Modern Slavery Statement

Our modern slavery statement sets out the principles, responsibilities, and controls that guide our approach to preventing exploitation in every part of our operations and supply chain. We are committed to maintaining a zero-tolerance policy toward forced labour, human trafficking, servitude, child labour, debt bondage, and any other form of unlawful exploitation. This commitment applies to all employees, contractors, suppliers, and business partners associated with our organisation.

Modern slavery is a serious violation of human rights and a threat to ethical business practice. We recognise that risks may arise in direct operations, outsourced services, and complex supply networks. For that reason, our slavery and human trafficking statement is designed to identify, reduce, and respond to risk through governance, due diligence, and continuous improvement. We expect all parties acting on our behalf to uphold the same ethical standards and comply with relevant laws and regulations.

Our board and senior management oversee this statement and take accountability for its implementation. Responsibilities are shared across procurement, operations, human resources, and compliance teams. We use a risk-based approach to assess higher-risk categories, geographies, and business relationships. This includes reviewing labour practices, recruitment methods, working conditions, and the use of subcontractors. Where concerns arise, we act promptly to investigate and, where necessary, suspend or end the relationship.

Supplier Due Diligence and Audits

Supplier due diligence is central to our modern slavery framework. Before engaging a new supplier, we evaluate its ownership, labour policies, and controls relating to recruitment and worker welfare. We require suppliers to confirm that they do not engage in exploitative practices and that they maintain accurate records, legal employment terms, and fair wage arrangements. Our contracts include obligations to comply with anti-slavery requirements and to cooperate with review processes.

We conduct supplier audits based on risk, size, sector, and location. These audits may include document reviews, worker interviews, site inspections, and checks on subcontracting arrangements. When gaps are identified, suppliers are expected to produce corrective action plans within agreed timelines. Persistent non-compliance can lead to remediation requirements, reduced business, or termination. In this way, our modern slavery policy is not only a statement of intent but also a practical control measure.

Training is provided to employees involved in procurement, onboarding, and supplier management so they can recognise warning signs such as excessive recruitment fees, withheld identity documents, restricted movement, or unsafe accommodation. We also encourage suppliers to train their own teams and to cascade expectations through their supply chains. By promoting awareness, we strengthen our ability to detect and prevent hidden forms of abuse.

Reporting Channels and Investigation

We provide clear and accessible reporting channels for employees, suppliers, and other stakeholders to raise concerns in good faith. Reports may relate to suspected slavery, trafficking, coercion, unlawful deductions, passport retention, or other forms of mistreatment. All concerns are treated seriously, reviewed confidentially, and investigated in line with our internal procedures. No one should fear retaliation for speaking up about suspected wrongdoing.

When a report is received, we assess the allegation, preserve evidence where appropriate, and determine the level of risk to affected individuals. If immediate harm is suspected, we take urgent protective action and engage specialist support where needed. Our approach seeks to prioritise the safety and dignity of workers while maintaining fairness and due process. This commitment reinforces the integrity of our modern slavery and human trafficking statement.

Where investigations substantiate concerns, we implement remediation measures that may include supplier corrective actions, changes to recruitment practices, repayment of unlawful fees, or disengagement from the supplier relationship. We also review whether our own controls contributed to the issue and strengthen them accordingly. Every case is used as a learning opportunity to improve our prevention measures and governance oversight.

Annual Review and Continuous Improvement

This statement is reviewed annually to ensure it remains effective, relevant, and aligned with legal obligations and emerging risk trends. The review considers audit findings, reported incidents, training completion, supplier performance, and any changes in our operating model or sourcing strategy. The outcome informs updates to policies, controls, and training priorities for the next cycle.

We are committed to continuous improvement in our anti-slavery efforts. As part of each annual review, we examine whether our due diligence processes are sufficiently robust, whether supplier audits are targeting the right risks, and whether reporting channels remain accessible and trusted. We also consider developments in legislation, enforcement activity, and sector best practice to enhance our response.

Our commitment is clear: modern slavery has no place in our business or in the relationships that support it. Through a zero-tolerance policy, careful supplier audits, reliable reporting channels, and an annual review process, we aim to protect workers, uphold human dignity, and maintain responsible business practices across our operations and supply chain.