Modern Slavery Statement

This Modern Slavery Statement sets out the approach of our organization to identifying, preventing, and addressing modern slavery and human trafficking in all areas of our operations. We are committed to maintaining a workplace and supply chain based on integrity, transparency, and respect for human rights. Our policy applies to employees, contractors, suppliers, and business partners, and it reflects our zero-tolerance stance toward any form of forced labor, servitude, debt bondage, child labor, or exploitation. As part of our broader modern slavery commitment, we expect every person and organization connected to our business to uphold the same standards.

We recognize that modern slavery can take many forms and may exist in complex supply chains or in service delivery arrangements where risks are less visible. For that reason, our modern slavery statement is built on proactive prevention rather than reaction alone. We conduct due diligence before engaging suppliers and continue monitoring throughout the relationship. This includes evaluating geographic, sector, and operational risk factors, reviewing policies, and confirming that labor practices align with legal and ethical requirements. Where concerns arise, we investigate promptly and take appropriate action without exception.

Our zero-tolerance policy is embedded in governance, procurement, and operational controls. Senior leaders are accountable for ensuring compliance, and responsibility is shared across teams involved in sourcing, onboarding, and supplier management. We do not accept any arrangement that hides labor abuse behind subcontracting, recruitment fees, or deceptive documentation. In every case, our expectation is simple: all work must be voluntary, fairly paid, and performed in safe conditions. This position is communicated regularly so that the principles of the modern slavery statement remain visible and enforced.

Supplier Due Diligence and Audits

Supplier oversight is central to the effectiveness of our modern slavery statement. We require suppliers to confirm their compliance with applicable labor laws and to maintain suitable policies and controls. High-risk suppliers are subject to enhanced review, which may include document checks, worker interviews, site inspections, and verification of recruitment and payment practices. Where necessary, we ask suppliers to demonstrate how they assess risks in their own supply chains and how they address non-compliance.

We also conduct supplier audits on a risk-based basis. These audits may be announced or unannounced, depending on the circumstances and the nature of the risk identified. Findings are recorded, remediation plans are agreed, and progress is tracked until issues are resolved. If a supplier fails to cooperate or repeatedly breaches our standards, we may suspend, reduce, or terminate the relationship. This approach supports a practical and consistent modern slavery policy that prioritizes prevention, correction, and accountability.

To strengthen our control framework, we provide internal teams with guidance on identifying indicators of exploitation, such as withheld documents, restricted movement, excessive overtime, or recruitment debt. Procurement staff are trained to recognize risk during tendering and contract renewal. We also encourage suppliers to adopt similar training and monitoring within their own operations. These measures help ensure that our modern slavery statement is not merely declarative, but actively reflected in decision-making and supplier selection.

Reporting Channels and Escalation

We maintain clear reporting channels so that concerns relating to modern slavery can be raised safely and promptly. Employees and business partners may report suspected misconduct, labor exploitation, or unethical recruitment practices through internal reporting routes established for compliance matters. Reports are handled confidentially and, where permitted by law, anonymously. We prohibit retaliation against any person who raises a concern in good faith. This protection is an essential part of our modern slavery statement and reinforces confidence in the reporting process.

All concerns are assessed by appropriately trained personnel and escalated when risk indicators suggest possible abuse. Investigations consider the nature of the allegation, the urgency of any immediate safeguarding issue, and any steps required to protect affected workers. If a matter is substantiated, we take corrective action, which may include remediation, enhanced monitoring, training, supplier improvement plans, or disengagement. Our response is designed to be proportionate, responsible, and consistent with our zero-tolerance position.

We recognize that reporting systems are only effective when they are trusted and accessible. Accordingly, our communication on these channels is regular and clear, and our managers are expected to support open reporting. This helps create a culture in which the modern slavery statement is understood as a shared commitment rather than a compliance exercise alone. We continue to review the effectiveness of escalation pathways to ensure concerns can be raised without delay.

Annual Review and Continuous Improvement

This statement is reviewed annually to ensure it remains effective, current, and aligned with legal and operational developments. The review assesses incidents, audit outcomes, supplier performance, training completion, and any changes in modern slavery risks. Lessons learned are incorporated into policy updates, procurement controls, and due diligence processes. Where gaps are identified, action plans are developed and monitored to completion.

The annual review also examines the adequacy of our modern slavery governance and whether additional resources or controls are required. We compare current performance against prior periods to identify trends and areas for improvement. This continuous improvement cycle helps strengthen our modern slavery statement and ensures it remains responsive to emerging risks across the business and supply chain.

Looking ahead, we will continue to reinforce our modern slavery policy through supplier engagement, internal training, and targeted audits. Our objective is to uphold a supply chain and operating environment free from exploitation, where human rights are respected at every stage. We remain committed to transparency, vigilance, and meaningful action, and this Modern Slavery Statement will be maintained as a living document that reflects ongoing progress and accountability.