Modern Slavery Statement
Modern Slavery Statement sets out our approach to preventing forced labour, human trafficking, servitude, and all forms of exploitation within our operations and supply chains. We recognise that modern slavery can occur in many sectors and geographies, and we are committed to maintaining a business culture based on dignity, fairness, and respect. This statement applies to all employees, contractors, suppliers, and business partners, and reflects our zero-tolerance policy toward any practice that undermines human rights.
Our commitment begins with governance. Senior leadership is responsible for overseeing the modern slavery framework, ensuring that risks are identified and addressed promptly. We embed responsible sourcing into procurement decisions and require that ethical conduct is considered alongside quality, service, and value. Where risks are identified, they are escalated, investigated, and managed through corrective action plans. We expect every part of the organisation to support this approach and to act with integrity at all times.
Supplier due diligence is central to our modern slavery compliance programme. Before engaging suppliers, we assess ownership structures, labour practices, recruitment methods, and geographic risk factors. Where needed, we request documentation to verify lawful employment, age verification, and appropriate working conditions. Suppliers must agree to comply with our standards and cooperate with audits.
We also reserve the right to suspend or terminate relationships where serious breaches are identified or where remediation is not possible.
Our supplier audits are designed to test both policy and practice. These may include announced or unannounced reviews, desktop assessments, site inspections, interviews with management, and, where appropriate, discussions with workers. Audit findings are documented, tracked, and followed up until corrective actions are completed. Particular attention is given to labour agents, overtime practices, wage payments, freedom of movement, and any indication of debt bondage or coercion. We treat repeated non-compliance as a serious breach of contract.
Training supports our modern slavery prevention efforts. Employees involved in procurement, recruitment, and supplier management receive guidance on recognising warning signs, such as restricted movement, withheld identity documents, inconsistent wage records, or signs of intimidation.
We expect staff to apply this knowledge in day-to-day decisions and to challenge concerns immediately. Internal controls are reviewed regularly to ensure that our slavery and trafficking prevention measures remain effective and proportionate to emerging risks.
Reporting channels are available to help individuals raise concerns safely and in good faith. Anyone who suspects modern slavery-related abuse, unethical recruitment, or exploitative working conditions is encouraged to report it through established internal mechanisms. Reports are handled confidentially, assessed promptly, and investigated without retaliation. We make clear that no person will suffer disadvantage for speaking up about a genuine concern. Where allegations are substantiated, we take decisive action, which may include remediation, disciplinary measures, or disengagement from suppliers.
Monitoring and improvement are essential to maintaining an effective modern slavery framework. We review risk indicators across our operations and supply chains, looking at sourcing regions, product categories, seasonal labour demand, and subcontracting exposure. Findings from audits, grievances, and due diligence are used to refine controls and strengthen prevention measures. This ongoing process helps us respond to changing risk profiles and reinforces our expectation that ethical labour standards must be upheld consistently.
We also recognise the importance of remediation where harm has occurred. If a case is identified, our priority is to protect the affected individual, work with relevant experts where appropriate, and ensure the situation is addressed in line with human rights principles. This may involve supporting safe working arrangements, revising supplier practices, or strengthening oversight of recruitment processes. Our approach seeks not only to identify abuse, but also to reduce the likelihood of recurrence.
All third parties are expected to align with our values and cooperate in maintaining transparent, lawful, and humane working conditions. Suppliers must cascade comparable requirements to their own subcontractors and maintain records that support traceability.
We believe that collaborative action, backed by clear standards, is necessary to prevent exploitation and protect vulnerable workers across the chain.
Annual Review
We will review this Modern Slavery Statement annually to ensure it remains accurate, effective, and aligned with evolving legal expectations and risk conditions. The review will consider audit results, supplier performance, training completion, incident trends, and any incidents reported through our channels. Where improvements are needed, we will update policies, strengthen controls, and communicate changes across the organisation. This annual process demonstrates our continuing commitment to responsible business conduct and the elimination of modern slavery in all its forms.
