Modern Slavery Statement
This Modern Slavery Statement sets out our zero-tolerance approach to slavery, servitude, forced labour, and human trafficking in all parts of our operations and supply chains. We recognise that modern slavery is a serious human rights abuse and that every business has a responsibility to help prevent it. Our commitment is reflected in our policies, governance, and day-to-day decision-making.
We expect the highest standards of ethical conduct from employees, partners, and suppliers. This modern slavery policy applies across our organisation and supports a culture of accountability, respect, and vigilance. We seek to identify, prevent, and address any risks that may arise in our business activities or procurement practices. Zero tolerance means that any confirmed breach will be treated as a material issue and escalated without delay.
Our approach begins with risk awareness. We assess where vulnerability may exist, particularly in sectors, regions, or labour models associated with elevated risk. Through these assessments, we strengthen our anti-slavery controls and improve oversight of suppliers, subcontractors, and business partners. We also require relevant teams to understand the signs of exploitation and act promptly where concerns arise.
Supplier due diligence is central to our modern slavery compliance framework. Before onboarding and during ongoing relationships, suppliers are reviewed against ethical, legal, and operational criteria. Where appropriate, we request declarations, policy evidence, and details of labour practices. Higher-risk suppliers may be subject to enhanced checks to ensure that worker treatment, recruitment practices, and working conditions meet our standards.
We conduct supplier audits to verify compliance and to identify areas for improvement. These audits may include document reviews, site visits, worker interviews, and checks on subcontracting arrangements. If non-compliance is found, we require corrective action plans with clear timelines. In serious cases, we reserve the right to suspend or terminate the relationship. This disciplined process helps us maintain a responsible and resilient supply chain.
Training and awareness are also important. Employees involved in procurement, operations, and contract management receive guidance on recognising indicators of exploitation, such as withheld wages, restriction of movement, deceptive recruitment, or excessive working hours. By strengthening internal knowledge, we improve our ability to respond effectively and uphold our slavery-free business commitments.
We encourage anyone who suspects wrongdoing to speak up without fear. Reporting channels are available for employees and external stakeholders to raise concerns about possible modern slavery, unethical labour practices, or breaches of our standards. Reports are handled seriously, sensitively, and, where possible, confidentially. Retaliation against those who report concerns in good faith is not tolerated.
All concerns are reviewed by appropriate personnel and, where necessary, investigated thoroughly. If a report indicates potential harm to workers, we act quickly to reduce risk and support remediation. This may involve escalating the matter through management channels, rechecking supplier controls, or working with relevant parties to improve conditions. Our aim is not only to identify issues, but also to prevent recurrence through stronger safeguards.
We document findings and use them to strengthen our broader modern slavery prevention programme. Lessons learned from incidents, audits, and assessments inform updates to our procedures, supplier standards, and training content. This continuous improvement approach helps us stay alert to emerging risks and maintain high ethical expectations across the business.
This statement is reviewed annually to ensure it remains effective, relevant, and aligned with current legal and ethical expectations. The annual review considers changes in our operations, supply chain risk, supplier performance, reported concerns, and the outcome of audits or investigations. Where improvements are needed, we update our controls and responsibilities accordingly.
Senior leadership oversees the modern slavery statement and supports its implementation across the organisation. Accountability is shared across functions so that procurement, operations, and management all play a role in safeguarding labour standards. We believe that clear ownership and consistent review are essential to maintaining an effective anti-slavery framework.
In summary, our commitment to a modern slavery-free supply chain is built on prevention, transparency, and action. Through zero tolerance, supplier audits, accessible reporting channels, and annual review, we aim to protect vulnerable people and uphold human dignity in every aspect of our work. This statement reflects our ongoing responsibility to improve, monitor, and respond with integrity.
