Modern Slavery Statement

This Modern Slavery Statement sets out the principles and controls that guide our approach to preventing slavery, servitude, forced labour, and human trafficking in any part of our operations or supply chain. We recognise that modern slavery can take many forms, including coercion, exploitation, deceptive recruitment, debt bondage, and other abusive labour practices. Our commitment is rooted in respect for human dignity, lawful employment, and ethical business conduct. We maintain a zero-tolerance policy toward all forms of modern slavery and expect the same standard from everyone acting on our behalf.

Our governance framework is designed to identify, prevent, and address risks across all activities. Senior management oversees the effectiveness of our modern slavery policy, ensuring it is embedded in decision-making, procurement, onboarding, and due diligence processes. We require relevant employees to understand the warning signs of exploitation and to act promptly if concerns arise. This Statement applies to our business units, subsidiaries, contractors, and suppliers where appropriate.

We are committed to continuous improvement, and our modern slavery commitment is supported by training, risk assessments, and internal accountability. Key controls are reviewed regularly to ensure they remain proportionate to the nature of our operations and the jurisdictions in which we work. We also aim to foster an organisational culture that values transparency, ethical sourcing, and lawful treatment of all workers.

Supplier integrity is a central part of our approach. We carry out due diligence on new and existing suppliers, with attention to labour standards, recruitment practices, subcontracting arrangements, and geographic risk. Where risk is elevated, we may request supporting documentation, contractual assurances, worker welfare evidence, or corrective action plans. Our procurement teams are trained to identify indicators that may suggest unethical labour practices.

Supplier Audits and Monitoring

We conduct supplier audits where appropriate, using a risk-based methodology to assess compliance with our standards. These audits may include site visits, document reviews, worker interviews, and checks on pay, hours, accommodation, and identity document retention. Findings are recorded and tracked to closure. If a supplier is unable or unwilling to address serious concerns, we reserve the right to suspend or terminate the relationship.

Our modern slavery statement is supported by contractual clauses requiring suppliers to comply with applicable labour laws and to cascade equivalent expectations through their own supply chains. We also encourage suppliers to maintain their own grievance processes and training programmes so that risks can be addressed as early as possible.

Reporting channels are essential to the effectiveness of our programme. Employees, workers, and business partners are encouraged to raise concerns about suspected modern slavery, unsafe recruitment, intimidation, withheld wages, or any other unethical labour practice. Reports may be made through internal management routes, compliance teams, or confidential escalation mechanisms established for this purpose. We ensure that concerns are treated seriously, assessed promptly, and managed discreetly.

We strictly prohibit retaliation against anyone who raises a concern in good faith or participates in an investigation. This protection is fundamental to our modern slavery prevention approach, as it supports openness and helps surface hidden risks. Any substantiated breach may result in disciplinary action, contract review, remediation requirements, or referral to appropriate authorities where necessary.

Zero tolerance means we do not accept deliberate ignorance, passive oversight, or business pressure that places workers at risk. We expect managers to model responsible behaviour, challenge poor practices, and escalate issues without delay. Where exploitation is identified, our priority is the safety and welfare of affected individuals, followed by remedial action and systemic prevention.

Our annual review process ensures the statement remains current and effective. Each year, we evaluate the risks identified, the outcomes of supplier audits, training completion, incident reports, and any remedial actions taken. The review also considers changes in legislation, industry practice, sourcing models, and geopolitical risk. This helps us refine controls and strengthen our response to emerging threats.

Annual Review and Continuous Improvement

The review is used to update policies, improve due diligence, and identify further opportunities for awareness-raising and supplier engagement. We may revise contractual terms, enhance monitoring, or expand training for teams in higher-risk functions. These steps support a stronger and more resilient modern slavery framework across the organisation.

We are committed to acting ethically, protecting vulnerable people, and maintaining transparency in the way we operate. Our modern slavery measures are not static; they evolve through ongoing assessment, practical oversight, and responsible leadership. By upholding our principles, we aim to contribute to supply chains and workplaces that respect human rights, lawful employment, and fair treatment for all.