Modern Slavery Statement
This Modern Slavery Statement sets out the principles and controls used to prevent modern slavery, human trafficking, forced labour, and child labour within our operations and across our supply chains. We are committed to maintaining a workplace and procurement environment that reflects zero tolerance for any form of exploitation. This commitment applies to our employees, contractors, suppliers, and business partners, and it is reinforced through policies, training, due diligence, and regular monitoring.
Our approach is based on respect for human rights, lawful employment practices, and responsible sourcing. We recognise that modern slavery risks can exist in complex supply networks, especially where labour is sourced through intermediaries or in regions with weaker labour protections. To address this, we require all relevant parties to comply with our standards and we expect them to uphold the same ethical labour principles that guide our own activities.
We also ensure that decisions are made with a clear understanding of risk. Higher-risk categories, such as labour-intensive services, overseas manufacturing, and temporary workforce arrangements, are subject to enhanced checks. These checks help us identify warning signs early and take action before harm occurs. Our statement is reviewed at the organisational level to ensure that anti-slavery measures remain effective, current, and aligned with changing legal and operational requirements.
Supplier governance is central to our modern slavery response. Before onboarding, suppliers are assessed against criteria covering employment practices, subcontracting controls, wage standards, and worker welfare. In addition, selected suppliers are subject to supplier audits designed to verify compliance with our expectations and to identify areas for improvement. These audits may include document reviews, site visits, interviews, and checks on labour agency arrangements. Where concerns are identified, we require corrective action within agreed timelines and may suspend or terminate relationships where remediation is inadequate.
The modern slavery policy is embedded in our procurement process so that risk is considered from the outset and not only after contracts are awarded. We also ask suppliers to confirm that they do not use forced, bonded, or trafficked labour and that workers are treated fairly, paid appropriately, and free to leave employment in accordance with legal requirements. Our teams receive guidance on recognising indicators of exploitation, including debt bondage, withheld identity documents, restricted movement, and threats of punishment.
Awareness and accountability are strengthened through training and internal communication. Employees involved in recruitment, procurement, operations, and contract management are provided with information on identifying and responding to modern slavery risks. This helps create a culture in which concerns are taken seriously and acted upon promptly. We encourage openness, due diligence, and escalation where needed so that suspected violations can be investigated without delay.
We provide multiple reporting channels so that concerns about modern slavery can be raised safely and in good faith. Reports may be made by employees, suppliers, workers, or other stakeholders through established internal escalation routes and protected whistleblowing mechanisms. All reports are handled confidentially as far as possible, and retaliation against anyone raising a concern is not tolerated. Every report is reviewed promptly, and where appropriate, investigations are launched with clear ownership and documented outcomes.
Where an incident or credible allegation arises, we take a risk-based response that may include immediate safeguarding measures, suspension of supplier activity, independent investigation, and engagement with relevant experts or authorities. Zero-tolerance policy means that proven breaches may result in disciplinary action, contract termination, or other remedial steps suited to the severity of the issue. We focus not only on enforcement but also on prevention, ensuring lessons learned are incorporated into future controls and supplier oversight.
Our commitment is supported by governance and measurable review. Senior leadership oversees the implementation of anti-slavery controls, monitors performance, and ensures that responsibilities are clearly assigned. Progress is tracked through audit findings, training completion, supplier assessments, and incident reporting trends. This structured oversight allows us to strengthen the slavery prevention framework and respond effectively to emerging risks across the business.
Each year, we conduct an annual review of this statement and the related processes to ensure they remain suitable and effective. The review considers changes in legislation, market conditions, sourcing patterns, audit results, and any reported concerns. Findings from the review are used to update policies, improve supplier controls, and refine training content. Through continuous improvement, we aim to keep our modern slavery controls robust, proportionate, and responsive to risk.
This statement reflects our ongoing commitment to responsible business conduct and the protection of vulnerable people. By maintaining strict standards, strengthening supplier audits, supporting safe reporting channels, and completing an annual review, we aim to reduce the risk of exploitation and promote dignity across our operations and supply chains. Our modern slavery statement is not a one-time commitment; it is a living framework that guides everyday decisions and long-term accountability.
