Modern Slavery Statement

This Modern Slavery Statement sets out our commitment to preventing slavery, human trafficking, forced 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 or violates fundamental labour rights. Our approach is grounded in ethical conduct, legal compliance, and continuous improvement. We expect everyone who works with or on behalf of the organisation to uphold these standards, whether they are employees, contractors, consultants, or business partners.

To support this commitment, we apply clear internal controls and due diligence processes designed to identify, assess, and reduce modern slavery risks. These measures include risk-based screening, contract provisions, staff training, and review of labour practices in higher-risk areas. We recognise that modern slavery can appear in complex forms and may be hidden behind layers of subcontracting or informal recruitment. For this reason, we treat vigilance as an ongoing responsibility, not a one-time exercise.

Our modern slavery response also depends on a culture of accountability. Managers are responsible for embedding ethical practice in day-to-day decision-making, while employees are encouraged to remain alert to warning signs such as withheld identity documents, excessive working hours, debt bondage, or restricted freedom of movement. Where concerns arise, we act promptly and proportionately, placing the safety and welfare of potential victims first.

Supply Chain Due Diligence

We expect our suppliers and service providers to share our commitment to the prevention of modern slavery and human trafficking. Before onboarding new suppliers, we conduct due diligence assessments that consider geography, sector, labour intensity, and recruitment practices. Higher-risk suppliers are subject to enhanced review, including documentary checks and, where appropriate, on-site supplier audits. These audits evaluate employment conditions, age verification, wage practices, worker freedom, health and safety, and the use of subcontractors.

When non-compliance is identified, we require corrective action plans with clear timelines and monitoring. If a supplier fails to demonstrate meaningful improvement, we reserve the right to suspend or terminate the relationship. We believe that commercial partnerships must be based on integrity, and that the presence of risk does not lessen our duty to respond decisively. Our procurement teams are trained to recognise warning signs and to escalate concerns without delay.

We also encourage suppliers to maintain their own robust policies and controls. This includes ensuring lawful recruitment, prohibiting fees charged to workers, and protecting whistleblowers from retaliation. By reinforcing expectations across the supply chain, we aim to reduce the likelihood that exploitation can occur unnoticed. Our modern slavery statement is therefore supported by practical governance, not merely written principles.

Reporting, Training, and Governance

Everyone associated with our business is expected to report concerns immediately if they suspect a breach of this statement or observe conduct inconsistent with our ethical standards. Multiple reporting channels are available internally, enabling concerns to be raised confidentially and without fear of retaliation. Reports are reviewed seriously, investigated appropriately, and handled with discretion. We prohibit victimisation of anyone who raises a concern in good faith.

Training is provided to relevant employees so they can recognise indicators of exploitation and understand how to respond. This includes teams involved in procurement, recruitment, operations, and contract management, where exposure to labour risk may be greater. Our training emphasises the importance of accurate recordkeeping, responsible escalation, and respect for worker rights. By strengthening awareness, we aim to create practical resilience against modern slavery risks.

Governance oversight is maintained by senior leadership, who review trends, audit outcomes, and remediation progress. This ensures that our anti-slavery commitments remain embedded in business planning and not treated as a standalone compliance task. Senior oversight helps us align ethical responsibility with operational decision-making and reinforces the message that exploitation is unacceptable in any form.

Annual Review and Continuous Improvement

We review this Modern Slavery Statement annually to assess the effectiveness of our controls and to reflect changes in legislation, operations, and supply chain risk. The review considers incident data, supplier performance, audit findings, training completion, and emerging risk indicators. Where gaps are identified, we strengthen procedures and refresh responsibilities so that our response remains relevant and effective.

Annual review is essential because the nature of labour exploitation can evolve quickly, especially in complex international supply chains. We therefore seek continual improvement through policy updates, enhanced due diligence, and stronger monitoring. Our objective is not only to comply with legal requirements, but to contribute to the prevention of forced labour and the protection of vulnerable workers.

This statement reflects our ongoing determination to operate responsibly and to promote fair, transparent, and lawful working conditions. Through a zero-tolerance stance, targeted supplier audits, secure reporting channels, and annual review, we aim to ensure that modern slavery has no place in our organisation or our supply network.