Modern Slavery Statement

This Modern Slavery Statement sets out the commitment of our organisation to prevent modern slavery, human trafficking, forced labour, servitude, and all forms of exploitation within our operations and supply chains. We recognise that modern slavery can affect any sector and any geography, and we therefore maintain a zero-tolerance policy toward any practice that undermines human dignity. This statement reflects our ongoing responsibility to identify risk, strengthen controls, and uphold ethical standards throughout the business.

Our modern slavery commitment is embedded in governance, procurement, and risk management. We expect directors, managers, employees, contractors, and business partners to act with integrity and to challenge any conduct that could enable exploitation. We also require that decisions involving recruitment, purchasing, and subcontracting are made with careful attention to labour rights and legal compliance. By taking this approach, we aim to ensure that our modern slavery controls are proactive rather than reactive.

The foundation of our approach is prevention. We conduct risk assessments across our operations and supplier base to identify areas where vulnerable workers, complex labour arrangements, or high-risk geographies may increase exposure. Where risks are identified, we apply additional due diligence, request supporting evidence, and monitor corrective actions. Modern slavery prevention is not treated as a one-time exercise; it is integrated into our daily management practices and reviewed regularly.

We also apply a structured supplier assurance programme. Key suppliers are expected to comply with our ethical sourcing requirements, and relevant contracts include obligations relating to labour standards, transparency, and lawful employment practices. Where appropriate, we carry out supplier audits, either announced or unannounced, to examine working conditions, payroll records, identity documentation, recruitment fees, and subcontracting controls. If non-compliance is found, suppliers must implement remedial actions within agreed timeframes, and continued failure may result in suspension or termination of the relationship.

Our modern slavery statement is supported by training for teams involved in procurement, operations, and human resources. This training helps staff recognise indicators such as restricted movement, debt bondage, withholding of passports, excessive overtime, or coercion. We believe informed employees are essential to spotting concerns early and escalating them appropriately. Internal guidance is maintained so that modern slavery risks can be identified consistently across different business functions.

We have established multiple reporting channels so that concerns can be raised safely and without fear of retaliation. Anyone who suspects a breach of our standards may report it through internal management routes, designated compliance processes, or anonymous whistleblowing mechanisms where available. Reports are handled confidentially, investigated promptly, and escalated when necessary. Reporting channels are an important part of our control framework because they help surface issues that may otherwise remain hidden.

In addition to monitoring suppliers, we review recruitment and labour practices within our own operations to ensure that workers are engaged voluntarily and treated fairly. We do not tolerate retention of identity documents, unlawful deductions, deceptive recruitment fees, or any practice that could restrict a person’s freedom. Our zero-tolerance policy extends to all stages of employment, from hiring and onboarding through to exit processes, because every stage must respect human rights and lawful standards.

We maintain records of findings, investigations, and corrective actions to support accountability and continuous improvement. Where a risk pattern emerges, we adjust controls, strengthen audits, and update supplier requirements. Our modern slavery governance model is designed to ensure that lessons learned are translated into action. This includes collaboration between relevant departments so that responsibilities are clear and issues are not managed in isolation.

This statement is reviewed annually to confirm that it remains accurate, effective, and aligned with changing legal, operational, and supply chain risks. The annual review considers audit results, incident trends, training completion, supplier performance, and any identified areas for improvement. Where needed, we revise policies and strengthen safeguards to reflect our continued commitment to ethical business conduct. Through this annual process, our Modern Slavery Statement remains a living document that supports accountability and long-term resilience.