Modern Slavery Statement

This modern slavery statement sets out our commitment to preventing forced labour, human trafficking, debt bondage, child labour, and all other forms of exploitation within our operations and supply chain. We believe that every person has the right to work freely, safely, and with dignity. Our zero-tolerance policy applies across the organisation and to every business relationship we maintain, regardless of location, role, or function.

We recognise that modern slavery risks can arise in complex supply chains, particularly where temporary labour, subcontracting, recruitment intermediaries, or geographically dispersed sourcing is involved. To address these risks, our modern slavery policy is embedded in procurement, onboarding, and compliance practices. We expect employees, contractors, and business partners to act with integrity and to uphold ethical labour standards at all times.

Our governance framework includes senior oversight, internal controls, and regular risk assessments. We identify higher-risk categories based on sector, geography, and service type, then apply proportionate safeguards. These measures help us strengthen our slavery and human trafficking prevention efforts and demonstrate that compliance is not a one-time exercise but an ongoing responsibility.

Supplier due diligence is a central part of our approach. Before engaging a new supplier, we assess labour practices, ownership structures, recruitment methods, and the use of subcontractors. Contract terms require suppliers to comply with applicable labour laws, prohibit forced or compulsory labour, and permit verification of relevant records where appropriate. Where concerns are identified, we require corrective action, enhanced monitoring, or termination of the relationship if risks cannot be resolved.

We also conduct supplier audits using a risk-based model. These audits may include document reviews, worker interviews, site visits, and follow-up assessments to confirm whether standards are being met. Findings are recorded and tracked through remediation plans. Our modern slavery due diligence process is designed to be practical and proportionate while still maintaining a clear expectation of accountability.

Training and awareness are essential to keeping our controls effective. Relevant employees receive guidance on recognising signs of exploitation, escalating concerns, and applying procurement safeguards. Managers involved in sourcing, onboarding, and supplier management are expected to understand the indicators of labour abuse and to support timely intervention where warning signs appear.

We provide multiple reporting channels so that concerns can be raised safely and promptly. Reports may be made through internal management lines, compliance functions, or other established whistleblowing routes. All concerns are treated seriously, handled confidentially where possible, and investigated without retaliation. We make it clear that speaking up about suspected modern slavery is both protected and encouraged.

Any allegation or indication of exploitation triggers a structured response. This may involve immediate fact-finding, supplier engagement, temporary suspension of work, or referral to the appropriate internal decision-makers. Where evidence suggests a serious breach, we will take decisive action, which may include ending a contract or relationship. Our aim is to protect affected individuals and prevent further harm while maintaining fair and consistent decision-making.

We document incidents, corrective actions, and outcomes to support learning and continuous improvement. The information gathered helps refine our controls, improve risk targeting, and strengthen our response to future concerns. This approach ensures that our modern slavery compliance framework remains active rather than merely procedural.

This statement is reviewed annually as part of our wider compliance and governance cycle. The annual review considers changes in legislation, emerging risks, audit findings, stakeholder expectations, and the effectiveness of existing controls. Updates may lead to revised training, enhanced supplier checks, improved reporting mechanisms, or changes to our procurement standards.

We recognise that combating modern slavery requires persistence, vigilance, and collaboration. No system can eliminate risk entirely, but a disciplined and transparent framework can reduce exposure and improve outcomes for workers. Our commitment is to continually strengthen our anti-slavery controls and to ensure that ethical conduct remains central to how we operate.

In summary, we maintain a firm zero-tolerance stance, apply targeted supplier audits, encourage safe reporting channels, and conduct an annual review to keep our approach current and effective. Through these measures, our modern slavery statement reflects a clear and enduring commitment to responsible business practice and the protection of human rights.