Modern Slavery Statement

This Modern Slavery Statement sets out the principles and actions that guide our approach to preventing modern slavery, human trafficking, forced labor, debt bondage, and other forms of exploitation across our operations and supply chain. We maintain a zero-tolerance policy toward any practice that denies individuals their freedom, dignity, or lawful rights. This commitment applies to all employees, contractors, suppliers, and business partners, and it is embedded within our broader ethical and compliance framework.

Our approach to modern slavery prevention is based on risk awareness, accountability, and continuous improvement. We expect all parties working with us to uphold fair labor practices, lawful employment standards, and safe working conditions. Where concerns are identified, they are treated seriously and investigated promptly. We also require managers to remain alert to indicators of exploitation, including restricted movement, withheld wages, excessive working hours, and intimidation.

We believe that effective prevention begins with clear expectations. Accordingly, our modern slavery policy is communicated internally and reinforced through procurement processes, induction materials, and relevant training. Employees involved in sourcing, contracting, and supplier management are expected to understand the risks associated with vulnerable labor channels and to act decisively where those risks arise.

To support compliance throughout our supply chain, we conduct supplier audits and due diligence reviews based on the nature of the goods and services procured, geographic risk, and the level of exposure to labor-intensive activities. These audits may include document checks, worker interviews, site visits, and corrective action plans where deficiencies are found. Suppliers are required to cooperate fully and to demonstrate their own controls against modern slavery and related abuses.

Our procurement decisions take into account labor standards, transparency, and the ability of suppliers to evidence responsible recruitment practices. We may request information on subcontractors, labor brokers, and workforce composition to better understand potential risks. If a supplier fails to meet our requirements, we reserve the right to suspend, remediate, or terminate the relationship depending on the severity of the issue and the willingness of the supplier to improve.

Training and awareness are central to our efforts. Relevant teams receive guidance on identifying warning signs and responding to allegations in a consistent, legally compliant manner. We also encourage a culture in which concerns can be raised early, without fear of retaliation. This helps ensure that modern slavery controls remain practical, visible, and effective across day-to-day operations.

Reporting and Escalation

We provide multiple reporting channels so that employees, workers, suppliers, and other stakeholders can raise concerns about suspected modern slavery or unethical labor practices. Reports may be made through management lines, compliance functions, or other internal reporting mechanisms established for safe escalation. All concerns are handled confidentially where possible, assessed promptly, and investigated in line with our procedures.

Retaliation against anyone who reports a concern in good faith is prohibited. We aim to ensure that allegations are reviewed objectively and that appropriate remedial steps are taken, which may include worker protection measures, supplier engagement, or involvement of external authorities where required. This reporting structure supports our anti-slavery commitment and reinforces trust in our governance arrangements.

Where modern slavery risks are identified, we seek to address root causes rather than relying solely on enforcement. This may involve strengthening policies, improving supplier capability, revising contract terms, or increasing monitoring in higher-risk areas. We recognize that meaningful change depends on both diligence and collaboration, and we work to ensure our response is proportionate to the circumstances.

Annual review is a key element of this statement and of our overall compliance program. We review our modern slavery arrangements at least once every year to assess effectiveness, consider emerging risks, and update our controls as necessary. The review includes a consideration of audit findings, supplier performance, reported concerns, training completion, and any changes in our operations or supply chain footprint.

Following the review, we identify actions for improvement and assign responsibility for implementation. This ongoing process helps ensure that our commitment remains active rather than symbolic. It also allows us to reflect on lessons learned, strengthen due diligence measures, and enhance oversight in vulnerable categories.

In closing, our modern slavery statement confirms our determination to operate responsibly, ethically, and transparently. We will continue to apply our zero-tolerance policy, maintain supplier audits, support robust reporting channels, and complete an annual review of our approach. By doing so, we aim to help protect people from exploitation and uphold respect for human rights throughout our business and supply chain.