Modern Slavery Statement

This Modern Slavery Statement sets out the approach taken to prevent slavery, servitude, forced labor, and human trafficking within our organization and across our supply chain. We recognize that modern slavery is a serious violation of human rights, and we are committed to maintaining a zero-tolerance policy toward any form of exploitation. Our commitment applies to all operations, business relationships, and procurement decisions. Through clear expectations, active oversight, and ongoing improvement, we aim to uphold ethical standards that protect workers and support responsible business conduct.

Our Commitment and Governance

We expect every employee, contractor, and business partner to act with integrity and to comply with laws and internal standards designed to prevent abuse. The modern slavery policy is embedded in governance processes so that risk is considered at the earliest stage of supplier selection and throughout the lifecycle of the relationship. Senior leadership has responsibility for oversight, ensuring that the issue of contemporary slavery remains a standing agenda item in risk management discussions. We also promote awareness so that people across the organization understand how to identify warning signs and escalate concerns promptly.

Our supplier management framework is central to the prevention of exploitation. Before onboarding and during the term of each contract, we conduct risk-based supplier audits to assess labor practices, wage compliance, working hours, document retention, and the treatment of vulnerable workers. Where elevated risk is identified, additional checks may be carried out, including site visits, document reviews, and corrective action plans. The modern slavery statement is supported by due diligence requirements that require suppliers to confirm their own commitments and extend ethical standards to their subcontractors and labor providers.

Risk Assessment and Due Diligence

We focus particular attention on sectors, geographies, and services where the risk of exploitation may be higher. This includes reviewing indicators such as recruitment fees, worker accommodation, identity document retention, and restrictions on freedom of movement. If concerns arise, we will investigate promptly, seek remediation where appropriate, and, if necessary, suspend or end the relationship. Our approach is designed to be practical, proportionate, and consistent with the severity of the risk. By applying these measures, our anti-slavery statement reinforces prevention rather than relying on reactive intervention alone.

We encourage anyone who suspects wrongdoing to raise concerns without fear of retaliation. Reporting channels are available for employees and supply chain personnel to report potential breaches confidentially and, where permitted, anonymously. All reports are assessed carefully, and investigations are handled with discretion, fairness, and urgency. If a concern is substantiated, we will implement corrective action, strengthen controls, and monitor progress until the issue is resolved. Protection for whistleblowers is essential to the effectiveness of our modern slavery controls, and any form of retaliation is prohibited.

Training, Monitoring, and Supplier Expectations

Training is provided to relevant teams so they can recognize signs of exploitation, understand escalation procedures, and apply responsible procurement practices. Suppliers are expected to maintain accurate records, respect workers’ rights, and cooperate with audits or follow-up reviews. Our modern-day slavery statement also requires suppliers to communicate these expectations to their own workforce and business partners. We monitor performance through periodic review, contract checks, and risk-based assessments, ensuring that standards remain visible and actionable across the supply chain.

We know that preventing modern slavery is an ongoing responsibility that depends on vigilance and collaboration. Therefore, we review our policies and procedures regularly to reflect changes in legislation, business activities, and emerging risks. Any lessons learned from incidents, audits, or investigations are used to improve controls and strengthen supplier oversight. Through this continuous process, we reinforce a culture of accountability and respect for human dignity.

Our commitment is not static; it is measured, tested, and improved over time. Each year, the modern slavery policy statement is reviewed to ensure it remains effective and aligned with current expectations. The annual review considers audit results, reporting trends, training completion, and supplier performance, as well as any developments in our sector or operating regions. Where necessary, we update our action plans and strengthen preventive measures.

This slavery and human trafficking statement reflects our continuing determination to operate responsibly and to contribute to the elimination of exploitation wherever it may occur. We will maintain our zero-tolerance approach, support transparent reporting, and continue to challenge risk in our supply chain through regular audits and meaningful due diligence. By doing so, we aim to protect people, uphold lawful and ethical practices, and ensure our business relationships are built on trust, fairness, and respect.