Modern Slavery Statement — Gardener Feltham

Gardener Feltham has published this Modern Slavery Statement to set out our clear position on slavery and human trafficking across our operations. This anti-slavery policy outlines expectations of our workforce and suppliers, demonstrates our zero-tolerance approach, and clarifies how we monitor and address potential risks in the supply chain.

Our zero-tolerance policy

We have a zero-tolerance policy for modern slavery, forced labour and human trafficking. All employees, contractors and partners must adhere to our standards. We require that work is voluntary, wages are fair, and working conditions are safe. Breaches of this policy will lead to disciplinary action and potential termination of commercial relationships.

We publish a clear slavery and human trafficking statement internally and externally to ensure transparency. Our leadership is committed to preventing exploitation by embedding ethical practices into procurement, recruitment and day-to-day operations. We train staff to recognise signs of exploitation and to understand required compliance measures.

We operate a risk-based supplier management framework to identify, assess and mitigate modern slavery risks. Our supplier engagement includes contractual clauses that require compliance with our Modern Slavery Policy and related labour standards. We screen new suppliers and reassess existing ones on a regular cadence.

Key elements of our approach include supplier due diligence, site visits where appropriate, and inclusion of anti-slavery clauses in contracts. We prioritise higher-risk categories for more frequent checks and enhanced controls. Our procurement teams are trained to apply ethical sourcing principles consistently.

We conduct supplier audits and assessments to verify compliance. Audits include document reviews, interviews and, when necessary, unannounced inspections. Findings drive corrective action plans, and persistent non-compliance may result in termination of supply agreements.

Audits are backed by a structured remediation process: suppliers must submit timely corrective action plans, demonstrate progress and provide evidence of improvements. We publish expectations for remediation and track outcomes until satisfactory resolution is achieved.

Supplier audits and accountability

Our monitoring program uses objective metrics and third-party auditors for selected suppliers. We also use risk indicators such as geography, labour intensity and subcontracting practices to focus our audit resources where they are most needed.

Where audits reveal potential exploitation or modern slavery, we take immediate steps to protect affected individuals, collaborate with relevant authorities and apply contractual remedies. Our priority is the welfare and protection of workers while pursuing responsible business outcomes.

We maintain clear reporting channels so concerns can be raised confidentially and without fear of retaliation. Employees and suppliers can raise issues through internal reporting lines, anonymous hotlines and designated ethics contacts. Reports are investigated promptly and fairly.

Reports related to forced labour or trafficking are escalated to senior management and, if necessary, to law enforcement or appropriate regulatory bodies. We document investigations and maintain records of actions taken to ensure accountability and continuous improvement.

To reinforce accountability, we integrate modern slavery considerations into contract renewals, supplier scorecards and performance reviews. Suppliers are evaluated not only on cost and quality but also on compliance with our anti-slavery standards.

We commit to continuous improvement through annual review and public reporting. Each year we will review our policies, risk assessments and remediation outcomes to measure effectiveness and identify enhancements to our approach to modern slavery.

Our annual review includes stakeholder consultation, analysis of audit results, and updates to training and due diligence procedures. We will update our leadership and refine resource allocation based on identified trends and emerging risks in the supply chain.

In conclusion, Gardener Feltham is resolute in preventing modern slavery in all forms. This slavery statement, our anti-slavery policy and supplier audits together reflect a robust and evolving programme. We will continue to strengthen reporting channels, enforce our zero-tolerance stance and perform an annual review to ensure sustained progress toward eradicating exploitation.