Modern Slavery Statement

Modern Slavery Statement reflects our commitment to conducting business with integrity, respect, and accountability. We recognise that modern slavery, including forced labour, servitude, human trafficking, and child exploitation, remains a serious global issue. This statement sets out the steps we take to identify, prevent, and address risks across our operations and supply chains. Our approach is grounded in a zero-tolerance policy, meaning that any form of modern slavery is wholly unacceptable in our business or in the businesses of those who work with us.

Our Commitment

We are committed to promoting ethical working conditions and protecting the dignity of every person connected to our organisation. As part of our modern slavery statement, we apply controls designed to reduce the risk of abuse, hidden labour exploitation, and unsafe recruitment practices. This includes clear internal standards, due diligence checks, and oversight of suppliers and subcontractors. We expect all business partners to share these expectations and to maintain lawful, fair, and transparent employment practices.

Our policies prohibit the use of forced, bonded, or involuntary labour in any form. We also prohibit the retention of identity documents, debt bondage, coercive recruitment fees, and any practice that restricts an individual’s freedom of movement. These requirements are communicated to relevant employees and are embedded into procurement and supplier onboarding processes. Ethical sourcing is not optional; it is a core condition of working with us.

Risk Management and Supplier Oversight

We recognise that certain sectors, geographies, and services may carry higher exposure to modern slavery risks. To address this, we conduct risk-based assessments across our supply chain, focusing on labour-intensive activities, outsourced services, and suppliers operating in regions where enforcement may be weaker. Where risks are identified, we require corrective action plans and may suspend or end relationships if adequate improvements are not made.

Supplier Audits

Our supplier management framework includes supplier audits and periodic reviews to help verify compliance with our standards. Audits may be announced or unannounced depending on the risk profile of the supplier and the nature of the work performed. During these assessments, we examine employment records, working hours, wage practices, worker accommodation where applicable, and recruitment methods. We also look for indicators of coercion, passport withholding, or restricted movement. Findings are documented, tracked, and escalated when necessary.

Supplier audits are supported by contractual terms that require cooperation, accurate recordkeeping, and prompt remediation of any non-compliance. We may also request additional documentation, training evidence, or third-party verification where a higher risk is identified. This approach helps us maintain meaningful oversight of the supply chain and reinforces the expectations set out in our modern slavery policy.

Reporting and Escalation

We encourage employees, workers, suppliers, and other stakeholders to raise concerns if they suspect modern slavery or related misconduct. Reporting channels are designed to be accessible, confidential, and free from retaliation. Concerns may be raised through internal management routes, compliance functions, or whistleblowing mechanisms. All reports are treated seriously and investigated promptly in line with our procedures.

We maintain a clear escalation process for allegations or signs of exploitation. Where a concern is substantiated, we take appropriate action, which may include immediate safeguarding measures, engagement with suppliers, remediation steps, training, disciplinary action, or reporting to relevant authorities. Our modern slavery statement is supported by a culture that encourages speaking up and protects those who report issues in good faith. We do not tolerate retaliation against anyone who raises a concern.

Training is provided to employees whose roles are most likely to influence procurement, supplier relationships, or workforce management. This ensures they can identify warning signs and respond effectively. We also expect suppliers to cascade similar expectations within their own operations, helping to strengthen awareness across the wider supply chain.

Monitoring, Review, and Continuous Improvement

Our modern slavery controls are monitored through ongoing compliance reviews, supplier performance checks, and internal governance processes. We review allegations, audit outcomes, and corrective actions to identify trends and improve our approach. When weaknesses are found, we update procedures, strengthen oversight, and revise supplier requirements where needed. This commitment supports continuous improvement and reinforces our zero-tolerance position.

This statement is reviewed annually to ensure it remains accurate, relevant, and aligned with legal requirements and operational changes. The annual review considers risk exposure, emerging threats, audit findings, and any changes in our supply base or working practices. Findings from the review inform future priorities, including updated training, improved due diligence, and enhanced supplier engagement.

Through this modern slavery statement, we affirm our responsibility to act decisively, fairly, and transparently. By maintaining a zero-tolerance policy, carrying out supplier audits, providing safe reporting channels, and completing an annual review, we aim to uphold human rights and help prevent exploitation wherever it may occur. We remain committed to strengthening our controls and working only with partners who respect the rights and welfare of all workers.