Modern Slavery Statement

This Modern Slavery Statement sets out our commitment to preventing slavery, human trafficking, forced labor, and child labor across our operations and supply chains. We maintain a zero-tolerance policy toward any form of modern slavery and expect the same standard from all employees, contractors, and business partners. Our approach is grounded in respect for human rights, ethical conduct, and continuous improvement.

We recognize that modern slavery can occur in complex supply chains and may be hidden in recruitment practices, labor arrangements, and subcontracting. To address this risk, we apply a risk-based framework that considers geography, sector, service type, and supplier behavior. Modern slavery prevention is integrated into our procurement, onboarding, and governance processes, ensuring that risk identification begins early and continues throughout the business relationship.

Our internal controls include due diligence checks, policy acknowledgements, and training for relevant teams. We require managers to escalate concerns immediately and to ensure that any suspected breach is investigated promptly. Ethical sourcing is not optional; it is embedded in decision-making and monitored through documented procedures that support transparency and accountability.

Supplier oversight is a core element of this statement. We conduct supplier audits based on risk level, which may include document reviews, site inspections, worker interviews, and corrective action tracking. These audits are designed to verify compliance with our standards and to identify vulnerabilities before they become serious issues. When non-compliance is found, we require remedial action within a defined timeframe and reserve the right to suspend or terminate relationships where necessary.

In addition to audits, we assess suppliers during onboarding and periodically thereafter. High-risk suppliers are subject to more frequent reviews, particularly where labor providers, outsourced production, or cross-border recruitment are involved. Supplier accountability is reinforced by contractual clauses that prohibit forced labor, debt bondage, confiscation of identity documents, and deceptive recruitment fees.

We also expect suppliers to maintain their own safeguards, including worker grievance mechanisms, age-verification controls, and responsible subcontracting practices. Where appropriate, we support suppliers in strengthening compliance systems, but we do not compromise on standards. Any modern slavery concerns identified through audits or assessments are treated as priority issues and escalated for action.

We encourage all personnel and external stakeholders to report concerns without fear of retaliation. Reporting channels are available through internal escalation routes and independent mechanisms designed to protect confidentiality and anonymity where possible. Concerns may include recruitment abuse, coercion, unsafe working conditions, withheld wages, or any suspected exploitation within our operations or supply chain.

All reports are reviewed by designated leaders and, where needed, investigated with appropriate urgency. Findings are documented, and corrective measures are tracked to completion. Whistleblowing protections apply to anyone raising a genuine concern in good faith, and retaliation of any kind is prohibited. We aim to create a culture in which people feel safe to speak up and confident that their concerns will be addressed fairly.

This statement is reviewed annually to ensure it remains effective, current, and aligned with legal requirements, operational changes, and emerging risks. The annual review includes evaluation of supplier audit results, training completion, reported incidents, remediation outcomes, and any changes to our procurement profile. Continuous improvement is essential to strengthening our response and ensuring that our controls evolve alongside the risks we face.

Senior leadership is responsible for overseeing implementation of this modern slavery policy and for promoting a culture of vigilance across the organization. Responsibility is shared across procurement, legal, operations, and human resources so that prevention measures are applied consistently. We will continue to strengthen our due diligence, enhance supplier engagement, and maintain a clear zero-tolerance stance toward exploitation in every part of our business.

By maintaining robust controls, transparent reporting, and regular review, we seek to uphold human dignity and protect vulnerable workers. Our commitment is ongoing, and we will continue to monitor risks, respond to concerns, and improve our practices where needed to ensure that modern slavery has no place in our operations or supply chains.