Modern Slavery Statement

This modern slavery statement sets out our zero-tolerance approach to slavery, human trafficking, forced labour, bonded labour, and all other forms of exploitation within our operations and supply chains. We are committed to acting ethically and transparently, and we expect the same standard from every business partner, contractor, and supplier that works with us. Our policy is clear: modern slavery has no place in our organization.

We recognise that the risk of exploitation can exist in any sector and across multiple tiers of supply. For that reason, our modern slavery policy applies not only to direct employees but also to agency workers, subcontractors, and suppliers of goods and services. We maintain internal controls designed to identify, prevent, and address risks early, and we ensure that responsibilities for oversight are understood by relevant teams.

A key part of our approach is due diligence. Before entering into new commercial relationships, we assess suppliers for ethical, legal, and labour-rights risks. This includes reviewing country of origin, industry risk, workforce vulnerability, and evidence of responsible employment practices. Where concerns are identified, we require corrective action plans and may decline or discontinue the relationship if adequate safeguards are not demonstrated.

Supplier audits are an important tool in our modern slavery commitment. We conduct periodic audits, either directly or through approved third parties, to verify labour standards and assess compliance with our expectations. Audits may include document reviews, site inspections, worker interviews, and evaluation of recruitment practices, working hours, wage records, and living conditions where applicable.

When an audit identifies a potential issue, we respond proportionately and promptly. Our process includes escalation, investigation, remediation, and follow-up verification. We seek to work with suppliers to improve conditions where possible, but we will not tolerate deliberate violations, concealment of evidence, or repeated non-compliance. In severe cases, the relationship may be suspended or terminated.

We also require suppliers to cascade our standards through their own subcontracting networks. This helps extend responsible practices beyond first-tier relationships and supports a broader culture of accountability. Our procurement teams are trained to include modern slavery risk indicators in sourcing decisions, contract terms, and performance reviews.

Speaking up is essential to our control framework. We provide multiple reporting channels so concerns can be raised safely and in good faith by employees, workers, suppliers, or other stakeholders. Reports may relate to suspected exploitation, unethical recruitment, wage withholding, document retention, threats, intimidation, or any other indicator of abuse. All reports are handled confidentially and assessed without retaliation.

We expect managers to act quickly if they receive a concern. Allegations are documented, investigated, and reviewed by appropriate leadership. Where a concern is substantiated, we implement remedial actions that may include worker support, contract review, supplier re-audit, training, or disciplinary action. We are committed to protecting anyone who reports a concern from victimisation or disadvantage.

Our training programme supports this work by helping employees understand how exploitation can occur and what warning signs to watch for. Relevant staff receive guidance on recruitment practices, supplier due diligence, grievance handling, and escalation routes. This strengthens our ability to identify risks in a modern slavery statement context and reinforces our wider ethical standards.

We will review the effectiveness of this statement and our related controls annually. The annual review considers audit findings, reported concerns, supplier performance, training completion, legal developments, and any changes in our business model or supply chain footprint. Findings from the review inform improvements to policy, procedures, and oversight arrangements.

Senior leadership is accountable for ensuring the modern slavery statement remains current, meaningful, and action-oriented. As part of the annual cycle, we assess whether additional controls are needed in higher-risk categories or geographies, and we update our approach accordingly. This commitment reflects our belief that prevention is most effective when it is embedded, measured, and continually improved.

In conclusion, our modern slavery commitment is founded on prevention, transparency, and accountability. Through a zero-tolerance policy, supplier audits, accessible reporting channels, and annual review, we aim to reduce risk and uphold the dignity and rights of every worker connected to our operations. We will continue to strengthen our practices and expect all parties in our supply chain to do the same.