Modern Slavery Statement

Our Modern Slavery Statement sets out the principles and controls that guide our approach to preventing slavery, servitude, forced labour, and human trafficking in every part of our operations. We recognise that modern slavery can exist in complex supply chains and may appear in hidden forms, including debt bondage, restricted movement, withholding of wages, and coercion. For that reason, our zero-tolerance policy applies across all business activities, functions, and relationships. We expect everyone who works with or for us to act with integrity, respect human rights, and uphold the highest ethical standards. This statement reflects our commitment to identifying risk early, acting decisively, and maintaining responsible practices throughout our organisation.

Our Zero-Tolerance Commitment

We maintain a firm zero-tolerance position toward any form of modern slavery. This means we will not knowingly engage with suppliers, partners, or contractors who fail to meet our ethical expectations. Our internal controls are designed to support compliance, including due diligence checks, policy acknowledgements, and employee training on recognising warning signs. We also require managers and procurement teams to assess labour practices when onboarding new suppliers or renewing existing arrangements. Any suspected breach is treated seriously and may lead to contract termination, remediation actions, or escalation to appropriate authorities where required.

Supplier Due Diligence and Audits

A core part of our modern slavery compliance framework is the assessment of supplier risk. We use a risk-based approach that considers geography, sector, labour model, and subcontracting exposure. Higher-risk suppliers are subject to enhanced scrutiny, including document reviews, worker welfare checks, and supplier audits. These audits may be announced or unannounced and are intended to verify employment practices, working hours, wage records, age verification, freedom of movement, and grievance handling. Where issues are identified, we work with suppliers to implement corrective action plans within clear timeframes. If a supplier is unwilling or unable to improve, we may suspend or end the relationship. Our modern slavery policy is embedded in supplier onboarding and contract terms so that expectations are clear from the outset.

Reporting Channels and Speaking Up

We encourage employees, contractors, and third parties to report any concern without delay. Reports can be made through internal management routes, compliance channels, or whistleblowing procedures designed to protect confidentiality and prevent retaliation. Concerns may relate to recruitment fees, passport retention, excessive overtime, unsafe accommodation, or any other indicator of exploitation. All reports are reviewed promptly and handled with discretion. We aim to create a culture where people feel safe raising issues and confident that they will be taken seriously. Any individual who raises a concern in good faith will be protected from victimisation, and all allegations are investigated in line with our procedures.

Training, Oversight, and Annual Review

Our modern slavery statement is supported by training and oversight. Relevant colleagues receive guidance on spotting signs of exploitation, managing supplier risk, and escalating concerns. Leadership reviews modern slavery risks as part of broader governance and compliance activity, ensuring that accountability remains visible at senior level. We also monitor audit outcomes, investigation findings, and remediation progress to help improve our controls over time. This monitoring supports continuous improvement and helps us respond to changes in law, industry practice, and emerging risk areas.

Annual review is a key element of our approach. At least once every year, we review this statement, our policies, supplier risk controls, and any incidents or allegations raised during the period. The review helps us assess whether our modern slavery commitments remain effective and whether additional action is needed. We use the findings to strengthen procedures, refine training, and improve supply chain oversight. Where necessary, we update our processes to reflect lessons learned and ensure our approach remains proportionate, relevant, and robust. This annual cycle ensures that our commitment is not static, but actively maintained and improved.

We understand that tackling modern slavery requires constant vigilance, strong governance, and practical action. Through our zero-tolerance stance, supplier audits, speaking-up channels, and annual review process, we seek to reduce risk and uphold human dignity across our operations. We will continue to promote ethical conduct, strengthen due diligence, and act promptly where concerns arise. Our responsibility is to ensure that our business relationships support fair treatment, lawful employment, and respect for basic rights.

Modern slavery prevention is a shared responsibility, and we expect all colleagues and suppliers to support this commitment. By maintaining clear standards and consistent oversight, we aim to protect workers, strengthen trust, and ensure that exploitation has no place in our organisation or supply chain.