Modern Slavery Statement

Modern slavery is a grave abuse of human rights, and we are committed to preventing it in every part of our operations. This modern slavery statement sets out the principles, controls, and responsibilities that guide our approach to identifying, preventing, and addressing slavery, forced labor, human trafficking, and related forms of exploitation. We recognize that these risks may exist not only within our direct activities but also across our supply chain, subcontracting arrangements, and service partners.

Our zero-tolerance policy is central to this commitment. We do not accept any form of forced, bonded, or involuntary labor, child labor, coercion, deceptive recruitment, or restriction of freedom of movement. All employees, contractors, and business partners are expected to comply with this policy. Where concerns arise, we act promptly and proportionately, using investigation, remediation, suspension, or termination of relationships where necessary. The aim of this modern slavery approach is to ensure that dignity, fairness, and lawful working conditions are upheld everywhere we operate.

To support this policy, we apply risk-based due diligence at the point of onboarding and throughout the life of the relationship. This includes reviewing supplier credentials, assessing labor practices, and considering geography, sector, and service type. In higher-risk areas, we expect enhanced controls, documented recruitment practices, and clear evidence that workers are engaged voluntarily. Our commitment to the modern slavery statement is not static; it is embedded in governance, procurement, and operational decision-making.

Supplier oversight is reinforced through regular audits and assessments. These supplier audits may be announced or unannounced, depending on risk and circumstance, and can include document checks, site reviews, worker interviews, and examinations of wage, hour, and identity records. If non-compliance is identified, we require corrective action plans with clear deadlines and follow-up reviews. Persistent or serious breaches may result in the suspension or end of business engagement. This process helps us maintain practical control over slavery and human trafficking risks in our supply chains.

We also require key suppliers to cascade equivalent standards to their own subcontractors and labor providers. Written commitments, ethical trading expectations, and contractual obligations are used to ensure that the standards in this modern slavery statement are understood and applied beyond our immediate relationships. We encourage transparency in labor sourcing, recruitment fees, and worker accommodation arrangements, as these areas can create vulnerability to exploitation if unmanaged.

Reporting channels are available for employees, workers, suppliers, and other stakeholders to raise concerns confidentially and without fear of retaliation. Reports can be made through internal management routes, compliance teams, or designated grievance mechanisms. We treat allegations seriously, assess them promptly, and preserve confidentiality wherever possible. Where a concern is substantiated, we take steps to protect affected individuals, correct root causes, and prevent recurrence. A trusted reporting culture is essential to detecting hidden risks in modern slavery and related misconduct.

Training and awareness are important parts of our program. Relevant teams receive guidance on recognizing indicators such as document withholding, excessive recruitment charges, threats, unsafe accommodation, or restricted movement. Procurement, human resources, and operational leaders are trained to apply a consistent standard when engaging workers and suppliers. This supports informed decision-making and strengthens the effectiveness of our modern slavery policy across the business.

Accountability for implementation is assigned to senior leadership, with oversight provided through internal governance processes. Performance against our obligations is reviewed through compliance monitoring, audit findings, corrective actions, and incident reporting. Where issues are identified, lessons learned are recorded and used to improve controls. Our approach reflects the view that preventing exploitation requires ongoing vigilance, not a one-time review.

We will conduct an annual review of this modern slavery statement and associated controls to ensure they remain relevant, effective, and aligned with legal requirements and operational risk. The review will consider audit outcomes, emerging risk trends, supplier performance, and any reports received through our channels. Where needed, we will strengthen our procedures, refine due diligence, and update our training and governance measures. This ongoing review demonstrates our continued commitment to eliminating modern slavery from our business and supply chains.