Modern Slavery Statement
This Modern Slavery Statement sets out the principles, controls, and responsibilities that guide our approach to preventing modern slavery, human trafficking, forced 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, and we expect the same commitment from every supplier, contractor, and business partner. Our aim is to ensure that our business is conducted ethically, transparently, and in line with applicable law.
We recognise that modern slavery can take many forms, including debt bondage, servitude, child labour, coercion, and deceptive recruitment practices. To address these risks, we apply proportionate due diligence across our procurement, operations, and governance processes. This modern slavery statement reflects our ongoing commitment to identifying risk, strengthening controls, and responding decisively where concerns arise.
Our governance framework assigns clear accountability to senior management, who oversee compliance efforts and review risk exposure across the business. Internal policies are designed to prevent exploitation at every stage of the employment and purchasing cycle. Where needed, we require corrective action plans and enhanced monitoring to ensure that issues are addressed promptly and effectively.
Supplier management is a central part of our modern slavery statement. Before engaging with a supplier, we assess the nature of the relationship, the geography involved, and the sensitivity of the services or goods provided. Suppliers are expected to uphold labour standards, maintain lawful working conditions, and cascade these expectations through their own subcontractors and labour providers.
To verify compliance, we conduct supplier audits based on risk level and business criticality. These audits may include document reviews, site visits, worker interviews, and checks of recruitment practices, wage records, working hours, and accommodation standards. When findings indicate potential non-compliance, we require immediate remediation and may suspend or terminate the relationship if improvement is not achieved.
Our modern slavery controls also cover recruitment and onboarding. We prohibit the charging of recruitment fees to workers and require that identity documents remain under the worker’s control. Any indication that a worker has been threatened, misled, or restricted in their movement is escalated for investigation. These measures help us maintain a responsible and lawful supply chain.
We encourage employees, contractors, and suppliers to report concerns without fear of retaliation. Reporting channels are designed to be accessible, confidential, and available for issues relating to exploitation, unsafe labour practices, and unethical conduct. All reports are reviewed carefully, and investigations are handled with discretion, fairness, and urgency. Where appropriate, we involve specialist support to assess risk and protect affected individuals.
In addition to formal reporting, we promote awareness through internal communications and training. Employees involved in procurement, human resources, operations, and supplier management receive guidance on recognising warning signs and responding appropriately. This Modern Slavery Statement reinforces that vigilance is everyone’s responsibility, and that early detection is essential to preventing harm.
We understand that modern slavery risks evolve over time, particularly as supply chains change, new markets are entered, or business models expand. For that reason, we carry out an annual review of our policies, due diligence processes, and supplier risk assessments. The review considers lessons learned from audits, incident reports, regulatory developments, and industry best practice.
The outcome of each annual review informs improvements to our controls, training, and monitoring arrangements. Where weaknesses are identified, we update procedures and strengthen oversight to reduce future risk. This ongoing cycle of assessment and improvement ensures that our modern slavery policy remains relevant, practical, and effective.
Our commitment is supported by a culture of integrity, accountability, and respect for human rights. We believe that ethical business practices are not only a legal requirement but also a fundamental responsibility. By maintaining robust safeguards, conducting supplier audits, enabling reporting channels, and completing an annual review, we work continuously to prevent exploitation and uphold the principles set out in this statement.
