Modern Slavery Statement

This Modern Slavery Statement sets out our commitment to preventing forced labour, human trafficking, child labour, debt bondage, and all forms of exploitation within our operations and supply chains. We recognise that modern slavery is a grave violation of human rights, and we maintain a zero-tolerance policy toward any practice that enables, conceals, or benefits from it. Our approach is grounded in respect, accountability, and continuous improvement, ensuring that every part of the business contributes to ethical and lawful conduct.

We apply this commitment across all business functions, from procurement and operations to governance and human resources. The modern slavery statement framework is embedded in our internal controls, supplier expectations, and training activities. We require leaders and employees to understand the warning signs of exploitation, including restricted movement, withheld wages, excessive working hours, identity document retention, and threats or coercion. These principles support our broader due diligence process and reinforce our responsibility to protect vulnerable workers.

Our modern slavery statement is reviewed against evolving legal requirements and best practice expectations. We take a risk-based approach to identifying potential exposure, paying particular attention to high-risk geographies, labour-intensive services, and complex supply chains. Where risks are identified, we assess the severity and likelihood of harm, then implement proportionate actions to prevent, mitigate, or remediate issues. This includes strengthening contractual terms, increasing oversight, and working only with suppliers that demonstrate credible ethical standards.

Supplier management is central to our response. We conduct supplier audits using a combination of questionnaires, document checks, site visits, and interviews where appropriate. These audits are designed to test compliance with labour standards, verify recruitment practices, and identify indicators of coercion or abuse. When concerns arise, we require corrective action plans, follow-up reviews, and, where necessary, suspension or termination of the relationship. Our procurement teams are trained to escalate issues quickly and to avoid commercial pressure overriding ethical judgement.

We also expect suppliers to cascade equivalent standards through their own subcontractors and labour providers. As part of our modern slavery policy, suppliers must confirm that they do not use any form of forced, bonded, or involuntary labour and that workers are free to leave employment with reasonable notice. We evaluate risks associated with labour agents, migrant workers, and temporary labour arrangements, since these areas can create heightened vulnerability. Ethical sourcing is therefore treated as a shared responsibility rather than a one-time check.

To support accountability, we provide multiple reporting channels for raising concerns in good faith. Employees, contractors, and supply chain workers are encouraged to report suspected modern slavery, unsafe labour practices, or policy breaches through confidential internal routes. Reports are handled discreetly and investigated promptly, with protections in place against retaliation. When allegations are substantiated, we take decisive action, which may include engaging specialist support, notifying relevant stakeholders, and reviewing whether remediation for affected individuals is required.

Training is a key part of maintaining awareness and effectiveness. Relevant employees receive guidance on recognising risk indicators, applying due diligence, and responding appropriately to concerns. We also communicate expectations to managers responsible for onboarding, procurement, and vendor oversight so they can identify risks early. Modern slavery awareness is reinforced through periodic reminders and updated internal materials, helping ensure that the issue remains visible throughout the organisation.

The effectiveness of our controls is measured through audit outcomes, incident tracking, training completion, and the quality of supplier responses. We review patterns in reported issues to identify systemic weaknesses and opportunities for improvement. If recurring concerns are found in a particular category or region, we strengthen scrutiny, adjust sourcing practices, or revise contractual safeguards. This approach ensures our modern slavery statement remains practical rather than purely aspirational.

We recognise that preventing exploitation requires ongoing vigilance. Accordingly, this statement is subject to an annual review by senior management to assess progress, update risk priorities, and confirm that our controls remain fit for purpose. The review considers changes in legislation, supply chain structure, operational footprint, and stakeholder expectations. Where improvements are identified, we document actions and assign responsibility for implementation. Continuous review helps us sustain momentum and respond effectively to emerging risks.

In the coming year, we will continue to strengthen supplier due diligence, increase the depth of our audits, and enhance staff awareness across relevant functions. We will also maintain our emphasis on ethical procurement and responsible engagement with third parties. The modern slavery statement reflects an organisation-wide commitment to ensure that modern slavery has no place in our business or supply chain.

By combining prevention, detection, response, and review, we aim to uphold human dignity and promote fair treatment throughout our operations. Our zero-tolerance approach, supplier audits, reporting channels, and annual review form the core of a structured and accountable system. We will continue to improve this framework so that our modern slavery statement remains robust, transparent, and aligned with our values.