Modern Slavery Statement
This modern slavery statement sets out the principles, controls, and responsibilities that guide our approach to preventing forced labour, human trafficking, child labour, and all forms of exploitation within our operations and supply chains. We maintain a zero-tolerance policy toward any practice that undermines human dignity or violates labour rights. Our commitment applies to every part of the business, including recruitment, procurement, contractor engagement, and supplier management. We expect ethical conduct at every level and require all personnel to uphold this standard without exception.
To support this commitment, we embed the requirements of our modern slavery policy into onboarding, training, and internal governance. Employees are encouraged to remain alert to warning signs such as coercion, debt bondage, document retention, excessive overtime, or restricted movement. Where concerns arise, they are treated seriously and investigated promptly. We also take a risk-based approach to prevention, focusing attention on areas, geographies, and categories where vulnerability to exploitation may be higher.
Our anti-slavery framework is built on transparency, accountability, and continuous improvement. Managers are responsible for ensuring that decisions affecting workers and suppliers are made fairly and lawfully. Any breach of our standards may result in corrective action, contract review, suspension, or termination depending on severity. By reinforcing clear expectations, we aim to reduce risk and protect the people connected to our business.
Supply Chain Due Diligence
We recognise that the greatest exposure to modern slavery risks often lies beyond direct operations. For that reason, supplier onboarding includes screening, contractual safeguards, and review of labour practices. Our procurement teams assess relevant suppliers for risk indicators such as use of labour brokers, low transparency, substandard working conditions, and reliance on temporary or migrant labour.
Supplier audits are a core feature of our due diligence programme. These audits may be announced or unannounced and are conducted according to risk level, business criticality, and historical performance. During each audit, we examine payroll records, working hours, age verification processes, recruitment practices, and worker accommodation where applicable. When gaps are identified, suppliers must complete corrective actions within agreed timelines.
We also require key suppliers to confirm compliance with our modern slavery statement expectations and to extend equivalent standards to their own subcontractors. Zero tolerance is not merely a policy expression; it is a condition of doing business. If a supplier cannot demonstrate responsible labour practices, we will work with them to improve or, where necessary, discontinue the relationship. This approach strengthens resilience and encourages better practice across the chain.
Reporting, Escalation, and Review
All workers, contractors, and relevant third parties are expected to report concerns without delay. Reporting channels are designed to be accessible, confidential, and free from retaliation. Concerns may include suspected exploitation, unsafe recruitment fees, withheld wages, threats, intimidation, or any sign that a person is unable to leave work freely. Every report is assessed promptly, and appropriate escalation procedures are followed.
We ensure that allegations are handled with discretion and that individuals raising concerns are protected from adverse treatment. Whistleblowing arrangements form part of our broader governance structure and are supported by trained decision-makers who can investigate and act on credible information. Where a potential incident is substantiated, we collaborate with relevant stakeholders to secure remedial action and prevent recurrence. Our goal is not only compliance, but meaningful protection for vulnerable people.
This modern slavery statement is reviewed annually to ensure that it remains current, effective, and aligned with legal requirements and business changes. The review considers audit findings, supplier performance, risk trends, reported concerns, and lessons learned from investigations. We update policies, strengthen controls, and refine training where needed. Through this annual review, we reaffirm our commitment to ethical sourcing, responsible employment, and the ongoing elimination of modern slavery in all its forms.
