Modern Slavery Statement

This Modern Slavery Statement sets out our zero-tolerance policy toward any form of modern slavery, human trafficking, forced labor, child labor, servitude, or exploitation within our operations and supply chains. We are committed to conducting business with integrity, dignity, and respect for human rights. Our approach is grounded in clear governance, responsible sourcing, and active monitoring so that the risk of modern slavery remains a priority at every level of the organization.

We recognize that modern slavery can occur in many forms and across many sectors. For that reason, our modern slavery statement applies to all employees, contractors, and business partners. It requires everyone connected with our business to uphold ethical standards and to act promptly where concerns arise. We also expect our suppliers and service providers to demonstrate the same commitment through their own policies, procedures, and working practices.

Our anti-slavery framework is built on prevention, detection, and response. We carry out risk assessments to identify areas where vulnerability may be higher, including geographic regions, labor-intensive services, and complex subcontracting arrangements. These assessments help us target controls more effectively and strengthen oversight across the supply chain.

Supplier due diligence is a key element of this statement. Before engaging new suppliers, we evaluate their labor practices, ownership structure, and compliance history. Where appropriate, we request documented evidence of ethical recruitment, fair pay, working hours, and the right to work. This helps us maintain a responsible supply network and reduce the likelihood of hidden exploitation.

We also conduct supplier audits on a regular basis, using both announced and unannounced methods where suitable. These audits examine employment records, wage practices, accommodation standards, freedom of movement, and worker treatment. Any non-compliance identified through an audit is treated seriously and may lead to corrective action plans, contract suspension, or termination if required.

Our modern slavery policy is supported by training for relevant employees so they can identify warning signs and respond appropriately. Training covers indicators such as debt bondage, confiscation of identity documents, excessive overtime, recruitment fees, intimidation, and restricted freedom. Awareness is essential because early identification can prevent harm and improve remediation outcomes.

We encourage a culture of openness through clear reporting channels that allow concerns to be raised safely and in confidence. Anyone who suspects a breach of this statement is expected to report it immediately through internal compliance routes or designated escalation processes. Reports are reviewed carefully, and we prohibit retaliation against anyone who raises a concern in good faith.

When a concern is identified, we investigate promptly and take action proportionate to the issue. Depending on the circumstances, this may include further supplier review, worker interviews, remediation support, or referral to the appropriate authorities. Our aim is not only to address incidents but also to understand root causes so that the risk of recurrence is reduced.

We expect all suppliers to cooperate fully with investigations and to maintain complete and accurate records. If a supplier is unable or unwilling to meet our standards, we will take decisive steps consistent with our zero-tolerance approach. This may include placing the relationship under review and, where necessary, ending it.

This statement is reviewed annually to ensure it remains effective, relevant, and aligned with evolving legal and ethical expectations. The annual review considers audit results, risk assessments, incidents, training outcomes, and feedback from internal governance processes. Where improvements are identified, policies and procedures are updated without delay.

We view the annual review as an essential part of continuous improvement rather than a formality. It helps us measure progress, strengthen controls, and reinforce our responsibility to protect vulnerable workers. The review also supports greater consistency in how our Modern Slavery Statement is implemented across the business and within the supply chain.

Through this commitment, we reaffirm that modern slavery has no place in our organization or in the networks that support our work. By maintaining strong oversight, reliable supplier audits, effective reporting channels, and a rigorous annual review, we aim to uphold the highest standards of ethical conduct and human rights protection.