Modern Slavery Statement

This Modern Slavery Statement sets out the principles and controls used to prevent modern slavery, human trafficking, forced labour, debt bondage, and exploitative recruitment within our operations and supply chains. We maintain a zero-tolerance policy toward any form of abuse that undermines human dignity. Our commitment is embedded in governance, procurement, and day-to-day decision-making, with clear expectations for employees, contractors, and business partners. We recognize that modern slavery can appear in many forms, including coercion, withholding of documents, excessive overtime, and unlawful wage deductions, and we are committed to identifying and addressing such risks wherever they may arise.

Our modern slavery policy is supported by internal controls designed to prevent, detect, and respond to risk. We require risk-based due diligence for new suppliers and review higher-risk categories more closely, particularly where labor-intensive services or complex subcontracting are involved. All personnel are expected to act with integrity and to escalate concerns promptly if anything appears inconsistent with our standards. Training materials reinforce these expectations and help teams understand warning signs, including unusual recruitment fees, restricted movement, or workers being controlled by third parties. We also expect managers to challenge practices that could indirectly contribute to exploitation.

As part of our modern slavery compliance approach, we monitor supplier relationships through periodic assessments and site reviews. These checks may include document verification, labor practice review, and confirmation that workers are employed voluntarily and receive lawful pay. Where appropriate, we ask suppliers to demonstrate how they manage their own sub-tier arrangements and recruitment processes. If a concern is identified, we seek immediate remediation, and where remediation is not possible or not completed, we may suspend or end the relationship. We believe preventive action is more effective than reactive response, and our due diligence process is designed accordingly.

Reporting channels are an essential part of this framework. Employees and third parties may raise concerns through internal reporting mechanisms, which are designed to allow issues to be reported safely and, where permitted, anonymously. Allegations are reviewed promptly and handled with appropriate confidentiality. No one should fear retaliation for speaking up in good faith. We encourage reporting of any suspected modern slavery, unsafe recruitment, document retention, intimidation, or other exploitative conduct. Every report is assessed, investigated proportionately, and, where needed, escalated to senior leadership for action.

Our approach to supplier oversight includes supplier audits that are proportionate to risk and tailored to the nature of the service or goods provided. These audits may be announced or unannounced, and they focus on working conditions, wages, hours, accommodation where relevant, subcontracting practices, and access to personal documents. Audit findings are documented, and corrective action plans are agreed with suppliers when gaps are identified. We expect timely closure of findings and will track progress until issues are resolved. Repeated or severe breaches are treated as evidence that the supplier relationship is not aligned with our standards.

We also recognize that effective prevention requires collaboration. Accordingly, we communicate our expectations through contractual clauses, supplier onboarding, and ongoing reviews. Suppliers are expected to apply the same principles to their own workforce and supply chains. Where a risk is elevated, we may request additional evidence, conduct deeper checks, or require independent verification. This risk-based methodology helps us focus resources on the areas most likely to present exposure to modern slavery while maintaining a consistent ethical baseline across all business activities.

Our commitment to continuous improvement means this modern slavery statement is reviewed annually and updated as needed to reflect changes in legislation, operational structure, and risk profile. The annual review includes assessment of incidents, audit outcomes, supplier performance, training completion, and the effectiveness of our reporting channels. Where lessons are identified, we strengthen controls, revise procedures, and refresh guidance to ensure our approach remains practical and effective. This review is not a formality; it is an opportunity to measure progress and reinforce accountability at every level.

We expect leaders to uphold these standards visibly and consistently. Governance oversight ensures that anti-slavery responsibilities remain on the agenda and that actions are assigned, tracked, and completed. If patterns emerge that suggest higher risk in a particular region, category, or process, we respond with enhanced monitoring and targeted interventions. Our objective is to create a resilient framework that protects vulnerable people, supports ethical business conduct, and reduces the likelihood of exploitation across our operations and supply chain.

In closing, this modern slavery declaration reflects our ongoing commitment to lawful, responsible, and humane business practices. We will continue to strengthen prevention, improve detection, and act decisively when concerns arise. By maintaining a zero-tolerance stance, conducting supplier audits, enabling clear reporting channels, and completing an annual review, we aim to ensure that our business remains firmly opposed to modern slavery in all its forms.