Modern Slavery Statement

This Modern Slavery Statement sets out our commitment to preventing modern slavery, human trafficking, forced labour, and exploitation in every part of our operations and supply chains. We recognise that modern slavery risks can exist in many sectors and geographies, and we take a zero-tolerance approach to any form of abuse, coercion, debt bondage, or child labour. Our position is clear: no business objective justifies exploitation. We expect all colleagues, contractors, and business partners to uphold the same principles and to act with integrity, respect, and accountability.

Our policy framework is designed to identify and reduce risk through prevention, detection, and response. We carry out due diligence on suppliers and partners before engagement and continue monitoring throughout the relationship. This includes assessing country risk, sector risk, labour practices, wage compliance, recruitment methods, and document verification where relevant. We also require suppliers to confirm adherence to our anti-slavery standards and to maintain records that support lawful employment practices. Where concerns arise, we investigate promptly and take corrective action, including suspension or termination of the relationship if necessary.

We reinforce our approach through training, internal controls, and clear governance. Managers responsible for procurement, operations, and people functions receive guidance on recognising warning signs such as restricted movement, retention of identity documents, abusive supervision, or unusual recruitment fees. Our slavery and human trafficking controls are reviewed against legal requirements and good practice so that our response remains effective. We also work to ensure that hiring decisions and supplier selections are based not only on commercial value, but also on ethical conduct and human rights performance.

Reporting concerns is a vital part of our prevention strategy. We provide reporting channels that allow workers, suppliers, and other stakeholders to raise issues safely and in confidence. Reports may be made without fear of retaliation, discrimination, or negative consequences. Allegations are treated seriously, investigated with discretion, and escalated where appropriate. We are committed to protecting whistleblowers and to ensuring that any person who raises a concern in good faith is supported throughout the process. Transparency and trust are essential to identifying hidden risks.

Supplier audits form a central part of our oversight model. We conduct audits based on risk, with higher-risk suppliers receiving closer scrutiny. Audits may include site visits, worker interviews, document checks, payroll reviews, and assessment of recruitment and accommodation practices. Findings are documented, tracked, and followed up until remedial actions are completed. Where a supplier fails to meet our standards, we require an improvement plan with deadlines and measurable outcomes. If serious breaches are identified, we reserve the right to disengage. This ensures our modern slavery policy is backed by practical enforcement.

We also recognise that modern slavery risks can change over time, particularly where supply chains expand, labour shortages occur, or sourcing regions shift. For that reason, our risk assessment process is ongoing rather than static. We review new suppliers, subcontracting arrangements, and labour providers to ensure that our standards continue to be applied consistently. In addition, we encourage open dialogue with business partners so that issues can be identified early and resolved before harm occurs.

Our commitment extends beyond compliance. We aim to promote fair treatment, lawful recruitment, and dignified work across the supply chain. This includes discouraging recruitment fee abuse, ensuring working hours are managed responsibly, and supporting suppliers to improve labour practices where needed. We believe that ethical sourcing strengthens resilience and reduces operational risk. By embedding anti-slavery principles into governance, procurement, and performance management, we help create a business culture where exploitation is not tolerated.

To maintain accountability, the statement is subject to an annual review. Each year, we assess the effectiveness of our controls, consider findings from audits and investigations, and update our actions in light of emerging risks, legal developments, and operational changes. This annual review allows us to strengthen our modern slavery measures and refine our approach to prevention. Any significant lessons learned are incorporated into training, supplier requirements, and oversight procedures so that continuous improvement remains central to our response.

We remain committed to continuous vigilance and responsible business conduct. Our zero-tolerance policy is not a symbolic statement; it is a practical commitment that guides decisions at every level of the organisation. Through supplier audits, confidential reporting channels, and annual review, we seek to identify risks early, respond effectively, and uphold human rights. Respect for people is a core expectation, and we will continue to strengthen our modern slavery response wherever improvement is needed.