Modern Slavery Statement
This Modern Slavery Statement sets out our zero-tolerance policy toward forced labour, human trafficking, debt bondage, child labour, and any form of modern slavery within our operations and supply chain. We are committed to acting ethically and with integrity in all business relationships, and we expect the same standards from every supplier, contractor, and business partner. Our approach is grounded in respect for human rights and in the belief that everyone deserves to work freely, safely, and with dignity.
We maintain clear internal controls to identify, prevent, and address risks associated with the Modern Slavery Statement framework. This includes risk-based due diligence during supplier onboarding, contractual commitments requiring compliance with labour laws, and periodic assessments of high-risk categories. Where concerns arise, we investigate promptly and take appropriate action, which may include corrective plans, suspension of orders, or termination of the relationship if remediation is not possible.
Our governance model supports accountability at every level. Senior leadership reviews slavery and trafficking risks as part of broader ethical sourcing oversight, while operational teams are responsible for implementing controls in daily practice. Training is provided to relevant staff so they can recognize warning signs, understand escalation procedures, and reinforce our commitment to a responsible and transparent supply chain.
Supplier Audits and Risk Management
Supplier audits are a key part of our modern slavery statement commitments. We conduct routine and targeted audits based on risk factors such as geography, sector, labour model, and past performance. Audits may include document reviews, worker interviews, site inspections, and checks for indicators such as withheld wages, restriction of movement, or unsafe working conditions. Where non-compliance is identified, we require remediation and monitor progress closely.
In addition to audits, we expect suppliers to maintain robust labour standards across their own subcontractors and raw material sources. Our supplier code of conduct reinforces expectations on recruitment practices, working hours, retention of identity documents, age verification, and freedom of association. We also encourage suppliers to adopt their own internal reporting mechanisms and to cascade these expectations throughout their operations.
To strengthen prevention, we integrate human rights considerations into procurement decisions and performance reviews. This means that ethical conduct is not treated as a separate issue, but as a core business requirement. We continually refine our controls using lessons learned from audits, industry developments, and changes in legal or regulatory expectations.
Reporting Channels and Escalation
We provide multiple reporting channels so concerns about modern slavery can be raised safely and promptly. These channels are designed to allow employees, workers, suppliers, and other stakeholders to report suspicions in good faith without fear of retaliation. Reports are handled confidentially where possible, investigated fairly, and escalated according to severity and urgency.
Our reporting process supports early intervention. When a concern is identified, it is reviewed by the appropriate compliance or governance lead, and if needed, escalated to senior management for action. We treat allegations seriously and seek to protect vulnerable individuals by coordinating with relevant internal teams and, where appropriate, external specialists. Protection from retaliation is a fundamental principle in our reporting approach.
Awareness of reporting options is reinforced through training, policy communication, and supplier engagement. We believe that clear, trusted channels are essential to uncover hidden risks and to ensure that anyone who sees or suspects abuse has a practical route to speak up.
Annual Review and Continuous Improvement
Our modern slavery policy and this statement are reviewed annually to ensure they remain effective, current, and aligned with best practice. The annual review considers audit findings, risk assessments, reported concerns, remediation outcomes, training completion, and changes in the operating environment. Findings are used to update procedures, strengthen oversight, and improve supplier engagement.
We recognize that combating modern slavery requires continuous improvement. For that reason, we regularly assess whether our controls are proportionate to the risks we face and whether additional measures are needed in vulnerable areas. This may include deeper supplier mapping, enhanced due diligence, more frequent audits, or targeted training for higher-risk functions.
We remain committed to embedding respect for human rights throughout our business and supply chain. By sustaining a firm zero-tolerance stance, strengthening supplier audits, maintaining accessible reporting channels, and completing an annual review, we aim to reduce the risk of exploitation and uphold a responsible standard of conduct in all our activities.
