Modern Slavery Statement

This Modern Slavery Statement sets out our zero-tolerance approach to all forms of modern slavery, including forced labour, human trafficking, servitude, debt bondage, and child labour. We are committed to acting ethically and with integrity in all business relationships, and we expect the same high standards from those who work with us. Our anti-slavery policy is embedded across our operations and is supported by training, oversight, and due diligence processes designed to reduce risk and strengthen accountability.

We recognize that modern slavery can exist in complex supply chains and may be hidden within recruitment, subcontracting, or labour brokerage arrangements. For that reason, our modern slavery commitment applies to employees, contractors, agencies, and suppliers at every level. We assess risk using a proportionate approach, focusing on geography, sector, service type, and workforce vulnerability. Where elevated risk is identified, we apply additional controls and require prompt corrective action.

Our governance model ensures that responsibility for this slavery and human trafficking statement is shared across leadership and operational teams. Management reviews relevant policies, monitors compliance indicators, and supports remediation where concerns arise. We also maintain clear internal standards on recruitment, document retention, working hours, and wages to help prevent exploitation and protect vulnerable workers.

Supplier Due Diligence and Audits

Supplier screening is a critical part of our modern slavery prevention framework. Before engaging suppliers, we conduct risk-based due diligence to understand their labour practices, ownership structure, and use of subcontractors. Contractual terms require suppliers to comply with applicable labour laws, prohibit exploitative practices, and flow the same expectations down their own supply chains.

We carry out supplier audits on a scheduled and risk-triggered basis. These audits may include document reviews, site inspections, worker interviews, and checks on recruitment practices. If deficiencies are found, we expect suppliers to implement corrective action plans within agreed timeframes. In cases of serious or repeated non-compliance, we reserve the right to suspend or end the relationship. This approach reinforces our anti-modern slavery standards and ensures that suppliers remain accountable.

We also provide guidance to suppliers on key indicators of risk, such as confiscation of identity documents, excessive recruitment fees, restricted freedom of movement, or threats of penalty. By combining auditing with ongoing engagement, we aim to build resilient supply relationships that respect labour rights and reduce the likelihood of exploitation.

Reporting Channels and Investigation

Everyone working with or for us is encouraged to raise concerns without delay if they suspect any form of abuse, coercion, or exploitation. Our reporting channels are designed to allow issues to be raised safely, confidentially, and without fear of retaliation. Concerns may be reported through management, compliance functions, or designated internal safeguarding routes, and all reports are treated seriously.

Once a concern is raised, it is assessed promptly and investigated in a structured manner. We may request records, interview relevant parties, and review supplier controls to determine the facts. Where evidence suggests that modern slavery may be present, we take immediate steps to protect affected individuals and to support remediation in line with legal and ethical obligations. Our modern slavery reporting process emphasizes confidentiality, fairness, and timely action.

We also promote awareness so that signs of exploitation are recognized early. Training and internal communications explain how to identify warning signals, why prompt reporting matters, and how workers can be protected during investigations. This culture of vigilance is essential to sustaining our zero-tolerance policy.

Annual Review and Continuous Improvement

This statement, along with our related policies and controls, is reviewed annually to ensure it remains effective, current, and aligned with evolving risks. The review considers changes in legislation, audit outcomes, supplier performance, grievance trends, and lessons learned from investigations. Where improvements are identified, we update procedures, strengthen oversight, and expand training.

The annual review also informs our priorities for the following year, including targeted supplier audits, enhanced due diligence in higher-risk categories, and more focused awareness-raising for relevant teams. We regard modern slavery prevention as an ongoing responsibility rather than a one-time exercise. Continuous improvement helps us strengthen assurance, support ethical business conduct, and uphold the dignity and rights of workers across our operations and supply chains.

Our commitment is clear: we will not knowingly engage in, tolerate, or benefit from any form of modern slavery. Through firm governance, supplier audits, effective reporting channels, and annual review, we aim to maintain a robust anti-slavery framework that supports responsible and lawful business practice.