Modern Slavery Statement
This Modern Slavery Statement sets out the principles, controls, and responsibilities that guide our approach to preventing exploitation in every part of our operations. We recognise that modern slavery can take many forms, including forced labour, bonded labour, human trafficking, and child exploitation. Our zero-tolerance policy applies across all business activities, and we expect the same commitment from everyone acting on our behalf. This statement reflects our ongoing effort to uphold dignity, fairness, and lawful working conditions throughout our supply chain.
We are committed to identifying, preventing, and addressing risks linked to modern slavery practices. To support this commitment, we maintain internal procedures designed to promote ethical conduct, transparency, and accountability. These procedures apply to recruitment, procurement, contractor management, and supplier relationships. We also provide regular awareness communication so that teams understand the warning signs of exploitation and the importance of acting promptly where concerns arise.
Our governance framework assigns clear responsibility for overseeing the modern slavery approach. Senior management reviews risk areas, monitors corrective actions, and ensures that relevant policies remain current. This includes reviewing labour practices, onboarding requirements, and due diligence checks for higher-risk partners. We expect decisions to be guided by integrity and by a firm refusal to engage with any person or organisation involved in abusive employment practices.
Supplier relationships are central to our risk management approach. We conduct supplier audits, both announced and unannounced where appropriate, to assess compliance with labour standards, wages, working hours, and worker freedom. These audits help us identify weaknesses in supplier practices and verify that agreed corrective measures are being implemented. Where concerns are identified, we require timely action plans, follow-up reviews, and, if necessary, termination of the relationship. Our supplier audits are an essential safeguard in supporting ethical sourcing and responsible procurement.
We also use risk-based screening when engaging new suppliers and periodically reassess existing arrangements. Factors such as geography, industry sector, labour model, and subcontracting complexity are considered when determining the level of scrutiny required. Where suppliers rely on labour intermediaries or temporary work arrangements, we seek additional assurance that workers are treated lawfully and fairly. This modern slavery statement approach is designed to be practical, proportionate, and effective.
To encourage transparency, we provide multiple reporting channels for employees, contractors, and suppliers to raise concerns about possible exploitation. Reports may be made through internal management lines, compliance functions, or designated whistleblowing processes. Concerns are treated seriously and investigated promptly, with confidentiality maintained wherever possible. Retaliation against anyone who raises a concern in good faith is prohibited. These reporting channels are a critical part of our protective framework and support early intervention before harm escalates.
We expect all workers, including agency staff and outsourced personnel, to be treated with respect and to have access to safe, lawful, and voluntary employment. Recruitment practices must never involve the payment of unlawful fees, deception, coercion, or identity document retention. We work to ensure that employment terms are clear, transparent, and understood by those affected. Training and oversight help reinforce our expectations and reduce the likelihood of abuse within operational or supplier environments.
Where a potential issue is identified, we assess the facts carefully and take a risk-based response. This may include immediate safeguarding measures, supplier engagement, remediation planning, or escalation to the appropriate authority where required. Our objective is not only to respond to incidents, but also to address root causes and prevent recurrence. We believe a responsible modern slavery policy must combine vigilance, practical controls, and a willingness to act decisively.
This statement will be reviewed annually to ensure it remains accurate, relevant, and aligned with evolving legal obligations and best practice. The annual review will consider audit findings, reported concerns, changes in the risk profile, and lessons learned from remediation activity. Updates may result in stronger controls, revised supplier expectations, or additional staff training. Through this annual review, we reinforce our long-term commitment to preventing modern slavery and maintaining ethical standards across our organisation and supply chain.
