Modern Slavery Statement
Modern slavery statement sets out our unwavering commitment to preventing slavery, forced labor, human trafficking, and all forms of exploitation within our operations and supply chains. We maintain a zero-tolerance policy toward any conduct that undermines human dignity, and we expect every employee, contractor, and business partner to uphold the same standard. This statement reflects our ongoing responsibility to identify, prevent, and address risks with diligence and integrity.
Our approach is grounded in respect for human rights and compliance with applicable law. We recognize that modern slavery can take many forms, including debt bondage, coercion, deceptive recruitment, withheld identity documents, and restricted freedom of movement. To counter these risks, our anti-slavery statement is embedded across procurement, onboarding, and governance processes, ensuring that ethical conduct remains a core business expectation.
We also require managers to complete periodic risk assessments that consider geography, industry sector, labor practices, and the nature of work performed. Where higher-risk conditions are identified, additional checks are applied, including workforce verification and review of labor agency practices. These safeguards help strengthen our modern slavery commitment and support early intervention before harm occurs.
Supplier oversight is a central part of this statement. We conduct supplier audits using a risk-based model, prioritizing suppliers in higher-risk regions or categories. Audits may include document reviews, interviews, site inspections, and evaluation of subcontracting arrangements. If a supplier fails to meet our standards, we require corrective action and may suspend or terminate the relationship where necessary.
Our procurement teams are trained to recognize warning signs such as unusually low wages, excessive overtime, recruitment fees charged to workers, and lack of transparent employment terms. We expect suppliers to maintain accurate records, use ethical recruitment practices, and ensure that workers understand the terms of employment in a language they can comprehend. Modern slavery prevention is treated as a shared responsibility across the supply chain.
We further require contractual clauses that prohibit forced labor and human trafficking. These clauses also permit us to investigate concerns and request evidence of compliance. In addition, we monitor high-risk categories through ongoing reviews, ensuring that supplier performance aligns with our anti-modern slavery expectations and legal obligations.
Effective reporting is essential to our response framework. We provide multiple reporting channels so that employees, contractors, and suppliers can raise concerns confidentially and without fear of retaliation. Reports may relate to recruitment practices, labor conditions, document retention, intimidation, or any other issue suggesting exploitation. All concerns are assessed promptly, recorded carefully, and escalated where appropriate.
Anyone making a report is protected under our non-retaliation principles. Retaliation, intimidation, or punishment for raising a concern will not be tolerated. Where an allegation is substantiated, we take action that may include remediation, supplier intervention, worker support measures, disciplinary action, or referral to relevant authorities. This structured response demonstrates the seriousness of our modern slavery policy.
Training supports this system by helping staff understand how to recognize concerns and escalate them properly. We also communicate our expectations to suppliers so they can encourage responsible speaking-up practices within their own operations and subcontracted networks. This builds a culture where concerns can surface early and be addressed effectively.
Annual review is a key element of continuous improvement. Each year, we review this statement, reassess risk exposure, evaluate audit findings, and measure the effectiveness of our controls. The review considers changes in legislation, business structure, supplier base, and emerging risk indicators. Where improvements are needed, we update procedures and strengthen oversight accordingly.
Senior leadership oversees this process and remains accountable for progress. By reviewing outcomes annually, we ensure that our modern slavery statement remains current, practical, and aligned with our values. We are committed to transparency, vigilance, and responsible action, and we will continue working to reduce the risk of exploitation in every part of our business.
