Modern Slavery Statement
This Modern Slavery Statement sets out our commitment to preventing modern slavery, human trafficking, forced labor, and exploitative working practices in every part of our operations. We maintain a zero-tolerance policy toward any form of slavery, servitude, debt bondage, or child labor. This commitment applies to our employees, contractors, business partners, and supply chain relationships. We expect all parties acting on our behalf to uphold the highest standards of ethical conduct, transparency, and human rights.
Our approach to modern slavery compliance is grounded in respect for dignity, fairness, and accountability. We recognize that risks may exist in sourcing, manufacturing, logistics, and outsourced services, particularly where labor may be indirect or complex. To address these risks, we assess our operations regularly and integrate due diligence into procurement, onboarding, and supplier management. This includes reviewing labor practices, wages, working hours, identity documentation, recruitment methods, and worker freedom of movement.
We communicate our expectations clearly through contractual clauses, supplier onboarding requirements, and internal policies. Every supplier is required to confirm that it does not engage in, tolerate, or benefit from any abusive labor practice. Where appropriate, we request evidence of compliance, including site-level controls, training records, and worker welfare measures. Our anti-slavery standards are not optional; they are a condition of doing business with us.
Supplier Oversight and Risk Management
We conduct supplier audits based on risk, geography, spend, and category exposure. Audits may be announced or unannounced and can include document reviews, site inspections, and worker interviews where permitted. When a potential concern is identified, we require corrective action plans with clear timelines and measurable outcomes. Persistent failures, refusal to cooperate, or evidence of serious abuse may result in suspension or termination of the commercial relationship.
Our audit process is designed to support improvement while protecting vulnerable workers. We look for indicators such as withholding of wages, retention of passports, excessive recruitment fees, unsafe accommodation, coercive supervision, or restrictions on leaving employment. These checks help us identify hidden modern slavery risks and encourage suppliers to strengthen their own controls. We also expect suppliers to cascade equivalent expectations to their subcontractors and labor providers.
Internal training supports this framework by helping relevant teams recognize warning signs and respond appropriately. Procurement, operations, and leadership personnel receive guidance on ethical sourcing, escalation routes, and the responsibilities associated with slavery and trafficking prevention. We believe awareness is essential to effective prevention, and we continuously improve our processes as risks evolve.
Reporting Channels and Escalation
We provide safe and accessible reporting channels so concerns can be raised without fear of retaliation. Reports may be submitted confidentially through internal ethics mechanisms, manager escalation, or designated grievance processes. We encourage anyone who suspects a breach of this statement to speak up promptly so the matter can be reviewed, investigated, and addressed. Retaliation against any person who raises a concern in good faith is strictly prohibited.
All reports are handled with discretion and seriousness. Depending on the nature of the allegation, we may involve compliance, legal, procurement, and senior management to ensure a thorough response. If a credible issue is found, we act quickly to protect affected individuals and preserve evidence. Where appropriate, we may work with suppliers to remediate harm, improve systems, and strengthen controls. Our modern slavery statement is effective only when concerns are raised and acted upon.
We also encourage our supply chain partners to maintain their own grievance mechanisms, allowing workers to report concerns in languages they understand and through channels that are easy to access. A robust reporting and escalation process is an essential safeguard against abuse and an important part of responsible business practice.
Monitoring, Review, and Continuous Improvement
This statement is reviewed annually to ensure it remains relevant, effective, and aligned with legal requirements and evolving risk. During the review, we consider audit findings, incident reports, supplier performance, training outcomes, and changes in our business operations or sourcing regions. The annual review helps us identify trends, strengthen governance, and refine our modern slavery prevention measures.
As part of continuous improvement, we update policies, enhance supplier engagement, and expand due diligence where necessary. We may introduce additional audits, targeted training, or corrective controls when higher-risk conditions are identified. Our aim is not only to comply with expectations, but to create a business environment in which exploitation cannot take root. We remain committed to learning, adapting, and improving our safeguards over time.
This Modern Slavery Statement reflects our ongoing responsibility to uphold human rights and prevent exploitation across our organization and supply chain. Through a zero-tolerance policy, risk-based supplier audits, clear reporting channels, and an annual review process, we seek to maintain strong oversight and meaningful accountability. We expect all stakeholders to support these standards and help ensure that dignity, safety, and lawful treatment remain central to every working relationship.
