Modern Slavery Statement

This Modern Slavery Statement sets out the principles, controls, and responsibilities that guide our approach to preventing slavery, servitude, forced labour, human trafficking, and other forms of exploitation within our operations and supply chains. We are committed to conducting business with zero tolerance for any form of modern slavery. This commitment applies to every level of our organisation, including employees, contractors, agents, and business partners. We recognise that modern slavery can take many forms, and we remain alert to risks wherever people may be vulnerable to coercion, deception, or abuse.

Our approach is founded on respect for human rights, lawful employment practices, and responsible sourcing. We expect all those who work with us to uphold the same standards. To reinforce this position, our policies are reviewed regularly and communicated internally so that ethical conduct remains embedded in decision-making. Prevention is not a one-time action; it requires ongoing vigilance, training, and accountability.

We assess modern slavery risks across our business activities and supply chain by considering geography, sector, labour model, and the nature of services or goods provided. Where risk indicators are identified, we apply enhanced due diligence and, where necessary, corrective action plans. Supplier onboarding includes expectations relating to labour rights, recruitment practices, wages, working hours, and freedom of movement. We also require suppliers to confirm that they do not engage in or tolerate exploitative practices.

Supplier Oversight and Audits

Our supplier management framework includes supplier audits designed to monitor compliance with our standards. These audits may be scheduled or unannounced, and may include document reviews, interviews, site inspections, and checks on subcontracting arrangements. When concerns are raised, we investigate promptly and proportionately. If non-compliance is found, we expect immediate remediation, and we reserve the right to suspend or end the relationship if corrective steps are not taken.

The organisation promotes a culture of transparency by maintaining clear internal escalation pathways. We encourage employees and suppliers to report concerns about labour exploitation, unsafe recruitment, passport retention, debt bondage, or any behaviour that may indicate abuse. Reports can be made in good faith without fear of retaliation. Every concern is treated seriously, reviewed confidentially, and assessed by appropriate leadership.

To support awareness, relevant staff receive training on recognising warning signs of modern slavery and understanding their responsibilities in preventing it. This includes guidance on how to identify unusual worker conditions, inconsistent records, restricted communication, or signs that individuals may not be acting of their own free will. Training is refreshed periodically so that expectations remain clear and current.

Reporting Channels and Governance

The organisation provides multiple internal reporting channels so that concerns can be raised safely and promptly. These include line management escalation, human resources, procurement oversight, and compliance review processes. Allegations are assessed without delay and may trigger investigation, supplier remediation, or involvement of senior leadership where appropriate. We do not tolerate victimisation of anyone who raises a concern in good faith.

Governance responsibility for modern slavery oversight sits with designated senior leaders who monitor risks, approve improvements, and review outcomes from audits and investigations. This oversight ensures that anti-slavery controls remain practical, proportionate, and effective. We also track trends across incidents and supplier assessments to identify recurring issues and strengthen prevention measures across the business.

Our zero-tolerance policy is not limited to direct employment relationships. It extends to recruitment agencies, labour providers, and all tiers of the supply chain. We require suppliers to apply similar standards to their own subcontractors and to disclose material risks where relevant. By extending accountability beyond our immediate operations, we aim to reduce the possibility that exploitation can occur unnoticed.

Annual Review and Continuous Improvement

This statement and the supporting controls are reviewed annually to ensure they remain aligned with current legislation, risk exposure, and operational changes. The annual review considers audit findings, reported concerns, supplier performance, training completion, and any changes in sourcing practices. Where improvements are identified, action plans are developed and monitored to completion.

Continuous improvement is central to our commitment. We recognise that modern slavery risks can evolve, particularly where supply chains are complex or involve temporary, seasonal, or migrant labour. Accordingly, we seek to strengthen due diligence, improve audit coverage, and refresh policy content over time. Our aim is to ensure that our response remains proactive rather than reactive.

This Modern Slavery Statement reflects our ongoing responsibility to uphold dignity, fairness, and lawful working conditions. Through zero tolerance, supplier audits, robust reporting channels, and annual review, we are committed to maintaining ethical standards and reducing the risk of exploitation in every area of our business.