Modern Slavery Statement

This Modern Slavery Statement sets out the principles and controls that guide our approach to preventing slavery, servitude, forced labour, and human trafficking in our operations and supply chains. We are committed to acting ethically and with integrity in all business relationships, and we expect the same from everyone who works with us. Our anti-slavery commitment is based on a clear zero-tolerance policy that applies to all employees, contractors, agents, and suppliers.

We recognise that modern slavery risks can exist in complex labour markets, procurement channels, and outsourced services. To address these risks, we maintain policies and procedures designed to identify, prevent, and respond to concerns promptly. These controls are reviewed regularly to ensure they remain effective and proportionate to the nature of our activities. We also provide training to relevant staff so that they can recognise warning signs and escalate concerns appropriately.

Our modern slavery statement is supported by governance arrangements that assign responsibility for compliance at senior level. This includes monitoring high-risk activities, reviewing risk indicators, and ensuring that corrective action is taken where needed. We do not accept any form of exploitation, and we expect suppliers to uphold equivalent standards across their own operations and downstream relationships.

Supplier Due Diligence and Audits

Supplier selection and ongoing oversight are central to our approach. Before engaging a supplier, we assess the nature of the service, the location of operations, labour conditions, and the supplier’s own ethical standards. Where the risk profile is elevated, enhanced checks are carried out and contractual safeguards are applied. Our modern slavery policy requires suppliers to confirm that they do not tolerate forced labour, child labour, or other exploitative practices.

Supplier audits form an important part of our assurance framework. Depending on the risk level, audits may include document reviews, management interviews, workforce sampling, and checks on recruitment practices. When concerns are identified, we expect a timely remediation plan and we may suspend or terminate the relationship if issues are not addressed. We also monitor subcontracting arrangements to ensure that compliance expectations extend beyond direct contractual partners.

In addition to formal audits, we use risk-based reviews to identify emerging issues in sectors or geographies where vulnerability may be greater. This modern slavery statement reflects our belief that prevention is most effective when due diligence is continuous, rather than limited to onboarding. We therefore aim to keep improving our controls as our business and supply chain evolve.

Reporting Channels and Investigation

We encourage anyone who suspects wrongdoing to raise concerns without delay. Reporting channels are available for employees, workers, suppliers, and other stakeholders to report suspected breaches of our standards. Concerns may relate to recruitment fees, retention of identity documents, restriction of movement, unsafe living conditions, intimidation, or any other indicator of exploitation.

All reports are taken seriously and handled discreetly. Where appropriate, matters are investigated by trained personnel and escalated to senior management. We prohibit retaliation against anyone who raises a concern in good faith, and we seek to protect the confidentiality of those involved wherever possible. If a modern slavery risk is identified, we act swiftly to safeguard affected individuals and to prevent recurrence.

Our anti-slavery framework also includes cooperation with relevant partners where remedial action is needed. We expect openness, accurate record-keeping, and constructive engagement when issues arise. These expectations help reinforce accountability and support a culture in which exploitation is neither ignored nor concealed.

Monitoring, Review, and Continuous Improvement

This statement is reviewed annually to assess progress, update risk priorities, and confirm that our controls remain suitable for the business environment. The review considers audit outcomes, incident trends, supplier performance, regulatory developments, and changes in operational risk. Where necessary, policies are revised and additional training or assurance measures are introduced.

Annual review is not limited to a formal exercise; it is part of an ongoing commitment to strengthen our modern slavery statement and improve our anti-exploitation controls. We aim to learn from findings, close gaps, and share expectations across the organisation. Through this continuous improvement cycle, we reinforce our zero-tolerance position and promote responsible business conduct.

We remain committed to preventing modern slavery in all forms and to using our influence responsibly throughout the value chain. By combining supplier audits, accessible reporting channels, strong governance, and an annual review, we seek to reduce risk and uphold the dignity and rights of every person connected to our business. This Modern Slavery Statement represents our ongoing commitment to ethical trade and responsible operations.