Modern Slavery Statement
This Modern Slavery Statement sets out our zero-tolerance policy toward forced labour, human trafficking, debt bondage, child labour, and any other form of exploitation within our operations and supply chains. We are committed to conducting business in a way that respects human rights and dignity. Our approach is grounded in prevention, transparency, and accountability, and we expect the same high standards from every supplier, contractor, and business partner. This statement reflects our ongoing commitment to identify, prevent, and address risks linked to modern slavery across our activities.
We recognise that modern slavery can exist in complex supply networks and may be hidden behind subcontracting, recruitment practices, or informal work arrangements. To reduce these risks, we assess our operations and the regions in which we source goods and services. Our modern slavery statement framework includes due diligence at onboarding, risk-based checks for higher-risk categories, and internal controls designed to identify warning signs early. Where concerns arise, we act promptly and proportionately.
Supplier expectations are clearly defined in our procurement standards and contractual terms. We require suppliers to comply with all applicable labour laws, prohibit the use of forced or trafficked labour, and ensure workers are treated fairly and lawfully. We also encourage suppliers to maintain accurate employment records, provide freedom of movement, and use ethical recruitment practices. Non-compliance may result in corrective action, suspension, or termination of the relationship.
Supply Chain Oversight and Risk Management
Our modern slavery policy is supported by a structured supplier assurance programme. We use a risk-based approach to target the areas most likely to present vulnerabilities, such as low-wage work, labour-intensive services, and cross-border sourcing. Supplier audits form a central part of this process. These audits may be announced or unannounced and can include document reviews, site inspections, worker interviews, and checks on subcontracting arrangements.
When an audit identifies potential concerns, we work with the supplier to establish a corrective action plan. This may involve improving worker contracts, strengthening age verification, revising payroll practices, or stopping the use of unapproved labour intermediaries. In serious cases, we reserve the right to disengage. We believe that meaningful remediation, when possible, is essential, but it must never weaken our zero-tolerance stance.
Training is provided to relevant employees to help them recognise indicators of exploitation and understand escalation procedures. Procurement, operations, and compliance teams are expected to remain alert to unusual wage deductions, restricted worker access, identity document retention, or signs that workers cannot leave employment freely. By improving awareness, we strengthen the effectiveness of our modern slavery controls and reinforce a culture of ethical conduct.
Reporting, Escalation, and Continuous Improvement
We maintain multiple reporting channels so that concerns can be raised safely and confidentially. Reports may be made through internal management routes, compliance teams, or designated whistleblowing mechanisms. Retaliation is strictly prohibited, and anyone raising a concern in good faith will be protected. All allegations are assessed promptly, and where necessary, investigated with discretion and urgency. This helps ensure that potential incidents are not ignored or dismissed.
Our modern slavery statement is reviewed annually to confirm its continued relevance and effectiveness. The annual review considers changes in legislation, supplier risk profiles, audit findings, grievance trends, and any incidents or corrective actions taken during the year. Findings from this review are used to update policies, refine due diligence practices, and strengthen training. This ongoing process ensures that our response remains practical, current, and aligned with best practice.
We are committed to continuous improvement and to working collaboratively with stakeholders to help eliminate exploitation from our value chain. Modern slavery has no place in our business, and we will continue to strengthen our controls, review our supplier relationships, and uphold the highest ethical standards. Through vigilance, accountability, and regular review, we aim to protect workers and support responsible business conduct across every part of our organisation.
