Modern Slavery Statement

This Modern Slavery Statement sets out the approach of the organization to preventing exploitation, forced labor, human trafficking, and all forms of modern slavery within its operations and supply chain. We recognize that modern slavery can affect any sector and any geography, and we are committed to acting responsibly, ethically, and with zero tolerance for abuse. Our position is clear: no level of slavery, servitude, debt bondage, child labor, or coercion is acceptable in any part of our business.

To support this commitment, the organization maintains policies and controls designed to identify, prevent, and address risks. These include due diligence checks during onboarding, internal governance reviews, and requirements that staff and managers remain alert to indicators of exploitation. We expect all employees to uphold ethical conduct and to take immediate action where concerns arise. Modern slavery prevention is not a one-time exercise; it is part of our ongoing responsibility.

We also require suppliers, contractors, and business partners to share this commitment. As part of our modern slavery compliance framework, we assess risk based on geography, sector, service type, and workforce profile. Where risk is higher, we apply additional scrutiny and may request evidence of labor standards, recruitment practices, and workplace protections. We will not knowingly continue a relationship with any party that fails to meet our standards.

Supplier audits are an important part of our controls. Depending on the level of risk, we may conduct desk-based reviews, request supporting documentation, or carry out onsite visits. These audits help us verify that suppliers are operating fairly, that wages are paid properly, and that workers are free from coercion or abuse. Where issues are identified, we expect timely corrective action, and repeated or serious breaches may lead to suspension or termination of the relationship.

Governance and Accountability

Responsibility for oversight of this modern slavery statement rests with senior leadership, who review progress and ensure appropriate resources are available. Managers are responsible for embedding the principles of this statement into daily operations and for supporting any investigation into suspected exploitation. Training and awareness efforts are used to help staff recognize warning signs, including restricted movement, withheld identification, unexplained debt, or signs of intimidation.

All concerns are treated seriously and handled with confidentiality. We encourage anyone who becomes aware of a potential issue to speak up without delay. Reporting channels are available internally so employees can raise concerns safely and without fear of retaliation. Reports may relate to our own operations or to the actions of suppliers, labor providers, or subcontractors. Every concern is reviewed and, where appropriate, escalated for investigation and remediation.

Risk Assessment and Remediation

When a risk or incident is identified, the organization will act promptly to protect affected individuals and reduce the likelihood of recurrence. This may include working with a supplier to improve recruitment practices, strengthen recordkeeping, or remove unlawful fees charged to workers. In severe cases, we will disengage from the relationship. Our approach is intended to be practical and proportionate while remaining firmly aligned with our zero-tolerance policy.

We also recognize that modern slavery risks may evolve over time. Changes in sourcing, labor markets, legislation, or supplier ownership can affect the level of exposure. For that reason, our controls are reviewed regularly and adjusted where necessary. We expect suppliers to cooperate fully with our assurance requests and to maintain their own policies, training, and grievance procedures that support fair treatment and lawful employment.

The organization is committed to continuous improvement. We monitor emerging risks, review incident trends, and consider whether additional preventive measures are needed. This may include updated contractual clauses, stronger onboarding checks, or more targeted audit activity. By combining prevention, detection, and remediation, we aim to keep our supply chain resilient and ethically sound.

This modern slavery declaration will be reviewed annually to ensure it remains accurate, relevant, and effective. The annual review considers changes in business activities, supplier risk, legal developments, and lessons learned from audits or reports. Findings from the review may lead to revisions in policy, training, supplier standards, or monitoring procedures so that our response continues to improve year by year.

We believe that strong standards, open reporting, and consistent oversight are essential to preventing exploitation. Every part of the organization has a role to play in supporting ethical labor practices and respectful working conditions. By holding ourselves and our partners to high standards, we help ensure that modern slavery has no place in our operations or supply chain.

This statement on modern slavery reflects our ongoing commitment to lawful, humane, and responsible business conduct. We will continue to strengthen our safeguards, act on concerns, and uphold our zero-tolerance approach across all areas of the business.