Modern Slavery Statement
This modern slavery statement sets out the principles, responsibilities, and actions used to prevent forced labor, human trafficking, debt bondage, child labor, and other forms of exploitation across our operations and supply chain. We recognize that modern slavery risks can arise in direct operations, subcontracted services, logistics, manufacturing, recruitment, and raw material sourcing. Accordingly, we maintain a zero-tolerance policy toward any practice that undermines human dignity, lawful employment, or fair treatment.
Our commitment is embedded in governance, procurement, and risk management. Senior leadership is responsible for overseeing compliance, while managers are expected to identify and address vulnerabilities within their teams and supplier networks. We require all relevant personnel to understand that ethical conduct is not optional. The company’s modern slavery policy applies to employees, agency workers, contractors, and all third parties acting on our behalf.
We assess risk through supplier due diligence, country and sector screening, and review of labor practices where exposure is higher. New suppliers are evaluated before onboarding, and existing relationships are monitored based on risk level. When indicators suggest possible abuse, the issue is escalated immediately for investigation and action. We also require written confirmation from suppliers that they comply with applicable labor laws and do not use exploitative recruitment fees or withheld identity documents.
Supplier oversight is strengthened through planned supplier audits, announced and unannounced where appropriate. These audits examine wage practices, working hours, recruitment methods, age verification, grievance procedures, and subcontracting controls. Findings are recorded, tracked, and followed up with corrective action plans. If serious non-compliance is identified, we may suspend orders, require remediation, or terminate the relationship if improvement is not credible or timely.
Our contracting process includes clauses that permit monitoring, evidence requests, and site visits. Suppliers are expected to maintain accurate records and ensure their own subcontractors follow the same standards. We look for signs of coercion, passport retention, intimidation, or unsafe housing arrangements. Where a higher-risk category is identified, additional checks may include worker interviews, document review, and independent verification. This approach supports a resilient anti-slavery framework.
Reporting channels are available so concerns can be raised without fear of retaliation. Employees, workers, and supply chain partners may report suspected misconduct, policy breaches, or unsafe conditions through designated internal routes. Reports are handled confidentially and investigated promptly. We encourage early reporting, because timely disclosure improves the chance of protecting affected individuals and preventing further harm. Retaliation against anyone who raises a concern in good faith is strictly prohibited.
Any allegation of exploitation is reviewed by trained personnel, and appropriate remedial steps are taken in line with the severity of the matter. This may include safeguarding the individual, engaging with suppliers, involving external specialists, or notifying authorities where required. Our response is guided by respect for human rights, legal compliance, and practical prevention. We also maintain records of issues raised, actions taken, and outcomes achieved to support accountability.
Training is provided to relevant staff so they can identify red flags such as unusual recruitment practices, excessive overtime, restricted freedom of movement, or inconsistent age documentation. Procurement and operational teams receive additional guidance on ethical sourcing and labor risk management. By strengthening awareness, we improve the ability of our people to detect and prevent modern slavery risks before they become embedded in business relationships.
This statement is reviewed annually to ensure it remains effective, relevant, and aligned with legal requirements and operational realities. The annual review considers audit results, incident trends, supplier performance, training completion, and changes in supply chain risk. Where improvements are needed, we update controls, refine processes, and set new targets. Our intention is continuous improvement and measurable progress in eliminating exploitation from our business and its extended supply chain.
Conclusion: We are committed to maintaining a transparent, responsible, and practical approach to preventing exploitation. Through a zero-tolerance policy, targeted supplier audits, accessible reporting channels, and an annual review cycle, we aim to uphold dignity, fairness, and lawful labor practices throughout our operations.
