Modern Slavery Statement

This Modern Slavery Statement sets out the principles and controls used to prevent modern slavery, human trafficking, forced labor, child labor, and other forms of exploitation within our operations and supply chain. We are committed to upholding human rights, acting ethically, and maintaining a zero-tolerance policy toward any practice that undermines personal freedom, dignity, or lawful employment.

Our approach applies to all business activities, including direct operations, procurement, logistics, and outsourced services. We expect all employees, contractors, and business partners to comply with applicable labor laws and to support responsible sourcing. The modern slavery statement is reviewed as part of our broader governance framework, ensuring that anti-slavery responsibilities remain embedded in decision-making, risk management, and commercial relationships.

We identify higher-risk areas through due diligence, supplier screening, and periodic risk assessments. These activities help us understand where vulnerabilities may exist, particularly in sectors or regions where exploitation is more likely. When concerns are identified, we take prompt action, which may include enhanced monitoring, corrective action plans, suspension of new orders, or termination of the relationship if necessary.

Supplier management is central to our modern slavery policy. We require suppliers to confirm compliance with relevant legal and ethical standards and to provide accurate information about labor practices, recruitment methods, and subcontracting arrangements. Contracts may include specific commitments relating to wages, working hours, freedom of movement, and the prohibition of any coercive or abusive conditions.

To verify these commitments, we conduct supplier audits on a risk-based schedule. Audits may be announced or unannounced and can include document reviews, site inspections, worker interviews, and checks on payroll and recruitment records. Where audit findings reveal non-compliance, we expect timely remediation and may support suppliers in implementing improvements. Repeated or severe breaches are treated seriously and can result in disengagement.

We also recognize that prevention depends on awareness and accountability across the organization. Relevant staff receive training on recognizing warning signs such as restricted movement, withholding of identity documents, unsafe accommodation, debt bondage, or intimidation. This helps ensure that our anti-slavery statement is supported by practical action rather than policy alone.

Reporting concerns is encouraged and protected. Anyone who suspects modern slavery, exploitation, or unethical recruitment practices may raise the issue through our internal reporting channels. Reports are handled confidentially, investigated promptly, and escalated where appropriate. We do not tolerate retaliation against any person who raises a concern in good faith, and we seek to protect the safety and welfare of individuals who may be affected.

Our grievance and whistleblowing arrangements are designed to allow concerns to be raised without fear of disadvantage. Where a report indicates possible harm to workers, we prioritize immediate safeguarding actions. This may involve pausing work, informing appropriate management, and coordinating with relevant stakeholders to reduce risk. The effectiveness of these mechanisms is monitored to ensure they remain accessible and trustworthy.

We work with suppliers and partners to promote a culture of transparency and respect. This includes encouraging them to maintain their own reporting channels and to communicate their labor standards clearly to workers. Our modern slavery commitments extend beyond compliance checks and aim to support responsible business conduct throughout the value chain.

Governance oversight is provided by senior management, who review performance against key risk areas and ensure that responsibilities are assigned appropriately. Modern slavery risks are considered alongside other ethical and operational risks, including procurement decisions, contract renewals, and new supplier onboarding. Where needed, corrective actions are tracked to completion and re-assessed for effectiveness.

We recognize that modern slavery risks can change over time due to market conditions, geographic exposure, labor shortages, or changes in sourcing models. For that reason, our modern slavery statement is not a static document. It is integrated into our compliance and risk management processes, helping us respond to emerging concerns and improve standards across our operations and supply chain.

This Modern Slavery Statement will be reviewed annually to confirm its continuing suitability, assess progress, and identify opportunities for improvement. The annual review considers audit results, reported incidents, supplier performance, training completion, and any changes in legal or operational risk. Updates may lead to revised controls, stronger due diligence, or additional supplier requirements.

Our aim is to ensure that the prevention of exploitation remains a living commitment, reflected in everyday practice and reinforced through oversight, engagement, and continuous improvement. By maintaining a firm zero-tolerance stance, strengthening supplier audits, supporting safe reporting channels, and conducting an annual review, we seek to uphold the highest standards of integrity and human rights.