Modern Slavery Statement
This Modern Slavery Statement sets out our zero-tolerance policy toward all forms of modern slavery, human trafficking, forced labor, bonded labor, and child labor. We are committed to ensuring that our operations and supply chains reflect the highest ethical standards. This statement applies to every area of our business and supports our wider commitment to responsible conduct, lawful employment, and respect for human rights.
We recognize that modern slavery risk can exist in many industries, regions, and tiers of supply. For that reason, we apply a structured risk-based approach to identifying, preventing, and addressing potential harm. Our modern slavery commitment is embedded in governance, procurement, onboarding, and ongoing supplier management. All employees involved in sourcing, recruitment, and vendor oversight are expected to understand and uphold these obligations.
Our policies prohibit any practice that exploits vulnerability or restricts freedom. This includes retention of identity documents, excessive recruitment fees, threats, coercion, deception, or other abusive practices. Every business unit is expected to act promptly where a concern is identified. Breaches of this policy may lead to corrective action, contract termination, or referral to relevant authorities where required.
We conduct supplier due diligence before entering into new relationships and continue oversight throughout the lifecycle of the contract. This includes reviewing labor practices, employment terms, subcontracting arrangements, and country-specific risks. Where appropriate, we require suppliers to confirm compliance with our anti-slavery standards and to provide evidence of their own controls.
Supplier audits are a central part of our modern slavery prevention program. Audits may be announced or unannounced, depending on risk level and business context. During audits, we assess records, worker accommodation, wage practices, age verification, working hours, grievance access, and freedom of movement. If issues are found, suppliers must implement corrective actions within agreed timelines.
In higher-risk categories, we may request deeper verification, including document reviews, management interviews, and worker engagement. We also monitor subcontracting and labor agencies to ensure that protections remain effective across the entire chain. Our supplier standards require partners to prevent exploitation and to cooperate fully with any compliance review.
We encourage all workers, contractors, and suppliers to report concerns without fear of retaliation. Reporting channels are designed to support confidential escalation of suspected modern slavery, unethical recruitment, unsafe working conditions, or any conduct that may violate this statement. Reports are reviewed seriously and handled with discretion, fairness, and urgency.
Where allegations are raised, we investigate promptly and proportionately. If a potential case of exploitation is identified, we may suspend business activity, require remediation, support affected individuals, and review the adequacy of internal controls. Our approach is based on accountability, because an effective modern slavery policy must do more than set expectations: it must create practical pathways for action.
Training and awareness are provided to teams with responsibility for hiring, procurement, contract management, and supplier oversight. This helps ensure that risks are understood early and that warning signs are escalated appropriately. We also require managers to maintain records that support traceability and compliance across key processes.
Our governance framework assigns responsibility for modern slavery oversight to senior leadership, supported by operational teams that monitor implementation. Performance against our commitments is reviewed through internal reporting, risk assessments, and supplier management activities. This ensures that the organization remains alert to changing conditions and emerging vulnerabilities.
We also work to strengthen preventive controls by integrating ethical sourcing principles into procurement decisions. Where needed, we may decline to work with suppliers that are unable or unwilling to meet our standards. This position reinforces our zero-tolerance approach and sends a clear message that exploitation has no place in our business relationships.
This statement will be reviewed annually to reflect progress, assess emerging risks, and improve our response measures. The annual review will consider audit findings, reported concerns, supplier performance, regulatory developments, and lessons learned from investigations. Through continuous improvement, we aim to ensure that our modern slavery statement remains effective, current, and aligned with our values.
