Gardener Shepherds Bush - Modern Slavery Statement

Gardener Shepherds Bush publishes this Modern Slavery Statement to affirm our ongoing commitment to preventing modern slavery, human trafficking and forced labour in our operations and supply chains. This anti-slavery statement sets out our approach, communicates our zero-tolerance policy and explains the steps we take to identify, assess and mitigate risks related to slavery and human trafficking.

Our commitment and zero-tolerance policy

We operate a zero-tolerance policy for any form of modern slavery. We will not tolerate exploitation of workers, and we require the same standard from our suppliers and partners. This company-wide Modern Slavery Policy is embedded into our code of conduct and applies to all employees, contractors, suppliers and subcontractors.

How we assess and manage risk

To manage risk across our business and supply chain, we undertake supplier due diligence, risk assessments and targeted audits. Our supplier audits and checks focus on high-risk countries, labour-intensive activities and third-party labour providers. We use a mix of document review, on-site inspections and third-party verification to validate compliance with our slavery and human trafficking statement.

We maintain the following minimum expectations of suppliers and contractors:

• Lawful employment: workers must be engaged under lawful contracts and paid fairly.
• Freedom of movement: no withholding of passports or identity documents.
• No forced labour: no forced, bonded or coerced labour tolerated.

These commitments are part of our broader Modern Slavery Policy and form the basis for supplier agreements, procurement terms and contract renewals.

Supplier audits are scheduled based on risk profiles and include both announced and unannounced visits. Audit findings inform corrective action plans and, where necessary, contract termination for suppliers who fail to remediate critical breaches. We also encourage continuous improvement through training and capacity-building with suppliers to promote ethical recruitment and worker welfare.

Reporting channels and whistleblowing

We provide secure reporting channels for staff, contractors and third parties to raise concerns about suspected modern slavery. Reports may be made anonymously through our internal reporting mechanism or via designated escalation paths. All reports are treated seriously, investigated promptly and handled with confidentiality. Retaliation against anyone reporting in good faith is strictly prohibited under our policies.

Training and awareness: We deliver training on modern slavery awareness to employees with procurement, HR and site management responsibilities. Training covers how to spot signs of exploitation, the steps to take when concerns arise and our obligations under the slavery and human trafficking statement and applicable laws.

Our monitoring approach includes regular review of key performance indicators such as audit outcomes, supplier remediation rates and the number of reported incidents. We analyse these metrics to identify trends and strengthen preventive measures.

Annual review and continuous improvement: This Modern Slavery Statement is reviewed at least once a year by senior management and the board to ensure it remains effective and aligned with evolving best practice. The annual review examines policy effectiveness, audit results, training uptake and incident responses; findings lead to updated risk mitigation actions, improved contractual clauses and enhanced supplier engagement.

Governance and accountability: Responsibility for implementing this statement sits with senior management supported by our procurement, HR and compliance teams. We report progress to the executive leadership team and maintain records of due diligence activities, audits, training and remediation actions.

Summary of key actions:

• Maintain and enforce a zero-tolerance policy on modern slavery.
• Conduct risk-based supplier audits and follow-up on remediation.
• Provide confidential reporting channels and protect whistleblowers.
• Deliver targeted training and perform an annual review of our modern slavery statement and policies.

Through these measures — our modern slavery statement, supplier audits, clear reporting channels and scheduled annual reviews — Gardener Shepherds Bush is committed to preventing slavery and human trafficking in all areas of our business and supply chains.