Modern Slavery Statement

This Modern Slavery Statement sets out our commitment to preventing modern slavery, human trafficking, forced labour, debt bondage, and child labour in any part of our operations and supply chain. We recognise that modern slavery can take many forms and may be hidden within complex commercial relationships. Our position is clear: there is zero tolerance for modern slavery in our business and in the businesses of those who supply us. We expect all colleagues, contractors, and suppliers to act ethically and to uphold the highest standards of human rights. This statement reflects our ongoing responsibility to identify, prevent, and address risks wherever they may arise.

Our approach is grounded in accountability, transparency, and continuous improvement. We embed human rights considerations into procurement, onboarding, and supplier management processes. As part of our modern slavery commitment, we assess risk indicators such as geography, sector, labour model, and subcontracting complexity. Where risk is identified, we apply enhanced due diligence and, where needed, corrective action plans. We also provide training to relevant teams so they can recognise warning signs and respond appropriately. These measures help ensure that modern slavery risks are managed proactively rather than reactively.

We maintain a zero-tolerance policy and will not knowingly engage with any party that is involved in exploitation or that fails to cooperate in efforts to remediate concerns. Suppliers are required to comply with applicable labour laws, respect the rights of workers, and maintain accurate records relating to wages, working hours, and identity documentation. Where breaches are suspected, we reserve the right to investigate, suspend activity, or terminate the relationship. This modern slavery statement applies across our operations and reflects our expectation that ethical conduct is non-negotiable.

Supplier Due Diligence and Oversight

To support our modern slavery policy, we conduct supplier risk assessments at onboarding and on a recurring basis. These reviews consider labour recruitment practices, use of migrant workers, subcontracting arrangements, and employment conditions. Higher-risk suppliers may be subject to supplier audits, document reviews, and management interviews. If a supplier is found to have insufficient controls, we require a remediation plan with clear actions and deadlines. Persistent non-compliance can lead to disengagement. Supplier audits are an important tool, but they are only one part of a broader programme that includes engagement, training, and monitoring.

Our procurement teams are trained to recognise indicators of exploitation, including unusually low pricing that may conceal abusive labour practices, restricted worker mobility, withholding of passports, or excessive recruitment fees. We also expect suppliers to cascade equivalent standards throughout their own supply chains. This anti-slavery approach is designed to reduce the risk of hidden exploitation and to create leverage for positive change. We review contract terms to ensure that suppliers understand their obligations, and we encourage open communication about any issues that may affect worker welfare.

Reporting channels are a critical part of our control framework. Employees, contractors, and supply chain workers can raise concerns about suspected exploitation, unsafe practices, or breaches of our standards through confidential internal reporting routes. All concerns are taken seriously, investigated promptly, and handled with discretion to protect those who speak up. We do not tolerate retaliation against anyone who reports a concern in good faith. The existence of effective reporting channels supports early intervention and helps us address risks before they escalate into harm.

Governance, Review, and Continuous Improvement

The middle of our programme is governance. Senior leadership oversight ensures that modern slavery risk remains visible and that actions are tracked to completion. Relevant functions share responsibility for prevention, detection, and remediation. We review trends in supplier performance, audit findings, and reported concerns to identify themes that require additional attention. This ongoing analysis supports targeted improvements across the organisation. Our modern slavery statement is therefore not a static document, but a reflection of an active control environment committed to ethical business conduct.

We are also mindful that modern slavery risks can change quickly due to market conditions, sourcing shifts, and external events. For that reason, we keep our policies under regular review and update controls where necessary. We promote awareness through training and internal communications so that staff understand both the human impact of exploitation and the practical steps needed to prevent it. In doing so, we aim to strengthen our capacity to identify signs of coercion, deception, or abuse and to act decisively when concerns arise.

Our annual review process evaluates the effectiveness of our controls, including risk assessment outcomes, audit coverage, supplier remediation, and the use of reporting channels. Findings are used to refine procedures and shape future priorities. We consider whether any additional sectors, geographies, or sourcing models require enhanced scrutiny. This annual review supports accountability and demonstrates our commitment to continual improvement. It also ensures that our response to modern slavery remains proportionate, practical, and aligned with emerging expectations.

Commitment to Responsible Supply Chains

We expect all suppliers to uphold our standards and to cooperate with investigations or corrective actions where concerns are identified. Where appropriate, we may require evidence of worker protections, recruitment fee reimbursement, improved recordkeeping, or independent verification of labour practices. We believe that responsible sourcing depends on informed decision-making, robust oversight, and the willingness to challenge unacceptable practices. Our modern slavery controls are designed not only to prevent harm, but also to reinforce dignity, fairness, and respect for every worker in the chain.

As part of our governance cycle, we assign ownership for actions arising from audits, complaints, or risk reviews and monitor progress until issues are closed. This helps ensure that commitments made in response to concerns are carried through effectively. We also compare supplier performance over time to identify repeat risks or signs of weakness in control systems. Such analysis supports a more resilient and transparent anti-slavery programme.

In the final part of this statement, we reaffirm that modern slavery has no place in our business or supply chains. Our zero-tolerance policy, supplier audits, reporting channels, and annual review process form the foundation of our prevention strategy. We will continue to strengthen our practices, learn from experience, and apply rigorous oversight to protect people from exploitation. This Modern Slavery Statement represents our continuing commitment to ethical conduct and human rights.