Modern Slavery Statement

This Modern Slavery Statement sets out the approach of our organization to preventing forced labour, human trafficking, child labour, and all forms of exploitation within our operations and supply chains. We are committed to maintaining a workplace and procurement environment founded on dignity, fairness, and zero tolerance for abuse. Our modern slavery policy applies to employees, contractors, agency workers, and business partners, and it requires compliance with all applicable laws and ethical standards.

We recognize that modern slavery can occur in complex global supply chains, particularly where labour is outsourced, recruitment practices are opaque, or work is carried out in sectors with elevated risk. For that reason, our anti-slavery framework is designed to identify risk early, reduce vulnerabilities, and respond quickly when concerns arise. We expect every person connected to our business to act responsibly and to uphold the principles outlined in this statement.

Our zero-tolerance policy means that any confirmed instance of slavery, servitude, forced labour, debt bondage, or human trafficking will result in decisive action. This may include termination of employment, suspension of a supplier relationship, or referral to the appropriate authorities. We do not accept excuses for exploitation, and we require all managers to embed this expectation in day-to-day decision-making.

Governance, Risk, and Supplier Oversight

To support the modern slavery commitment, we conduct risk-based due diligence on suppliers, contractors, and service providers. This includes reviewing business practices, assessing geographic and sector risk, and evaluating labour standards before engagement and during the relationship. Where higher risks are identified, we may request supporting evidence, targeted remediation plans, or additional assurances.

Our supplier audits are an essential part of this process. Audits may be announced or unannounced and can include document reviews, site visits, worker interviews, and checks on recruitment, working hours, wages, and freedom of movement. If shortcomings are identified, we expect prompt corrective action and measurable improvement. Continued non-compliance may lead to contract suspension or termination.

We also use contractual clauses to reinforce our expectations. Suppliers must confirm that they, and where relevant their own suppliers, comply with anti-slavery laws and maintain safe reporting mechanisms. In addition, we monitor risk indicators such as excessive recruitment fees, withheld identity documents, restricted access to grievance systems, or signs of coercion. These controls help strengthen our broader modern slavery prevention strategy.

Training and Awareness

Employees involved in procurement, human resources, logistics, and operational management receive training appropriate to their responsibilities. This training helps them recognize warning signs, understand escalation procedures, and apply due diligence consistently. By improving awareness, we strengthen our ability to prevent exploitation before it occurs and to respond appropriately when concerns are raised.

We also encourage a culture of vigilance across the organization. Everyone has a role in safeguarding ethical labour practices, whether by reviewing supplier documentation, questioning unusual employment arrangements, or ensuring that vulnerable workers are not exposed to coercion. Our approach reflects a commitment to responsible sourcing and to protecting people throughout the value chain.

Where a risk is identified, we assess whether remediation is possible and whether the affected individuals are safe. Any action taken will prioritize the welfare of workers and the integrity of the investigation. Our procedures are designed to be practical, fair, and consistent with the principles of respect and accountability.

Reporting Channels and Accountability

We maintain confidential reporting channels so that employees, suppliers, and other stakeholders can raise concerns about modern slavery without fear of retaliation. Reports may relate to labour practices, recruitment conduct, document retention, threats, intimidation, or any behaviour that may indicate exploitation. All concerns are taken seriously and reviewed promptly.

Retaliation against anyone who raises a concern in good faith is strictly prohibited. This protection is essential to encouraging early reporting and ensuring that issues are addressed before harm escalates. Allegations are investigated by appropriate personnel, with findings documented and corrective actions tracked to completion.

This modern slavery statement is reviewed annually to ensure it remains effective, current, and aligned with legal and ethical expectations. The review considers audit outcomes, risk assessments, training activity, incident reports, and any changes to our operations or supply chains. We will continue to strengthen our controls and improve our response to evolving risks.