Modern Slavery Statement

Our organization is committed to upholding human dignity, ethical conduct, and responsible business practices across every part of our operations. This modern slavery statement sets out the steps we take to prevent slavery, servitude, forced labour, and human trafficking from occurring in our business and supply chains. We maintain a zero-tolerance policy toward any form of exploitation and expect the same standard from all employees, contractors, and business partners.

As part of our commitment, we assess risks regularly and apply controls designed to identify and address potential abuse. Our approach to modern slavery is rooted in accountability, vigilance, and continuous improvement. We recognize that modern slavery can appear in many forms, including debt bondage, child labour, deceptive recruitment, and coercive working conditions. Therefore, our anti-slavery framework is designed to protect vulnerable workers and promote fair treatment throughout the business relationship.

We also embed these expectations into governance and decision-making. Senior management is responsible for overseeing compliance, reviewing risk indicators, and ensuring that this anti-slavery statement is implemented effectively. Training, due diligence, and supplier engagement are used to help maintain a resilient ethical culture.

Our Policies and Controls

We maintain policies that prohibit all forms of modern slavery and require all personnel to act in accordance with applicable labour and human rights standards. These policies are supported by internal procedures covering recruitment, onboarding, procurement, and subcontracting. We do not allow the use of retention of identity documents, unlawful deductions, recruitment fees charged to workers, or any practice that restricts freedom of movement.

Due diligence is applied to new and existing business relationships, with a particular focus on higher-risk regions, sectors, and services. Where risks are identified, we require corrective action plans and, if necessary, suspend or end the relationship. Our process is designed to ensure that concerns are handled promptly and responsibly.

We expect our leadership teams to model ethical behaviour and to ensure that the principles of this modern slavery policy are reflected in daily operations. Regular internal reviews help us maintain alignment with our values and identify opportunities for improvement.

Supplier Audits and Risk Management

Our supplier management programme includes supplier audits and targeted reviews to verify compliance with our labour standards. Audits may be announced or unannounced depending on risk level, and they focus on working hours, wages, age verification, subcontracting practices, freedom of association, and document retention. We use audit findings to measure compliance and to support remediation where gaps are found.

Suppliers are required to confirm that they do not use forced or trafficked labour and that they have appropriate controls in place for their own supply chains. Where suppliers operate in higher-risk environments, we may request evidence of worker recruitment practices, site-level records, or independent assessments. This approach strengthens the integrity of our supply chain and helps prevent exploitation before it occurs.

Risk management is an ongoing process, not a one-time check. By combining supplier audits, contractual obligations, and escalation procedures, we strengthen oversight and reduce exposure to unethical practices. Our objective is to build long-term partnerships with suppliers who share our commitment to fairness and respect.

Reporting Concerns and Raising Issues

We encourage employees, workers, suppliers, and other stakeholders to raise concerns if they suspect a breach of this statement or any sign of exploitation. Reports may relate to unfair recruitment fees, restricted movement, unsafe living conditions, intimidation, or any behaviour that suggests a breach of labour rights. Concerns are reviewed seriously, promptly, and confidentially where possible.

Our reporting channels are designed to allow individuals to speak up without fear of retaliation. Allegations are investigated in line with our internal procedures, and appropriate action is taken based on the findings. Where needed, we work with relevant partners to protect affected individuals and to address root causes.

We are committed to a culture where speaking up is supported and respected. This helps ensure that our modern slavery commitment is not just a policy on paper, but a practical and enforceable standard across the organisation.

Annual Review and Continuous Improvement

We review this statement annually to ensure it remains effective, relevant, and aligned with changes in legislation, business activity, and emerging risks. The annual review considers audit outcomes, reported concerns, training completion, supplier performance, and any incidents requiring remediation. Findings are used to strengthen our controls and improve future prevention efforts.

The review process also supports learning across the business. We update procedures where necessary, reinforce expectations with suppliers, and enhance training to address new or evolving risks. This helps ensure that our approach to the modern slavery statement remains practical and forward-looking.

Through these measures, we aim to maintain a responsible supply chain and uphold the rights and dignity of every worker connected to our operations. Our zero-tolerance policy, supplier oversight, reporting channels, and annual review together form a comprehensive framework for preventing abuse and promoting ethical business conduct.