Modern Slavery Statement

Our organisation is committed to preventing modern slavery, human trafficking, forced labour, debt bondage, and child labour in every part of our operations. This Modern Slavery Statement sets out the actions we take to identify, prevent, and address risks within our business and supply chains. We recognise that slavery and exploitation can take many forms, and we maintain a zero-tolerance policy toward any practice that undermines human rights or dignity. All employees, contractors, and suppliers are expected to uphold these principles and to act with integrity at all times.

Our Commitment and Governance

Responsibility for modern slavery prevention is embedded across our governance structure. Senior leaders oversee risk management, compliance, and due diligence activities, while relevant teams receive training to recognise warning signs. We require all decision-makers to support ethical sourcing and responsible procurement. In line with our slavery and human trafficking statement, we review policies, controls, and supplier relationships to ensure they remain aligned with legal obligations and ethical expectations.

To strengthen accountability, we maintain documented procedures for onboarding, monitoring, and escalating concerns. Our approach reflects the belief that a strong anti-slavery framework depends on clear expectations, consistent oversight, and timely action. Where risks are identified, corrective measures are implemented without delay, and relationships may be suspended or terminated if improvements are not made.

We undertake risk-based assessments of our operations and suppliers, focusing on sectors, geographies, and services where exploitation risks may be higher. This includes evaluating recruitment practices, labour conditions, subcontracting arrangements, and payment structures. We expect suppliers to maintain lawful employment practices and to provide accurate information during due diligence reviews. Our modern slavery policy is communicated as part of supplier onboarding and contract management.

Supplier Audits and Due Diligence

Supplier audits are a key control in our prevention programme. Audits may be announced or unannounced, depending on the level of risk and the nature of the relationship. During these reviews, we assess working hours, wage records, identity documentation, accommodation standards where relevant, and worker freedom of movement. Where a supplier is unable to meet required standards, we seek immediate remediation plans and follow-up evidence of progress.

In addition to audits, we use contractual safeguards that require compliance with labour laws and permit verification by our internal teams or designated third parties. We also expect suppliers to cascade equivalent standards through their own supply chains. This helps ensure that our modern slavery statement is supported not only by policy, but by practical controls that reach deeper into the network of suppliers and labour providers.

Reporting Channels and Investigation

Employees and external parties are encouraged to report suspected breaches, concerns, or suspicious behaviour through our reporting channels. Reports may be made confidentially and without fear of retaliation. We take every concern seriously and investigate allegations promptly and proportionately. If there is any indication of exploitation, safeguarding concerns are escalated to the appropriate leaders for immediate review and action.

Our response process includes fact-finding, evidence preservation, risk assessment, and corrective action planning. When necessary, we cooperate with relevant authorities and support affected individuals through appropriate remedial steps. We also monitor recurring issues to identify root causes, strengthen controls, and reduce the likelihood of repeat incidents. This proactive approach supports our broader anti-slavery commitments.

Training is provided to relevant staff so they can recognise indicators such as intimidation, restricted movement, withheld wages, document retention, and signs of coercion. Awareness is vital because modern slavery often remains hidden behind legitimate-looking arrangements. By combining training, escalation routes, and monitoring, we aim to create a workplace culture where exploitation is identified early and addressed decisively.

Annual Review and Continuous Improvement

This statement and the underlying programme are reviewed annually to ensure continued effectiveness and compliance. The annual review considers changes in law, emerging risks, audit outcomes, incident trends, and supplier performance. Findings are used to update policies, refine training, and improve due diligence processes. We regard continuous improvement as essential to maintaining a credible modern slavery statement and to demonstrating meaningful progress over time.

Our ongoing objective is to ensure that ethical conduct is embedded in every stage of our operations and procurement decisions. By maintaining a strict zero-tolerance stance, strengthening supplier audits, supporting clear reporting channels, and conducting annual reviews, we reinforce our commitment to responsible business practices and the protection of human rights.