Modern Slavery Statement
This Modern Slavery Statement sets out our commitment to preventing modern slavery, human trafficking, forced labour, and all forms of exploitation across our operations and supply chains. We recognise that modern slavery can affect any industry, any geography, and any stage of production. Our approach is grounded in vigilance, accountability, and continuous improvement. We maintain a zero-tolerance policy toward slavery and exploitation, and we expect every employee, contractor, and business partner to uphold the same standard. This commitment is supported by internal controls, training, and robust oversight designed to identify and address risk early.
Our responsibility begins with clear governance. Senior management reviews modern slavery risks as part of broader compliance and ethics oversight, ensuring that prevention remains embedded in decision-making. We require all relevant teams to understand the signs of exploitation and to escalate concerns without delay. Modern slavery risks may include debt bondage, restricted movement, passport retention, deception about terms of work, and unsafe or coercive conditions. We address these risks through policy enforcement, supplier due diligence, and corrective action where needed.
We also apply a structured risk-based approach to our operations and procurement activities. This includes assessing regions, sectors, and service categories that may present heightened vulnerability. Where risk is identified, we apply enhanced checks, request supporting evidence, and monitor performance more closely. Our goal is not only compliance, but the active prevention of harm through practical, measurable controls.
Supplier management is a central part of our modern slavery framework. We expect suppliers to comply with all applicable labour laws, respect human rights, and prohibit child labour, forced labour, and trafficking in any form. Contracts and onboarding requirements reinforce these expectations, and suppliers may be required to confirm their own controls and the practices of their subcontractors. We maintain supplier audits as a key assurance measure, using a combination of document reviews, site visits, and follow-up assessments. Where audit findings indicate non-compliance, we request immediate remediation and track progress until issues are resolved.
To strengthen the integrity of our supply chain, we work with suppliers to improve awareness and capability. This includes encouraging transparent recruitment practices, fair wages, reasonable working hours, and freedom to leave employment without penalty. In high-risk cases, we may suspend engagement, limit sourcing, or terminate relationships if credible evidence of abuse is found and corrective action is not possible. This proactive stance reinforces our modern slavery statement and demonstrates that ethical conduct is a condition of doing business with us.
We also recognise that effective prevention depends on accessible ways to raise concerns. We provide reporting channels that allow workers, managers, and third parties to report suspected misconduct safely and without fear of retaliation. Concerns may relate to labour exploitation, recruitment fees, coercion, document withholding, or any other sign of abuse. Reports are treated seriously, investigated promptly, and handled with confidentiality where appropriate. Retaliation against anyone who raises a concern in good faith is strictly prohibited.
Training is another important element of our programme. Relevant employees receive guidance on recognising indicators of modern slavery, understanding escalation routes, and carrying out due diligence responsibilities. Procurement, operations, and management teams receive additional support tailored to their exposure to supply chain risk. We review the effectiveness of training through completion records, audit outcomes, and the quality of reporting. This helps ensure that our anti-slavery measures remain practical and relevant.
Our internal controls are designed to support traceability, accountability, and evidence-based decision-making. We keep records of supplier assessments, audit results, remediation steps, and any concerns raised through reporting channels. These records help us identify trends, strengthen controls, and prioritise interventions where risk is greatest.
As part of our continuing commitment, we use this information to refine processes and improve the consistency of our response to modern slavery risks across the business.
This statement is subject to an annual review to ensure that it remains current, effective, and aligned with evolving legal requirements and emerging risk factors. Each review considers changes in our operations, supply chains, and external environment, along with lessons learned from audits, investigations, and stakeholder engagement. Where improvements are identified, action plans are updated and responsibilities assigned. Through regular review and sustained attention, we aim to strengthen our prevention efforts and uphold the highest standards of ethical conduct.
