Modern Slavery Statement
This Modern Slavery Statement sets out our commitment to preventing slavery, human trafficking, forced labor, and all other forms of exploitation within our operations and supply chains. We maintain a zero-tolerance policy toward any practice that violates human rights or undermines dignity, freedom, and fair treatment. Our approach is grounded in ethical conduct, responsible sourcing, and continuous vigilance across every level of our business.
We recognize that modern slavery risks can exist in complex supply networks, especially where labor is recruited through intermediaries, where oversight may be limited, or where workers may be vulnerable due to geography, language, or economic pressure. To reduce these risks, we require all employees, contractors, and business partners to follow our internal standards and respect applicable laws. Our modern slavery commitment is not a one-time declaration; it is embedded in procurement, onboarding, due diligence, and ongoing management processes.
Our supplier management framework includes supplier audits as a core safeguard. High-risk suppliers may be assessed through desktop reviews, document checks, self-assessments, and on-site inspections where appropriate. These audits are designed to identify indicators of forced labor, child labor, debt bondage, withheld wages, unsafe housing, restricted movement, or coercive recruitment practices. Where concerns are identified, we require corrective action plans, enhanced monitoring, or termination of the relationship if the issue cannot be resolved satisfactorily.
Governance and Controls
Responsibility for addressing modern slavery sits with leadership and is shared across procurement, compliance, and operational teams. Training is provided so that relevant personnel can recognize warning signs and respond appropriately. In support of our modern slavery statement, we also expect suppliers to cascade equivalent standards throughout their own supply chains. This requirement helps extend due diligence beyond direct relationships and supports a wider culture of accountability.
Our reporting channels are designed to allow concerns to be raised safely and in good faith. Employees and suppliers may report suspected breaches, unethical recruitment practices, or any form of labor exploitation through confidential internal mechanisms. Reports are reviewed promptly and handled with discretion, and retaliation against anyone raising a concern is strictly prohibited. We encourage early reporting so that potential harm can be investigated and addressed before it escalates.
Risk assessment is reviewed regularly to reflect changes in geography, sector exposure, labor models, and supplier performance. We prioritize monitoring where the likelihood of modern slavery is higher, including in outsourced labor, seasonal work, and subcontracted services. This risk-based method allows us to focus resources where they are most needed while maintaining proportionate controls across the supply chain.
Due Diligence and Remediation
When non-compliance is identified, we aim to work with suppliers to remedy issues responsibly and swiftly. Remediation may include policy updates, worker interviews, recruitment reform, wage correction, or independent verification of improvements. However, where a supplier shows unwillingness to cooperate, repeats serious breaches, or fails to protect workers, we will take decisive action, including suspension or exit from the relationship. Our modern slavery approach seeks not only compliance, but meaningful prevention and improvement.
Annual Review
We conduct an annual review of this statement, our controls, and the effectiveness of our anti-slavery measures. This review considers audit findings, incident reports, supplier performance, regulatory developments, and changes in business structure. It also informs improvements to training, due diligence, and monitoring processes. By reviewing our arrangements every year, we strengthen accountability and ensure our response remains relevant and effective.
We remain committed to continuous improvement in combating slavery and human trafficking in all forms. The modern slavery statement reflects our values, our zero-tolerance stance, and our determination to uphold ethical business standards. Through supplier audits, strong reporting channels, and annual review, we will continue to identify risks, support remediation, and protect vulnerable people across our operations and supply chains.
