Modern Slavery Statement

We are committed to conducting business with integrity, dignity, and respect for human rights. This Modern Slavery Statement sets out the principles and controls we apply to prevent modern slavery, human trafficking, forced labour, and child labour within our operations and supply chain. Our modern slavery policy reflects a clear zero-tolerance approach to any practice that exploits or coerces people. We expect every colleague, partner, and supplier to uphold the same standards.

Our commitment is embedded in our governance, procurement, and risk management practices. We recognise that modern slavery risks can exist in any sector, geography, or tier of the supply chain, particularly where labour is outsourced or where work is seasonal, manual, or low paid. To address these risks, we carry out due diligence on suppliers and assess where enhanced scrutiny is needed. Where concerns arise, we act promptly to investigate, remediate, and, if necessary, terminate the relationship.

We also require all personnel to understand their role in preventing slavery and trafficking. Training and awareness activities support our expectations around ethical conduct, responsible sourcing, and escalation of concerns. By strengthening awareness, we reinforce our anti-slavery statement across the organisation and ensure that risks are recognised early.

Supplier engagement is a key part of our approach. We expect suppliers to maintain lawful employment practices, verify the right to work, and ensure workers are treated fairly and paid appropriately. Modern slavery checks are proportionate to risk and may include questionnaire-based reviews, document verification, and contract clauses requiring compliance with labour standards. High-risk suppliers may be subject to more detailed assessments.

We conduct supplier audits where appropriate, focusing on working conditions, recruitment practices, wage records, hours of work, and freedom of movement. These audits may be announced or unannounced depending on the risk profile. If audit findings identify non-compliance, we require corrective actions within defined timeframes and monitor completion closely. Repeat or serious breaches are escalated for senior review.

Our reporting channels are designed to allow concerns to be raised safely and in good faith. Employees and other stakeholders can report suspected exploitation, unethical recruitment, or any breach of our modern slavery commitments through internal escalation routes and protected reporting mechanisms. All reports are treated seriously, handled confidentially where possible, and assessed without retaliation against the person raising the concern.

Where a report indicates immediate risk, we prioritise urgent action to safeguard individuals. This may include pausing work, increasing supervision, engaging specialist support, or notifying relevant authorities where required. Our approach is guided by the principle that protecting people comes before business convenience. We believe that effective response is essential to any credible modern slavery statement.

We also work to improve transparency in supplier relationships by requiring sub-contracting disclosure and responsible labour sourcing. Procurement teams are trained to identify warning signs such as excessive recruitment fees, identity document retention, debt bondage, or workers unable to leave employment freely. These indicators are taken seriously and are reviewed as part of our ongoing modern slavery risk management.

Before closing each reporting cycle, we assess the effectiveness of our controls and track progress against action plans. This includes reviewing audit outcomes, reported incidents, training completion, and supplier performance. The results inform future priorities and help ensure that our anti-slavery measures remain practical, relevant, and robust.

We undertake an annual review of this statement and our wider programme to reflect changes in legislation, business structure, and emerging risk. The annual review is overseen by responsible leadership and considers whether our zero-tolerance policy, supplier audits, and reporting channels remain effective. Any required updates are incorporated into policy, training, procurement practices, and contract management.

Through this continuous improvement process, we seek to strengthen our prevention and detection measures year after year. Our aim is not only to comply with legal requirements, but to uphold the highest ethical standards in every part of our business. This Modern Slavery Statement represents our ongoing commitment to protecting vulnerable people and ensuring that modern slavery has no place in our operations or supply chain.