Modern Slavery Statement
This Modern Slavery Statement sets out the principles and actions used to prevent slavery, servitude, forced labour, and human trafficking within our operations and supply chains. We recognise that modern slavery can affect any industry, region, or workforce, and that robust controls are essential to support ethical business conduct. Our approach is built on zero tolerance, continuous due diligence, and clear accountability across all levels of the organisation.
We are committed to maintaining a workplace and supply chain that respect human rights and dignity. This commitment applies to direct employment, subcontracted activity, agency labour, and outsourced services. To reinforce this position, we require managers, procurement teams, and relevant decision-makers to assess modern slavery risks as part of everyday business practice. Our slavery and human trafficking controls are designed to identify warning signs early and respond decisively where concerns arise.
Our Zero-Tolerance Policy
We operate a zero-tolerance policy towards all forms of modern slavery. Any confirmed breach, or credible indication of exploitation, is treated as a serious matter and may result in contract termination, reporting to the appropriate authorities, or other corrective action. This policy is non-negotiable and applies to all employees, contractors, consultants, and suppliers.
Supplier Due Diligence and Audits
We expect suppliers to share our standards and to demonstrate effective safeguards in their own operations and downstream networks. Risk-based supplier audits are used to assess compliance, including labour practices, recruitment methods, working conditions, wage controls, and document retention. Where higher-risk categories are identified, enhanced review may include site visits, evidence requests, interviews, and corrective action plans.
Our procurement processes incorporate modern slavery screening at onboarding and during contract renewal. Suppliers must confirm that they do not use forced, bonded, or involuntary labour and that they provide lawful working arrangements. If deficiencies are found, we seek prompt remediation; however, repeated failure or deliberate concealment will lead to escalation. We also review suppliers’ subcontracting arrangements to reduce hidden risk within complex supply chains.
We recognise that meaningful oversight requires both prevention and verification. For that reason, audit findings are monitored for trends, and remediation is tracked until completion. This helps ensure that our modern slavery controls remain practical, measurable, and proportionate to risk.
Reporting channels are available for employees, workers, and external parties to raise concerns about suspected exploitation or unethical labour practices. Reports may be made through internal management routes, compliance functions, or whistleblowing mechanisms, and all concerns are handled with confidentiality and seriousness. No person will suffer retaliation for making a report in good faith.
All allegations are assessed promptly to determine the appropriate response, which may include internal investigation, supplier engagement, suspension of work, or referral to external authorities. Where necessary, we will take steps to protect vulnerable individuals and preserve evidence. Transparency, protection, and timely action are central to the effectiveness of our modern slavery response.
We also provide awareness training to relevant personnel so they can recognise indicators such as restricted movement, withheld identity documents, unusual recruitment fees, coercion, or unexplained vulnerability. This supports stronger decision-making and helps embed ethical labour standards throughout the organisation.
Governance of this Modern Slavery Statement is overseen by senior leadership, with responsibility shared across procurement, compliance, operations, and human resources. We regularly review risk indicators from sourcing regions, labour models, and supplier performance to ensure our actions remain aligned with current exposure. Findings are used to update controls, strengthen training, and improve supplier engagement.
An annual review of this statement and the related controls is completed to confirm effectiveness and identify opportunities for improvement. The review considers audit outcomes, incident reports, training completion, remediation progress, and evolving legal or sector expectations. Where changes are needed, we update policies, procedures, and responsibilities accordingly.
Through these measures, we aim to uphold a responsible and resilient business culture that rejects exploitation in every form. Our commitment to preventing modern slavery and human trafficking is ongoing, and we expect all partners to support this standard. By combining vigilance, accountability, and ethical procurement, we reinforce a supply chain founded on respect for human rights and lawful working conditions.
