Modern Slavery Statement

We are committed to conducting our operations with integrity, transparency, and respect for human rights. This modern slavery statement sets out the principles and controls that guide our approach to preventing slavery, servitude, forced labour, and human trafficking in any part of our business or supply chain. Our zero-tolerance policy applies to all employees, contractors, suppliers, and business partners. We will not knowingly engage with any party involved in exploitation, coercion, debt bondage, child labour, or any practice that undermines the dignity and freedom of workers. We expect everyone connected with our organisation to act ethically and to uphold fair, lawful, and responsible working conditions.

Our governance framework is designed to identify and reduce risk across the full lifecycle of procurement and operations. The board and senior leadership review slavery and human trafficking risks as part of broader compliance and sustainability oversight. Relevant teams receive training to recognise warning signs, including unusual recruitment fees, withheld identity documents, restricted movement, or inconsistent wage practices. This anti-slavery commitment is embedded in our policies, supplier expectations, and internal controls, ensuring that modern slavery risks are addressed proactively rather than reactively.

We assess risk using a combination of country, sector, product, and relationship-based indicators. High-risk categories are subject to enhanced due diligence, including documentary checks and targeted supplier audits. If concerns arise, we investigate promptly and, where necessary, require corrective action plans or terminate the relationship. Our approach to modern slavery prevention is continuous and risk-led, recognising that supply chains can change over time and require ongoing monitoring.

Supplier audits are a central part of our modern slavery statement framework. Audits may be announced or unannounced depending on risk, and may include site visits, worker interviews, payroll checks, and review of recruitment and subcontracting practices. We also evaluate whether suppliers maintain adequate records, provide contracts in understandable language, and prohibit recruitment fees charged to workers. Where non-compliance is identified, we work with suppliers to correct issues quickly, while reserving the right to suspend or end engagement if remediation is not credible. Our due diligence also extends to subcontractors where there is a material exposure to labour exploitation.

To support responsible business conduct, we require suppliers to confirm that they share our expectations on ethical labour practices and that they will cascade equivalent standards through their own supply chains. Contracts may include clauses relating to modern slavery, audit rights, worker welfare, and reporting obligations. We recognise that prevention is more effective when suppliers understand the standards expected of them and are encouraged to improve systems, not simply comply on paper. This helps strengthen the resilience and accountability of the wider supply chain.

The organisation also provides internal and external reporting channels so that any suspected issue can be raised without delay. Concerns may be reported through formal grievance procedures, management escalation routes, or anonymous whistleblowing mechanisms where permitted. We do not tolerate retaliation against anyone who raises a concern in good faith. Every report is assessed promptly, documented carefully, and referred to the appropriate decision-makers for investigation. If an allegation is substantiated, we take proportionate action, which may include worker protection measures, supplier remediation, disciplinary steps, or referral to relevant authorities when required by law.

Awareness and training are essential to making this statement effective. Employees involved in procurement, onboarding, logistics, and supplier management receive guidance on identifying modern slavery indicators and responding appropriately. Training materials are refreshed to reflect emerging risks and legal developments. In addition, our internal review processes encourage teams to consider labour exploitation risk at the earliest possible stage, especially when entering new markets or sourcing from high-risk sectors. By strengthening understanding across the organisation, we improve our ability to detect and prevent abuse.

We are also attentive to recruitment practices, particularly where workers are supplied through agencies or third parties. We expect all recruiters to follow ethical recruitment principles, including clear contracts, no worker-paid recruitment fees, and freedom for workers to leave employment in line with lawful notice requirements. Any evidence of coercion, deception, or document retention is treated as a serious breach of our standards. Our modern slavery controls therefore extend beyond direct employment to include all forms of labour sourcing associated with our operations.

This statement is reviewed annually to ensure it remains effective, relevant, and aligned with our risk profile. The annual review considers audit findings, reported incidents, supplier performance, training completion, and any changes in law or guidance. Where weaknesses are identified, we update policies, strengthen oversight, and revise our procedures accordingly. We reaffirm our zero-tolerance approach to modern slavery each year and remain committed to continuous improvement in prevention, detection, and remediation across our business and supply chains.