Gardener Heston Modern Slavery Statement

Gardener Heston publishes this Modern Slavery Statement to set out our commitment to identify, prevent and remediate any instances of modern slavery, forced labour or human trafficking in our operations and supply chains. This anti-slavery declaration explains our policies, the steps we take and the responsibilities held by our teams. We recognise that addressing modern slavery requires continual vigilance, strong supplier management and clear reporting channels.

We operate a zero-tolerance policy on all forms of slavery and forced labour. Our expectation is clear: any practice that amounts to exploitation, coercion or withholding of wages is strictly prohibited in Gardener Heston’s business and with our partners. All colleagues, contractors and suppliers are bound by our anti-slavery rules and contractual clauses that reflect this position.

Our modern slavery and human trafficking statement outlines how we identify risk areas and act decisively. We screen high-risk sectors, review recruitment and subcontracting practices, and require upfront disclosure from vendors. The slavery and trafficking policy is integrated into procurement and sourcing decisions and applies across all regions where we operate. We use a risk-based approach to prioritise action where forced labour risks are greatest.

Our supplier assurance programme includes regular audits, on-site inspections and documentation checks. We conduct supplier audits to verify compliance with our anti-slavery requirements, with a focus on wages, working hours, identity security and freedom of movement. Where non-conformances are found, we require corrective action plans and monitor implementation until resolved.

We employ a mix of third-party auditors and internal procurement reviews to ensure independence and consistency. Audit outcomes inform supplier scorecards and future sourcing decisions. We are committed to supporting suppliers to improve through remediation assistance, training and contractual incentives for sustainable practices.

Key actions in our supplier programme include:

• Risk assessments for new and existing suppliers to identify forced labour and human trafficking risks.
• Scheduled audits and surprise inspections in higher-risk categories.
• Contract clauses that require suppliers to comply with our anti-slavery policy and allow us to terminate relationships where breaches persist.

We maintain multiple reporting channels to enable staff, suppliers and third parties to raise concerns about modern slavery, exploitation or unethical conduct. Reports may be raised confidentially via designated internal processes. All reports are investigated promptly, and where appropriate, escalated to senior management.

Training is provided to procurement teams, site managers and HR staff to help them identify signs of forced labour and understand the steps to take. Our training materials include examples of modern slavery indicators and guidance on how to respond safely and legally. We emphasise the importance of protecting whistleblowers and ensuring no retaliation.

Gardener Heston undertakes an annual review of this slavery prevention programme and the effectiveness of our policies. The review examines audit results, remediation outcomes, training completion rates and any new risk factors. Findings from the annual review shape our future priorities, supplier engagement plans and resource allocation to strengthen our anti-slavery and forced labor safeguards. We publish an updated statement each year that summarises progress and sets measurable goals for the coming period.