Modern Slavery Statement

This Modern Slavery Statement sets out our zero-tolerance approach to all forms of forced labour, human trafficking, debt bondage, child labour, and exploitation within our operations and supply chains. We are committed to conducting business with integrity, dignity, and respect for human rights. Our modern slavery policy applies to everyone working for or on behalf of the organisation, including employees, contractors, agency workers, and business partners. We expect the same ethical standards from all suppliers and service providers.

We recognise that modern slavery can occur in many industries and geographies, often hidden within complex procurement networks. For that reason, our approach focuses on prevention, detection, and response. We maintain internal controls designed to reduce risk, including due diligence during onboarding, risk-based assessments, and clear contractual expectations. Any breach of our standards may result in corrective action or termination of the relationship.

Our commitment is supported by senior leadership oversight and regular internal awareness activity. We promote a culture in which workers understand their rights and managers understand their responsibilities. This modern slavery statement reflects our ongoing determination to improve labour practices, strengthen controls, and uphold ethical business conduct across the organisation.

Supplier Standards and Audits

We apply a risk-based supplier audit programme to help identify, monitor, and address potential modern slavery risks. Higher-risk suppliers may be subject to pre-qualification checks, document reviews, on-site inspections, or independent assessments. These audits focus on working hours, wages, age verification, freedom of movement, recruitment practices, and the handling of worker passports or identity documents.

Suppliers are required to confirm compliance with applicable laws and to maintain accurate records supporting lawful employment practices. Where concerns are identified, we seek immediate corrective action and may require a remediation plan with measurable timelines. If a supplier fails to demonstrate improvement, the relationship may be suspended or ended. Our procurement teams are trained to escalate red flags and to include human rights considerations in sourcing decisions.

We also encourage suppliers to apply the same standards to their own subcontractors and labour providers. This extends the reach of our modern slavery compliance efforts beyond direct contractual relationships. By embedding ethical expectations into our supply chain controls, we aim to reduce the likelihood of exploitation and improve accountability at every tier.

Reporting Channels and Protection

We provide multiple reporting channels so concerns about modern slavery can be raised promptly and safely. Reports may be made through line management, human resources, compliance teams, or other internal routes established for ethical concerns. Individuals may raise issues anonymously where local law permits. All reports are handled with discretion, and information is shared only with those who need to know in order to investigate and respond appropriately.

We do not tolerate retaliation against anyone who raises a concern in good faith or supports an investigation. This protection applies to employees, agency workers, contractors, and suppliers' personnel where relevant. Suspected cases are investigated promptly, and findings are reviewed to determine corrective, disciplinary, or remedial actions. Where appropriate, we may refer matters to external authorities.

Awareness of warning signs is an important part of our modern slavery prevention approach. We encourage people to report indicators such as restriction of movement, excessive recruitment fees, withheld wages, intimidation, or unsafe living conditions. Creating a safe reporting culture helps us identify risks earlier and take meaningful action to protect vulnerable workers.

Governance, Training, and Annual Review

Our governance framework ensures that responsibility for modern slavery is shared across leadership, operations, procurement, and compliance functions. Training is provided to relevant staff so they can recognise risks, conduct appropriate checks, and respond effectively to concerns. This includes guidance on supplier engagement, escalation procedures, and the importance of maintaining accurate records.

We review the effectiveness of our controls regularly and update them when risks, regulations, or business activities change. This process helps us maintain a practical and proportionate response to evolving threats. The modern slavery statement is reviewed annually to ensure it remains current, transparent, and aligned with our operational reality and ethical commitments.

Each annual review considers audit outcomes, incidents reported, remediation progress, supplier performance, and any lessons learned during the year. Where improvements are needed, we implement action plans and assign accountability for delivery. Through continuous review and improvement, we aim to strengthen our modern slavery standards and sustain a responsible, rights-respecting organisation.