Modern Slavery Statement

Our organisation publishes this Modern Slavery Statement to affirm a zero-tolerance policy towards all forms of slavery, forced labour and human trafficking across our operations and supply chain. This anti-slavery statement sets out the steps we take to prevent modern slavery, our expectations of suppliers, and how we respond to concerns. We refer to this as our anti-slavery policy and it applies to every person working for or on behalf of the organisation, including temporary and contract staff.

We have a clear zero-tolerance stance: any instance of forced labour, debt bondage, or exploitative practice will result in immediate action. Our forced labour statement clarifies that non-compliance with anti-slavery commitments may lead to termination of contracts and remediation where necessary. We emphasise continuous improvement, integrating the principles of the modern slavery declaration into procurement, HR and operational policies.

As part of our modern slavery compliance programme, we conduct targeted due diligence and risk assessments in higher-risk geographies and sectors. The slavery and human trafficking statement is supported by risk-based supplier screening, contractual anti-slavery clauses and mandatory compliance requirements. We also maintain a register of high-risk suppliers and goods, and record actions taken to mitigate risk.

Supplier Audits and Oversight

We operate a structured programme of supplier audits and verification measures to assess working conditions and ethical practices. Audit activities include:

• Document reviews of payroll, timekeeping and contract terms;
• On-site inspections carried out by qualified auditors or third-party specialists;
• Worker interviews and anonymous feedback mechanisms during audits;
• Corrective action plans that are tracked until closure.

Where audits reveal concerns, we require suppliers to implement remediation plans within defined timeframes. Persistent or severe breaches trigger contract suspension or termination and escalation for further investigation. Our supplier code of conduct and purchasing terms embed these expectations and form part of our procurement contractual framework.

Reporting Channels and Whistleblowing

Employees, contractors and third parties are encouraged to report any suspected incidents of modern slavery or breaches of our anti-slavery policy through multiple confidential channels. We provide secure, anonymous reporting routes that prohibit retaliation and ensure concerns are handled promptly. All reports are triaged by a dedicated compliance team and escalated to senior management when appropriate.

Reports lead to investigations, corrective actions and, where necessary, co-operation with law enforcement. We train managers and HR personnel on recognising indicators of forced labour and ensure that victims are provided with protection, support and access to remedy as required. Our whistleblowing approach is central to an effective modern slavery reporting framework.

We publish annual disclosures to stakeholders outlining the outcomes of investigations, remediation efforts and improvements in supplier performance. Transparency underpins our slavery prevention strategy, and we aim to be clear about both successes and areas for development without compromising confidentiality or safety of affected individuals.

Governance and continuous improvement are key: the board and senior leadership are responsible for this modern slavery and human trafficking policy, ensuring resources and oversight are allocated. We invest in training for procurement staff, site managers and relevant teams to embed anti-slavery due diligence into day-to-day decisions and supplier relationships.

Our annual review cycle includes assessment of policy effectiveness, audit outcomes, supplier performance metrics and any changes in the risk landscape. The Annual Review of this modern slavery statement evaluates whether current measures are sufficient and recommends enhancements to controls, training or supplier engagement based on evidence and lessons learned.

In conclusion, this forced labour statement reaffirms our commitment to preventing modern slavery throughout our business and supply chains. We will continue to strengthen supplier audits, maintain clear reporting channels and undertake a rigorous annual review to drive continual improvement and safeguarding for all workers associated with our operations.