Modern Slavery Statement

This Modern Slavery Statement sets out our zero-tolerance policy toward forced labor, human trafficking, debt bondage, child exploitation, and any other form of modern slavery in our operations and supply chains. We are committed to conducting business with integrity, dignity, and respect for human rights. This modern slavery statement applies to all employees, contractors, and business partners, and it reflects our obligation to identify, prevent, and address risks wherever they may arise.

We recognize that modern slavery can occur in many forms and across many sectors, often hidden within complex supply networks. To reduce this risk, we implement due diligence processes at the onboarding stage and throughout supplier relationships. Our approach includes assessing geographic, sector, and product-related risks, as well as reviewing labor practices, recruitment methods, and subcontracting arrangements. Zero tolerance means that any confirmed breach may result in corrective action, suspension, or termination of the relationship.

We also expect suppliers to maintain the same standards and to cascade these requirements to their own partners. Our anti-slavery statement is embedded in procurement controls, contractual clauses, and internal training so that responsible purchasing decisions support ethical outcomes. By requiring transparency and accountability, we aim to reduce the likelihood of exploitation and strengthen the resilience of our supply base.

Supplier oversight is a core part of our framework. We carry out supplier audits using a risk-based model, prioritizing higher-risk categories, locations, and labor-intensive activities. Audits may include document reviews, worker interviews, site inspections, and checks on recruitment fees, wages, working hours, and identity document retention. Where gaps are found, we require a corrective action plan with clear deadlines and follow-up verification.

Our modern slavery policy is supported by internal governance that assigns responsibility to leadership, procurement teams, and compliance functions. Training is provided to help staff recognize red flags such as restricted movement, withheld pay, excessive overtime, or signs of coercion. We use these controls to improve detection and promote informed decision-making across the organization.

We understand that risk does not end at the first tier of suppliers. Therefore, we assess sub-tier exposure where practicable and expect primary suppliers to cooperate with information requests. This process strengthens our ability to monitor supply chain conditions and to respond quickly if concerns emerge.

To encourage early reporting, we maintain multiple reporting channels through which workers, colleagues, and third parties can raise concerns about suspected modern slavery or unsafe labor practices. Reports may be made confidentially and, where permitted by law, anonymously. All concerns are reviewed promptly, documented carefully, and escalated through appropriate internal processes for assessment and action.

Any allegation is treated seriously and investigated with fairness, discretion, and urgency. If modern slavery indicators are identified, we work with relevant parties to protect affected individuals, remediate harm where possible, and prevent recurrence. We will not tolerate retaliation against anyone who raises a concern in good faith, and we reinforce this principle through policy, communication, and management oversight.

Our modern slavery statement is also informed by industry developments and evolving legal expectations. We continuously refine our controls to respond to emerging risks such as deceptive recruitment, labor brokerage abuse, and exploitative subcontracting. By combining prevention, detection, and remediation, we aim to uphold ethical business practices in every area of operation.

Governance, Monitoring, and Continuous Improvement

The effectiveness of this statement depends on active oversight and measurable progress. Management receives updates on risk assessments, audit findings, training completion, and the handling of reported concerns. Where improvements are needed, action plans are tracked to completion and reviewed for effectiveness. This helps ensure that our modern slavery commitments remain practical, current, and enforceable.

We are committed to building capability across the business and within our supplier network. As part of this effort, we promote responsible recruitment, fair treatment, and clear employment terms. These measures support a workplace culture that respects human rights and rejects exploitation in all forms.

Annual Review

This statement is reviewed annually to confirm its continuing suitability and to reflect changes in legislation, operations, and risk profile. The annual review considers audit outcomes, grievance trends, supplier performance, training effectiveness, and any incidents or investigations relating to modern slavery risks. Findings from the review inform updates to policy, controls, and priority actions for the following year.

We regard annual review as an essential part of accountability. It allows us to measure progress, identify weaknesses, and strengthen our response to human rights risks across the organization and its supply chain. Through this process, our anti-modern slavery statement remains aligned with our values and practical obligations.

In summary, this Modern Slavery Statement reflects our unwavering commitment to ethical conduct, supplier accountability, safe reporting, and continuous improvement. We will continue to apply our zero-tolerance approach, conduct supplier audits, maintain accessible reporting channels, and review our actions each year so that our standards remain robust and meaningful.