Modern Slavery Statement

This Modern Slavery Statement sets out the approach to preventing, identifying, and addressing modern slavery and human trafficking across our operations and supply chains. We recognise that forced labour, debt bondage, child labour, and other forms of exploitation are severe human rights abuses. Our commitment is grounded in a zero-tolerance policy toward any practice that compromises human dignity, and we expect the same standard from employees, contractors, and business partners.

Our modern slavery statement applies to all parts of the organisation and supports responsible sourcing, fair employment, and ethical business conduct. We aim to ensure that decisions are made with care, transparency, and respect for the people connected to our business. This statement is reviewed alongside our wider governance framework so that risks can be monitored and controls strengthened where needed.

We also require that managers and procurement teams understand the indicators of exploitation and respond promptly if concerns arise. Where necessary, we use risk-based assessments to focus on higher-risk materials, geographies, and supplier relationships. By maintaining clear standards and reinforcing accountability, our slavery and human trafficking statement helps build a culture in which abuse is not ignored or tolerated.

Our Policies and Governance

The organisation maintains policies that prohibit forced labour, child labour, involuntary work, withholding of wages, retention of identity documents, and any form of coercion. These requirements are embedded in recruitment, procurement, and workforce management processes. Zero tolerance means that any confirmed breach may result in termination of the relationship, disciplinary action, or referral to authorities where appropriate.

To support our modern slavery policy, we provide internal guidance for staff involved in hiring, supplier selection, and contract management. Contracts may include obligations on labour standards, ethical sourcing, and cooperation with investigations. We seek to ensure that our modern slavery and human trafficking controls are practical, measurable, and proportionate to the risks identified.

Training is delivered to relevant teams so that potential warning signs, such as unusual recruitment fees, restricted movement, or poor working conditions, can be recognised early. This training reinforces that our approach is not symbolic; it is an operational responsibility. As part of the broader modern slavery framework, leaders are expected to escalate concerns without delay and to support corrective action.

Supplier Due Diligence and Audits

We expect our suppliers to operate with integrity and to uphold labour standards consistent with our own. New suppliers may be subject to screening before engagement, including checks on ownership, location, sector risk, and labour practices. Existing relationships are periodically reassessed, especially where the modern slavery statement obligations indicate elevated exposure to exploitation.

Supplier assurance includes questionnaires, document reviews, and, where appropriate, on-site or remote supplier audits. These audits may examine wages, working hours, age verification, subcontracting, recruitment practices, and freedom of movement. Where gaps are identified, suppliers may be asked to complete corrective action plans within defined timeframes.

We recognise that audit findings alone do not eliminate risk. For that reason, the modern slavery approach also includes collaborative improvement, targeted follow-up, and the option to suspend or end relationships if remediation is not achieved. Our aim is to promote lasting change while ensuring that human rights are protected throughout the supply chain.

Reporting Channels and Response

Employees and suppliers are encouraged to report concerns promptly through established reporting channels, including management escalation routes and internal whistleblowing processes. Reports may relate to suspicious labour practices, unsafe conditions, deceptive recruitment, or any sign of exploitation. All concerns are treated seriously, and confidentiality is maintained as far as possible.

Investigations are handled sensitively and in line with applicable procedures. If a report suggests a risk of modern slavery, we will assess the issue, take immediate protective action where needed, and determine whether external support or referral is required. We do not permit retaliation against anyone who raises a concern in good faith, and this protection is a core part of our anti-slavery commitment.

Where an issue is confirmed, we will seek to remedy harm, address root causes, and strengthen controls to prevent recurrence. The response may include supplier remediation, staff retraining, process changes, or contract review. Our modern slavery statement is therefore not only a declaration of intent, but a framework for action and accountability.

Annual Review and Continuous Improvement

We review this statement annually to ensure it remains current, effective, and aligned with changing legal expectations and operational risks. The review considers incident trends, audit results, supplier performance, training completion, and any lessons learned from investigations. This process helps us refine our slavery and human trafficking controls year by year.

The annual review also assesses whether the zero-tolerance policy is being applied consistently and whether reporting channels are working as intended. If improvements are needed, action plans are established and tracked through management oversight. In this way, the modern slavery and human trafficking statement remains a living document rather than a static declaration.

Through ongoing review, due diligence, and strong governance, we seek to reduce the risk of exploitation in our operations and supply chains. Our commitment is to conduct business ethically, to support fair treatment for all workers, and to uphold the principles set out in this Modern Slavery Statement with diligence and resolve.