Modern Slavery Statement
Modern slavery is a grave violation of human dignity, and we are committed to preventing it in every part of our operations and supply chain. This modern slavery statement sets out the principles, controls, and responsibilities that guide our approach to identifying, preventing, and addressing forced labour, human trafficking, debt bondage, child labour, and other forms of exploitation. Zero tolerance is the foundation of our policy: we will not knowingly engage with any individual, supplier, or business partner involved in modern slavery practices.
Our commitment applies across all business activities, including procurement, recruitment, operations, and logistics. We expect every person working for or with us to act ethically and to uphold fair treatment, lawful employment, and safe working conditions. The company’s anti-slavery position is embedded in policies, onboarding processes, and contractual expectations so that the modern slavery policy is not only written but actively applied. We also require our managers to consider human rights risks when making commercial decisions, especially where labour is sourced through agencies, subcontractors, or cross-border supply networks.
Risk identification is central to our modern slavery statement framework. We assess the industries, locations, and business models most likely to present elevated risk, then apply controls proportionate to those risks. These controls include due diligence checks, supplier questionnaires, worker welfare assessments, and periodic reviews of labour practices. Where concerns arise, we investigate promptly and require corrective action. If a supplier fails to meet our standards, we may suspend orders, demand remediation, or end the relationship. This approach helps ensure that our anti-slavery commitment remains practical and enforceable.
Supplier oversight is strengthened through structured supplier audits and monitoring. Audits may be announced or unannounced, depending on the risk profile and the nature of the relationship. They examine wage records, working hours, age verification, freedom of movement, recruitment practices, and the use of labour intermediaries. We also look for indicators such as withheld identity documents, unlawful deductions, coercive supervision, or unsafe living conditions. Findings are documented, tracked, and reviewed by responsible leaders so that gaps are addressed without delay. The goal is not only compliance, but genuine improvement in ethical sourcing and labour standards.
To support reporting and accountability, we maintain multiple reporting channels so that concerns can be raised safely and in confidence. Employees, contractors, and suppliers are encouraged to report suspected abuse, unethical recruitment, or any sign of exploitation without fear of retaliation. Reports may be made through internal management routes, compliance teams, or other authorised mechanisms established for that purpose. All allegations are treated seriously, assessed promptly, and investigated with appropriate confidentiality. Where a report is substantiated, corrective measures are implemented and, when necessary, matters are escalated to the appropriate authorities.
Training and awareness are also important elements of our response. Relevant staff receive guidance on recognising indicators of modern slavery, understanding escalation procedures, and applying due diligence requirements in everyday work. Procurement teams are trained to identify risk in supply chains, while people managers are instructed to monitor recruitment and employment practices carefully. This helps build a culture in which modern slavery risks are understood early and handled responsibly. Training content is refreshed when laws, risks, or internal controls change, ensuring that our organisation remains alert and informed.
Governance for the modern slavery statement is owned at senior level, with oversight from leadership and regular reporting on key risks, incidents, and remediation actions. The company reviews the effectiveness of its controls against evolving legal requirements, operational changes, and emerging risk areas. This includes considering whether additional audits, stronger contract clauses, or enhanced supplier onboarding measures are needed. Our aim is to ensure that anti-slavery commitments remain embedded in decision-making rather than treated as a one-time declaration.
We also expect our suppliers to maintain comparable standards throughout their own supply chains. Where appropriate, contracts require suppliers to cascade our ethical expectations to subcontractors and labour providers. Any supplier found to be obstructing an investigation, providing misleading information, or failing to remedy serious concerns may face termination. This firm position reinforces our zero-tolerance policy and signals that compliance with labour rights is a condition of doing business with us. In addition, we continue to monitor high-risk categories to improve prevention and reduce the possibility of hidden exploitation.
This statement is reviewed annually to ensure it remains accurate, effective, and aligned with our operating environment. Each annual review considers audit outcomes, reported concerns, remediation progress, changes in legislation, and lessons learned from risk assessments. Updates are approved through the appropriate governance process and reflected in future actions and priorities. By reviewing the modern slavery statement every year, we reinforce accountability and continuous improvement. We remain committed to acting with integrity, protecting vulnerable people, and strengthening our controls across every area of the business.
