Modern Slavery Statement
This Modern Slavery Statement sets out the principles and controls used to prevent slavery, servitude, forced labour, and human trafficking in our operations and supply chains. We maintain a zero-tolerance policy toward any form of modern slavery and require all employees, contractors, and business partners to uphold the same standard. Our commitment applies across procurement, operations, logistics, and all business relationships, with clear expectations that ethical conduct is non-negotiable.
To support this commitment, we conduct risk-based due diligence on suppliers and service providers before engagement and throughout the relationship. This includes reviewing labour practices, recruitment methods, wage standards, working hours, identity documentation controls, and subcontracting arrangements. Where we identify elevated risk, we apply enhanced checks and ask for evidence of corrective action. Any supplier found to be in breach of our modern slavery policy may face immediate remediation requirements, suspension, or termination.
We also expect suppliers to cascade these requirements through their own supply chains. Our procurement teams are trained to recognise warning signs such as withheld passports, excessive recruitment fees, restricted movement, or signs of coercion. By embedding these controls, we aim to prevent abuse before it occurs and strengthen accountability at every stage of the supply chain.
Governance and Risk Management
Oversight of our modern slavery framework is maintained through internal governance processes that monitor compliance, investigate concerns, and track corrective actions. Senior management reviews high-risk sourcing categories and any material incidents involving labour exploitation. In addition, we require relevant teams to keep records of supplier assessments, audit outcomes, and follow-up actions so that decisions are transparent and traceable.
The organisation recognises that modern slavery risks can vary by geography, industry, and labour model. For this reason, we apply a proportional approach that focuses resources on the most vulnerable areas, including outsourced production, manual labour, temporary workforces, and complex subcontracting chains. This helps us direct attention where the risk is greatest while sustaining consistent standards across all operations.
Our anti-slavery statement is supported by internal training, policy communication, and periodic review of controls. Employees involved in supplier selection, contract management, and site oversight are expected to understand both the practical indicators of exploitation and the steps required to escalate concerns. Where issues are identified, we seek to protect affected workers first and then address root causes through remediation plans and, where necessary, business sanctions.
We provide multiple reporting channels so concerns can be raised safely and confidentially. Reports may be submitted by employees, suppliers, workers, or third parties through established internal channels, and concerns are treated seriously regardless of source. We prohibit retaliation against anyone who raises an issue in good faith and we investigate allegations promptly, fairly, and discreetly. This reporting structure is a vital part of our modern slavery compliance approach.
In response to a report, we assess the immediate risk to individuals, preserve relevant information, and determine whether urgent action is required. If indicators of exploitation are confirmed, we work with relevant stakeholders to implement corrective measures, which may include worker support, supplier remediation, increased monitoring, or disengagement. Where lawful and appropriate, matters may also be referred to external authorities.
We believe that effective modern slavery prevention depends on trust, vigilance, and consistent enforcement. That is why our channels are designed to be accessible and free from unnecessary barriers. Every report is an opportunity to strengthen our controls and demonstrate that ethical conduct is more than a policy statement; it is an operational requirement.
Supplier Audits and Corrective Action
Supplier audits form an essential part of our assurance process. We carry out scheduled and, where appropriate, unannounced audits based on risk profiles and past performance. These audits review payroll records, working conditions, worker interviews, age verification, recruitment practices, and the use of labour agencies. Findings are documented, and suppliers are expected to implement corrective actions within agreed timelines.
If a supplier fails to address serious non-compliance, we may increase monitoring, place the relationship under review, or end the contract. We expect openness during audits and treat concealment, falsification, or repeated breaches as serious misconduct. Our aim is not only to detect violations but to drive sustained improvement in labour standards and safeguard vulnerable workers.
Modern slavery risk management is therefore integrated into the wider supplier lifecycle, from onboarding through renewal and performance review. This ensures that ethical expectations remain visible and measurable over time, rather than being treated as a one-time assessment.
Annual Review and Continuous Improvement
This Modern Slavery Statement is reviewed annually to reflect changes in law, operations, sourcing models, and emerging risks. Each review considers audit results, incident trends, training completion, supplier performance, and the effectiveness of reporting channels. We use the findings to update controls, refine responsibilities, and strengthen prevention measures where needed.
The annual review also helps us assess whether our modern slavery statement remains accurate and whether additional action is required to improve transparency and protection. Continuous improvement is central to our approach, and we remain committed to building resilient supply chains grounded in respect for human rights.
By maintaining a zero-tolerance policy, conducting supplier audits, enabling secure reporting channels, and completing an annual review, we reinforce a culture of accountability and ethical practice. This statement reflects our ongoing commitment to preventing modern slavery in all parts of our business and supply chain.
