Modern Slavery Statement

This Modern Slavery Statement sets out our zero-tolerance approach to modern slavery, human trafficking, forced labour, debt bondage, child labour, and any form of exploitation within our operations and supply chains. We are committed to conducting business ethically, responsibly, and with respect for human rights. Our modern slavery policy applies to all employees, contractors, agencies, and suppliers, and it is supported by governance, risk assessment, and ongoing training.

We recognise that the risk of modern slavery can exist in complex supply chains, particularly where labour is sourced through intermediaries, seasonal work, manufacturing, logistics, or high-risk raw materials. To address this, we maintain a clear due diligence process designed to identify, prevent, and mitigate risk. Our anti-slavery statement is reviewed against current legal requirements and informed by industry best practice, operational risk, and stakeholder expectations.

Our commitment begins with leadership. Senior management is responsible for embedding ethical standards across the organisation and for ensuring that the modern slavery statement remains practical, measurable, and effective. All relevant staff are expected to understand the signs of exploitation, challenge suspicious activity, and escalate concerns without delay. We will not knowingly work with any party that fails to meet our expectations on human rights and labour standards.

Supplier Standards and Due Diligence

Supplier selection is a critical control in our approach. We require suppliers to confirm compliance with applicable labour laws and to uphold our code of conduct. As part of onboarding, higher-risk suppliers may be asked to provide workforce policies, recruitment practices, subcontracting arrangements, and evidence of lawful working conditions. We use this information to assess the modern slavery risk associated with each relationship.

Where risk indicators are present, we may conduct supplier audits, desktop reviews, or targeted assessments. These audits can include document checks, worker interviews, site observations, and verification of age, wage, and working-hour records. If a supplier is unable or unwilling to demonstrate compliance, we will require a corrective action plan and may suspend or terminate the relationship if improvement is not achieved. Serious breaches are treated as zero-tolerance matters.

We also expect suppliers to apply equivalent standards to their own subcontractors and labour providers. This cascading responsibility is essential to preventing hidden exploitation deeper in the supply chain. Our purchasing teams are trained to recognise commercial practices that can increase vulnerability, such as unrealistic lead times, excessive cost pressure, or informal labour arrangements. Responsible sourcing is therefore embedded into procurement decisions, not treated as a separate exercise.

Reporting, Investigation, and Remediation

We encourage anyone who suspects wrongdoing to report it through our internal reporting channels. Concerns may be raised confidentially and without fear of retaliation. Reports are reviewed promptly, investigated proportionately, and escalated where necessary. Our reporting framework is designed to support safe disclosure and to ensure that potential victims are protected while facts are established.

When an issue is confirmed, we take swift action. This may include supplier suspension, removal of individuals from a site, remediation for affected workers, enhanced monitoring, or reporting to relevant authorities where required. We seek to remedy harm wherever possible and to strengthen controls so that similar incidents do not recur. Our approach balances accountability with a commitment to ethical improvement.

Training is a further safeguard. Relevant employees receive guidance on recognising indicators of exploitation, managing supplier relationships responsibly, and handling escalations appropriately. Modern slavery prevention is not static; it depends on awareness, vigilance, and consistent application of standards across the business. We reinforce this through internal communications, management oversight, and periodic refreshers.

Annual Review and Continuous Improvement

This statement is subject to an annual review to ensure it remains effective and aligned with our operations, legal duties, and risk profile. The review considers supplier audit results, reported concerns, due diligence findings, remediation progress, and any emerging trends in modern slavery risk. Where necessary, we update our controls, training, and sourcing requirements to reflect lessons learned.

Modern slavery compliance is a continuous responsibility. Each year, we assess whether our policy framework has been properly implemented and whether further action is needed to improve prevention, detection, and response. We also evaluate the effectiveness of our supplier monitoring arrangements and the accessibility of our reporting channels.

Through this Modern Slavery Statement, we reaffirm our commitment to eradicating exploitation from our business and supply chains. Our zero-tolerance policy, supplier audits, reporting mechanisms, and annual review process form the foundation of a practical and accountable response. We will continue to strengthen our approach and act decisively wherever risks are identified.