Modern Slavery Statement

Our modern slavery statement reflects a clear and uncompromising commitment to preventing slavery, servitude, forced labour, and human trafficking in every part of our operations. We recognise that modern slavery can take many forms and may occur in complex supply chains, making vigilance essential. Our modern slavery policy applies to all employees, contractors, partners, and suppliers, and it is supported by training, oversight, and a culture of accountability. We maintain a zero-tolerance approach to any practice that exploits individuals or undermines their basic rights.

Our Commitment and Principles

We are committed to respecting human dignity and ensuring that our business practices do not contribute to exploitation. This commitment is embedded in our procurement decisions, contract management, and internal controls. Our anti-slavery statement sets out the principles that guide how we select suppliers, evaluate risk, and respond to concerns. We expect all suppliers to uphold the same standards, including fair wages, lawful working hours, safe conditions, and freedom of movement. Where there is any indication of abuse, we act promptly to investigate and, where necessary, to disengage responsibly.

A key part of this commitment is awareness. We provide relevant training so employees can identify warning signs of labour exploitation, including withheld documents, coercion, debt bondage, or restricted access to communication. Through this approach, our modern slavery commitment is reinforced not only by policy but by everyday practice.

Supplier Due Diligence and Audits

We apply a risk-based due diligence process to suppliers and service providers, giving particular attention to sectors and regions where modern slavery risks may be higher. Before onboarding, suppliers are assessed against ethical, legal, and operational criteria. Our modern slavery controls include contract clauses requiring compliance with labour laws, cooperation with investigations, and immediate notification of any suspected breach.

Supplier audits are a central part of our assurance process. These audits may be announced or unannounced, depending on the level of risk and the nature of the relationship. During each review, we examine recruitment practices, wage records, identity document handling, grievance mechanisms, and evidence of worker freedom. If weaknesses are identified, we require corrective action plans with clear deadlines. Failure to improve can lead to suspension or termination of the relationship. This process helps ensure that our modern slavery framework remains effective and responsive.

Monitoring and Escalation

We monitor compliance through regular reviews, management reporting, and follow-up checks after audit findings. Where concerns arise, they are escalated to senior leadership and reviewed against the severity of the risk. Our approach is both preventative and corrective, aiming to protect affected individuals and reduce the likelihood of recurrence.

We encourage anyone who suspects wrongdoing to raise concerns without delay. Reporting channels are available through internal grievance routes, manager escalation, and protected whistleblowing mechanisms. These channels are designed to be accessible, confidential, and free from retaliation. Modern slavery reporting is treated seriously, and all concerns are recorded, assessed, and investigated proportionately. Individuals who speak up in good faith are supported, and retaliation against them is not tolerated. By maintaining clear reporting routes, we strengthen trust and improve our ability to detect and address hidden risks.

Governance and Annual Review

Responsibility for overseeing this statement rests with senior management, supported by procurement, legal, and compliance functions. We review risk indicators, audit outcomes, and reported incidents to identify trends and improve controls. Our governance approach ensures that the modern slavery statement is not a static document but a living framework that guides continuous improvement. Where needed, we update training, policies, and supplier requirements to reflect emerging risks and regulatory expectations.

This statement is reviewed annually to confirm its continued relevance and effectiveness. The annual review considers changes in operations, supply chain structure, legislation, and audit findings. Any lessons learned are incorporated into our next action plan, ensuring that our anti-slavery measures remain robust. We remain dedicated to identifying risks early, taking decisive action, and promoting ethical conduct across the business and its supply chain. Our goal is simple: to ensure that modern slavery has no place in our organisation or in the relationships that support it.