Modern Slavery Statement

Our Modern Slavery Statement reflects a clear commitment to preventing modern slavery, human trafficking, forced labour, child labour, and all forms of exploitation within our operations and supply chains. We maintain a zero-tolerance policy toward any practice that undermines human dignity, and we expect the same ethical standard from everyone who works with or for us. This statement sets out the principles, controls, and review processes that support our approach.

We recognise that modern slavery can occur in many forms and in many sectors, particularly where vulnerable workers, complex supply chains, or subcontracting arrangements are involved. For that reason, our modern slavery policy is embedded in our governance framework and is reviewed alongside wider compliance and risk management processes. We require managers, procurement teams, and operational leaders to remain alert to warning signs and to act quickly if concerns arise.

Our commitment extends beyond compliance. We aim to build a culture where integrity, accountability, and respect are part of everyday decision-making. This includes training relevant staff to identify red flags, strengthening supplier due diligence, and taking a proportionate but firm response where risks are identified. We also expect continuous improvement in controls designed to prevent abuse and protect workers.

Supplier management is central to our approach. Before entering into new relationships, we assess suppliers based on geography, sector, labour practices, and their own stated commitments to preventing exploitation. High-risk suppliers may be subject to additional checks, contractual safeguards, and enhanced oversight. Our supplier audits help us verify labour standards, working conditions, wage practices, and the use of subcontractors where relevant.

Where appropriate, our audits may include document reviews, worker interviews, site visits, and follow-up actions to address identified issues. If a supplier falls short of our expectations, we require corrective action within a defined timeframe. In serious cases, we may suspend or terminate the relationship. These measures are designed to ensure that our anti-slavery statement is supported by practical action rather than policy alone.

We also work to strengthen contractual controls by including clauses that require compliance with applicable labour laws and permit investigation where concerns are raised. Suppliers are expected to provide accurate information, cooperate fully with audits, and notify us promptly of any suspected breach. This helps us maintain responsible sourcing practices and uphold the standards set out in our modern slavery declaration.

To encourage early reporting, we provide multiple reporting channels for employees, contractors, and supply chain partners to raise concerns in good faith. Reports may relate to unsafe working conditions, coercion, debt bondage, document retention, or any other sign of exploitation. Concerns are treated seriously, handled sensitively, and investigated promptly by the appropriate internal team.

We are committed to ensuring that no one suffers retaliation for speaking up. Any allegation of modern slavery is escalated according to the seriousness of the issue and the level of risk involved. Where necessary, we may involve specialist advisers, law enforcement, or other relevant authorities. Protection for whistleblowers is a key element of our modern slavery compliance framework.

Our response process also includes remediation where possible and appropriate. If an issue is confirmed, we seek to protect affected individuals, remove them from harm, and address root causes to prevent recurrence. We recognise that an effective modern slavery policy must focus not only on detection, but also on meaningful action and worker-centred outcomes.

This statement is subject to annual review to ensure it remains current, effective, and aligned with legal requirements, business changes, and evolving risk factors. The review examines incidents, audit findings, supplier performance, training completion, and any changes in legislation or guidance. Findings from the review are used to refine controls and improve our approach for the following year.

Ownership of modern slavery risk is shared across the organisation, with leadership providing oversight and relevant teams implementing controls in day-to-day operations. We expect decision-makers to consider human rights impacts when selecting suppliers, approving contracts, or managing commercial pressure. This integrated approach supports our broader responsibility to conduct business ethically and responsibly.

Through this modern slavery statement, we reaffirm our commitment to preventing exploitation in all forms. Our zero-tolerance policy, supplier audits, reporting channels, and annual review process are key parts of a wider framework designed to protect people and promote fair, lawful, and respectful working practices throughout our operations and supply chains.