Modern Slavery Statement
Our commitment to ethical conduct is central to this modern slavery statement. We maintain a zero-tolerance policy toward forced labor, child labor, servitude, human trafficking, and any form of exploitation in our operations and supply chains. This commitment applies to all employees, contractors, partners, and third parties acting on our behalf.
Our approach to preventing modern slavery
We recognize that the risks associated with modern slavery can appear anywhere in complex business networks. To address these risks, we embed due diligence into procurement, onboarding, and ongoing oversight. Every supplier is expected to comply with our ethical standards, labor expectations, and legal obligations. Where risks are identified, we take prompt action to investigate, remediate, and, if needed, end the relationship.
Our modern slavery policy is supported by internal training, risk assessments, and management accountability. We require leaders to monitor high-risk categories, geographies, and labor arrangements. In addition, we review contractual terms to ensure they include obligations on human rights, workplace safety, wage compliance, and sub-tier transparency.
Supplier due diligence and audits
Supplier management is a key part of our modern slavery response. Before engagement, we assess suppliers against ethical, operational, and legal criteria. Existing suppliers are monitored through periodic reviews, document checks, and site visits where appropriate. Higher-risk suppliers may be subject to enhanced due diligence, including workforce interviews, payroll verification, and inspection of recruitment practices.
We conduct supplier audits to verify compliance and identify indicators of exploitation. These audits may be scheduled or unannounced, depending on the level of risk and the nature of the relationship. Findings are documented, corrective actions are agreed, and progress is tracked to completion. Suppliers that fail to improve or that refuse cooperation may be removed from our approved supplier base.
To strengthen prevention, we encourage responsible recruitment practices and prohibit worker-paid recruitment fees where legally and practically possible. We also look for evidence that workers understand their terms of employment, retain identity documents, and can move freely without coercion. These measures support a more resilient and ethical supply chain.
Reporting channels and accountability
We provide clear reporting channels so concerns about suspected exploitation can be raised safely. Reports may be made through internal management routes, compliance teams, or designated escalation processes. All concerns are treated seriously, investigated confidentially, and handled with appropriate safeguards to protect individuals from retaliation. Anonymous reporting is supported where permitted, and every report is reviewed by responsible personnel.
Accountability is shared across the organization. Managers are expected to act on warning signs, escalate concerns promptly, and support remediation. We also expect suppliers to maintain effective grievance mechanisms for workers, so concerns can be raised at the earliest possible stage. This layered approach helps us identify issues before they become entrenched.
Our governance framework ensures that the modern slavery statement remains active, practical, and measurable. Senior leadership reviews material issues, monitors progress, and approves improvement plans. Training is provided to relevant teams so they can recognize indicators such as restricted movement, excessive recruitment debt, withholding of wages, or intimidation.
Annual review and continuous improvement
We review this statement and the underlying controls annually to ensure they remain effective and aligned with evolving risks. The review considers audit outcomes, supplier performance, reported concerns, training completion, and regulatory developments. Where gaps are identified, we update our controls, strengthen oversight, and refine our due diligence processes.
Continuous improvement is essential to our modern slavery prevention efforts. We will continue to assess risk, reinforce ethical purchasing practices, and work with suppliers who demonstrate a genuine commitment to lawful and responsible labor standards. Our objective is not only compliance, but the active protection of human dignity across our operations and supply chains.
By maintaining this commitment, we affirm that exploitation has no place in our organization. This modern slavery statement reflects our current practices and our determination to improve them year by year, with integrity, vigilance, and accountability at every level.
