Modern Slavery Statement

Modern slavery and human trafficking have no place in our organisation or in the supply chains that support our work. This Modern Slavery Statement sets out the principles, controls, and responsibilities we use to identify, prevent, and address any risk of exploitation. We are committed to upholding human dignity, ethical conduct, and lawful working practices across every area of operation.

Our zero-tolerance position applies to all forms of slavery, servitude, forced labour, debt bondage, and child exploitation. We expect every employee, contractor, agency worker, and business partner to act with integrity and to reject any practice that could enable abuse. This commitment is embedded in our policies, our procurement approach, and our day-to-day decision-making.

We recognise that modern slavery risks can arise in complex supply chains, particularly where labour is sourced through third parties or where goods and services are produced in higher-risk regions or sectors. To address this, we carry out risk-based due diligence before engaging suppliers and continue monitoring throughout the relationship. Where concerns are identified, we act promptly to investigate and, if necessary, to suspend or end the relationship.

Our supplier standards require all vendors to comply with applicable labour laws, prohibit forced or trafficked labour, and maintain safe and fair working conditions. As part of our supplier audits, we review documentation, labour practices, wage records, recruitment methods, and site controls. These audits may be announced or unannounced, depending on the level of risk and the nature of the supplier arrangement.

In addition to audits, we expect suppliers to provide accurate information about their workforce, subcontractors, and recruitment processes. We reserve the right to request corrective action plans where weaknesses are found. Persistent non-compliance, refusal to cooperate, or evidence of exploitation may result in immediate escalation and commercial termination. This approach supports a stronger anti-slavery framework and reinforces accountability across the supply chain.

Training is provided to relevant staff so they can recognise warning signs such as excessive recruitment fees, document retention, restricted movement, intimidation, or signs of coercion. By strengthening awareness, we improve our ability to detect modern slavery risks early and respond effectively. Managers are expected to maintain oversight of procurement and labour-related decisions so that ethical standards remain central.

We also maintain accessible reporting channels so that concerns can be raised in confidence and without fear of retaliation. Reports may be submitted by employees, suppliers, or other stakeholders through established internal procedures. All concerns are treated seriously, investigated proportionately, and managed with appropriate confidentiality. Retaliation against anyone who raises a concern in good faith is strictly prohibited.

Our response framework prioritises prompt assessment, evidence gathering, and corrective action. If a report suggests possible exploitation, we engage the relevant teams to determine immediate safeguards and longer-term remediation. Where appropriate, we work with suppliers to improve conditions; however, where the risk cannot be mitigated, we will take decisive action to protect those affected.

This statement is supported by governance arrangements that assign clear responsibility for oversight of modern slavery prevention. Leadership reviews key risks, audit findings, and remediation progress to ensure that commitments are translated into practical action. Policies are updated as needed to reflect legal developments, operational changes, and emerging risk indicators.

Annual review is an essential part of our approach. Each year, we evaluate the effectiveness of our controls, including supplier due diligence, audit outcomes, training activity, and reporting trends. The review helps us identify lessons learned, strengthen our modern slavery statement, and improve our risk management practices over time.

As part of that review, we assess whether our zero-tolerance policy remains clearly communicated and consistently applied. We also examine whether our supplier audits are proportionate to risk and whether reporting channels remain trusted and accessible. This cycle of review and improvement ensures that our approach remains active, credible, and responsive to changing circumstances.

We remain committed to continuous improvement and to working with partners who share our values. By maintaining vigilance, enforcing standards, and acting on concerns, we aim to help eliminate exploitation from our operations and supply chains. This Modern Slavery Statement reflects our ongoing responsibility to protect workers and uphold ethical business conduct.