Modern Slavery Statement

This Modern Slavery Statement sets out our approach to identifying, preventing, and addressing the risks of modern slavery and human trafficking within our operations and supply chains. We are committed to conducting business with integrity, fairness, and respect for human rights. Our zero-tolerance policy applies to all forms of forced labour, child labour, servitude, debt bondage, and any practice that undermines personal freedom or dignity. We expect every colleague, supplier, contractor, and business partner to uphold these principles.

Our anti-slavery commitment is embedded in our governance framework and reinforced through internal controls, procurement processes, and due diligence reviews. We recognise that modern slavery can take many forms and may appear deep within supply networks. For that reason, we take a risk-based approach, prioritising categories, geographies, and activities where the likelihood of exploitation may be higher. This includes careful assessment of labour practices, recruitment methods, and subcontracting arrangements.

We also maintain a clear modern slavery policy that defines expected standards, prohibited conduct, and escalation routes. Any breach of this policy may result in remedial action, contract review, or termination of the relationship. Our objective is not only to respond to concerns, but to prevent harm before it occurs by strengthening oversight, training, and accountability.

Supplier Due Diligence and Monitoring

We apply structured due diligence to suppliers before engagement and throughout the life of the relationship. This includes evaluating ownership, labour standards, recruitment practices, and the transparency of sourcing chains. Where risk indicators are identified, additional checks are carried out and corrective measures are required. In higher-risk categories, we may request supporting documents, conduct site visits, or require evidence of worker protections.

Supplier audits are a key part of our assurance model. These audits may be announced or unannounced depending on the level of risk and the nature of the relationship. They are designed to verify compliance with our ethical standards, including working hours, wage practices, age verification, and freedom of movement. If issues are found, suppliers are expected to implement corrective action plans within agreed timelines.

Our supply chain expectations are communicated through contractual terms and procurement standards. We seek suppliers who can demonstrate responsible hiring, ethical sourcing, and the ability to monitor their own subcontractors. We also encourage transparency in labour recruitment and prohibit the charging of recruitment fees to workers. If a supplier fails to meet our requirements, we reserve the right to pause purchases, escalate the matter, or disengage where necessary.

Reporting, Training, and Review

We encourage all workers and stakeholders to report concerns as early as possible. Reporting channels are designed to allow concerns to be raised safely, confidentially, and without fear of retaliation. Concerns may relate to suspected coercion, unsafe recruitment practices, document retention, or any other indicator of exploitation. Reports are reviewed promptly and handled with discretion, and appropriate remediation is pursued where concerns are substantiated.

To support our approach, we provide relevant training to teams involved in procurement, supplier management, and governance. The training helps colleagues recognise signs of modern slavery, understand escalation steps, and apply our modern slavery statement commitments in day-to-day decisions. We also promote awareness of the broader social and ethical responsibilities that come with operating in complex supply chains.

We carry out an annual review of our controls, incidents, supplier performance, and emerging risks to ensure continuous improvement. This review informs updates to policy, audit priorities, and training content. We also assess whether additional controls are needed in response to regulatory developments or changing supply chain conditions. Our aim is to ensure that the slavery statement remains practical, current, and effective in reducing risk.

We remain committed to strengthening our safeguards and taking decisive action where risks are identified. Through zero-tolerance expectations, supplier audits, accessible reporting channels, and regular annual review, we aim to uphold human rights and ensure that modern slavery has no place in our business or supply chain.