation pathways help ensure that allegations are handled consistently and by the appropriate teams. When a concern is raised, we evaluate the facts, determine the level of risk, and take proportionate action. This may include investigation, temporary suspension of activity, cooperation with external experts, or referral to relevant authorities where required by law.

We also expect suppliers to maintain their own safe reporting mechanisms for workers, including access to grievance processes in languages they understand. By encouraging open reporting and active remediation, our modern slavery commitments support a culture of accountability and help reduce the likelihood that abuses remain hidden.

Our governance framework assigns responsibility for the modern slavery programme to senior leadership, with oversight from relevant operational and risk functions. Key performance indicators, remediation progress, and audit outcomes are tracked so that risks can be addressed in a timely manner. This ensures that our slavery and human trafficking statement is not merely descriptive, but actively informs decision-making.

We recognise that meaningful progress depends on working collaboratively with suppliers, internal stakeholders, and other partners. Where issues are identified, we prioritise remediation that puts the welfare of affected people first. This may include improving wage practices, strengthening recruitment controls, reducing reliance on high-risk labour intermediaries, or revising contractual requirements.

The effectiveness of our modern slavery framework is measured through reviews of incident trends, audit findings, training uptake, and supplier responsiveness. These measures help us understand where controls are working and where further action is needed. We remain committed to improving our processes and strengthening the resilience of our supply chain.

This modern slavery statement is reviewed annually to ensure it remains accurate, current, and aligned with operational realities and legal expectations. The annual review considers changes in our business model, supplier base, risk profile, and regulatory environment. It also informs updates to policies, training, audits, and reporting arrangements for the next cycle.

By maintaining a clear zero-tolerance position, using supplier audits to monitor compliance, and offering accessible reporting channels, we aim to prevent exploitation and respond effectively where concerns arise. Our ongoing review process helps us strengthen the standards we set and the actions we take, year after year.